ML17056A619

for the

REFUEL condition

only.

In

other

instances

TS

interpretations

are

being

used

to

support

the operability

requirements

for REFUEL.

The inspector

has

requested

that

NMPC provide

a list of all

TS

interpretations

and

10 CFR 50.59 reviews which will be used to satisfy the refueling sys-

tems operability requirements.

Pending

inspector

review of the above

requested

material, it appeared

that

had

adequate

methods

in place

to ensure

that operability

requirements

for systems

necessary

to

support

the

REFUEL condition

are identified and met.

1.2

TS Surveillance

Review and Verification

An adjunct to the

TS review was

a review of TS required surveillance

tests

for systems

required for reload.

The

inspector

reviewed

the

Unit

1

Surveillance

Test

Matrix,

a

document

which correlates

TS

required

survei llances

with the

NMPC surveillance

test

procedures.

The Test Matrix also lists all

modes

in which the surveillance test

must

be satisfied.

Inspector

review of this document

identified

no

deficiencies.

By use of a separate

computer listing of the Test Matrix, the inspec-

tor reviewed

when

a particular surveillance

procedure

was last

per-

formed.

Through discussion with NMPC personnel,

the inspector deter-

mined that not all

TS Matrix entries reflect

the

most current

sur.-

veillance

procedure revision and/or procedure

number.

Therefore,

the

last completion date for some

surveillance

procedures

was not avail-

able.

However,

the

inspector

determined

that

NMPC personnel

were

aware of these

discrepancies

and that

measures

were

being

taken

to

address

them.

Overall, the Surveillance

Test Matrix appeared

to be

a

complete

document

which

should

be

beneficial

in

ensuring

that

TS

required surveillance

tests

are identified and performed within their

periodicity.

Safet

S stem Walkdowns

Part

of

NMPC's

preparation

for reload

was

a

walkdown

of

systems

determined

to

be

necessary

for reload activities.

This was

accom-

plished using Temporary

Procedure

N1-88-6.6, R"start Requirements

for

Core

Reloading

System

and Area Walkdown for Restart

Procedure.

This

procedure

required

walkdown of 26 systems,

as well as,

general

area

walkdowns in various parts of the plant.

The

inspectors

chose

two

systems

which

had

completed

per

Nl-88-6.6.

The inspectors

performed

independent

walkdowns

using

the

observation

criteria

listed

in

N1-88-6.6.

The first walkdown

wag

performed

on the

Emergency Ventilation (EV) System.

Comparing walk-

down deficiency lists,

the inspectors

noted that none of their find-

ings

were contained

in the

NMPC list of material

deficiencies,

(EV

system

walkdown findings were discussed

in IR 89-07

and in Section

4

of this report).

Based

on the results of the

EV system walkdown,

the

inspectors

were

concerned

that

had

not

performed

an

adequate

walkdown

per

Nl-88-6.6

and

discussed

this

concern

with

management.

In response,

NMPC reinspected

the

EV System

and confirmed the inspec-

tor's findings.

They .also

reinspected

the

Fuel

Pool

Filtering

and

Cooling

System

( FPF&CS)

per

N1-88-6.6.

Their reinspection

of the

FPF&CS

showed

good correlation

between initial walkdown findings

and

their recent list.

Consequently,

NMPC concluded that the

EV walkdown

findings of the

NRC inspectors

were isolated

only to that

system

and

that

a

broader

problem

with

implementation

of

N1-88-6.6

did

not

exist.

To validate their initial concern

the inspectors

conducted

a walkdown

of the Control

Room

Emergency Ventilation (CREV) System

(see

Section

4. 1.c).

Similar to the

EV

system

walkdown results,

the

inspectors

identified

numerous

deficiencies

which were

not

noted

in the

walkdown of the

CREV

system.

Collectively,

these

findings

led the

inspectors

to further question

the

adequacy

of NMPC's

system walk-

downs per Nl-88-6.6.

The

inspectors

again

met with

management

to communicate their

concerns

in this

area.

At that

meeting,

NMPC management

indicated

that they were also starting to question

the

adequacy

of their walk-

downs

as

a result

of

an in-office review of the results

of their

completed

walkdowns.

Subsequent

to this meeting,

NMPC evaluated

the walkdown procedure

and

the

manner

in which it was

implemented

and identified major incon-

sistencies.

As

a result,

NMPC substantially

revised

the

walkdown

procedure

to give clearer

guidance to personnel

and provided training

on

how and what to inspect

per the

new revision.

The revision also

required

walkdowns

to

be

performed

by

a

team of individuals

from

various departments

and also required

gA to provide

an individual to

accompany

each

walkdown

team.

Additionally, all

systems

previously

inspected

were

reinspected

per

the

new

procedure

and

inspection

criteria.

Ins ector Assessment

The

inspectors

concluded

that

there

had

been

a

breakdown

in

management

effectiveness

in oversight of the walkdown procedure.

The

Unit Superintendent's

expectation

of how system

walkdowns

should

be

done

was

not effectively

communicated

to the

staff.

The

walkdown

procedure

was

not uniformly implemented

by the

personnel

performing

the

system

walkdowns,

and line management

did not provide oversight

and

training

on

the initial

walkdown

requirements.

Additionally,

line management

oversight of the

implementation

of the

walkdowns

was

deficient in that, while in-office reviews of the completed

paperwork

were

performed,

no

independent

field verifications

were

performed.

Lastly,

the

site (}uality Assurance

Department

missed

an opportunity

to assess

unit readiness

for reload

and provide

management

feedback

on

the

same.

The inspector

concluded that the ineffective walkdown

procedure

and the inconsistent

implementation of the procedure

repre-

sented

an

apparent

violation of

10 CFR 50,

Appendix

B, Criterion V.

(50-220/89-08-01)

Problem

Re ort Pro

ram Review and Item Status

The

inspector

reviewed

the

Unit

1

Problem

Report

(PR)

Program

and

current

status

with the

responsible

site

manager.

The

inspector

reviewed

PR processing

and observed

several

PRs

in various

stages

of

resolution.

The inspector

observed

that

PRs

are closely tracked via

a

computer

program

from their origin to final, resolution

and that

0

NMPC management

receives daily status

reports to monitor overall pro-

gress.

The inspector determined that the

PR originators are

provided

the resolution

to their

concern

prior to final closeout

of the

PR.

Disagreements

on

the

final

resolutions

are

appropriately

resolved

with the originator.

The

inspector

reviewed

the

status

of critical

reload

PRs with the

responsible

manager.

The number of open

PRs impacting reload is also

tracked

via the daily outage

schedule.

No discrepancies

were noted,

and the inspector

concluded

that

PRs

were being

evaluated

properly.

Nuclear

Commitment Trackin

S stem

NCTS

Review

The inspector

reviewed Niagara

Mohawk's actions for assuring that all

commitments

required for reload

and restart

had

been identified

and

were

included

in

NCTS.

The process

involved

an

item by item review

of all entries

in the

NCTS

and

comparison

with the priority defi-

nitions

specified

in procedure

Nl-88-6. 11 "Restart

Requirements

for

Core

Reloading,

Plant

Procedures

Checklist,

Surveillance

Tests,

and

NCTS Review for Core Reloading".

Source documentation (e.g.,

memos to

NRC, meeting

minu as)

were

reviewed '.f items

were

questionable.

In

addition,

Niagara

Mohawk

is

reviewing

all

1987,

1988,

1989

NRC

inspection reports for potential

or "implied" commitments

as well

as

the Unit

1 Restart .Action Plan.

The inspector

reviewed approximately

one half of, the

NCTS

items

and

noted

that

Niagara

Mohawk

had

beeq

conservative

in

its

classification

of

items

as

"required

for

startup."

The inspector

noted

no concerns

and -concluded that imple-

mentation of NCTS was

adequate'ontrol

Drawin

Review

The

inspector

reviewed

the

program for maintaining up-to-date

drawings in the control

room at Unit 1.

The

program is outlined in

Nuclear

Design

Procedure

ND-160,

Revision

1, "Drawing Change Control

for Nuclear Design - Unit 1."

The

inspector

discussed

the

drawing control

program with the

lead

electrical/I&C engineer

at

the

NMPC corporate office.

The engineer

stated that

NMPC currently has about

4000 total

drawings for Unit l.

Of these

drawings,

900 are designated

as controlled critical drawings

and are available

in the control

room.

Due to concerns

identified by the guality Assurance

(gA) Department

regarding

drawing

control

and

the

incorporation

of design

changes

into these

drawings,

the

gA Department

issued

Stop

Work Order

(SWO)87-500

against

the

Engineering

Department

in January,

1987.

As

a

result,'Revision

1 to ND-160 was developed.

0

The

inspector

concluded

that

updating

and

control of drawings

were

acceptable

based

on

the

following reviews.

The

inspector

reviewed

ND-160,

as well as

a representative

sample

(31) of critical drawings.

The

inspector

reviewed

the

correspondence

related to the resolution

and lifting of

SWO

87-500.

In

addition,

the

inspector

reviewed

several

operator

aid

drawings

in the plant to determine

the status

and timeliness of updating these

drawings.

1.7

ualit

Assurance

De artment Activities Review

On September

25,

1989,

the inspector contacted

the site

QA Manager to

determine

. what

plans, if any,

QA

had

for,

special

monitoring

of

reload/restart activities.

The inspector

was informed, at that time,

that

no

special

inspection

or surveillance activities

were

planned.

However,

the

normal

QA surveillance

routine would be in effect,

but

on

a

more frequent surveillance

schedule.

The

QA Manager

indicated

that

the

normal

QA program,

at

an

enhanced

surveillance

schedule,

would

be

adequate

to

handle

the

upcoming activities.

If problems

were detected

in monitored activities,

then the

QA Department

would

react

to

them,

at

.hat time.

As stated

above

in Section

1.3.,

the

in-pectors

considered

the lack of additional

QA Department

oversight

in the area of reload preparation

to be

a valuable missed opportunity

for assessment.

For the

QA Department

not to take

a

more proactive

role

in monitoring

these

activities

also

indicated

a

weakness

in

senior

NMPC management

planning for the upcoming activity.

1.8

Review of Selected

S ecific Activities/Issues

Satin American Overcurrent Tri

Devices

The inspector

reviewed

the

replacement

of General Electric Type

EC-1,EC-lB,

and

EC-2A series

overcurrent trip devices

supplied

by Satin

America

Corporation

(SAC).

These

breakers

had

been

identified by the

NRC in Information Notice 89-45

as potentially

substandard

because

of modifications

and refurbishment

which did

not meet the original design.

reviewed all purchase

orders with

SAC

and determined

that

154 of the trip devices

had

been

purchased.

subsequently

performed

a walkdown of all 600 volt power boards

and identified

22 applications at Unit

1 where

SAC trip devices

were installed

in power boards with safety-related

applications.

,The inspector

reviewed documentation

which concluded that

no

SAC equipment

was

installed at Unit 2.

Niagara

Mohawk originally completed

a justification to reload

the

core with

SAC breaker trip devices still installed

in the

plant.

Near

the

end of this inspection period,

NMPC decided to

replace all these trip devices prior to reload.

The

inspector

concluded that this approach

resolved the technical

concern with

SAC trip devices.

b.

SSFI Followup - (see Section

3. 1. l.a, b, c, d,

and e.)

c.

SCRAM

Discharge

Volume

(SDV)

Test

Results

-

(see

Section

3.1.2.b.)

2.

Review of Plant Events

2

~ 1

Unit'

The

reactor

remained

shutdown

and

defueled

throughout

the

report

period.

Efforts

continued

towards

core

reload

in

the

near

term.

Latest

reload

and

restart

target

dates

determined

by

are

October 27,

1989,

and January

13,

1990,

respectively,

as

of the

end

of the inspection period.

a.

Between

September

17

and

28, four reactor

scrams

a'nd associated

Emergency Ventilations System initiations occurred

due to a loss

of power on Reactor Protection

System

(RPS)

bus

11.

Th'e loss of

power on

RPS

bus ll was believed to

have

been

caused

by

a mal-

functioning

voltage

regulator/speed

controller

on

motor-

generator

(MG) Set

162

which provides

continuous

power

to

RPS

bus

11.

The problem was first identified during the performance

of the

Loss of Offsite Power/Loss

of Coolant Accident surveil-

lance test.

Troubleshooting

on

MG Set

162 was still ongoing at

the close of this inspection

periods

Resolution of this problem

will be discussed

in a later report.

2.2

Unit 2

The reactor

was manually

scrammed

on September

8, at which time

commenced

a

planned

two

week

maintenance

outage.

The

outage

was

completed

on

schedule

and

the

reactor

was

taken

critical

on

September

22.

a.

On

September

25,

NMPC determined

that

the

screenwell

building

at Unit

2

was radioactively

contaminated.

The

source

of

the contamination

was determined

to

be

from the

radwaste

floor

drain, header

to which the

pump for the

screenwell

sump is

connected.

The

contamination

apparently

occurred

due

to

a

design

deficiency with the

screenwell

pump discharge

line

which, allowed radioactive material

in the floor drain

header

to

collect in the line

and

problems with a check valve in the line

which allowed the backflow of radioactively

contaminated

water

through the line.

No offsite release

of contamination

occurred.

The

inspector

toured

the

affected

areas,

examined

the

piping

configuration

and discussed

the

problem with the

radwaste

oper-

ations

supervisor

and

the

Unit

2 radiation

protection

super-

visor.

Corrective actions to prevent

a recurrence

of this event

were

being

developed.

The

inspector

concluded

that

cleanup

efforts

on the

sump were -appropriate.

On

September

8,

with the

reactor

at

88%

power,

both. reactor

recirculation

pumps

downshifted

to

slow

speed

for

no apparent

reason.

Core

thermal

power

and

core flow decreased

to

44%

and

34%,

respectively.

After consulting

Procedure

N2-OP-29 (flow-

chart for sudden'ecrease

in flow), the

SSS

directed

that

the

reactor

be manually

scrammed

by placing the

mode

switch to the

SHUTDOWN position.

This action

was

taken

because

the downshift

.

of

the

recirculation

pumps

placed

the unit in the restricted

zone of the power to flow map where the reactor is vulnerable to

power osci llations.

No emergency

core cooling systems initiated

and plant systems

responded

as

designed.

There

were

no indica-

tions

of

power oscillations

on

average

power

range

monitors

while the unit was

in the restricted

zone of the

power to flow

map.

The

inspector

responded

to

the

site

shortly after

the

and observed that

NNPC's actions

were proper.

NNPC

conducted

an

investigation

to determine

the

cause

of the

downshift

of

the

reactor

recirculation

pumps

to

slow

speed.

From troubleshooting

and

computer point analysis, it was

found

that

oscillations

in

the

Feedwater

Control

System

D.C.

power

supply

unit

(C33A-K613)

caused

the

recirculation

pump

low

reactor

water

level trip relays

to drop out,

resulting

in

a

recirculation

pump downshift.

This

power

supply

was

replaced

and

post-maintenance

testing

was satisfactorily performed.

The

inspector

reviewed the post

scram report

and identified

no con-

cernss.

Inspector

assessment

of this

event

was that the oper-

ators

took the proper

actions

in

accordance

with station

pro-

cedures'~

Operator

technical

expertise

was

reflected

in their

quick diagnosis

of the

faulty

power

supply

which

caused

the

recirculation

pump downshift.

While performing

the shift turnover

Control

Panel

walkdown

on

the

evening

of September

9,

the

oncoming

Chief Shift Operator

(CSO)

found

the Division III emergency

diesel

generator

(EDG)

control

room unit cooler

(2HVC"U2C) was

not available for oper-

ation.

The

Station.

Shift

Supervisor

was

informed

and

the

Division III EDG was

immediately declared

inoperable.

Mai nten-

ance

had

been

completed

on

2HVC*U2C the

and

the

Division III

EDG

was

declared

at

6:50 p.m.

on

September

8,

with

the

unit

in

Operating

Condition

3

(HOT

STANDBY).

Subsequent

Niagara

Mohawk staff investigation identi-

fied a knife switch in the

power supply circuit had

been

inad-

vertently left

open

following maintenance

on

the unit cooler

breaker

per

Electrical

Maintenance

Procedure

N2-EPM-CSH-R583.

This condition .existed

for. approximately

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Inspector

followup of this- event

identified

a

number

of con-

cerns.

Procedure

N2-EPM-CSH-R583,

600V G.E.

HPCS

MCC Starter/

Breaker

and

Motor Inspection,

was

inadequately

written for the

specific maintenance

task performed.

Step 7.5 contains

instruc-

tions to .perform

a megger of the

2HVC"U2C motor and to measure

the winding resistance

phase

to

phase.

To

accomplish

this,

a

local

knife switch

must

be

opened

to gain

access

to the

load

side

of the

local controller.

The

procedure

did

not

contain

steps

to

open

and

reclose

the

knife

switch.

The electrical

maintenance

technician failed to close the knife switch when the

m intenance

was

completed.

Electrical

Maintenance

personnel

have

been operating knife switches for this purpose

on the

HPCS

unit cooler

motor

and other motor local controllers

informally

fcr

some

time.

This

maintenance

practice

conflicts with the

requirements

of Station

General

Order

89-03

which stipulates

strict procedural

compliance.

E

The inspector

concluded that the operator

appeared

to have

been

.

inattentive

to the activity being performed.

Upon completion of

the maintenance,

the system

markup was cleared

by a control

room

operator.

After removing

the

tags

and

supposedly

reenergizing

the

circuit

the

operator

failed

to

recognize

the

breaker

position indication was de-energized.

In addition,

a lit annun-

ciator and

a lit trouble light were in

an

alarmed

state

indica-

ting no power was available to the cooler.

, The

most

significant

concern

identified

by the

inspector

was

that

no

post-maintenance

test

(PMT)

was

performed

on

2HVC'U2C

following the

preventive

maintenance

conducted

on

September

8.

Procedure

N2-EPM-CSH-R583 lists general

guidance

on what

PMT may

be

used,

but does not clearly specify that it must be performed.

The

electricians

performing

the

maintenance

are

procedurally

required to only inform Operations

Department that the mainten-

ance

is complete

and that the

equipment

is available for test-

ing.

The

inspector

determined

that neither

the electrician or

the

on-duty

operators

discussed

PMT of the

unit coolers.

In

addition,

the

Equipment

Status

Log entry for this maintenance

activity was ambiguous

as to the need for PMT.

Although

procedural

inadequacies

existed

and

several

station

personnel

erred

in

restoring

and

verifying safety

equipment

restoration

to operability,

the performance

of

a post-mainten-

ance

test

may

have

identified

these

oversights.

10 CFR 50,

Appendix

B, Criteria

XI states,

in part,

that

preoperational

proof tests

be

performed

on

nuclear

power

plant

systems

and

components

to

ensure

they will perform satisfactorily

in ser-

vice.

The station

staff did not

perform

any

post-maintenance

testing of the Division III EDG control

room unit cooler follow-

ing

the

performance

of

maintenance

on

the

cooler

motor

on

September

8.

This is

a violation (50-410/89-08-02).

The.,following corrective

actions

were

taken in response

to this

event:

1.

Retraining

was

conducted

with all

maintenance

personnel

stressing

the applicable

portions of Station

General

Order .

89-03 which emphasize strict procedural

compliance.

2.

NMPC reviewed all completed

preventive

maintenance

proced-

ures

to ensure

system/component

operability

subsequent

to

the maintenance.

3.

All preventive

maintenance

procedures

will be

accompanied

by

a

PMT

report

which will clearly

delineate

the

PMT

requirements

and their completion.

4.

The Unit

2 Superintendent

issued

a lessons

learned

trans-

mittal that covered

the

programmatic

and

personnel

break-

downs

that

occurred.

The

inspector

reviewed this trans-

mittal and found it to be satisfactory.

The

inspectors

were

concerned

that

the

personnel

errors dis-

cussed

above

and

a number of similar events

indicated

a trend in

poor control of equipment/system

status.

Other recent

examples

include:

10

On May 11, the

HPCS

keep fill pump was

removed

from service

without performing

a safety evaluation.

On

June

13,

the Division II service 'water

bay unit cooler

was

returned

to service

with outstanding

maintenance

and

resulted

in

a

TS violatioq.

On

June

29,

the closing contact for an offgas

sy'tem

com-

pressor

exploded

when

the

compressor

was

attempted

to be

started.

The

compres'sor

was

declared

inoperable

earlier,

but not tagged to prevent

use.

On September

25, valves

WCS*V344 and *Y345 were left out of

their normal position

and resulted

in an unexpected

reactor

water cleanup

system transient

(see

Section 2.2.e).

d.

On

September

14,

while preparing

to test

the

"C" Transversing

Incore

Probe

(TIP) squib valve,

an

unplanned

retraction of the

"A" TIP occurred.

The

"A" TIP withdrew from approximately

50

.inches

below the

core to its shield

location

in the

TIP

room.

Workers

evacuated

the

TIP

room

upon notification of movement of

the

"A" TIP.

These

workers

did

not

receive

any

appreciable

exposure

due to,this event.

In response

to this'vent,

Radia-

tion

Protection

supervision

issued

a

Stop

Work

Order

and

initiated

a Radiological Incident Report (N2-89-5).

Niagara

Mohawk investigation

determined

that

the

procedure

in

progress,

N2-ISP-'IP-R001,

was initially written

such

that all

TIP detectors

not being tested

must be stored

in their shield in

the TIP room prior to testing

any single

TIP detector.

Shortly

prior to this event,

a Temporary

Change

Notice (TCN) was initi-

ated

that

required all

TIP detectors

not

being

tested

to

be

inserted

into the

drywell

area

below

the

core

to

reduce

per-

sonnel

exposure of the workers in the TIP room.

This was

accom-

plished,

however,

Niagara

Mohawk

concluded

that this

TCN

was

inadequate

because

it. did not de-energize

the

TIPs

which were

not being tested

to prevent

inadvertent

retraction.

Subsequent

to

this

event

another

TCN

was

issued

to

accomplish

this

function.

Secondly,

due to poor communications

between

the supervisor

and

IKC technician

performing the surveillance test,

work was

com-

menced

on the incorrect

TIP drive,

A vice

C.

As

a result,

the

runback feature of the

A TIP was inadvertently

actuated

by the

IEC technician.

The

inspector

was

concerned

that

the initial

TCN

was

not

adequately

researched

and

the

workers

were

not

adequately

briefed or supervised.

11

On

September

25,

a Reactor

Water Cleanup

System

(WCS) isolation

occurred

as

a

result

of high Non-Regenerative

Heat

Exchanger

(NRHX) inlet temperature.

During the event,

the

Reactor Build-

ing

Close

Loop Cooling

(CCP)

pumps

tripped

and

a

waterhammer

occurred in the

WCS system piping,

The

CCP

pumps were restarted

immediately and

NMPC commenced

an investigation to determine

the

cause.

An

inspection

of

snubbers

in

the

system

per

TS

Surveillance

4.7.5.d

was

initiated

due

to

the

potentially

damaging transient.

After several

days,

NMPC identified the following chronology to

be

the

cause

of this

event.

During

the

dayshift,

a

twenty

gallon per minute leak was discovered

in the

WCS valve room.

In

an attempt

to isolate

the leak,

an operator

secured

"0" filter

demineralizer

and

depressurized

it by opening

valves

WCS*V345

and

WCS"V344.

This valve lineup established

a path from the

system

to

the

phase

separator

tank in the

radioactive

liquid

waste

system.

This

method

of depressurizing

the

"D" filter

demineralizer

was not recognized

by the Operating

Procedure

and

was

performed

under

emergency

circumstances

to

stop

the

leak.

However,

these

actions

did

not

stop

the

leak.

The

operator

realized

the

leak

was actually

from a mechanical fitting in the

"C" filter demineralizer

and

isolated

the

"C" filter deminer-

alizer,

leaving the "D" filter demineralizer

secured

and vented.

The operator failed to note in the

log

book and/or

notify thy

Station Shift Supervisor

(SSS) that the "D" filter demineralizer

was

vented

to the

phase

separator

tank via valves

WCS*V345 and

WCS*V344.

Later on September

25, the next operating

crew placed

"0" filter demineralizer

in service,

not realizing the vent path

to

the

phase

separator

tank

was

established.

Consequently,

several

thousand

gallons of water

was inadvertently

sent

to the

phase

separator

tank

causing

increased

flow through

the

NRHX

resulting in high

NRHX inlet temperature,

CCP

pumps to trip and

waterhammer

in the

WCS system.

As

a

result

of

the

snubber

inspections,

NMPC identified

and

repaired

one

snubber which was sluggish,

NMPC took the follow-

ing corrective actions

in response

to this event:

A Lessons

Learned transmittal

was issued.

Disciplinary action

was taken against the operator

who left

valves

WCS*V344 and WCS"V345

open

and neither

informed the

SSS

nor

logged it in the logbook.

The

Operations

Superintendent

conducted

training with all

shifts

on

the

Lessons

Learned

from this

event

and

the

corrective actions.

12

The

inspector

considered

that

NMPC's

loss

of control

of

system

status

was

noteworthy.

The

actual

safety

significance

was

low

since

the

isolation

feature

of

initiated,

as

designed,

and

was

not

inhibited

by

the

valves

being

out

of

position.

The inspector

planned additional

review of corrective

actions

as part of reviewing

LER 89-33.

On

October

13,

a reactor

occur red

from 60 percent

power.

The

scram resulted

from a turbine trip on turbine control valve

fast closure

due to low condenser

vacuum.

Investigation of the

scram identified that Electrical Maintenance

personnel

were per-

forming preventive

maintenance

on the

B mechanical

vacuum

pump

motor

breaker.

When

the

breaker

was

closed

in

the

TEST

position,

the

steam

jet 'air

ejectors

inlet

isolation

valve

(AOV-104)

closed,

as

designed,

resulting

in the

loss

of con-

denser

vacuum.

The

vacuum

pumps

remained

mechanically

isolated

from the

vacuum

stream via another

valve (AOV-105) which is also

electrically

interlocked.

Upon

receipt

of the

low condenser

vacuum alarm, operators

attempted

to maintain

vacuum

by reducing

reactor

power via lowering recirculation

flow and driving rods

in.

Reactor

power

was

100

percent

at

the

beginning

of

the

transient.

The

cause

of this

was determined to be operator

and tech-

nician error.

Plant impact of this maintenance activity had not

been

properly evaluated.

Placing

AOV-104 valve control

switch

in the

OPEN position vice the

AUTO position would have prevented

the automatic interlock function

from initiating.

This inter-

lock is designed

to prevent

reverse

flow through the mechanical

vacuum

pumps.

The unit was restarted

on October

15.

The

inspector

was

concerned

since

the

inadequate

plant

impact

assessment

represented

a

repeat

problem.

The

inspectors

will

review the Licensee

Event Report

(89-35) to assess

NMPC correc-

tive actions.

On October

17,

operators

identified

an increasing

reactor cool-

ant

leak rate

and at ll:28 p.m.

station

management

ordered

a

unit

shutdown

to investigate

the

source

of leakage.

The leak

rate

had increased

to approximately 4.0

gpm

by the time reactor

power reduction

was started.

While reducing

reactor

power

and attempting

to transfer recir-

culation

pumps to slow speed,

the

B recirculation

pump failed to

start

on

slow speed.

Subsequent

attempts

were unsuccessful

and

action

was taken to adjust the

APRM and

Rod Block Monitor (RBM)

flow biased

setpoints

in accordance

with Technical Specification

13

(TS)

3.4.1.1

for

single

recirculation

loop

operation.

At

approximately

4:30 a.m.,

(four hours after the

B recirculation

pump failed to start

on

slow

speed),

Niagara

Mohawk entered

a

forced

shutdown

( 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months

LCO)

due to the inability to complete

the flow bias setpoint adjustments within the

TS four hour time

limit.

I&C technicians

completed

th'e

adjustments

at 6: 13 a.m.

and

the

operators

exited

the

TS 3.4. 1. 1

forced

shutdown

LCO.

At 6: 16 a.m.,

a Reactor Protection

System reactor

scram occurred

due

to

IRM High Flux.

The reactor

was

operating

at

approxi-

mately

500 psig with IRMs in range six and

seven at the time of

the

scram.

All protective

systems

functioned

as designed

and

no

ECCS

actuations

occurred.

The

cause

of the

IRM High Flux trip

was

the result of concurrent

additions

of positive reactivity.

The

reactivity

additions

consisted

of

a

combination

of

an

increase

in feedwater flow and

a slight increase

in pressure

due

to

a fairly rapid

isolation

of

steam

to

the

steam jet air

ejectors.

The unit was restarted

on October 26.

In

the

Night

Notes

book,

Operations

management

stressed

the

highly sensitive

nature of the

IRMs to any

powa,

changes;

Senior

Reactor

Operators

need to increase

their involvement of activ-

ities

associated

with reactivity changes;

and operators

should

not

perform

more

than

one activity at

a

time

that

affects

reactivity.

The

inspector

will review final

NMPC correcti,ve

.

actions

once the

LER (89-36) is issued.

3.

Followu

on Previous Identified Items

3. 1

Unit

1

3.1.1

The inspector

held followup meetings with Niagara

Mohawk on

August 15,

1989

and September

8,

1989, to review the status

of

open

items

from

Safety

System

Functional

Inspection

(SSFI)

Followup

Report

Number

(50-220/89-18).

The status

of these

items is as follows:

(Open)

Unresolved

Item (50-220/89-18-01):

Core

Spray

System

Design Deficiencies:

1.

System

Performance

Curves

(Open - Section 2.2(A))

In

order

to

resolve

concerns

regarding

the

appropriateness

of values

used for system resis-

tance

in

ECCS

performance

analyses,

Niagara

Mohawk committed to perform

a special test of the

system

to

determine

actual

resistances.

Test

procedure

Nl-88-7. 12 "Core Spray

System Injection

Test" was approved

by

SORC

on 8/31/89.

This item

will remain

open

pending satisfactory

completion

of this testing.

14

Net

Positive

Suction

Head

Analysis

(Closed

Section

2.2(B)) -

The

core

spray

system

net

, positive suction

head

(NPSH) calculation provided

during

the initial

inspection

were

non-

conservative.

The

licensee

provided

additional

information to

NRR for review in letters

dated

March 28,

1989

and July 6,

1989.

The

NRR safety

evaluation

was

provided

in

a

memorandum

from

M. Slosson

to J. Wiggins dated August 9,

1989

and

concluded

that for design

basis

accidents

with

the

expected

containment

conditions,

sufficient

NPSH will be available for the core

spray

pumps.

On the basis

of the

NRR evaluation, this item is-

closed.

Core

Spray

System Susceptibility

to Water

Hammer

(Open

Section

2.2(C)) -,During the

a con-

cern

was

raised

that

nearly

two-thirds

of

the

core

spray

system

pi ping

may

be voided in normal

system

standby

conditions.

System

initiation

with

such

a

voided

conditicn

could

result

in

damage

from water

hammer.

Niagara

Mohawk,

in

a

letter

dated

July 6,

1989,

provided'n

analysis

of the water

hammer concern

and committed to per-

form

a

core

spray injection test prior to plan(

startup.

Both

small

break

and

large

break

sequences

will

be tested

to verify that dynamic

loads during startup will not damage

the

systems.

Closeout-

of

this

item

is

dependent

upon

the

successful

completion of this test.

Adequacy

of

Alarm

Setpoints

(Open

-

Section

2.2(D)) -

The review of this

item in Inspection

Report

50-220/89-18

included

the

statement

"the

licensee

plans

to

complete

the

review of

the

other engineered

safeguard

system

alarms prior to

unit restart".

indicated

that

the

review

had been

completed

and

recommendations

were cur-

rently under evaluation.

NMPC committed to pro-

vide, prior to restart,

a

summary of the findings

and

the

NMPC decisions

on the

study

recommenda-

tions.

The inspector will followup on this item

in

a subsequent

report.

15

b.

(Open)

Unresolved

Item (50-220/89-18-02):

Inadequate

Core Spray System Test Flow Rate.

During the followup

inspection

to

the

the

concern

was

raised

that

testing of the core spray

system

is performed at flow

rates

well

below

those

assumed

in

ECCS

performance

analyses.

NMPC indicated that testing is performed at

the

lower flow rate

to

avoid vibration

problems

and

lifting of

the

minimum

flow relief, valve.

At

a

September

8,

1989 meeting,

NMPC indicated that gagging

of the relief valve (an option proposed earlier) would

not

be used after startup.

New relief valve internals

will be tested

before restart,

but even if successful,

the

flow in the test

line would still

be

less

than

ECCS flow.

A decision

on

a long-term fix is expected

by

the

end

of this

year.

This

item

remains

open

pending

NRC review of NMPC's long term fix.

(Open)

Unresolved

Item (50-220/89-18-03):

Core

Spray

System Testing:

Control of

Pump

Curves

(Open - Section 2.7(A))-

The

identified specific

inadequacies

with

regard

to the control of core

spray

pump curves

which are

used in

ECCS performance

analyses.

The

followup inspection

report

concluded

that

had

taken

adequate

actions

to correct

the

core

spray

pump deficiencies.

However,

a broader

con-

cern with regard

to other

pump

curves

remained

open.

NMPC committed to validate the performance

of all

pumps required

by Technical Specifications

prior to plant startup.

The

acceptance

criteria

are given in MDC-11,"Nine Mile Point Unit

1

Pump

Curves

and

Acceptance

Criteria

Specification".

This item remains

open

pending

inspector

review

of the validation results.

2.

Lack of

FW Check

Valve Testing

(Open - Section

2.7(E))

The

team

was

concerned

with the

lack of surveillance for the

feedwater-(FW)

pump

and

FW booster

pump discharge

check valves.

had

committed

to

check

valve

testing

prior to

startup

and

a periodic surveillance

program.

At

a

September

8,

1989 meeting,

NMPC indicated that

test

procedures

Nl-ST-Q3

"HPCI

Pump

and

Check

Valve Operability Test"

and Nl-ST-V12 "Condensate

and Feedwater

Booster

Pump Operability

Test"

had

been

drafted

and

were

undergoing

review.

This

item remains

open pending

NRC review of the final

surveillance

procedures.

16

3.

ASME Section

XI Testing

on

the

Core

Spray

MOVs

and

Pumps

(Open

Section 2.7(F)) - The SSFI team

raised

the generic

concern

that the existence of

limited design

margin

may preclude

the detection

of

pump or valve

degradation

prior to reaching

Technical

Specification limits.

At a meeting

on

September

8,

1989,

NMPC committed to provide the

NRC, prior to restart,

a

summary of the

margin

required to perform

ASME Code Section

XI trending

for each

pump

and

valve

in the

IST program

and

the margin actually available.

This item remains

open pending

NRC evaluation

of NMPC's ability to

implement

ASME

Code

Section

XI

acceptance

criteria.

d.

(Open)

Unresolved

Item

(50-220/89-18-04):

HPCI/FW

System

Testing.

The

identified

that

Niagara

Mohawk

failed

to

adequately

control

HPCI/Pl

pump

curves.

had

committed

to develop

and validate

individual

pump

performance

curves

for

the

FW,

FW

booster,

and

FW

condensate

pumps.

At

a mee'ng

on

September

8,

1989,

NMPC indicated that test

procedure

Nl-88-7. 11.

"High

Pressure

Coolant

Injection

Pump

Curves

Field Validation

Test"

had

been

approved

by

SORC

and

the test

was tentatively

scheduled

for thy

third week of October.

This item remains

open

pending

successful

completion

of the testing

and

NRC evalua-

tion of the validated

pump performance

curves.

e.

(Open)

Unresolved

Item (50-220/89-18-05):

NRC Report-

ing.

This

item pertains

to the failure to take

ade-

quate corrective action relative to

10 CFR 50.72

and

50 '3 reports to the

NRC and to address

how they would

identify unanalyzed

safety

conditions

in the future.

At a meeting

on September

8,

1989,

NMPC indicated that

a

formal

response

was

prepared

and

under

internal

review.

This

concern

is

open

pending

NRC evaluation

of the response.

Other Unit

1 0 erations

a.

(Closed)

Temporary

Instruction

(TI)

2500/17

-

Heat

Shrinkable

Tubing.

Information Notice

( IN) 86-53

was

issued

to notify NRC licensees

of installation

prob-

lems

observed with Raychem

Heat Shrinkable Tubing.

To

ensure that licensees

properly

implemented

the

recom-

mendations

contained

in 'N 86-53,

Ti 2500/17

was

issued to provide guidance 'to inspectors

for review of

this issue.

0

17

This

TI

was

reviewed

in

Inspection

Report

50-220/

89-17;

however,

the inspector

did not

document clo-

sure of the TI in that report.

TI 2500/17 is closed.

(Closed)

Unresolved

Item

(50-220/87-24-02):

Scram

Discharge

Volume testing.

This

issue

was previously

reviewed in Inspection

Report

89-04

and the l,icensing

concerns

regarding

this

issue

were

considered

resolved.

This

issue

is. addressed

in

the

Restart

Action Plan

and the inspector

reviewed

NMPC's actions

regarding

the testing of the

scram discharge

volume as

committed to in

NMPC correspondence

dated

June 3,

1988

and in the proposed

Technical Specification

amendment,

submitted

on

December

27,

1988.

In these

'submittals,

NMPC agreed

to perform

a test

once

per operating cycle

and

following

maintenance

to

the

discharge

volume (SDV).

This test

involves filling the

SDV and

timing

'the

draindown

time

of

the

water

from

the

system.

If the time to drain the volume is consistent

with the initial preoperational

testing

of the

SDV,

then

the test

confirms that

there

is

no

blockage

of

the

system.

In addition,

the

time for

the

high

and

low water level alarms to clear in 'each o'i'he instru-

ment lines will be compared to verify that

one instru-

ment

line

is

not

draining

faster

than

the

other,

indicating

that

one

of

the

instrument

lines

may

be

plugged'he

inspector

reviewed

Operations

Surveillance

Test

Nl-ST-C21," Control

Rod

Drive

SDV, Vent, Drain,

Header

and Holding Tank Performance

Test", Revision

0,

dated

May 24,

1989.

The test

was performed

on June

16

and

17,

1989,

and the results

of the test

were deter-

mined to

be satisfactory.

The inspector

reviewed the

test

procedure,

as

well

as,

the

acceptance

criteria

and determined

them to

be technically correct.

While

the inspector did note that the test

was rewritten

on

two previous

occasions

(attempts

to conduct this test

in

June,

1988

and

February,

1989

ended

with tests

results that were determined to be unacceptable

due to

accuracy

and repeatabi lity concerns),

no problems with

the testing

method

used

in the present

procedure

were

noted.

This item is closed.

18

(Update)

Violation

(50-220/88-09-01):

(1)

did

not establish

adequate

controls

over the nondestruc-

tive .testing

measurement

locations

used

in

their

erosion/corrosion

program,

and (2) torus

shell thick-

ness

measurements

were

not

taken

to

a

sufficient

degree

of

accuracy

to

provide

meaningful

data

for

evaluation.

This violation

was

previously

reviewed in Inspection

Reports

(IRs) 50-220/88-81

and

50-220/89-04.

Regard-

ing item (1),

IR 88-81

reviewed

NMPC's

proposed

cor-

rective actions for this portion of the violation, but

did= not verify that

the corrective

actions

had

been

implemented.

The inspector

reviewed

these

corrective

actions at

NMPC's corporate office in March,

1989

and

determined

that these

corrective

actions

were accept-

able.

However,

the violation was left open

since

the

Restart

Action Plan

(RAP) activities

on this item and

item (2) remained

open.

Regarding

item (2;, the thickness

measurements

of the

torus

shell

wall

were

reviewed

in

IR

88-81

and

IR

89-04.

During

IR 88-81,

NMPC committed to performing

torus

shell

thickness

measurements

every

six

months

versus

every

twelve

months,

as

previously

committed.

During IR 89-04,

the inspector

reviewed

NMPC's program

for nondestructively

examining

the torus

shell thick-

ness

and identified

no problems with the program.

He

noted

that

was

taking

torus

thickness

measure-

ments

to three digit accuracy,

has

expanded

the

size

-and

number

of

locations

that

are

examined

on

the

torus,

and

has

improved the markings/identification of

the grid locations

ex'amined

on

the

torus

to

ensure

repeatability of the results.

Item

(2)

remained

open

following

IR

89-04

pending

additional

information being gathered

by

NMPC on torus

wall thinning.

This violation

remains

open

pending

the satisfactory

resolution of the

torus

wall thick-

ness

concerns

and

review

by specialist

inspectors.

(Closed)

Unresolved

Item

(50-220/88-32-01):

could

not provide

an

engineering

evaluation,

as

re-

quired

by Administrative Procedure

7.2,

for the

ade-

quacy

of the'urbine

Building floor elevation

261 to

support material

stored

on that floor.

19

The inspector

reviewed Engineering

Department calcula-

tion number

S6-TB261-C508

which addressed

the projec-

'ed

loading

on this

floor

in

a

worst

case

loading

scenario.

The

calculation,

dated

May 4,

1987,

con-

cluded that the floor would not be overstressed

by the

use

of the

noted

area

of the

Turbine Building for

material

storage.

Given that the evaluation

was per-

formed prior to storing this material

in this area

and

prior to the conduct of IR 50-220/88-32,

no violation

of NRC requirements

occurred.

This issue is resolved.

(Closed)

Violation (50-220/89-06-03):

NMPC failed to

take adequate

corrective actions to prevent the recur-

rence

of conditions adverse

to quality.

NMPC admitted

that the violations occurred

and that timely and

ade-

quate

corrective

action

had

not

been

implemented.

NMPC considered

these

events to be examples

of manage-

ment ineffectiveness

in the

area

of problem identifi-

cation,

resolution

and

communications

Further,

claimed

that

part

of

the

reason

why

the

events

oc urred was that the Restart Action Plan

had not pro-

gressed

far

enough

to

provide

effective

management

controls for communication

and teamwork.

The inspector

reviewed the corrective actions for each

of

the

incidents

cited

in the violation

and

agreed

that they appeared

thorough

and

adequate

to prevent

a

recurrence

of these

events.

He noted that

no repeat

of any of these

incidents

has

occurred

since

the last

event in late June.

This violation is closed.

(Closed)

Unresolved

Item (50-220/87-24-01):

Licensee

identified violation of Technical

Specification

(TS)

thermal

limit parameter

(total

peaking

factor).

On-

November

16,

1987,

during

the

supervisory

review of

completed

surveillance

procedure

Nl-RPSP-l,

Reactor

Physics Daily Surveillance, it was determined that the

Maximum Total Peaking

Factor

(MTPF) had been in excess

of the specified limit for a period of approximately

19.4

hours

on

November

15,

1987.

Licensee

Event

Report

( LER) 87-22 documents

Niagara

Mohawk's investi-

gation of this event,

the root causes

and the correc-

tive actions to preclude

recurrence.

20

Review of

LER 87-22

and discussions

with responsible

station

employees

determined

that

the

consequence

of

this

TS violation was to reduce

the

available

safety

margin.

This

event

did not initiate or result in

a

cladding

failure.

With

a

MTPF

greater

than

3.00,

action

should

have

been

taken

per

TSs to reduce

the

APRM rod block and

scram setpoints.

The

cause

for this

event

was

determined

by Niagara

Mohawk

to

be

personnel

error.

Lack of procedural

clarity was identified as

a contributing factor.

Cor-

rective

actions

taken

by

station

management

were:

disciplinary action

against

the

reactor

analyst

who

failed to identify the thermal limit violation; clar-

ification of Nl-RPSP-1

and

similar

procedures;

and,

training

for all

reactor

analysts

on

the

'Lessons

Learned

for this

event.

The

inspection

also

deter-

mined that to ensure

more timely supervisory

review of

completed

reactor

analyst's

surveillance

procedures

the reactor

analyst unit supervisor

(Unit

1 & 2) have

had

te'.ephone

facsimile

machines

installed

in their

homes.

The

inspector

considers

these

corrective

actions

to

be satisfactory.

In

accordance

with the

Enforcement

Policy

Guidance

of

10 CFR 2,

Appendix

C,

Section

a. 1,

a Notice of Violation is not being issued

for this licensee identified TS violation.

3.2

Unit 2

(Open)

Unresolved

Item (50-410/88-201-01):

Deficiencies

concerning

the

performance

of safety

related circuit breaker

testing

per

Pro-

cedure

N2-EPM-GEN-V582.

An

NRC Vendor Branch inspection

performed in

August,

.1988

identified

three

potential

deficiencies.

has

resolved

one

deficiency

concerning

the setting

of adjustable

trip

settings

on

breakers

by

changing

their test

methodology.

Breaker

trip settings

are

set

to

the

maximum

value

for testing

and

then

returned to the "as-found" setting.

NMPC Engineering

and Electrical

Maintenance

personnel

are

evaluating

the

two remaining

issues

con-

cerning test acceptance

criteria and

where

the breaker trip settings

should

be

set

for the

particular

applications

This

item

remains

open.

4.

Safet

S stem

0 erabilit

Verification

4. 1

Emer enc

Ventilation

S stem

EV

Unit

1

Report

89-07 contained

preliminary findings regarding

an inspector's

walkdown of the

EV system.

Resolution

of some of those findings,

as

well as additional findings identified during this inspection

period,

are discussed

below:

21

Resolution of concerns identified in IR 89-07:

1.

The

1

KW thermostats

were determined to be incorrectly set.

NMPC performed

a surveillance

procedure

on the

EV system,

Nl-ISP-R-202-003,

to

check

the

EV filter train

heater

thermostat

settings.

Using

a heat

probe

and recording the

surface

temperature

of

each filter train,

the

following

results

were obtained:

Train

11 (Heater 202-72) as-found

temp:

126'F

Train

11 Initial thermostat

setting of:

150'F

Train

12 (Heater 202-73) as-found

temp:

145'F

Train

12 Initial thermostat

setting of:

165'F

Procedure

Nl-ISP-R-202-003

provided

guidance

to

set

the

train

11 and

12 thermostats

to achieve

a temperature

probe

contact

reading

on the filter train of 162-168

degrees

F.

To

achieve

this

value, it

was

necessary

to

raise

each

thermostat

to

a setting of 200 degrees

F.

P

After reviewing

the

completed

procedure

test results,

the

inspector questioned

NMPC as to whether

the as-found

ther-'ostat

settings

for trains

11

and

12 affected

past

oper-

ability of the

EV system.

The .inspector

determined

that

neither

Engineering

nor

the station

staff

had

con-

sidered this question.

As

a result,

a

Problem

Report

to

addres's

the inspector's

concern

was written.

Disposition of the

Problem

Report indicated that with tem-

perature

maintained

less

than

165 degrees

F, the

EV. system

would not

meet its design

basis.

Temperatures

below this

limit could allow condensation

on the charcoal filter beds

and

thereby

reduce

adsorption

of radio-iodides

by the

EV

system in the event of an actual

emergency actuation.

Sub-

sequently,

made

a notification under the requirements

of 10 CFR 50.72.b.2.i.

Ins ector Assessment

The inspector

concluded that prior to issuance

of procedure

Nl-ISP-R-202-003

(issued

9/89) that there

were

no proced-

ural controls

in place for the proper setting

or calibra-

tion of the

EY system thermostat units.

Failure to control

.these

units

under

a calibration

or surveillance

procedure

is

an

apparent

violation of Technical Specification 6.8. 1

22

and

Regulatory

Guide

1.33

(50-220/89-08-03).

The

conse-

quence of not calibrating the -thermostat units was that the

EV system

may not have

been able to function per its design

basis

and

thus

may not

have

been

per

TS 3.4.4.

The potential

exists

for the

EV

system

not

having

been

since

1969

when it

was

initially put

into

operation.

2.

.The

inspector

was

concerned

over

the

identification

and

labeling of components,

sample

points,

and other portions

of the

EV system.

Discussion

with

NMPC reveals

that

they

have

plans

to implement

a unit wide program for the

iden-

tification and

labeling of plant

equipment.

The

process

used will be similar to that used at Unit 2.

The inspector

judged this approach

to be acceptable.

The

wooden

blocks

under

flow

element

201.2-367A

were

removed.

No satisfactory

explanation

for their

presence

under the flow element

was provided by NMPC.

4.

Heater

202-76

was

determined

to

be

a

10

KW heater.

The

electrical

schematic

was in error regarding it being

a

9

KW

heater.

The

FSAR

was

determined

to

be correct

in refer-

encing the heater to be

10

KW ~

b.

Subsequent

to the findings discussed

in IR 89-07,

the inspector

identified the following concerns:

P&ID,

C-18013-C,

identifies

sample

connections

in the

EV

system

that

can

be

used

for

flooding

the

system

when

required.

The inspector

determined

that this

statement

on

the

PAID was

no longer

applicable

as,

in 1981,

a manually

initiated water

deluge

system (for combatting

a

charcoal

bed fire in

an

EV train)

was installed

in the

EV system.

The inspector

was

concerned

that initiation of the

deluge

system could affect system operability and requested

a copy

of NMPC's safety evaluation

be

provided

so that

he

could

determine if, or

what,

system

operability

concerns

were

considered

prior to installing the deluge

system.

After a

two week search,

NMPC concluded

that there

was

no existing

safety evaluation for the modification.

A parallel

evalua-

tion

completed

during

the

inspection

period

was

found

by

the inspectors

to

be

incomplete

as it did not address

the

inspectors'oncerns.

Failure to perform

a safety evalua-

tion for the modification to the

EV system is

an apparent

violation

of

the

requirements

of

10 CFR 50.59

(50-200/

89-08-04).

'

23

2.

Operating

Procedure

(OP)

10,

"Reactor

Building Heating,-

Cooling

and

Ventilating

System,"

Section

H.7,

provides

instructions

on two methods of cooling the

EV filter trains

following a

Loss of Coolant Accident (LOCA), yet the alarm

response

procedures

(ARPs) section of OP-10

and the

Emerg-

ency Operating

Procedures

(EOPs)

never direct the operators

to Section

H.7.

3.

The

ARPs

in

OP-10 for "Emergency

Vent

System

Temp

High"

contain

vague instructions

on required

actions.

Addition-

ally,

many

of

the

manual

actions

required

may

not

be

realistically

carried

out

under

actual,

emergency

use

of

the

EV system

due to radiation exposure

concerns.

4.

Similarly, the

ARPs in OP-21 for "RB Charcoal Filters" con-

tains

vague

instructions

and

are

also potentially unreal-

istic

as

they too call for manual

actions

to

be

taken

in

the vicinity of the

EV system.

Ins ector Assessment

was

questioned

as

to the

above

concerns.

The

inspector

concluded that

the existing

procedures

(OP-10

& 21)

contained

actions

which are

vague

and potentially unrealistic.

The inade-

quacy of these

procedures

represents

an

apparent

violation of

10 CFR 50,

Appendix

B,

Criterion

V,

regarding

procedures

(50-220/89-08-05).

c.

Control

Room

Emer enc

Ventilation

S stem

CREV

Unit

1

The

inspectors

performed

a

walkdown of

a portion of the

CREV

system,

focusing

on

visual

inspection

requirements

of

NMPC's

reload

procedure

N1-88-6.6,

"System

and

Area

Malkdown

for

Restart

Procedure."

The inspector identified

numerous

materia]

and equipment deficiencies.

The inspectors

compared their list

with NMPC's list of deficiencies

identified during NMPC's walk-

down of the system in July 1989.

The inspectors

determined

that

none

of their identified deficiencies

were contained

on

NMPC's

completed

system

walkdown punchlist.

The inspector's

findings

were discussed

with the Unit Superintendent,

and the inspectors

are

awaiting

NMPC's

response.

Inspector,followup

of

these

observations

will

be

performed

in

a later

inspection

period.

5.

Plant Ins ection Tours

During this reporting period,

the inspectors

made tours of the Unit

1 and

2 control

rooms

and accessible

plant areas

to monitor station activities

and to

make

an

independent

assessment

of equipment

status,

radiological

conditions,

safety

and

adherence

to regulatory requirements'he

follow-

ing were observed:

24

5.1

Unit

The inspector did not identify any concerns

and concluded that condi-

tions were acceptable.

5.2

Unit 2

a.

The inspector

reviewed

a video surveillance

system

and concluded

that this enhancement

was

an example that

NMP proactively imple-

mented

the

ALARA concept.

During

the

September

1989

two-week

maintenance

outage,

NMPC installed

a video surveillance

system

in each

feedwater

bay

and in the

condenser

area

of the Turbine

Building.

These

surveillance

systems

consisted

of

remotely

operated

cameras

and monitors.

As

a result,

entry

into

high

'adiation

areas

was

not

required

during operator

rounds.

Two

spare

cameras

were also provided for job coverage 'in other

high

radiation

areas,

as

the

need arises'hese

video systems

could

result

in

a

reduction

of personnel

exposure

while maintaining

the intent of the inspection

performed

during operator

rounds,

an example of a good

ALARA approach.

While reviewing the

SSS

logs

on October

11, the inspector

noted

an

entry

where

the

humidity inputs to the temperature

control

valve

(2HVR"TV22B) in the chilled water

system for the

Control

Building

Relay

Room

were

".broken"

and

did

not affect

system

operability.

This problem developed

while

I&C technicians

were

performing

a

loop

calibration

of

2HVR*TV22B

inputs.

The

humidity inputs were found out of specification

and could not be

corrected

in

a timely manner.

The

inspector

reviewed

the

equipment

status

log, but found

no

explanation

of why the

system

was

with the

"broken"

humidity inputs.

The inspector

reviewed the

FSAR and found that

this

system,

including the

humidity input,

is

described

pic-

torally

and

in words.

After much discussion

with the station

staff,

the

inspector

determined

that

at

a

meeting

held

on

October

10

between

mangement

and

technical

staff, it was con-

cluded that the

system

was operable

without the humidity input

and that

a written engineering

safety evaluation

would follow.

The

inspector

expressed

concern

to

station

management

that

Niagara

Mohawk did not utilize

a formal

and controlled

10 CFR 50.59 process

to assess

the impact of this component'malfunction

on overall

system operability or the potential for an unreviewed,

safety question

being

introduced.

This item remains

unresolved

pending

further

discussion

with

the

station

management.

UNRESOLVED ITEM (50-410/89-08-02)

C

'

6.

Surveillance

Review

25

The inspectors

observed

portions of the surveillance

testing listed below

to verify that the test

instrumentation

was properly calibrated,

approved

procedures

were

used,

the

work

was

performed

by qualified

personnel,

limiting conditions for operations

were

met,

and the system

was correctly

restored following the testing.

6.1

Unit

1

The inspector

reviewed portions of the "Mini-R2" test which simulates

loss

of off-site

power coincident with

LOCA conditions.

This test

supports

operability verification requirements

of the

one train of

Core

Spray

needed

to

support

reload.

The

inspector

also

reviewed

procedure

Nl-ISP-R-202-003

which tests

the operation

of the

1KW and

10

KW heaters

on the

EV system..

6.2

Unit 2

a.

The inspector

reviewed

the local

leak rate testing

on feedwater

system

check valves per

N2-ISP-CNT-RQ005,

"Type 'C'alve

Leak-

age Test Feedwater

Valves

2FWS"AOV23A."

No concerns

were noted.

b.

The

inspectors

observed

numerous

Operations

shift

turnovers

including the performance

of the turnover surviellance checklisg

by an

oncoming

CSO prior to assuming

the watch.

The inspectors

also

attended

shift turnover

briefings

held

by

the

SSS.

No

concerns

were identified.

7

~

Maintenance

Review

The

inspector

observed

portions

of various

safety-related

maintenance

activities

to

determine

that

redundant

components

were

operable,

that

these

activities

did not violate

the limiting conditions for operation,

that requi red administrative

approvals

and tagouts

were obtained prior to

initiating the

work, that

approved

procedures

were

used

or the activity

was within the "skills of the trade",

that appropriate

radiological

con-

trols

were

implemented,

that ignition/fire prevention

controls

were pro-

perly implemented,

and that equipment

was properly tested prior to return-

ing it to service.

The inspectors

concluded that the maintenance

program

was being effectively implemented.

7.1

Unit

1

Maintenance

was

observed

on

the

Emergency

Diesel

Generators

and

on

the Core Spray Topping

Pumps.

No discrepancies

noted.

26

7.2

Unit 2

During the

outage,

the major work items were:

general

inspec-

tion

and

preventive

maintenance

on the Division III Emergency

Diesel

Generator

(EDG);

leak

testing

feedwater

valves

for

Appendix

H requirements;

minor modifications

to the

feedwater

minimum flow valve circuit; drywell to suppression

chamber leak

test;

and cooling tower maintenance.

The outage

was finished

on

schedule.

During

the

course

of

the

outage,

the

inspector

observed

several

maintenance

activities

and noted the following:

The

inspector

observed

the work performed

on the Division

III EOG under Procedure

N2-MSP-EGS-R002.

The work was per-

formed by the

mechanical

maintenance

group.

The technic-

ians

followed the

procedure

and

used

good work practices.

Quality

Control

coverage

and

supervisory

oversight

was

present

at the work site.

The inspector noticed the main-

tenance

crew- brought

a

large

radio into the diesel

space

and

was

playing

music.

The technicians

stated

that this

was

an accepted

practice.

The inspector

was concerned

that

the

music could poter,"ially drowned

out station alarms

and

announcements

and

brought

this

concern

to

management's

attention.

The radio

was

removed

from the

work site

and

such

practices

are

not

allowed

per

Unit

Superintendent

policy.

Niagara

Mohawk identified that

an incorrect grade of crank-

case

lube oil was

provided

and

added

to

the Division III

EDG

lube oil

sump.

This

resulted

in additional

work of

pumping

down the

EDG

and adding the correct grade

lube

oil which

was

specified

by the

procedure.

The

inspector

was

concerned

that

the

maintenance

technicians

failed

to

verify the correct lube oil was obtained prior to adding it

to the crankcase.

Additionally, materials

management

per-

sonnel

incorrectly

changed

the material

issue

sheet

which

caused

the incorrect

lube oil to be delivered

to the work

site.

These

examples

indicated

more care

was

needed

to obtain procure-

ment parts

and deliver the correct

parts

to

the

work site

to

support maintenance activities.

0

27

b.

During the

review of training

on the

lessons

learned

from the

valves left out of position (discussed

in Section

2.2.e of this

report),

.the

inspector

learned

of other

problems

experie~ced

during routine

operation

of the

reactor

water

cleanup

system.

The inspector obtained

a printout of the maintenance

backlog for

the

system.

There

were

113 total

work requests

(WR) out-

standing

in

this

particular

system.

Sixty-eight

WRs

. were

related to

a specific

type of air

operated

valve in the

system

that would not fully shut

on

a loss of air,

as designed.

These

valves are

scheduled

to be repaired

during the next refuel out-

age.

The inspector

reviewed

the

impact of these

valves

on

operability

and

found

they

did

not

inhibit

the

containment

isolation feature.

8.

Alle ation Followu

During

the

inspection

period,

the

inspectors

conducted

interviews

and

inspections

in response

to allegations

presented

to the

NRC.

The inspec-

tor and licensee

actions resulting

from these allegations

are noted below:

8.1

Unit

1

RI-89-A-0094:

Allegation

concerning

a contractor

empl'oyed

at

NMP.

Specifically, it was alleged that information

may not

have

been

pro-

vided to

NMP Security

personnel

by the individual during completioq

of the

background

questionnaire

and that the

employee

was

an

occas-

ional

drug user while off-duty.

(Reference

NRC Letter, J.

T. Wiggins

to L. Burkhardt, III, dated August 24,

1989).

The

inspectors

first

became

aware

of

the

allegation

on

August 16,

1989.

At that time,

the individual's

name

was

provided

to

NMPC Security

along

with pertinent

details

of

the

allegation.

Results of NMPC's investigation follow.

Regarding

the allegation of drug

use,

the individual

was questioned

by

NMPC Security

on August 18,

and was drug tested

the

same day.

The

individual

was cooperative

with

NMPC Security during questioning

and

in agreeing

to

the

drug test.

Results

of the

drug test,

returned

several

days

later,

were

negative

for the

presence

of illegal drug

metabolites.

Therefore,

the

allegation

of off-site

drug

use

was

uncorroborated.

28

The other aspect

of the allegation

concerning discrepancies

in back-

ground

information

was partially correct,

in that

a discrepancy

was

found

in

the

individual's

background

information.

However,

Security

had already identified

a problem with this when contacted

by

the inspector

on August 16.

NMPC Security allowed the individual

90

days

to clarify the discrepancy

in the background

information.

The

individual, through the services of an attorney,

was able to explain

the discrepancy

to the satisfaction

of

NMPC Security.

The'inspector

reviewed the information with NMPC Security

personnel

and

was satis-

fied with the- resolution.

This allegation is

closed'.2

Unit 2

RI-86-A-0129:

In

a letter

dated

July 18,

1989,

Region I requested

NMPC to investigate

two additional

concerns

generated

by the

review

of

an

NRC investigation.

The

NRC's

review of the

completed

inves-

tigation report identified

two additional

safety

concerns.

First,

the alleger

named five individuals alleged to have either

used drugs

onsite

or

known to

have

used/purchased

drugs

~nsite.

Second,

the

alleger

claimed

that

he

informed

a

gC Supervisor

of his findings

(i.e.,

improper

weld activities)

and

that

this

information

was

contained

in five (5) logbooks turned over to that supervisor.

NMPC Security,

and

the guality First

Program

investigated

these

two

safety

concerns.

Results

of

the

investigation

were

discussed

in

detail

with the

inspectors.

A

summary

of

NMPC's findings follows:

Regarding

the drug allegations,

NMPC was able to locate

and talk with

the five individuals

named.

None of the individuals

named presently

wor k for NMPC nor are they in the

New York State

area.

All individ-

uals

contacted

denied

drug

use onsite.

Only one individual admitted

to

casual

drug

use off-site,

but denied

ever

working onsite

while

under

the influence.

Three of the individuals have

been drug tested

at their sites

(since

employment

with

NMPC) with negative

results.

One individual. no longer works in the nuclear field and the other

has

not been tested

since

employment with NMPC. It should

be noted that

the

alleged

period of onsite

drug

use

predates

the

new Fitness

For

Duty rule recently

promulgated

by the

NRC.

Overall,

the

inspector

was satisfied with the depth

and thoroughness

of NMPC's investigation

into the drug

use concern

and considered this matter closed.

r

29

Regarding

the

five

weld

logbooks,