ML17056C045
| ML17056C045 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 09/25/1992 |
| From: | Drysdale P, Eapen P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17056C044 | List: |
| References | |
| 50-220-92-18, 50-410-92-20, GL-88-14, NUDOCS 9210080003 | |
| Download: ML17056C045 (14) | |
See also: IR 05000220/1992018
Text
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
REPORT NOS.
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50-220/92-18,
50-410/92-20
DOCKET NOS.
LICENSE NOS.
50-220
50-410
NPF-69
LICENSEE:
FACILITYNAME:
INSPECTION AT:
Niagara Mohawk Power Corporation
301 Plainfield Road
Syracuse, New York 13212
Nine Mile Point, Units
1 and 2
Scriba, New York
INSPECTION DATES:
July 27 - August 7; and August 31 - September
1, 1992
INSPECTOR:
P. Drysdale, Sr.
eactor Engineer,
Systems Section, EB, DRS
Date
APPROVED BY:
Dr. P. K. Eapen, Chic
Systems Section,
Engineering Branch, .DRS
Date
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actions for the Instrument Air System in Unit 1;
the licensee's corrective actions for
violation NOV 50-410/91-12-02 (inadvertent isolation of a secondary containment unit
cooler); and the licensee's actions to address
unresolved item URI 50-410/91-12-04 (reduction
in cooling capability in certain unit coolers).
9210080003
920930
ADOCK 05000220
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The licensee is nearing completion on Phase IIof a three phase response to Generic Letter 88-14 for Unit 1.
As a result of the design basis reconstitution effort for the
Instrument Air system, several design issues remain open.
The significance and priority for
resolving these items remain as concerns to the NRC. The initial schedule committed by the
licensee for this GL was not met due to changes in operating cycle and the resulting
postponement of the outage required to complete the actions.
The licensee agreed to provide
a revised schedule and the status of open engineering issues by September 3, 1992.
The licensee's corrective actions for violation 50-410/91-12-02 was adequate.
Therefore this
violation is closed.
However, complete and documented engineering bases for current service
water cooling capabilities were not available.
Consequently,
unresolved item URI
50-410/91-12-04 remains open.
3
1.0
UNIT 1 RESPONSE TO NRC GENERIC LETTER 88-14, "INSTRUMENTAIR
SUPPLY SYSTEM PROBLEMS AFFECTING SAFETY-RELATED
EQUIPlVH<JitT"
The inspector reviewed Niagara Mohawk's response and progress on actions imposed through
NRC Generic Letter (GL) 88-14.
The GL was issued in August of 1988 as a result of NRC
concerns about instrument air system failures which have caused adverse effects upon
safety-related equipment.
The letter requested
licensees to verify that safety-related
instrument air "systems are operated,
maintained, and tested in accordance with design basis
requirements and that system components would perform as expected in all design basis
events.
Niagara Mohawk responded
to the GL in April 1989.
This response outlined the following
three phase evaluation of plant air and gas systems (Instrument, Service, and Breathing Air):
Phase I:
Short term actions to verify the systems'peration,
testing, and maintenance
are performed in accordance with the original design basis.:
Phase II:
Long term,* complex operational considerations involving testing, analysis, and
evaluation of system aging and degradation to assure continued performance
and fulfillmentof mtended functions.
Phase III:
Implementation of corrective actions and system improvements.
The response letter indicated that an engineering evaluation was performed in Phase I to
determine that the IAS system was being operated within its design, operational basis and its
safety evaluation.
The design and operational bases were also verified by a detailed
evaluation of the engineering documentation.
The Phase I reviews concluded that all air systems were operated,
maintained, and tested in
accordance with the design basis requirements.
Phase II work was ongoing during this
inspection and a separate project was undertaken to reconstitute the design bases for the
plant's air systems as part of the licensee's efforts to reestablish the design bases for
safety-related
systems at Unit 1. This work has proceeded in parallel with the Phase II work
to evaluate IAS performance.
A contractor was hired to establish the design basis for the air
systems and to produce a System Design Basis Document (SDBD). This work was nearing
completion at the time of this inspection.
In April 1992, the contractor notified Niagara Mohawk getter 1120-140-SYR-199, 4/7/92) of
twenty nine outstanding engineering and design basis issues for Unit 1 air systems and
provided a description of all plant equipment and documents affected by each issue.
Also in
April 1992, Niagara Mohawk Engineering and the contractor conducted a formal meeting and.
addressed
sixteen of the above issues.
The meeting identified the potential safety significance
of all sixteen open items and the actions required to resolve them.
The licensee determined
that each of the sixteen items was not a technically significant discrepancy.
Niagara Mohawk
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Evaluation engineers performed a preliminary evaluation of all design-related
open items in
accordance with procedure DBGR-012, "Discrepancy Evaluation Guideline"; however, the
classification of their significance was preliminary since the issues were not completely
evaluated and their resolution remained open.
Engineering evaluations were performed by
the contractor on 16 of the current 29 outstanding open items.
The inspector reviewed the current status of engineering and design reconstitution efforts for
the Unit 1 IAS and the unresolved engineering issues against the licensee's response letter.
Niagara Mohawk's initial response to the GL was based upon the existing body of
engineering and design basis information available within the company in 1989;
The original
architect-engineer (AE) for Unit 1 was not involved with the initial response to the GL and
the current design basis reconstitution is supported by the contractor.
The response letter
indicated that completion of the Phase II work was dependent on the next scheduled refueling
outage which was then scheduled for Spring of 1991.
However, the operating cycle was
delayed and the refueling outage was postponed until 1993.
The letter also indicated that the
results of Phase IIwould be submitted after the next refueling outage (initiallyplanned for
Spring of 1991) and Phase IIIresults would be submitted by January 1992,
The delayed
operating cycle affected Phase
11 and Phase IIIand the licensee has not established new
completion dates for these activities.
The inspector discussed
the above inconsistencies in the
response letter with the licensee.
The licensee agreed to document the revised schedule for
the completion of the required actions in a letter to the NRC by September 30, 1992.
Out of the total twenty nine unresolved items, the inspector observed that four were
significant as they had a potential impact upon operation and testing (see ABB letter of
4/7/92, items OI-506-'S020, -S021, -S022, and -S027).
These items were:
1) lack of design
basis information for safety relief valve setpoints; 2) unable to determine cooling water
requirements for instrument air compressors;
3) pipe and pipe support design load and stress
analyses do not exist; and 4) analysis of the instrument air capability under a 50% duty cycle
does not exist.,The inspector discussed
the status of these items with the licensee and noted
the licensee had only completed a preliminary evaluation of these and other items.
The
formal classification of all of the open engineering issues for the IAS was pending at the time
of this inspection.
Therefore, this issue remains unresolved pending the licensee's completion
of the formal evaluation of the IAS and resolution of all open engineering issues
(URI 50-220/92-18-01).
2.0
FOLLOWUP TO PREVIOUS NRC CONCERNS (92702)
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In NRC inspection report 50-410/91-12, a violation was issued to address the inadvertent
valving out of SW unit cooler 2HVR*UC404D for an extended time.
Preventive
Maintenance work and testing were initiated on the cooler and an isolation tag permit
("markup") was approved by the operations staff.
The maintenance work was interrupted
prior to completion as the cooler's SW discharge throttle valve could not be positioned
properly to provide the required SW outlet flow. The markup was voided and tags were
removed from the cooler.
However, the SW inlet valve was not returned to the open
position, thus making the cooler unavailable.
The condition was noted approximately two
weeks later when a confirmatory valve lineup was performed by operations personnel and the
valve was noted to be out of its required position.
This situation was reported by the licensee
in LER 91-16 on August 1, 1991, and its supplements
dated September 3, 1991, and
November 21, 1991.
The initial violation addressed
the apparent inoperability of this cooler
from a technical specifications point of view.
After an engineering review of the cooling capacity provided by this heat exchanger,
Niiagara
Mohawk concluded that the reduction in heat removal capability did not represent a loss in
capacity below the required minimum for post-accident cooling of the secondary containment.
Under the analyzed worse case conditions in the SW system (maximum heat loading in
containment and minimum temperature difference between SW and containment), the
minimum time required to meet secondary containment drawdown to -1/4" water gauge could
still be achieved.
This information was presented to the NRC during an enforcement
conference on October 17, 1991.
Based on this enforcement conference,
the NRC concluded
that the reduction in heat removal capability for cooler 2HVR*UC404D was not a violation
of technical specifications as previously stated.
The NRC also concluded that the inadvertent
isolation of this cooler was an indication of inadequate configuration control which was a
violation of NRC requirements.
The violation was therefore reissued to reflect inadequate
procedure controls over the implementation and voiding of equipment markups as discussed
in the NRC letter dated October 23, 1991, and in inspection report 50-410/91-17.
The inspector reviewed the licensees actions in response to this violation.
Generation
Administrative Procedure GAP-OPS-02, "Control of Equipment Markups" was revised on
November 11, 1991, to specify additional requirements for voided markups.
These included
instructions to retain all voided markups for accountability.
The inspector reviewed the file of equipment markups maintained in the Unit 2 control room
and randomly selected ten voided markups to examine them for conformance with
GAP-OPS-02.
Allof these files contained complete records of markup sheets and tags as
required by the procedure.
In addition, necessary approval signatures for voiding the markup
were appropriately documented.
Two of the files examined involved markup tags which had
been applied to plant equipment before they were voided.
As required by the procedure,
these files contained all of the tags that had been removed; however, a notation that all the
tags had been accounted for was not entered into the file as required by the GAP., The
inspector performed a complete accounting for these markup files and confirmed that all tags
had been removed and retained.
No tags were noted to be missing and all tag identification
numbers corresponded
to the numbers listed in the file. The operations manager was
informed that two voided markups had not been annotated
as required by the procedure and
that'operations personnel responsible for performing an accounting of tags might not fully
understand the procedure requirements.
The operations manager issued an instruction to all
station shift supervisors on August 11, 1992 to assure that a complete tag accounting is
performed and documented.
The inspector considered that the revised procedure
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requirements to retain all voided markup files and tags provided the necessary
administrative
controls to complete necessary corrective actions for the violation.
The additional actions
taken by the operations manager to assure that voided tags are inventoried and documented
are also considered adequate to address the inspectors concerns.
Based upon the above
review, this item is closed (NOV 50-410/91-12-02).
'he inspector noted that additional actions were taken by the licensee to provide a
methodology for operations personnel to interpret technical specifications requirements and to
determine the operational status of serviceable unit coolers when one or more coolers are
removed from service for maintenance or testing.
The interpretation provided a means to
assure that the available cooling capacity was adequate to provide minimum post-accident
containment cooling and drawdown.
The inspector reviewed the licensee's evaluations of
cooler performance and noted that the interpretation was based upon an assumed
average
cooler degradation of 30% under worse case conditions.
However, detailed and formalized
engineering calculations were not available at the time of this inspection to substantiate
the
validity of this assumption.
This is of particular concern to the NRC since some coolers
(2HVC*UC407C and 2HVC*UC407E) were demonstrated
by testing in May 1991 to have
less than 63% design capacity available.
Therefore, the assumed
average of 70% available
capacity may not be valid for all situations where some unit coolers are permitted to be
removed from service.
The potential safety significance of these concerns were expressed
to
the licensee within the context of unresolved item 50-410/91-12-04,
"Build-up of
Silt/Corrosion Products in Unit Coolers," and willbe tracked for resolution under that item.
3.0
EXIT INTERVIEW
The inspector held a preliminary exit interview with Unit 2 management
on August 4, 1992
to review the results of the follow-up to the violation. A final exit interview was conducted
on September
1, 1992 with corporate engineering and Unit 1 licensing personnel to conclude
the review of the Unit 1 response to Generic Letter 88-14.
Attachment
1 contains a list of
personnel attending the exit meetings.
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ATTACHMENT1
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P. Bartollini, Lead Mechanical Engineer
G. Brownell, Site Licensing
J. Conway, Technical Support Manager
A. DeGracia, Operations Manager
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P. Francisco, SDBD Control Point Manager
M. Friedman, Mechanical Design Engineer
S. Godamunne,
Mechanical Design Engineer
D. Green, System Engineer
M. Jaquin, Operations Support
E. Klein, Engineering Project Manager
B. Magnant, Site Licensing
M. McCormick, Plant Manager
+ R. Oleck, Design Basis Reconstitution Program Director
D. Rathbun, Operations Support
+ ¹ Spangoletti, I.icensing Program Director
. G. Thompson, Supervisory System Engineer
+ W. Yeager, Engineering Manager
T. Zannick, Site Licensing Manager
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W. Schmidt, Senior Resident Inspector, NMP
R. Laura, Resident Inspector, NMP Unit 1
B. Mattingly, Resident Inspector, NMP Unit 2
C. Beardslee,
Inspector Intern
Present at the preexit meeting on August 4, 1992
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Present at the exit meeting on September
1, 1992
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