ML17058A727
| ML17058A727 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 04/18/1991 |
| From: | Linville J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Sylvia B NIAGARA MOHAWK POWER CORP. |
| References | |
| NUDOCS 9105020014 | |
| Download: ML17058A727 (14) | |
See also: IR 05000220/1991002
Text
Docket No. 50-220
Niagara Mohawk Power Corporation
ATTN: Mr. B. Ralph Sylvia
Executive Vice President
Nuclear Operations
301 Plainfield Road
Syracuse, New York 13212
Subject:
NRC Region I Inspection Report No. 50-220/91-02
Dear Mr. Sylvia:
This refers to your letter dated April 12, 1991 (NMP1L 0578), in response to our letter dated
March 7, 1991.
Thank you for informing us of the corrective and preventive actions documented in your letter
related to the implementation of a 10 CFR 50, Appendix J exception.
These actions will be
reviewed during a future inspection in the operations area.
Your cooperation with us is appreciated.
Sincerely,
""'.t':"'"'~ 'igAed t,"li.
>" '-a
C. l.inttli
James C. Linville, Chief
Reactor Projects Branch No.
1
Division of Reactor Projects
OFFICIALRECORD COPY
a: Rpl91-02.NM1
~
'
Niagara Mohawk Power Corporation
APR i8 1991
CC:
J, Firlit, Vice President - Nuclear Generation
C. Terry, Vice President - Nuclear Engineering
J. Perry, Vice President - Quality Assurance
S. Wilczek, Jr., Vice President - Nuclear Support
K. Dahlberg, Unit 1 Plant Manager
M. McCormick, Unit 2 Plant Manager
D. Greene, Manager, Quality Assurance Operations - Unit 1
C. Beckham, Manager, Quality Assurance Operations - Unit 2
R. Tessier, Manager, Operations - Unit 1
M. Colomb, Manager, Operations
Unit 2
K. Thomas, Supervisor - Site Licensing
J. Warden, New York Consumer Protection Branch
M. Wetterhahn, Jr., Esquire
G. Wilson, Senior Attorney
Director, Power Division, Department of Public Service, State
State of New York, Department of Law
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
State of New York, SLO Designee
of New.York
OFH~CIALRECORD COPY
a: Rpl91-02. NM1
Niagara Mohawk Power Corporation
bcc:
Region I Docket Room (with concurrences)
J. Joyner, DRSS
J. Linville, DRP
D. Vito, DRP
D. Haverkamp, DRP
T. Vegel, DRP
K. Brockman, EDO
R. Capra, NRR
D. Brinkman, NRR
WCook/mjd
4/l~/91
DHaverkamp
4/591
JL4ville
4)j5I/91
OFFICIALRECORD COPY
a: Rp191-02.NM1
7 NlA
U MOHAWK
lose ph F. Firlit
Vice President
Nuclear Generation
NINE MILK POINT NUCLEAR STATION IP.O. BOX 32 LYCOMING,NEW YORK 13093/TELEPHONE (315) 343-21 10
April 12,
1991
NMP1L 0578
U. S. Nuclear Regulatory
Commission
Attn:
Document Control Desk
D.
C.
20555
Re:
Nine Mile Point Unit
1
Docket No. 50-220
Gentlemen:
Attached is Niagara
Mohawk Power Corporation's
response
to the Notice of
Violation contained in Inspection Report
Numbers 50-220/91-02
and 50-410/91-
02 dated
March 7,
1991. If you have .any questions
concerning this matter,
please call me.
Very truly yours,
NIAGARA MOHAWK POWER CORPORATION
F. Firlit
'ice President
Nuclear Generation
NAS/rp
000975KK
xcs
Regional Administrator, Region
Mr.
W. A. Cook, Senior Resident Inspector
Records
Management
e
NINE MILE POINT UNIT 1
DOCE33T NO. 50-220
RESPONSE
TO NOTICE OF VIOLATION CONTAINED IN
INSPECTION REPORT NOS. 50-220/91-02
AND 50-410/91-02
VIOLATION
Nine Mile Point Unit
1 Technical Specification 6.8.1 states
that written
procedures
shall be established,
implemented
and maintained
that
meet or
exceed
the requirements
of Section 5.3 of ANSI N18.7-1972 which states,
in
part, that written procedures,
including revisions or changes,
shall be
reviewed for adequacy
and approved
by authorized
personnel.
Contrary to the above,
on May 7,
1990, Operating Procedure
Nl-OP-14,
Containment
Spray System Nos.
80
& 93,
was revised
to incorporate operational
alternatives
to 10 CFR 50, Appendix J, testing of the containment
spray
(CS)
system discharge
check valves in a manner which conflicted with existing
procedures.
Specifically,
the revision to N1-OP-14:
Conflicted with the requirements
of Emergency Operating Procedure
(EOP)
4 regarding criteria for termination of containment
spray;
2.
Failed to identify that portions of Section H.8 of N1-OP-14 could not
be
performed,
in that post-LOCA radiation fields would likely prohibit
local operation of two of the
CS system's
cross-tie valves per EOP-10
(valves modified ta manual operation only, per the Appendix J exemption
Safety Evaluation 89-13);
and,
3 ~
Vas written in a manner which created
confusion
among oper'ators
interviewed
as to its applicability and implementation.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:
Niagara
Mohawk Power Corporation admits to the cited violation.
THE REASON
FOR THE VIOLATION:
Niagara
Mohawk has determined
that this violation occurred
due to inadequate
technical review.
The root cause for this inadequate
review was poor
definition of the roles
and responsibilities of the involved departments.
Management
overview of the Restart Action Plan focused
on defining the
Appendix J licensing requirements.
The same
emphasis
was not applied to the
technical review and implementation of these
requirements.
The reviewers of Safety Evaluation No. 89-13,
"Appendix J-Mater Seal"
(SE 89-13) failed to address
adequately
the impact of procedural
and technical
issues prior to its approval.
As a result, this review failed to identify the
inconsistencies
between Operating Procedure'1-0P-14,
"Containment
Spray
System"
(OP-14),
and Emergency Operating Procedures
(EOPs).
In addition,
89-13 did not evaluate
the additional requirements
of operation of valves 80-
40 and 80-45 for mitigation or recovery
from an accident.
CORRECTIVE STEPS
VHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
Section H.7.0 of OP-14 has
been revised
to remove
the conflict between
N1-EOP-4 and
OP-14 regarding implementation of the water seal during a Design
Basis
Loss of Coolant Accident
(LOCA).
Steps
H.7.3 through H.7.8 which were
added
to provide a water seal during times without drywell spraying have
been
deleted.
SE 89-13 was revised
to clarify the implementation of a water seal
when containment
spray is in the spray
mode during the Containment
Design
Basis
LOCA.
SE 89-13 was also revised
to clarify that intertie valves 80-40
and 80-45 are not accessible
following an accident
and specified alternate
actions are required if these
valves
must
be closed.
In this regard,
Section
been revised
to allow Drywell Flooding if intertie
valves 80-40 or 80-45 are inaccessible
due to radiological conditions.
'he
OP-14 revisions
have
been
reviewed under
the provisions of 10CFR50.59
and
no unreviewed safety question exists.
Shift briefings were held to provide operators
clear direction to enter
a
Limiting Condition of Operation for those activities requiring closure of a
containment
spray isolation valve and closing of one or both of the
two
normally open intertie valves.
These shift briefings eliminated
the confusion
among operators
regarding Limiting Condition of Operation for those activities
described
above.
On-shift training for all operating
crews on, the revised
OP-14 will be
complete
by April 19,
1991.
Reinforcement
training for the operators
on the
simulator will be complete
by August 1,
1991.
CORRECTIVE STEPS
VHICH HAVE BEEN TAKEN TO AVOID FURTHER VIOLATION:
The recently completed Niagara
Mohawk Nuclear Division reorganization
provides
for improved clarification of roles
and responsibilities.
The responsibility
for maintenance
and development
of the Operations
department
procedures,
including OPs
and
EOPs,,
now resides with'a single individual, the General
Supervisor of Operations
Support.
This organizational
feature will provide
better accountability,. for Operations
Department
technical review.
Safety
Evaluations
are
now prepared
by Nuclear Engineering rather
than the Licensing
engineer.
This allows Engineering
to more effectively interact
on technical
and licensing issues
with=-Nuclear Generation
and Nuclear Support.
The Nuclear Division will be implementing
two new Directives; Project
and Task
Management
(NDD-PTM) and Evaluation
and Corrective Action for Deviation/Event
Reporting
(NDD-ECA).
The Project
and Task Management Directive will establish
requirements
and define responsibilities for managing Nuclear'Division "Tasks"
and,"Projects"
in a uniform manner consistent
with governing regulatory
requirements
and the Nuclear Division Business
Plan.
The Nuclear Division
will also
implement
a Deviation Event Report
(DER) system.
A systematic
process will be applied to issues
requiring evaluation
and implementation,
such
as
Appendix J.
Among other'things,
this process is designed
to
identify clearly the accountability for actions necessary
to disposition the
DER.
This process
also formalizes
a review of completed disposition actions
for effectiveness
in resolving the
DER issue.
New Administrative Procedures
for procedure
use
and control, procedure
preparation,
review and issue,
and procedure
change evaluations
are being
implemented
per the schedule of the Business
Plan.
These
procedures will
provide an improved
review process for procedures
and will identify
procedure
reviewers.
The 10CFR50.59
reviewers will attend additional training
on 10CFR50.59
before implementation of the new administrative
procedures.
DATE OF FULL COMPLIANCE:
On-shift training for all operating
crews
on the revised
OP-14 will be
complete
by April 19,
1991.
Full compliance will be achieved
by August 1,
1991 with the reinforcement training of operators
on the simulator.