ML17059B715

Insp Repts 50-220/97-06 & 50-410/97-06 on 970629-0809. Violations Noted.Major Areas Inspected:Operations, Maintenance,Engineering,Plant Support & Mgt Meeting

ML17059B715
Person / Time
Site:	Nine Mile Point
Issue date:	09/15/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML17059B713	List: ML17059B712 ML17059B714 ML17059B715
References
50-220-97-06, 50-220-97-6, 50-410-97-06, 50-410-97-6, NUDOCS 9709220165
Download: ML17059B715 (86)

See also: IR 05000220/1997006

Text

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Docket/Report Nos.:

50-220/97-06

50-410/97-06

License Nos.:

DPR-63

NPF-69

Licensee:

Niagara Mohawk Power Corporation

P. O. Box 63

Lycoming, NY 13093

Facility:

Nine Mile Point, Units

1 and 2

Location:

Scriba, New York

Dates:

June 29- August 9, 1997

Inspectors:

B. S. Norris, Senior Resident Inspector

T. A. Beltz, Resident Inspector

J. C. Jang, Senior Radiation Specialist

W. A. Maier, Senior Emergency Preparedness

Specialist

R. A. Skokowski, Resident Inspector

Approved by:

Lawrence T. Doerflein, Chief

Reactor Projects Branch

1

Division of Reactor Projects

'7709220ih5 9709i5

PDR

ADQCK 05000220

6

PDR

TABLE OF CONTENTS

page

TABLE OF CONTENTS

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EXECUTIVE SUMMARY

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SUMMARY OF ACTIVITIES

Niagara Mohawk Power Corporation (NMPC) Activities ................

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Nuclear Regulatory Commission (NRC) Staff Activities

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OPERATIONS

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Conduct of Operations..........,

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01.1

General Comments

01.2

Inadvertent Initiation of the NMP1 Containment Spray System

02

Operational Status of Facilities and Equipment

02.1

NMP2 Shutdown and Unusual Event due to High Drywell Floor

Drain Leak Rate.........

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05

Operator Training and Qualification

05.1

Review of INPO Re-Accreditation Report

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Miscellaneous Operations Issues..........

08.1

(Closed) LER 50-410/97-03:

Technical Specification Violation

Caused

by Procedural Non-Compliance

Due to Personnel

Error

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08.2

(Closed) LER 50-410/97-05:

High Pressure

Core Spray System

Inoperable Due to Failed Unit Cooler ..................

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II. MAINTENANCE,... ~ ~.....................

M1

Conduct of Maintenance

M1.1

General Comments

M1.2

Calibration of NMP2 LPRM Neutron Monitoring System

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M1.3

NMP1 Reactor Protection System Calibration .......

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M1.4 Corrective Maintenance

Backlog ..................

M2

Maintenance

and Material Condition of Facilities and Equipment

M2.1

Repair of NMP2 Drywell Equipment Drain Tank Leak Rate

Monltol

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III.ENGINEERING...............................................

E1

Conduct of Engineering

E1.1

General Comments

E1.2

Engineering Backlog.......... ~...................

E8

Miscellaneous

Engineering Issues

E8.1

(Closed) IFI 50-410/96-06-02:

Clarification of Wording in the

NMP2 UFSAR Regarding

Full Core Offloads ........ ~....

E8.2

(Closed) IFI 50-410/96-06-04:

Review of Corrective Actions

~Associated with LER 50-410/96-03-01

E8.3

(Closed)'VIO 50-410/EA-96-116-1012:

Discrimination of an

Employee for Raising Safety Concerns.................

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Table of Contents (cont'd)

E8.4

(Closed) LER 50-410/97-02-02:

Potential Inoperability of

Emergency Diesel Generator Service Water Cooling Water

Outlet Valves During a Control Room Fire

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IV. PLANT

R1

R2

R3

R6

R7

P2

P3

P4

P5

P7

P8

S1

S8

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SUPPORT

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Radiological Protection and Chemistry (RP5C) Controls

R1.1

General Comments

R1.2

Implementation of the Radioactive Liquid and Gaseous

Efflu

Control Programs ~........................

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Status of RPRC Facilities and Equipment ..

R2.1

Compliance with Posting Requirements

of 10 CFR Part 19

R2.2

Calibration of Effluent/Process

Radiation Monitoring System

R2.3

Surveillance Tests for Air Cleaning Systems

and Plant Air

Balance

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RP&C Procedures

and Documentation ....................

R3.1

Review of Radioactive Effluents Procedures

and Reports ..

RPRC Organization and Administration

R6.1

Staffing Levels

Quality Assurance

(QA) in RPS.C Activities .

R7.1

QA Audits of Effluent Activities

Status of Emergency Preparedness

(EP) Facilities, Equipment and

Resources ..'

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Emergency Response

Facilities ~...................

.EP Procedures

and Documentation

P3.1

Emergency Plan and Associated Procedures....

Staff Knowledge and Performance

in EP

P4.1

Staff Performance

in the Simulator

Staff Training and Qualification in EP . ~...................

P5.1

EP Qualification Tracking

P5.2

Drill and Exercise Performance

P5.3

General

EP Training

Quality Assurance

in EP Activities

P7.1

Deviation/Event Reports ........................

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External Audits

Miscellaneous

EP Issues

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P8.1

(Closed) IFI 50-220/96-07-19

and 50-410/96-07-19:

Weaknesses

in the Emergency Preparedness

Program....

Conduct of Security and Safeguards Activities..............

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'General Comments

Miscellaneous Security and Safeguards

Issues ..............

S8.1

(Closed) URI 50-410/97-04-11:

NMP2 Refuel Floor Access

Gate Found Unlocked ..

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Table of Contents (cont'd)

V. MANAGEMENTMEETINGS

X1

Exit Meeting Summary.........,.....

ATTACHMENT 1

- PARTIALLIST OF PERSONS CONTACTED

- INSPECTION PROCEDURES USED

- ITEMS OPENED, CLOSED, AND UPDATED

- LIST OF ACRONYMS USED

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EXECUTIVE SUMMARY

Nine Mile Point Units 1 and 2

50-220/97-06

8c 50-410/97-06

June 29 - August 9, 1997

This integrated

NRC inspection report includes reviews of licensee activities in the

functional areas of operations,

engineering,

maintenance,

and plant support.

The report

covers a six week period of inspections

and reviews by the resident staff, and regional

specialists in the areas of emergency preparedness

and radiological effluent monitoring.

PLANT OPERATIONS

During the inspection period, four procedural non-compliances

occurred as a result of

personnel

errors. (VIO) The most significant event was the inadvertent spray-down of the

NMP1 containment due to an operator opening the wrong valve during a surveillance.

In

addition, during the review of a Licensee Event Report, it was noted that the failure to

.. properly implement.a.procedure

resulted in NMP2 changing operational conditions without

meeting the requirements of the Technical Specification.

Several personnel performance

errors have been identified at both units during the past year; suggesting

continued NMPC

management. attention is warranted in this area.

The response

of the NMP2 control room crew and supervision to an increasing drywell

floor drain leak rate was good.

The work by maintenance

and engineering to identify and

repair the leaking flex-hose were also good.

RP support during the forced outage was

considered outstanding.

MAINTENANCE

The inspectors observed instrument and calibration (IRC) technicians perform surveillances

tests on safety related systems at both units.

In each case, the work was performed

carefully, with good communications between the IRC technicians

and with the control

room operators.

Since August 1996, NMP1 has made little progress

in lowering the total non-outage

corrective maintenance

(CM) backlog; in contrast, NMP2 has made slow, but steady,

progress

in lowering the backlog.

Both units reduced the percentage

of long-standing

safety-related

CM backlog items, and no long-standing safety-related

CM backlog items

were safety significant.

The inspectors considered the repairs of the NMP2 drywell equipment drain tank leak rate

monitor to be acceptable.

Procedures

and work orders were used at the job and all test

equipment was properly calibrated.

Executive Summary (cont'd)

ENGINEERING

Both units have experienced

an increase

in the overall engineering

backlog during the past

year.

However, NMPC management

was able to eliminate all long-standing

non-outage

temporary modifications.

PLANT SUPPORT

The NMPC program for posting of related regulatory documents was adequate

and in

compliance with the requirements of 10 CFR 19.11.

The licensee maintained and implemented very good programs for routine radioactive liquid

and gaseous

effluent releases.

They actively pursued program enhancements

in the

effluent program to maintain offsite exposure

as-low-as-is-reasonably

achievable.

The implementation of the emergency preparedness

program is inconsistent.

Some strong

areas were noted in the operational readiness

of the emergency response

facilities and

training content.

The evaluation to support the move of the Emergency Operations facility

was well documented.

However, some programmatic controls were weak: the

qualification tracking system failed to detect that the qualification of nine members of the

emergency response

organization had lapsed, and a required annual offsite augmentation

drill had not been performed in several years.

(VIO) The licensee's

annual audit of the

.emergency

preparedness

program was performance-based

but failed to identify the above

problems.

REPORT DETAILS

Nine Mile Point Units 1 and 2

50-220/97-06 & 50-410/97-06

June 29 - August 9, 1997

SUMMARYOF ACTIVITIES

Niagara Mohawk Power Corporation (NMPC) Activities

NMP1

Nine Mile Point Unit 1 (NMP1) started the inspection period at full power.

On July 11,

the unit was shutdown due to an increasing drywell floor drain leak rate.

The source

of the leak was subsequently

determined to be a packing leak on a valve in the post-

accident sampling system.

The valve was repaired, and the unit was returned to service

on July 13; full power was achieved on July 16.

NMP1 maintained essentially full power

. for,. the remainder,.of.,the

inspection period.

NMP2

Nine Mile Point Unit 2;(NMP2) started the inspection period at 95% of full power, limited

due to the moisture separator reheaters

being isolated.

On August 4, control room

operators manually scrammed the reactor from 60% power.due to a high drywell floor

drain leak rate.

The. source of the leak was subsequently

determined to be a leaking

flexible drain hose on the "B" recirculation flow control valve.

(See Section 02.1 of this

inspection report.)

The inspection period ended with NMP2 in startup.

Mana ement Chan

es

During the inspection period, several changes were made to the Nine Mile Point senior

management

team:

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Mr. Martin McCormick, previously Vice President - Nuclear Engineering,

assumed

a new

position as Vice President - Special Projects, with a primary focus on developing the

New York Nuclear Operating Company (NYNOC).

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Mr. John Conway, previously Plant Manager - NMP2, became the new Vice President-

Nuclear Engineering.

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Mr. Kim Dahlberg, previously General Manager - Projects, is the interim Plant Manager-

NMP2, until a permanent selection is made.

Afterwards, Mr. Dahlberg will assume new

duties as the Vice President - Nuclear Operations.

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Mr. Norman Rademacher,

previously Plant Manager - NMP1, assumed

new duties

related to regulatory affairs and performance issues.

~'r. Richard Abbott, currently Vice President and General Manager - Nuclear, is the

interim Plant Manager - NMP1, until a permanent selection is made.

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EI

2

Nuclear Regulatory Commission (NRC) Staff Activities

Ins ection Activities

The NRC conducted

inspection activities during normal, backshift, and deep backshift

hours.

In addition to the inspection activities completed by the resident inspectors,

regional specialists conducted

inspections

and reviews in the areas of effluent controls and

emergency preparedness.

The results of the specialist inspections

are contained

in the

applicable sections of this report.

U dated Final Safet

Anal sis Re ort Reviews

A discovery of a licensee operating their facility in a manner contrary to the Updated Final

Safety Analysis Report (UFSAR) description highlighted the need for additional verification

that licensees were complying with UFSAR commitments.

While performing the

inspections discussed

in this report, the inspectors reviewed the applicable portions of the

UFSAR related to the areas inspected.

The inspectors verified that the UFSAR wording

was consistent with the. observed plant practices, procedures

and/or parameters.

I. OPERATIONS

01

Conduct of. Operations (71707, 90712, 92700)

'1.1

General Comments

Using NRC Inspection Procedure 71707, the resident inspectors conducted frequent

reviews of ongoing plant operations.

Specialist inspectors-in this area used other

procedures

during their reviews of operations activities; these inspection procedures

are listed,,as applicable, for the respective sections of the inspection report.

In

general, the conduct of operations was professional

and safety-conscious;

specific

events and noteworthy observations

are detailed in the sections below.

01.2

Inadvertent Initiation of the NMP1 Containme t S ra

S stem

a.

Ins ection Sco 'e

The inspectors reviewed the inadvertent initiation of the NMP1 containment spray

system.

The. inspectors discussed

the event with an onshift licensed reactor

operator and the Assistant Shift Supervisor (ASSS), and reviewed the associated

Deviation/Event Report (DER). The inspectors

also reviewed the associated

surveillance test procedure

and selected recorder traces, and attended

NMPC

management

meetings relating to the event.

Topical headings such as 01, M8, etc., are used in accordance withthe NRC standardized reactor inspection report outline.

Individual reports are not expected to address

all outline topics.

The NRC inspection manual procedure or temporary

instruction that was used as inspection guidance is listed for each applicable report section.

b.

Observations

and Findin s

On July 1, 1997, containment spray quarterly surveillance testing was in progress

at NMP1. Containment spray pump ¹121 was taking a suction from the torus and

discharging back to the torus through flow control valve (FCV)80-118.

A licensed

control room operator was conducting the surveillance test and had established

the

proper flow path, in accordance

with the procedure.

The next step in the procedure

required the operator to establish

a system flow rate by throttling FCV 80-118.

The

operator inadvertently opened containment spray blocking valve 80-40.

Valve 80-

40 established

a direct flow path to the containment through the containment spray

header.

The operator immediately identified the error and shut valve 80-40.

The

licensee estimated the valve was partially open for approximately thirty seconds.

Later, while standing at the control panel, the operator discussed

the event with the

inspectors.

The operator had a copy of surveillance test Procedure

N1-ST-Q6B,

"Containment Spray System Loop 121 Quarterly Operability Test," Revision 04.

The operator stated that he had the procedure

in one hand and had just throttled

FCV 80-118 with the other.

The operator removed his hand from the control

switch for FCV 80-118 to point to the flow gage and verify flow rate.

While

attempting to readjust the flow rate using FCV 80-118, the operator failed to

reverify that his hand was on the proper valve.

The control switch for valve 80-40,

physically located directly below the control switch for FCV 80-118 on the control

panel, was inadvertently operated.

Following the event, process computer data indicated that containment

temperatures

and pressures

changed very little due to the spray initiation. The

drywell floor drain (DWFD) sump rate-of-change

momentarily exceeded'Technical

Specification (TS) limits; however, the immediate isolation of the containment spray

restored the rate of change to within TS requirements.

The licensee estimated

between 150-200 gallons of water was discharged to the drywell. The inspectors

reviewed the DWFD recorder traces to independently verify the quantity of water

injected, and concurred with the licensee estimations.

NMP1 engineering staff performed an operability determination,

and determined that

the containment spray system, the containment,

and all equipment within

containment, remained operable.

The engineering operability determination was

reviewed, and subsequently

concurred upon, by the Station Operations Review

Committee (SORC).

The inspe'ctors considered the operability determination to be

detailed and to have received

a thorough review by NMP1 management.

In

addition, during a subsequent

plant shutdown and drywell entry, maintenance

and

engineering personnel examined the equipment in the drywall and confirmed that

there was no damage.

NMPC's apparent root cause of the event was that the consequences

of inadvertent

compone'nt operation during this surveillance test had not been considered;

As

such, less than adequate

self-checking was performed.

Licensee procedures

required independent

or peer verification when the failure to properly perform a step

could result in equipment damage,

personnel injury, or a reactor trip. During the

performance of the surveillance test, direct observation of valve manipulations was

not specifically required.

As a result of this event, NMP1 is evaluating the need for

generic procedural enhancements

to ensure that evolutions having the potential to

impact reactor plant safety are adequately

supervised.

Also, the NMP1 Operations

Manager directed that all control ro'om switch manipulations would now require a

peer verification. The inspectors considered the less than thorough appreciation for

the consequences

of improper control panel manipulations to be a weakness.

In addition to the above, the following personnel performance

errors occurred during

this observation period:

On July 23, NMP1 operators opened the wrong circuit breaker while isolating

motor generator set ¹167 prior to maintenance.

The label for the circuit breaker

opened did not agree with the markup (tagout) sheet and tag.

This resulted in

an unplanned

de-energization

of various equipment, including the control room

process computer.

On July 22,,during preventive maintenance

on the deluge sprinkler system,

a fire

brigade member operated

an incorrect valve, resulting in an unplanned

pressurization

of the water deluge sprinkler system in the NMP2 turbine building

condenser

area.

No equipment was damaged.

On July 18, a NMP1,radiological waste operator, clearing a markup following

maintenance,

positioned three valves different from the position on the

restoration sheet without permission from the Station Shift Supervisor (SSS).

This unexpected

system configuration later resulted in overflowing a tank in the

radiological waste building.

On all four occasions,

personnel failed to comply with or adequately implement

written procedures.

These procedural non-compliances

are violations of NMP1 TS, Section 6.8.1, and NMP2 TS, Section 6.8.1, regarding procedural adherence.

(VIO 50-220/97-06-01

and 50-410/97-06-01)

The inspectors noted that the above errors were a result of either inattention-to-

detail, a,lack of a questioning attitude, or a less-than-adequate

focus on potential

plant impact resulting from improper actions.

Many of the events resulted from

personnel lacking conservative judgement and decision making.

Although none of

the above issues had any immediate safety consequence,

the inspectors consider

this indicative of a continuing problems in personnel performance at Nine Mile Point.

Conclusions

During the observation period, four procedural non-compliances

occurred as a result

of personnel

errors. (VIO) The most significant event was the inadvertent spray-

down of the NMP1 containment due to'an op'erator opening the wrong valve during

a surveillance test,

These four, errors are just the latest examples of poor personnel

performance at both units during the past year, indicating the need for continued

NMPC management

attention in this area.

o.

02.1

5

Operational Status of Facilities and Equipment

NMP2 Shutdown and Unusual Event due to Hi h Dr well Floor Drain Leak Rate

Ins ection Sco

e

The NMP2 reactor was manually scrammed,

and an Unusual Event declared,

due to

increasing drywell floor drain (DWFD) leak rate.

The inspectors were in the control

room and observed the operating crew during the initial phases of the event.

Subsequently,

the inspectors monitored the licensee's activities associated

with the

identification and repair of the leak.

b.

Observations

and Findin s

On August 4, 1997, with NMP2 at 95% power, the control room received alarms

indicating increasing drywell (DW) radiation levels and pressure;

during the review,

the operators identified a rising DWFD leak rate.

NMP2 TS, Section 3.4.3.2, limits

unidentified leakage to 5.0 gallons per minute (gpm); otherwise, the unit must be

shutdown.

The TS define unidentified leakage as that which is not identified.

Examples of identified leakage. would be pump seal or valve packing leaks collected

into a sump, or leakage into the containment atmosphere

from a source which is

specifically known'nd is not part of the pressure

boundary.

In accordance

with NMPC procedures,

the initial response

by the SSS was to

reduce power to 60%.

Subsequently,

the SSS, in consultation with the Operations

Manager and Plant Manager, directed the reactor to be manually scrammed from

60%. The SSS declared an Unusual Event, in accordance

with the NMP2

Emergency Plan, when DW leakage exceeded

10 gpm.

The inspectors were in the

NMP2 control room during the. initial phases of the event, and considered the

response

by the control room crew and supervision to'be good.

The emergency

declaration was proper and timely. When DWFD leakage was reduced to less than

4.0 gpm, the SSS terminated the event, in accordance

with the Emergency Plan.

Notifications to the appropriate federal, state, and local officials were completed

within the required timeframe.

NMPC performed a comprehensive

review of the

plant response to the manual scram, per Procedure

N2-REP-6, "Post-Scram

Review," Revision 01.

When the plant was in a coLD sHUTDowN condition (i.e., reactor coolant temperature

less than 200'F), personnel entered the DW and found that the maintenance

drain

flexible-hose (flex-hose) on the "B" recirculation flow control valve (2RCS" HYV17B)

was leaking.

The inspectors entered the DW and observed the failed flex-hose.

NMPC decided to remove the flex-hose and cap the open pipe ends, rather that

replace it or attempt to repair it. The questions from the NMP2 engineering

and

maintenance staff revealed

a good. understanding

of the potential complications and

the need for contingencies if the repair did not proceed

as expected.

The inspectors

monitored the licensee's

plarlning meetings,.reviewed

tlie below documentation

associated

with the modification, and considered them acceptable:

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Engineering

Design Document Change DDC Number N2-97-063,

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Licensing Document Change Request LDCR Number 2-97-UFS-105,

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Safety Evaluation SE Number 97-82,

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Applicability Review AR,25509, and

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Maintenance Work Order WO 97-12122-06

In addition to the removal of the failed flex-hose, immediate corrective actions

included:

(1) an inspection of all remaining accessible flex-hoses in the DW, and (2)

an evaluation of equipment in the area of the water spray for detrimental affects.

Actions to prevent recurrence

included plans to remove as many of the flex-hoses

as possible during the next refueling outage.

The root cause evaluation for the

failed flex-hose will not be available until a destructive analysis, by an outside

contractor, is completed.

An inspector follow item (IFI) is opened to review the root

cause analysis and any supplementary

corrective actions.

(IFI 50410/97-06-02)

The inspectors noted that the NMP2 SORC members generally conducted

a

'thorough review of the DERs associated

with this event.

Several of the DERs

addressed

specific problems identified during the NMPC inspections of other flex-

hoses in the drywell~

Each discrepancy was satisfactorily addressed

before the

plant was restarted.

However, during the SORC review of DER 2-97-2300, "Failed

Flex-Hose Resulting in Plant Scram," it was not noted during the engineering

disposition, nor'by any of the SORC members during the review, that the accident

analysis was inaccurate in that it assumed

there would be only one leak path from

the failed flex-hose.

After the DER was approved, the inspectors questioned the

unique design configuration of the flex-hose on 2RCS"HYV17B; specifically, a

.- catastrophic failure of this hose would equate to two leakage paths.

The NMP2

Plant Manager agreed that the accident analysis only accounted for half of the

'possible leakage.

Although'the overall consequences

did not change, the inspectors

considered this an example of a weak questioning attitude by the licensee's

engineering organization.

In addition, the inspectors discussed

the potential catastrophic failure of the flex-

hose as it related to the NMP2 Individual Plant Examination/Probability

Risk Analysis

(IPE/PRA).

For a small-break loss of coolant accident (SBLOCA), the IPE/PRA only

models pipe breaks greater than

1 inch; thus, a break of most 3/4 inch pipes would

be considered

a plant transient.

However, a complete failure of this 3/4 inch flex-

hose results in two leak paths and would be classified as a SBLOCA, since the total

break size is larger than

1 inch.

Nonetheless,

based on the relatively small number

of flex-hoses in this configuration, NMPC concluded that the overall probability of a

SBLOCA remained relatively unchanged.

The inspectors considered

NMPC's

conclusion to be acceptable.

The radiation protection (RP) support during the investigation and repairs of the flex-

- hose were outstanding,

Good ALARA[as-low-as-is-reasonably-achievable]

practices, such as pre-job briefs, protective clothing, and the use of remote cameras

in the DW, resulted in maintaining the total dose received at a minimum. The

maintenance

activities to repair the leak, including the RP and engineering support,

were well planned and executed.

Overall, the inspectors considered the efforts of

the NMP2 staff in response to the failed flex-hose to be above average.

c.

Conclusion

The response

of the NMP2 control room crew and supervision to an increasing DW

leakage was good.

The work by maintenance

and engineering to identify and repair

the leaking flex-hose were also good.

RP support during the forced outage was

considered outstanding.

05

Operator Training and Qualification

05.1

Review of INPO Re-Accreditation

Re ort

The Institute of Nuclear Power Operations

(INPO) conducted

a review of Nine Mile

.training programs from April 28 - May 2, 1997.

The INPO evaluation was based on

an NMPC self-assessment

and an on-site review.

The purpose of the review was to

determine the effectiveness of the below. training programs for re-accreditation

in

.accordance

with the standards

established

by. the INPO National Academy. for ..

Nuclear Training:

~

Non-Licensed Operators

~

Reactor Operators

~

Senior Reactor Operators

~

Station Shift Supervisors

~

Shift Technical Advisors

~

Continuing Training for Licensed Personnel

The inspectors reviewed the INPO Re-Accreditation Evaluation Report, issued on

July 21, 1997, and identified no issues that the NRC was not already aware of. No

additional followup by the NRC is warranted.

08

MIscellaneous Operations Issues (90712, 92700)

08.1

Closed

.LER 50-410 97-03: Technical S ecification Violation Caused

b

Procedural

Non-Com liance Due to Personnel

Error

On June 8, 1997, approximately one hour after NMP2 changed

operational

conditions from Mode 2 (sTARTUF) to Mode

1 (RUN), a DW communication circuit

(2LAR-PNLUO3-12) was found to be energized.

This circuit was not provided with

backup containment penetration overcurrent protection and therefore, in accordance

with NMP2 TS 3.8.4.1, was required to be de-energized

following final DW

inspectio~.

Upon discovery; NMP2 licensed operators entered the appropriate TS Limiting

Condition of Operation (LCO), pnd de-energized

the circuit. The licensee determined

the root cause of the event to be personnel

error.

Particularly, the operator failed to

open the circuit breaker and observe the proper system response

(i.e., no self-

0

checking) during the performance of the Primary Containment AC Circuit Check.

Subsequently,

the operator was temporarily removed from watch standing duties;

remediation included counseling

on the use of self-checking techniques,

and the

performance of Job Performance

Measures

emphasizing self-checking.

Notwithstanding, the licensee violated TS 3.0.4, which states that entry into an

operational condition shall not be made unless the conditions for the LCO are met

without reliance on provisions contained

in the Action Statements.

This non-

repetitive, licensee-identified violation is being treated as a Non-Cited Violation,

consistent with Section VII.B.1 of the NRC Enforcement Policy.

(NCV 50-41 0/97-06-03)

The inspectors reviewed the Licensee Event Report (LER) and found it to be timely

and to accurately describe the event.

Also, the inspectors considered

the

immediate corrective actions and actions taken to prevent recurrence

appropriate.

This LER.is closed.

08.2

Closed

LER 50-41097-05:

Hi h Pressure

Core S ra

S stem lno arable Due to

Failed Unit Cooler

-The event described

in.this LER was discussed

in NRC IR 50-410/97-04, Section,

02.2.

The description and analysis of the event, as contained in the LER, is

consistent with the inspectors'nderstanding

of the event.

The corrective actions

in the LER state that a detailed failure analysis of the terminal board will be

performed, estimated to be completed by January 1998.

This LER is closed.

II. MAINTENANCE

'1

Conduct of Maintenance (61726, 62707)

M1.1

General Comments

Using NRC Inspection Procedures

61726 and 62707, the resident inspectors

periodically observed plant maintenance

activities and the performance of various

surveillance tests.

Specialist inspectors

in this area used other procedures

during

their reviews of maintenance

and surveillance activities; these inspection procedures

are listed, as applicable, for the respective sections of the inspection report.

In

general, maintenance

and surveillance activities were conducted

professionally, with

the work orders (WOs) and necessary

procedures

in use at the work site, and with

the appropriate focus on safety.

Specific activities and noteworthy observations

are

detailed in the inspection report.

The inspectors reviewed procedures

and observed

all or portions of the following maintenance/surveillance

activities:

Surveillance activities are included under "Maintenance."

For example, a section involving surveillance observations might

be included as a separate sub-topic under M1, "Conduct of Maintenance."

~

N1-ISP-036-003

~

N2-ESP-BYS-W675

~

N2-ESP-ICS-0@002

~

N2-RESP-04

~

WO 96-1 5884-00

~

WO 97-10019-00

~

WO 97-10944-00

~

WO 97-11224-00

High-Low Reactor Water Level Instrument Trip Channel

Test/Calibration

125 Volt DC Weekly Battery Surveillance

RCIC [Reactor Core Injection Cooling] Pump and Valve

Operability and System Integrity Test and ASME

[American Society of Mechanical Engineers] XI

Functional Test

LPRM [Local Power Range Monitor] Calibration

Replacement of the Division II Emergency

Dies'el

Generator

Fuel Transfer Pump Mechanical Seal

Drywell Equipment Drain Chart Recorder Behaving

Erratic

Erratic Indication on Drywell Equipment Drain Pump

Flows Causes

Erroneous

Leakage Rate

B Drywell Floor Drain Flow Rate Indication on Recorder

is Erratic

M1.2

Calibration of NMP2 LPRM Neutron Monitorin

S stem

a.

Ins ection Sco

e

The inspectors observed

a portion of the calibration of the local power range

monitors (LPRMs) by NMP2 instrument and controls (I&C) technicians.

In addition,

the inspectors reviewed the completed calibration documentation.

b.

Observations

and Findin s

With NMP2 operating at 95% of rated power, I&Ctechnicians performed

a

calibration of NMP2 LPRMs, using reactor engineering surveillance test, procedure

N2-RESP-4, "LPRM Calibration," Revision 02. The activities within the LPRM

cabinets were performed carefully and the technicians used good three-way

communications between themselves

and with the control room operators.

The

Supervisor, Reactor Engineering, reviewed the completed surveillance test the next

day'and confirmed that no unsatisfactory results were obtained.

The inspectors reviewed the precautions,

limitations, and potential plant impact

statements,

and verified that all necessary

actions had been taken.

Also, the

inspectors verified that the digital multimeter being used by the l&C technicians was

in calibration.

The inspectors performed an independent

review of the completed

surveillance test procedure

and identified no unsatisfactory results.

C.

Conclusion

The inspectors determined that the calibration of the NMP2 LPRMs was performed

carefully by the l&C technicians, with good communications

used consistently.

The

supervisory review identified, no unacceptable

results and was completed in a timely

manner.

M1.3

ar

10

NMP1 Reactor Protection

S stem Calibration

Ins ection Sco

e

The inspectors monitored NMP1 IRC technicians calibrate the instrument trip units

for the reactor water level high/low trip inputs to the reactor protection system

(RPS)

~

b.

Observations

and Findin s

Using instrument surveillance test procedure N1-ISP-0360003,

"Hi-Lo Reactor

Water Level Instrument Trip Channel Test/Calibration," Revision 02, NMP1 IRC

technicians verified the operability of the high and low level trip inputs to the RPS.

The performance of this surveillance test procedure required several personnel at

various locations: the lead technician was stationed

in the control room, another

was at the remote shutdown panel, and a third was at the analog trip system (ATS)

cabinets.'n

addition, since performance of the procedure generated

a half-scram, it

was classified as a "Category 1" activity, requiring a first-line supervisor from the

respective department to.be present during the entire activity.

The procedure was completed without incident.

The supervisory oversight was

performed without being intrusive.

Three-part communications were observed to be

consistently used by all personnel

involved in the'evolution, the IRC technicians, the

supervisor,

and the control room operators.

The technicians were knowledgeable of

the procedure

and the physical operation of the system.

Overall, the inspectors

considered the performance of the technicians during the surveillance test to be

thorough and professionally conducted.

C.

Conclusion

Performance of half-scram testing of the reactor protection system was completed

without incident.

Good three-part communications were consistently used by the

IRC technicians.

M1.4 Corrective Maintenance

Backlo

aO

Ins ection Sco

e

The inspectors reviewed the corrective maintenance

(CM) backlog for both units,

and discussed the backlog with the respective Maintenance

Managers and Outage

Managers.

b.

Observations

and Findin s

The inspectors reviewed the CM backlog trend data for the last year.The NMP1

hon-outage

CM backlog has remained relatively constant, approximately 400, from

August 1996 to July 1997.

The NMP1 Maintenance

and Outage Managers stated

11

that they considered the current CM backlog to be unsatisfactory,

and that they

developed

a plan to aggressively reduce it.

The NMP2 non-outage

CM backlog had been reduced from 412 in August 1996 to

242 in May 1997.

Overall, the inspectors considered that NMP2 has made

consistent progress

in lowering the backlog since August 1996.

The inspectors reviewed the CM backlog with respect to safety-related

items. At

both units, the inspectors identified no long-standing

(i.e. greater than three

months) items which could potentially impact safe plant operation.

In the past year,

the safety-related

CM backlog had remained relatively constant at NMP1, and had

been declining at NMP2. However, the percent contribution of long-standing safety-

related items to the overall CM backlog had been reduced slightly at both units

since August 1996.

C.

Conclusions

M2

M2.1

Since August 1996, NMP1 had made little progress

in lowering the total non-outage

CM backlog items and NMP2 had made slow, but consistent,

progress

in lowering

the total backlog of non-outage

CM items.

Both units had reduced the percentage

of long-standing safety-related

CM backlog items, and no long-standing safety-

related CM backlog items having safety consequence

were identified.

Maintenance and Material Condition of Facilities and Equipment (62707)

Re air of NMP2 Dr well E ui ment Drain Tank Leak Rate Monitor

lns ection Sco

e

The NMP2 drywell equipment drain tank (DWEDT) leak rate monitor exhibited erratic

indication on the pump flow rate chart recorder.

The instrument was declared

inoperable and a 30-day LCO was entered.

The inspectors evaluated the use of an

alternate means of determining leak rate.

In addition, selected portions of the repair

activities were monitored, and discussions

were held with the maintenance

supervisor.

b.

Observations

and Findin s

On June '23, 1997, the chart recorder for monitoring the NMP2 DWEDT leak rate

(2DER-FR123) exhibited erratic indication of flow rate.

The SSS declared the

instrument inoperable, entered

a 30-day shutdown

LCO in accordance

with TS 3.4.3.1.b, and initiated DER 2-97-1872.

Using WO 97-10019-00, IRC conducted

troubleshooting

of the recorder; however, no further erratic behavior was noted

initially and the technicians were unable to identify the cause for the erratic

behavior.

Subsequently,

on June 27, the recordei was returned to service.

On July 12, the chart recorder again indicated erratic pump flows and was declared

inoperable.

A second

DER (¹2-97-2049) was written, noting that this appeared to

12

be a repeat failure.

NMPC considered the that the recorder itself could potentially

be the problem; corrective actions in WO 2-97-10944 included replacing the chart

paper drive motor, the servo-amplifier card, and several corroded wires.

The

recorder was returned to service on July 18; on July 19, the indications were still

erratic and the recorder was declared inoperable.

A new WO (2-97-11224) was

generated,

consisting of signal tracing with an oscilloscope,

measurement

of power

supply voltages, verification that no additional corrosion existed, and tightening of

all terminal connections.

In addition, the differential pressure transmitter instrument

lines were flushed, refilled, and vented to remove any entrapped

air.

A final

calibration was performed after completion of maintenance.

No further problems

have been noted.

NMPC determined the root cause to be multiple degraded

components

and air in the

transmitter sensing

lines.

The immediate corrective actions appeared

adequate.

Actions to prevent recurrence

included a review, by NMPC, of IRC procedures to

ensure the maximum reliability of control room recorders.

The inspectors discussed

the failed instrument with several shift operators

and

noted that all crews-were able to use an alternate method.to determine drywell

equipment leak rate, as required by TS 3.4.3.1.

The inspectors observed portions

of the repair activities and noted that maintenance

work orders and calibration

procedures

were in use at the job site, and that all test equipment was in

calibration.

The inspectors identified no discrepancies

during the review of the

associated

DERs, WOs, 5 calibration records.

c.

Conclusion

The inspectors considered the repairs of the NMP2 DWEDT leak rate monitor to be

adequate.

Procedures

and work orders were used at the job and all test equipment

.was properly calibrated.

III. ENGINEERING

E1

Conduct. of Engineering (37551)

E1.1

General Comments

Using NRC Inspection Procedure 37551, the resident inspectors frequently reviewed

design and system engineering activities and the support by the engineering

organizations to plant activities.

Specialist inspectors

in this area used other

procedures

during their reviews of engineering activities; these inspection

.procedures

are listed, as applicable, for the respective sections of the inspection

.

report.

0

13

E1.2

En ineerin

Backlo

a.

Ins ection Sco

e

The inspectors

assessed

the backlog of engineering work for both units.

Specifically, the inspectors reviewed DER trend data and the temporary modification

backlog.

The inspectors discussed

the issues with engineering staff for both units.

b.

Observations

and Findin s

The inspectors reviewed the engineering

DER backlog trend data for the last year,

noting a steady increase

in backlog items during the past few months at both units.

For NMP1, the engineering

DER backlog had risen from 207 in June 1996 to 298 in

June 1997,

The NMP2 engineering

DER backlog had risen from 274 in June 1996

to 364 in June 1997.

The inspectors discussed,

with both engineering staffs, the proposed

actions to

reduce the backlog.

Both units have established

a multi-disciplined DER team to

. assist in backlog reduction.and to improve the quality of DER dispositions.

As part

of this effort, NMP2 increased

resources

by 13 temporary engineers,

and NMP1

was evaluating similarly supplementing

the engineering staff.

Further refinement of

backlog prioritizatioh and reevaluation of refueling modifications was another

management

action item to reduce the backlog.

The inspectors noted that licensee

management

had been addressing

the engineering backlog, but that the current

trend indicated these actions were ineffective during the last year.

The inspectors additionally reviewed the status of temporary modifications at both

units.

The inspectors noted that only one non-outage

temporary modification

greater than one year old existed, and that was at NMP1

~ The long-standing

temporary modification for NMP1 was the Thermex modular waste treatment

system, which became

a permanent modification subsequent

to the inspection '

period.

The inspectors considered that NMPC's goal to eliminate long-standing

non-

outage temporary modifications was appropriate

and appeared to be effective.

C.

Conclusions

The engineering

DER backlog for both units has risen over the last year.

NMPC's

efforts have had minimal impact in reducing the overall engineering

DER backlog

during the past year.

Management's

goal to eliminate long-standing

non-outage

temporary modifications was appropriate

and appeared to be effective.

14

E8

Miscellaneous Engineering Issues (90712, 92700, 93903)

E8.1

Closed

IFI 50-410 96-06-02:

Clarification of Wordin

in the NMP2 UFSAR

Re ardin

Full Core Offloads

a.

Ins ection Sco

e

During a 1996 NRC inspection, it was identified that the NMP2 UFSAR did not

accurately reflect the practice of performing a complete reactor core offload for a

normal refueling outage.

At that time, NMPC committed to clarify the wording in

the NMP2 UFSAR, and an inspector follow item (IFI) was opened to track the

completion of the revision.

The inspectors reviewed the licensee's documentation

which approved the change.

b.

Observations

and Findin s

The inspectors reviewed the following NMPC documents

related to the changes to

Section 9.1.3 of the NMP2 UFSAR:

~

Safety Evaluation Number SE-96-074, Revision 0, "Spent Fuel Pool Cooling,

Residual Heat Removal, Alternate Decay Heat Removal, and Secondary

Containment"

'

Applicability Review Number AR-12996, Revision 0

~

Licensing Document Change Request Number LDCR- 2-96-UFS-084, Revision 0

!

SORC Minutes for Meeting 96-79-02, which approved the change

The changes

clarified the fact that a full core offload was the normal practice, and

that the transfer of fuel to the spent fuel pool could begin as early as 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> after

reactor shutdown.

The inspectors noted that the approved changes were

incorporated into the UFSAR in May 1997.

c.

Conclusion

The inspectors considered the safety evaluation and associated

documents to be

complete and to accurately reflect the practice currently used by NMP2 for normal

reactor refueling evolutions.

No unreviewed safety questions were identified during

the review.

E8.2

Closed

IFI 50-410 96-06-04:

Review of Corrective Actions Associated with

LER 50-410 96-03-01

a.

Ins ection Sco

e

During a 1996 NRC inspection, it.was noted by the inspectors that the corrective

actions detailed in an LER appeared to appropriately address the identified root

causes..ln the associated

NRC inspection report, an IFI was opened to track the

completion of the corrective actions.

~,

15

b.

Observations

and Findin s

The inspectors reviewed the corrective actions described

in LER 50-410/96-03-01,

associated with the full core offload and operation of the spent fuel pool cooling

system outside of design basis.

The corrective actions, and review to verify

completion, included:

~

The training program for personnel qualified to perform safety evaluations

and

applicability reviews was revised to include a discussion of the need to perform

a thorough review of the system design basis when writing and/or revising

procedures.

The inspectors verified that the training lesson plan (QAR-SE-Q/R/S-030,

Revision 1, "QARSE [Qualified Applicability Reviewer/Safety Evaluator]

Qualification, QARSE Requalification, or QARSE SORC/SRAB [Station Operation

Review Committee/Safety Review and Audit Board]) was appropriately revised

to incorporate

a description of the event and the associated

LER.

~

~ -The UFSAR and associated

refueling procedures

were revised to address spent

fuel pool cooling operations.

N2-FHP-13.1

Complete Core Offload, Revision 04

N2-FHP-13.2 Complete Core Reload, Revision 05

N2-FHP-13.3 Core Shuffle, Revision 00

The UFSAR revision was discussed

in Section E8.1 of this report.

The fuel

handling procedures

(listed below) were reviewed and appeared to contain the

necessary

changes

in response to the deficiencies noted in the inspection report

and the LER related to spent fuel pool cooling requirements

and a partial core

offload with fuel shuffle.

~

Divisional bus outage procedures,

operating procedures,

and refueling

administrative procedures were revised to include spent fuel pool cooling system

design basis requirements.

Spent Fuel Pool Cooling and Cleanup System, Revision 08

Shutdown Operations Protection Instruction, Revision 02

Shutdown Safety, Revision 02

The inspectors reviewed the below operating and administrative procedures/

instructions and determined that the changes

appeared to adequately

address

the system design basis requirements of the UFSAR and Technical

Specifications.

N2-OP-38

N2-ODI-5.60

NIP-OUT-01

On September 29, 1996, NMPC informed the NRC that the divisional bus outage

work was not scheduled for the September

1996 refueling outage; as such, the

procedures would.not be revised until prior to the next scheduled

bus outage

16

during the next refueling (Spring 1998).

The inspectors verified that the

associated

procedures

(N2-PM@12 and N2-PM@13) had been deactivated.

~

A lessons learned transmittal was issued describing the event and the need to

perform an in-depth review and evaluation of design basis when writing and/or

revising procedures.

The inspectors reviewed the Lessons

Learned Transmittal, dated July 16, 1996,

and verified that applicable personnel

in affected departments

were trained.

~

A review was conducted of selected portions of the UFSAR to validate that

necessary

programs and procedures

were in place which comply with the

UFSAR.

NMPC reviewed the UFSAR for the following systems:

control rod drive, reactor

core isolation cooling, reactor building closed loop cooling, and non-safety

portions of main steam.

Numerous

DERs were written to resolve identified

discrepancies.

The inspectors reviewed a sample of the DERs and considered

-. the identification and resolutions to be:adequate.

Based on the above reviews, this item is closed.

c.

Conclusion

The corrective actions related to NMP2 practices contrary to the UFSAR for full core

offload during refueling, and the operation of the spent fuel pool cooling system

were thorough and acceptable.

E8.3

Closed

VIO 50-410 EA-96-116-1012:

Discrimination of an Em lo ee for Raisin

Safet

Concerns

On July 24, 1996, the NRC issued

a Severity Level II Notice of Violation (Notice)

and imposed a Civil Penalty of $80,000 against NMPC for discrimination against a

former employee for raising safety concerns at the. Nine Mile facility. The Notice

was based on the Recommended

Decision and OI'der of a U.S. Department of Labor

Administrative Law Judge.

The NRC noted in the letter which transmitted

the'otice

that NMPC denied that any discrimination occurred against the individual, but

that corrective actions were taken to ensure

an environment free for raising safety

concerns.

These. actions included:

~

reemphasizing to management

the rights and responsibilities of employees to

raise safety issues;

~

reinforcing, at all levels of management,

the value of reporting issues to improve

performance;

and

~

reemphasizing

the availability of the Quality First Program.

h

Based. on frequent observation by the resident inspectors, it appears that NMPC has

promoted an open environment for raising safety concerns.

In addition, the

17

inspectors have not seen any attitudes or actions by management

to indicate that

they are privately or internally dismissing this violation, thereby creating a "chilling

effect" at the Nine Mile Point site.

This item is closed.

ESA

Closed

LER 50-410 97-02-02:

Potential Ino erabilit

of Emer enc

Diesel

Generator Service Water Coolin

Water Outlet Valves Durin

a Control Room Fire

The technical issues related to this were described

in NRC IR 50-410/97-04.

The

LER was timely and satisfactorily described the issues.

The inspectors reviewed the

root cause

and corrective actions provided in the LER and considered them to be

appropriate.

This LER is closed.

IV. PLANT SUPPORT

Using NRC Inspection Procedure 71750, the resident inspectors routinely monitored

the performance of activities related to the areas of radiological controls, chemistry,

emergency preparedness,

security, and fire protection.

Minor deficiencies were

discussed with the. appropriate management,

significant observations

are. detailed.

below.

Specialist inspectors in the same areas used other procedures

during their

reviews of plant support activities; these inspection procedures

are listed, as

applicable, for the respective sections of the inspection report.

R1

Radiological Protection and Chemistry (RP&C) Controls (71750, 84750)

R1.1

General Comments

During entry into and exit from radiologically controlled areas (RCAs), the inspectors

verified that proper warning signs were posted, personnel entering were wearing.

proper dosimetry, personnel

and materials leaving were properly monitored for

radioactive contamination,

and monitoring instruments were functional and in

calibration.

During periodic plant tours, the inspectors verified that radiation work

permits (RWPs) and survey maps were current and accurately reflected plant

conditions.

They observed activities in the RCAs and verified that personnel were

complying with the requirements of applicable RWPs, and that workers were aware

of the radiological conditions in the area.

R1.2

Im lementation of the Radioactive

Li uid and Gaseous

Effluent Control Pro rams

a.

Ins ection Sco

e

The inspectors toured the plant, including the control rooms, and reviewed liquid

and gaseous

effluent release permits, airborne tritium quantification techniques,

and

unplanned

and unmonitored release pathways.

b.

Observations

and Findin s

18

The inspectors toured the control rooms and selected radioactive liquid and gas

processing facilities and equipment.

Included in this review were the effluent

radiation monitor systems

(RMS) and air cleaning systems at both units.

All

equipment was operable at the time of the tour. The inspectors noted that the

licensee maintained and monitored air balances for the reactor, turbine, and

radioactive waste (radwaste) buildings at both units to assure conformance to

UFSAR specifications.

The inspectors toured the NMP2'RMS calibration laboratory.

This laboratory was equipped with two operable calibration chambers

(closed and

open air calibrators). The open air calibrator was an excellent methodology to avoid

back-scattering

radiation during process/area

RMS detector calibration.

During the review of selected radioactive liquid and gaseous

effluent discharge

permits, the inspectors determined that the discharge permits were complete and

met the criteria of the TS-required Offsite Dose Calculation Manual (ODCM) for

sampling and analyses at the frequencies

and lower limits of detection established

in the ODCM. The inspectors noted that.there had been no radioactive liquid

~ releases from NMP1 -for several. years while pursuing. effluent ALARAand plant

>

'ater

conservation.

The inspectors

also noted that there were no unplanned/unmonitored

radioactive

liquid or gas releases

since the previous inspection conducted

in September

1995.

The inspectors noted that the licensee had reviewed the effluent control programs

relative to the NRC Inspection and Enforcement

(IE)Bulletin 80-10, "Contamination

of Nonradioactive System and Resulting Potential for Unmonitored, Uncontrolled

Release of Radioactivity to Environment."

Recently, the licensee re-reviewed the

safety evaluation reports for the turbine building (a potential -unmonitored release

pathway) to determine if better monitoring devices could be used to demonstrate

compliance with IE Bulletin 80-10 using more restrictive criteria. The inspectors

noted that the previous safety evaluation concluded that there was no unmonitored

release through the turbine building.

The inspectors requested the licensee demonstrate

its capabilities in monitoring and

quantifying airborne tritium. The NMP2 staff calculated the total amount of water

loss from the spent fuel pool (SFP).

The licensee assumed that water loss was due

to evaporation from the SFP released to the environment via the plant main stack.

The licensee calculated the airborne tritium released

using SFP tritium measurement

results.

Calculated airborne tritium released through the plant main stack during

February 1997 was 6,190 micro-Curie per day (pCI/day).

Measured airborne tritium

release for this same period was 5,390 yCI/day, which was an excellent

comparison.

The inspectors noted that the airborne tritium measurement

error was

about 50%, as reported in the licensee's

semiannual report.

The inspectors stated,

through this comparison, that the licensee demonstrated

its capability to, measure

airborne tritium releases accurately.

The NMP1 staff had some difficulty in calculating the airborne tritium released from

the SFP to the main stack since condenser

gases were also directed to the main

, ~

8'. 'I ~

L

19

stack.

Consequently,

the licensee found it difficultto determine the tritium

contribution from the SFP.

The licensee stated that the tritium fractions (SFP and

steam evacuation) will be determined using airborne tritium measurement

results

during plant operations

and during a refueling outage, since there is no airborne

tritium releases

due to condenser

gases during a refueling outage.

C.

Conclusion

Based on the above reviews and observations,

the inspectors determined that the

licensee maintained and implemented effective radioactive liquid and gaseous

effluent control programs.

The licensee was vigorously pursuing the enhancement

of the effluent control programs at both units through: (1) the elimination of all

radioactive liquid releases from NMP1; (2) re-reviewing the safety evaluation to

comply better with IE Bulletin 80-10 requirements;

and (3) the establishment of a

RMS calibration laboratory in NMP2.

R2"

Status of RP&C Facilities and Equipment (71750, 84750)

.R2.1 .,Com liance with Postin

Re uirements of 10 CFR Part 19 71750

aO

Ins ection Sco

e

The inspectors evaluated

licensee compliance with the NRC requirements of Title 10

of the Code of Federal Regulations (10 CFR) Part 19, "Notices, Instructions and

Reports to Workers:

Inspections

and Investigations," relative to posting of

regulatory documents.

The inspectors reviewed the NMPC implementing procedure,

reviewed the location and content of postings both onsite and offsite, and,

discussed

the issue with NMPC licensing staff.

b.

Observations

and Findin s

The inspectors reviewed NMPC Nuclear Division Directive NDD-RPR, "Regulatory

Posting Requirements,"

Revision 03, which established

requirements for the posting

of regulatory documents,

including NRC Form 3 and enforcement correspondence.

The inspectors determined that NDD-RPR adequately

implemented the requirements

of 10 CFR 19.11.

The procedure

also described posting locations and which

documents were to be posted.

The inspectors determined that the posting areas

specified in NDD-RPR were maintained and were in sufficient locations to allow

ready access

by plant personnel.

All documents

required to be posted were

available for review. The inspectors considered that the NMPC program was

adequate

and in compliance with the posting requirements of 10 CFR Part 19.11.

The. inspectors discussed with the licensing staff the periodicity and documentation

-of posting verification. by the licensee. -Licensing staff stated that posting

.

verification was conducted

on a periodic basis, but was not formally documented.

The inspectors noted that many of the posted documents'related

to enforcement

correspondence

were old issues and no longer required posting; however,

0

20

maintaining the posting beyond that required was conservative

and did not

contradict either licensee procedures

or NRC regulations.

c.

Conclusions

The NMPC program to meet posting of regulatory documents was adequate

and

was in compliance with the requirements of 10 CFR 19.11.

R2.2

Calibration of Effluent Process

Radiation Monitorin

S stems

a.

Ins ection Sco

e

The inspectors reviewed the RMS availability, selected

IRC calibration procedures,

and the most recent calibration results for the following effluent/process

RMS, as

designated for each unit.

NMP1

~

Liquid Radwaste Effluent Radiation Monitor

~ -Service Water Effluent Radiation Monitor

~

Main Steam Line Radiation Monitors

~

Stack Gaseous

Effluent Monitors (Low and High Ranges)

~

Offgas Radiation'Monitors

~

Emergency Condenser Vent Monitors

NMP2

~

Liquid Radwaste Effluent Radiation Monitor

~

Service Water Effluent Radiation Monitor

~

Cooling Tower Blowdown Line Radiation Monitor

~

Cooling Tower Blowdown Flow Rate

~

Radwaste/Reactor

Building Vent Monitors (Low and High Range)

~

Main Stack Gaseous

Effluent Monitors (Low and High Range)

b.

Observations

and Findin s

NMP1

The IRC, chemistry, and radiation protection departments

had the responsibility to

perform electronic and radiological calibrations for the above radiation monitors.

All

calibration results reviewed were within the licensee's acceptance

criteria, with the

exception of the liquid radwaste effluent radiation monitor.

The last annual and

quarterly calibrations of this monitor were on September

6, 1994, and

August 29, 1995, respectively.

The licensee did not release any radioactive liquid

since the last calibration.

Calibration, and the operability of this monitor, is required

-by TS only prior to radioactive liquid release to the environment.

The licensee's,

intention was that the radioactive liquid effluent radiation monitor would be

calibrated and made operable prior to any anticipated radioactive liquid release.

21

During the review of the above RMS calibration documentation,

the inspectors

independently

calculated and compared several calibration results, including linearity

tests and conversion factors.

The inspectors determined that the licensee's results

were comparable to the independent

calculations.

The inspectors noted that ownership of RMS varied.

For example, the stack RMS

availability was tracked and trended by the chemistry staff, while the radiation

protection department

had responsibility for the radioactive liquid effluent RMS.

NMP2

The radiation protection department

had the responsibility to perform electronic and

radiological calibration for all NMP2 RMSs.

The inspectors noted that one individual

was responsible for the program, and effectively tracked the availability for all

effluent, process,

and area RMSs.

Calibration results were within the licensee's

acceptance

criteria. The responsible

individual demonstrated

the RMS status to the

inspectors at the monitoring panel in the control room during the plant tour.

",-'uring the review of the'above

RMS calibration documentation,

the inspectors

also

independently

calculated and compared several calibration results, iricluding linearity

tests and conversion factors.

The inspectors determined that the licensee's results

were comparable to the independent

calculations.

c.

Conclusions

Based on the above reviews, the inspectors determined that the licensee maintained

and implemented good calibration and assessment/trending

programs for effluent,

processand

area radiation monitoring systems.

R2.3

Surveillance Tests for Air Cleanin

S stems and Plant Air Balance

80

Ins ection Sco

e

The inspectors reviewed the licensee's most recent surveillance test results for the

below systems,

and the status of the air balance for the following buildings:

NMP1

~

Reactor Building Emergency Ventilation System

~

Control Room AirTreatment System

NMP2

~

Standby Gas Treatment System

~

Control Room Outdoor Air Special Filter Train System

22

Air Balance for both Units

~

Turbine Buildings

~

Reactor Buildings

~

Radwaste

Buildings

~

Control Rooms

b.

Observations

and Findin s

All surveillance results (visual inspection, in-place HEPA [high efficiency particulate

air] and charcoal leak tests, air capacity tests, pressure drop tests, and laboratory

tests for the iodine collection efficiencies) were within TS acceptance

criteria. Air

balance for the turbine, reactor, and radwaste buildings and the control room were

maintained as described

in the UFSAR.

Recently, the NRC Office of Nuclear Reactor Regulation (NRR) identified a potential

conflict regarding the charcoal testing methodology for the iodine collection

efficiency performed by the licensee/contractor

laboratory.

The licensee's TS

specify Regulatory Guide (RG) 1.52, Revision 2, March 1978, Position C.6.a, as the

requirement for the laboratory testing of the charcoal; and RG 1.52 references

American National Standards

Institute (ANSI) N509-1976, "Nuclear Power Plant Air-

Cleaning Units and Components."

ANSI N509-1976 specifies that testing is to be

performed in accordance

with paragraph 4.5.3 of RDT M-161T, "Gas Phase

Adsorbents for Trapping Radioactive Iodine and Iodine Components."

The essential

testing criteria are:

(1) 70% or 95% relative humidity (RH); (2) 5-hour pre-

equilibration time, with air at 25

C and plant specific RH; (3) 2-hour challenge,

with gas at 80

C and plant-specific RH; and (4) 2-hour elution time, with air at

25

C and plant-specific RH. The latest acceptable

methodology for the laboratory

testing of the charcoal is ASTM [American Society for Testing and Materials]

D 3803-1989, which requires licensee's to maintain 30

C during all testing phases.

The inspectors confirmed that the licensee also used ASTM D 3803 methodology.

C.

Conclusions

Based on the above reviews, the inspectors determined that the licensee maintained

the plant air cleaning systems in accordance with established

design specification

and TS requirements.

R3

RP5C Procedures

and Documentation (84750)

R3.1

Review of Radioactive Effluents Procedures

and Re orts

ao

Ins ection Sco

e

The inspectors reviewed selected chemistry procedures to determine whether the

licensee could implement the radioactive liquid and gaseous

effluent control

programs effectively. The inspectors

also reviewed the 1995 and 1996 Semiannual

Effluent Reports for both units; and contents of the ODCM.

23

b.

Observations

and Findin s

The inspectors noted that effluent control procedures

were detailed and easy to

follow, and that ODCM requirements were incorporated into the appropriate

procedures.

The licensee had good procedures

to satisfy the ODCM requirements

for routine and emergency operations.

The inspectors reviewed the 1995 and 1996 Semiannual

Radioactive Effluent

Release

Reports for both units.

These reports provided data indicating total released

radioactivity for liquid and gaseous

effluents.

The reports also summarized the

assessment

of the projected maximum individual and population doses resulting

from routine radioactive airborne and liquid effluents.

Projected'doses

to the public

were well below the TS limits. The inspectors determined that there were no

anomalous

measurements,

omissions or adverse trends in the reports.

The NMP1 and NMP2 ODCMs provided descriptions of the sampling and analysis

programs, which were established for quantifying radioactive liquid and gaseous

effluent concentrations,

and for calculating projected doses to the public. All

necessary

parameters,

such as effluent radiation monitor setpoint calculation

methodologies,

site-specific dilution factors, and dose factors, were listed in the

~

ODCM. The licensee adopted other parameters from RG 1.109 as appropriate.

c.

Conclusions

Based on the above reviews; the inspectors determined that the NMPC effluent

control procedures

were sufficiently detailed to facilitate performance of all

necessary

steps for routine and emergency operations, the licensee effectively

implemented the ODCM requirements for reporting effluent releases

and projected

- doses to the public, and the licensee's

ODCM contained sufficient information to

acceptably implement and maintain the radioactive liquid and gaseous

effluent

control programs.

R6

RPRC Organization and Administration (84750)

The inspectors reviewed the organization and administration of the radioactive liquid

and gaseous

effluent control programs and discussed with the licensee changes

made since the last inspection; conducted

in September

1995.

There were no

changes

since the last inspection of the programs.

Staffing levels appeared to be

appropriate for the conduct of routine and emergency operations.

24

R7

Quality Assurance

(QA) in RPRC Activities (84750)

R7.1

QA Audits of Effluent Activities

aO

Ins ection Sco

e

The inspectors reviewed the 1995 and 1996 QA audits and chemistry measurement

laboratory QA/QC [quality control] data to validate the quantification methodology

for the total releases.

b.

Observations

and Findin s

The inspectors reviewed QA Audit Report Numbers95-019 and 96-022,

The

inspectors noted that the audit teams included technical personnel.

The 1995 and

1996 audit teams identified no findings of safety significance.

The inspectors noted

that the. scope and technical depth of the audits were sufficient to assess

the

quality of the radioactive liquid and gaseous

effluent control programs.

The licensee maintained

a good.QA policy and verified program performance

throughout the chemistry department,

including the analytical measurement

laboratory. The inspectors reviewed the QC data for intra/inter-laboratory

comparisons.

When discrepancies

were found, effective resolutions were

determined

and implemented.

C.

Conclusions

Based on the above reviews, the inspectors determined that the licensee's

QA

audits'were sufficient to effectively assess

the radioactive'liquid and gaseous

effluent control programs.

The licensee implemented

a very good QA/QC program

to validate measurement

results for effluent samples.

P2

Status of Emergency Preparedness

(EP) Facilities, Equipment and Resources

(82701)

P2.1

Emer enc

Res

onse Facilities

aO

Ins ection Sco

e

The inspectors toured the offsite Emergency Operations Facility (EOF), the offsite

Joint News Center (JNC), and the onsite Operations Support Center (OSC).

The

inspectors conducted

an audit of the instrumentation,

supplies, and equipment

contained

in the EOF and OSC, and reviewed completed quarterly inventories for the

.past four calendar quarters for completeness,

accuracy,

and compliance.

b.

Observatiohs

and Findin s

The licensee had recently (December 1996) relocated to a new EOF, sharing the

.facility used arid maintained by the New York Power Authority (NYPA) for the

25

James A. Fitzpatrick nuclear plant.

The NRC had previously accepted this facility

for use by the Fitzpatrick plant.

As part of the agreement for the use of this facility,

NMPC built and maintained

a new JNC facility for use by the two licensees.

The inspectors

noted that NMPC had provided for separate

resources for their use in

the central decision-making

area of the EOF and had provided for co-locating with

NYPA in the support areas of the EOF for those events that would result in an

emergency at both sites.

As part of the relocation, NMPC committed to perform a

drill with NYPA that would demonstrate

the dual activation of the facility by both

sites.

The NMPC portions of the EOF were kept in an acceptable

state of readiness.

Required procedures

were in place, including adequate

numbers of emergency

classification matrices.

Telephone lists for important emergency response

organization personnel

and locations were readily available.

A spot check of

telephone circuit operability showed no inoperable circuits.

The inspectors noted that there were more items at the EOF and OSC than were

specified on the NMPC inventory sheets.

Licensee

EP staff explained that the

overages

resulted from the closure of the alternate

EOF, which was no longer

required, and the transfer of those instruments to the remaining facilities. The

inspectors reviewed'a sample of inventory and equipment surveillance tests and

verified that they had been performed in the last four calendar quarters.

The review

of DERs showed recurring problems in late submittals of completed inventories to

the EP staff for their review (see section P7.1).

The inspectors'our of the JNC showed adequate

telephone capacity for use by

both the licensee's staff and the news media.

A spot check of telephones

showed

no inoperable circuits.

C.

Conclusions

The inspectors concluded that the maintenance

of the emergency response

facilities

and equipment was being well implemented and that the facilities were operationally

ready.

P3

EP Procedures

and Documentation (82701)

P3.1

Emer enc

Plan and Associated Procedures

The inspectors reviewed the change made to the Nine Mile Point Nuclear Station

Site Emergency Plan that provided for the EOF relocation and the safety evaluation

performed for this change.

The inspectors also reviewed recent changes the

licensee made to the emergency plan implementing procedures

and emergency plan

maintenance

procedures.

The inspectors performed this review in the NRC regional

office. The safety evaluation written for the move of the EOF was well-thought out

and systematically done.

The author drew references from recognized

NRC

.sources,

including the plant's safety evaluation report.

The safety evaluation

26

included a review of the change's effect on the emergency

plan, including licensing

commitments.

The inspectors concluded that the changes

made to the below

procedures

did not decrease

the overall effectiveness of the Nine Mile Point Nuclear

Station site emergency

plan and, after limited review of the changes,

no NRC

approval is required in accordance

with 10 CFR 50.54(q).

Implementation of these

changes

is subject to future inspection effort to confirm that the changes

have not

decreased

the effectiveness of the emergency plan.

~

EPIP-EPP-08

~

EPIP-EPP-1 2

~

EPIP-EPP-13

~

EPIP-EPP-21

~

EPIP-EPP-28

~

EPIP-EPP-30

~ 'PMP-EPP-02

Off-Site Dose Assessment

and Protective Action

Recommendation,

Revision 7

Re-Entry Procedure,

Revision 3

Emergency Response

Facilities Activation and Operation,

Revision 7

Radiation Emergencies,

Revision 3

Fire Fighting, Revision 3

Prompt Notification System Problem Response,

Revision 2

Emergency Equipment Inventories and Checklists, Revision 10

P4

Staff Knowledge and Performance in EP (82701)

P4.1

Staff Performance

in the Simulator

a.

Ins ection Sco

e

The inspectors observed the EP activities of two shift crews, one from each unit, on

the respective plant-specific simulators.

They observed

each crew, which included

licensed reactor operators

and senior reactor operators, communicators,

and dose

. assessment

personnel,

in the performance of one scenario'.-The activities observed

.

included assessment

of plant conditions, classification of emergency events,

notification of offsite authorities, offsite dose assessment,

and the formulation and

transmittal of protective action recommendations.

b.

Observations

and Findin s

The crews were knowledgeable

in the performance of their duties.

Operators were

.able to assess

plant conditions quickly and accurately.

All classifications were

correct.

Notifications were made in a timely fashion.

The crews were able to stay

current with a rapidly degrading plant condition, in which escalations of emergency

classes were occurring within minutes of each other.

Dose assessment

personnel

were familiar with the operation of the automated

dose assessment

model and were

able to make correct protective action recommendations

based on the projected

offsite doses.

c.

Conclusions

The inspectors concluded that, the members of the emergency response

organization

responsible for on-shift plant conditions assessment,

classification, notification, and

0

0

27

offsite radiological consequence

assessment

were adequately trained in the

performance of their duties.

p5

Staff Training and Qualification in EP (82701)

P5.1

EP Qualification Trackin

ao

Ins ection Sco

e

The inspectors reviewed EP training records, training procedures,

and the portions

of the emergency

plan dealing with training. They also interviewed EP and training

staff with EP training responsibilities and reviewed a recent qualification status

report-for the entire emergency response

organization.

Finally, they interviewed

two individuals to determine their knowledge of their responsibilities for EP

qualification tracking.

b.

Observations

and Findin s

A training specialist in the licensee's training department was responsible for

administering the EP training program.

The specialist maintained

a close liaison with

the EP staff, although functionally separate from it. The training specialist reviewed

qualification status of emergency response

organization

(ERO) members each

calendar quarter, and scheduled the training to ensure that qualifications were kept

current.

The continuing training for ERO members to maintain their qualifications was given

annually and the-training (including specialized training for certain ERO members)

was required to be completed within the prior 15 months:to prevent lapse of

qualification.

The data base printouts used for review of this requirement did not

sort to give a list of individuals coming due for.retraining.

Rather, they provided an

"X" in the heading for continuing training or specialized training for each member of

the ERO who had the training within the required time. The printout did not give

any indication of impending lapse of qualifications.

It omitted the "X" only after an

individual's qualification had lapsed.

ERO members qualified within the last year

also did not have the "X" in the heading for continuing training or specialized

training, since they had been qualified based on their initial training.

The inspectors reviewed the printout for the ERO qualifications and questioned the

fact that some individuals assigned

dose assessment

duties at the EOF did not

appear to have completed the specialized training.

The training specialist, after

reviewing the records of the individual ERO members, discovered that nine members

of the dose assessment

staff at the EOF had lapsed in their qualifications.

Most of

these

ERO members had lapsed in early June, 1997; however, they continued to be

listed on the ERO roster.

Three of these individuals were initial responders;

i.e.,

ERO members who are the designated

responder for their position during a rotating

duty period.

28

The licensee staff took immediate corrective action to address this oversight,

including informing the ERO members whose qualification had lapsed, and

designating qualified individuals to respond.

The license documented

the problem

on a DER, and they scheduled

remedial training for the members whose

qualifications had lapsed.

Notwithstanding, the failure to maintain the training

requirements of the approved Site Emergency

Plan is a violation of NRC

requirements.

(VIO 50-220/97-06-04 and 50-410/97-06-04)

The licensee has also delegated

some responsibilities for the administration of the

EP training and qualification program to the individual ERO members.

This

delegation was proceduralized

in NIP-EPP-01, "Emergency Response

Organization

Expectations

and Responsibilities."

One of these responsibilities was for the

Team

1 initial responders

to maintain secondary

responder

personnel

in sufficient

quantity to support the requirements of the Site Emergency Plan.

Another

responsibility was for the individual ERO members to maintain their training and

qualifications current.

These individuals did not have a method for readily

determining the status of their own, or their subordinates,

qualifications in order to

satisfy these requirements.

The inspectors interviewed two Team

'1 initial responders

with responsibility for

~

maintenance

of subordinate

ERO members.

Neither of these individuals knew how

to verify the qualification status of the secondary

responders

for which they were

responsible.

Both believed that the Community Alert Network (CAN) printout listing

the telephone

numbers of the secondary

responders

listed only fully qualified ERO

members.

The Director, Emergency Preparedness,

(EPD) told the inspectors that

this was not the case, that the CAN printout only listed the names of members who

had been designated for ERO response.

Conclusions

The inspectors concluded that the licensee's method for tracking EP qualifications

was inadequate for meeting the procedure requirements.

Licensee training staff

could not readily identify personnel who needed periodic training until the

qualification had lapsed.

Based on the limited number of personnel interviewed, the

inspectors concluded that the expectations

and requirements of ERO personnel were

not clearly understood.

The inspectors identified the failure to maintain the training

requirements

listed in the approved Site Emergency

Plan as a violation of NRC

requirements.

(VIO)

Drill and Exercise Performance

Ins ection Sco

e

The inspectors reviewed the approved Site Emergency Plan requirements for the

conduct of drills and exercises

and the EP Maintenance

Procedures

covering

the'equired

drill and exercise scheduling

and performance objectives.

They also

reviewed a recent matrix of drills and objectives to determine how effectively the

licensee was complying with the requirements of the plan and procedures.

b.

Observations

and Findin s

29

The licensee conducts

EP drills and exercises

in accordance with the requirements

of two procedures.

EP Maintenance

Procedure

EPMP-EPP-01,

"Maintenance of

Emergency Preparedness,"

lists periodic requirements for drills and exercises,

and

EPMP-EPP-04,

"Emergency Exercise/Drill Procedure," contains

a required

performance-based

matrix for the conduct of drills and exercises.

Both procedures

specify frequencies at which the various objectives are to be demonstrated.

The licensee's drill matrix lists the drills and exercises for the past six years and the

objectives from the two EPMP procedures that were demonstrated

in each drill. The

inspectors'eview of this matrix showed that the objectives were satisfied with one

exception.

Procedure

EPMP-EPP-01

required the conduct of an annual

ERO

augmentation

drill, by activation of the notification system, with actual personnel

response

from offsite to the emergency facilities.

- The inspectors. determined that the licensee had been taking credit for satisfying

this objective through the periodic notification drills they performed during off-hours.

. These notification drills, however, did not require actual transit by the ERO members

to their assigned

emergency response facility. The inspectors learned, through

discussion with the EPD, that a call-out of the ERO with actual report to the

facilities from offsite'had not been performed since November 1994.

The inspectors discussed this fact with the EPD and learned that licensee

management

did not expect an actual report of the ERO from offsite to the ERFs,

and that the procedure

did not correctly reflect the actual expectation.

The EPD.

stated that NMPC recognized the value of such augmentation

drills, but that they

were infrequently performed, and that there was no intention to procedurally

formalize such a practice beyond the requirement to conduct an off-hours exercise

every six years.

The EPD reported that the annual augmentation

drill requirement in EPMP-EPP-01

had been contained

in that procedure since 1991.

The licensee had failed to

recognize the existence of this requirement, despite its explicit wording, and was

taking credit for its completion with the performance of the periodic call-out drills in

which ERO members respond via telephone with an estimate of their reporting time.

The practice of estimating the reporting time, however, had only recently been

implemented as a result of an NRC observation during the last EP program

inspection.

(NRC.lR 96-04 Section P2)

. The licensee had performed a comparison check of the Site Emergency Plan, the EP

.implementing procedures,

EP.maintenance

procedures,

and established

practices

within the past year.

The purpose of this comparison was to identify and resolve

conflicts between the various documents

and practices.

This effort failed to reveal

the discrepancy between the augmentation

drill requirement in EPMP-EPP-01

and

.'he accepted practice of performing call-out notifications without actual report to

the ERF.

The failure to conduct the annual callout drill is a violation of the

30

Emergency

Plan and EP Maintenance

Procedures.

(VIO 50-220/97-06-05 and 50-

410/97-06-05)

C.

Conclusions

Emergency drills/exercises have satisfied the requirements of the EP maintenance

procedures

with the exception of the annual callout drill. (VIO) This is significant in

that a comparison was recently performed to identify conflicts, but NMPC failed to

recognize the existing requirement.

P5.3

General

EP Trainin

ao

Ins ection Sco

e

The inspectors reviewed EP training records, training procedures,

lesson plans, job

performance measures,

and the portions of the emergency plan dealing with

training. As part of this review, they reviewed the presentation

and training

feedback forms from the licensee's recently completed pilot program of computer-

based EP-continuing training.- They also interviewed EP.and training staff with EP

training responsibilities.

The inspectors attended

a training lesson that was given to

- some ERO members at the newly established

EOF and reviewed the lesson plan and

attendance

record's for the training given to ERO responders

prior to the relocation

to the new EOF.

Finally, the inspectors interviewed four individuals to determine

their impressions of the EP continuing training recently received.

b.

Observations

and Findin s

The training specialist instructs for,some lessons, monitors. the instruction given by

subject matter experts for other training, and maintains the overall EP training

program.

This same individual also oversees the maintenance

of the general

employee and radiation protection training programs.

The training that the inspectors observed was held on-station at the EOF and was

administered by the Team

1 initial responder

responsible for the clerical staff. The

EP Training Specialist also administered some of the lesson.

The training was

highly-task oriented, with the instructor leading the trainees around to the various

work stations where they would be performing duties.

The attendees

asked

questions freely, and the instructor readily answered those questions.

The

attendees

were provided a task to perform, and quizzed at the end of the training.

The licensee instituted a pilot training program during the last unit outage in which

initial responders

in the ERO were given an opportunity to take their EP continuing

training by use of a computer-based

training presentation.

They were to take a quiz

and return it to the Training Department.

Also, they were given feedback forms to

communicate their impressions back to the Training Department.'he

inspectors

noted that the computer-based

training was generally'ell received by the

attendees.

Two ERO members interviewed felt that it was'a positive experience.

Comments received on the feedback forms were mostly favorable.

0

31

The content of the computer-based

lesson presentation for the Technical Support

Center (TSC) initial responder continuing training was consistent with the content of

the formal lesson plan for that course.

The training included lessons

learned from

past Nine Mile Point drills as well as lessons

learned from the industry that were

presented

in NRC inspection reports.

There were skill-oriented presentations

on

proper three-way communications

and effective listening,

The EP training given in preparation for the relocation of the EOF was completed for

nearly all the responders

shortly before the move to that facility. Lesson plans

focused on the tasks to be performed and equipment to be used by the responders.

C.

Conclusions

The inspectors concluded that the general content of the EP training program was

well maintained and the program well implemented.

The training given to the EOF

responders

was adequate

and conducted

before the move.

The computer-based

training pilot training program was effectively implemented and met all training

objectives.

P7

Quality Assurance in EP Activities (82701)

P7.1

Deviation Event'Re

orts

aO

Ins ection Sco

e

The inspectors reviewed the outstanding

DERs dealing with EP that were assigned

to other groups for resolution, as well as the DER backlog for the EP group and the

'rend-analysis

performed.by'the'EP staff on DERs assigned to them.

The inspector

- also reviewed the outstanding entries in the Emergency Preparedness

Task Tracking

System (EPTTS).

b.

Observations

and Findin s

The licensee

EP staff frequently relied on the use of DERs to document and track EP

issues.

The threshold for use of this corrective action tool was low. The EP staff

wrote one DER to document the failure of some senior managers to attend required

EP continuing training. The EPD stated that he relies on the DER process to ensure

that the EP activities delegated to the line organizations

are completed properly.

.The inspectors noted six open DERs that the EP group was tracking related to the

inventory of ERF equipment.

The DERs dealt with improperly completed inventories

and with failures of the reporting groups to forward the completed inventories to the

EP staff.

In May 'l997, the EP staff changed the EPMP procedure goverriing the

conduct of the inventories to require forwarding the completed inventories.

The.

- inspectors could not establish the success of this action, since another DER was:

written during the week of the inspection.

The EP staff performed a trend analysis of DERs assigned to them for resolution in

accordance

with Instruction NTI-3.0, "Nuclear Learning Center Self Assessment

Instruction."

The inspectors determined that the EP staff had performed the trend

32

analysis correctly in accordance

with NTI-3.0. The inspectors concluded that, due

to the small number of DERs assigned to the EP staff, the results of the trend

analysis were inconclusive.

The EP staff tracks tasks internally via the EPTTS system.

The EPTTS backlog

contained some long-standing

items that were more than three years old. New due

dates had been assigned to items that had missed their original due dates.

When

questioned

by the inspectors about this practice, the EPD stated that the EPTTS

was an informal system, used by the EP staff, for tracking tasks that were not

captured

in any other administrative procedure/system.

The inspectors noted that

the EPTTS has no procedure or instruction governing its use.

C.

Conclusions

The inspectors concluded that the licensee made good use of the DER system to

maintain the quality control of EP activities; however, the DER system showed

'""- limited success

in ensuring adequate

oversight of EP activities assigned to other

groups, as demonstrated

by repeated

problems with facility inventory processing.

The inspectors concluded that the EPTTS was useful as a reminder file of EP tasks,

. but a poor indicator of the EP.staff's effectiveness

in documenting, trending, and

correcting problems.

P7.2

ao

External Audits

Ins ection Sco

e

The inspectors reviewed the annual QA audit reports for the'last three years, paying

particular attention to the 1997 audit, which was completed in May.

b.

Observations

and Findin s

The audits reviewed were performed by teams that included personnel from other

utilities who were knowledgeable

in EP. They were performance-based

to a limited

extent in that they included observation of a single drill performance.

The audits

looked at the interface between the licensee with the State and local governments

in EP matters.

Copies of the audit reports were made available to the State and

local governments.

The 1997 audit team reviewed drill records and procedure changes,

and had one

minor finding in the latter area.

Despite this fact, the audit team did not find that

the licensee had not followed a long-standing

drill requirement

(see Section P5.2).

Also, the 1997 audit team did not draw any conclusions about the EP staff's need

to write repeated

DERs dealing with improperly processed

facility inventories see

Section P7.1).

C.

Conclusions

The inspectors determined that the annual QA audits met the regulatory

requirements of 10 CFR 50.54(t), but were not effective in identifying some

problems in the licensee's

EP organization.

33

P8

Miscellaneous

EP Issues (92904)

P8.1

Closed

IFI 50-220 96-07-19 and 50-410 96-07-19:

Weaknesses

in the

Emer enc

Pre

aredness

Pro ram

This item was opened

in response to a finding during the 1996 Integrated

Performance Assessment

Program (IPAP) team inspection (NRC IR 50-220/96-201

and 50-410/96-210), in which the IPAP team concluded that sufficient weaknesses

existed in the EP program at Nine Mile Point to warrant increased

inspection effort.

The'inspectors

reviewed this item by evaluating whether actions employed by the

EP staff to identify, correct, and prevent recurrence of problems were adequate to

justify less inspection effort and close the item.

Based on the problems identified during this inspection period, including two

violations, the inspectors confirmed that weaknesses

still exist in the NMPC EP

program.

Additional NRC attention in this area willoccur during the follow-up to

'the violations.

This item is being administratively closed.

S1

Conduct of Security and Safeguards Activities

S1.1

General Comments

During routine tours, the inspectors verified that security posts were properly

staffed, protected area gates and vital area access points were locked or guarded,

and isolation zones were free of obstructions.

In general, access controls were in

accordance with the Nine Mile Point Security Plan.

S8

Miscellaneous Security and Safeguards

Issues

S8.1

Closed

URI 50-410 97-04-11:

NMP2 Refuel Floor Access Gate Found Unlocked

During a tour of the NMP2 reactor building, NRC inspectors found the access gate

to the NMP2 refuel floor improperly secured.

At that time, DER 2-97-1806 was

initiated to determine the significance, root cause,

and necessary

corrective actions

to prevent recurrence.

The inspectors reviewed the completed

DER, and discussed

the issue with the Security Manager and Nine Mile senior management.

The DER

disposition noted that the gate was neither a security barrier nor a radiological

boundary.

As such, there was no requirement for the gate to be locked.

However,

further review by NMPC determined that there were numerous gates and doors that

unnecessarily

required the use of a hard key or an electronic card reader.

Corrective

actions included a review of all locked doors/gates,

with the potential to remove the

unnecessary

access control.

The DER identified the cause as weak management

direction; in that, expectations

were not well understood with respect to ensuring

that gates/doors

were locked.

This URI is closed.

34

V. MANAGEMENTMEETINGS

X1

Exit Meeting Summary

At periodic intervals, and at the conclusion of the inspection period, meetings were

.held with senior station management

to discuss the scope and findings of this

inspection.

The exit meetings for specialist inspections were conducted

upon

completion of their onsite inspection:

~

Emergency Preparedness

July 18, 1997

~

Radioactive Effluents Monitoring

July 18, 1997

The final exit meeting occurred on August 21, 1997.

During this meeting, the

resident inspectors findings were presented.

NMPC did not dispute any of the

inspectors findings or conclusions.

Based on the NRC Region

I review of this

report, and discussions with NMPC representatives,

it was determined that this

report does not contain safeguards

or proprietary information.

ATTACHMENT1

PARTIALLIST OF PERSONS CONTACTED

Nia ara Mohawk Power Cor oration

R. Abbott

D. Barcomb

C. Beckham

D. Bosnic

J. Burton

H. Christensen

J. Conway

G. Correll

A. DeGracia

S. Doty

K. Dahlberg

G. Helker

..P. Mazzafero

L. Pisano

R. Randall

P. Smalley

R. Smith

C. Terry

R. Tessier

K: Ward

C. Ware

D. Wolniak

Plant Manager,

NMP1 (Acting)

Manager, NMP2 Radiation Protection

Manager, Quality Assurance

Manager, NMP2 Operations

Director, ISEG

Manager, Security

Vice President,

Nuclear Engineering

Manager, NMP1 Chemistry

Manager, NMP1 Work Control

Manager, NMP1 Maintenance

Plant Manager, NMP2 (Acting)

Manager, NMP2 Work Control

Manager, NMP1 Technical Support

Manager, NMP2 Maintenance

Manager,

NMP1 Engineering

Manager,

NMP1 Radiation Protection

Manager,

NMP1 Operations

Vice President,

Nuclear Safety Assessment

& Support

Manager, Training

Manager, NMP2 Technical Support

Manager, NMP2 Chemistry

Manager, Licensing

INSPECTION PROCEDURES USED

IP 37551:

IP 61726:

IP 62707:

IP 71707:

IP 71750:

IP 82701:

IP 84750:

IP 90712:

IP 92700:

IP 92901:

IP 92903:

IP 92904:

On-Site Engineering

Surveillance Observations

Maintenance Observation

Plant Operations

Plant Support

Operational Status of the Emergency Preparedness

Program

Radioactive Waste Treatment, and Effluent and Environmental

Monitoring

In-Office Review of Written Reports of Nonroutine Events at Power

Reactor Facilities

Onsite Followup of Written Reports of Nonroutine Events at Power

Reactor Facilities

Followup - Operations

Followup - Engineering

Followup - Plant Support

Attachment

1

ITEMS OPENED, CLOSED, AND UPDATED

OPENED

50-220

8L

50-410/97-06-01

50-410/97-06-02

50-410/97-06-03

VIO

Multiple examples of failure to follow procedures

IFI

Review root cause and additional corrective actions after

destructive testing of flex-hose

NCV

Personnel

error resulted in changing from STARTUP to

RUN without meeting all conditions of the TS

50-220

8L

50-410/97-06-04

50-220 5

50-41 0/97-06-05

CLOSED

50-410/96-06-02

IFI

Clarification of wording in the NMP2 UFSAR regarding full

core offloads

Review. of corrective actions associated

with LER 96-03-01

Weaknesses

in the emergency preparedness

program

IFI

IFI

50-410/96-06-04

- 50-220

8L

50-41 0/96-07-1 9

50-410/97-04-1

1

URI

50-410/

VIO

EA-96-1 1 6-1 01 2

50-410/97-06-03

.

NCV

NMP2 refuel floor access gate found unlocked

Discrimination of an employee for raising safety concerns

Personnel

error resulted in changing from STARTUP

to RUN without meeting all conditions of the TS

Potential inoperability of EDG service water cooling water

outlet valves during a control room fire

TS violation caused

by procedural non-compliance

due to

personnel

error

HPCS system inoperable due to failed unit cooler

50-410/97-02-02

LER

50-410/97-03

LER

LER

50-410/97-05

UPDATED-

none

VIO

Annual retraining of some ERO members was

not completed

VIO

An annual

ERO augmentation

callout drill was not performed

since 1994

LIST OF ACRONYMS USED

ALARA

ASME

ASTM

ANSI

ASSS

ATS

CFR

CM

As Low As Reasonably Achievable

American Society of Mechanical Engineers

American Society for Testing and Materials

American National Standard

Assistant Station Shift Supervisor

Analog Trip System

'ode

of Federal Regulations

Corrective Maintenance

A-2

Attachment

1

DER

DW

DWEDT

DWFD

EA

EDG

EOF

EP

FCV

GL

gpm

HEPA

HPCS

HRA

IE

IFI

IR

ltkC

JNC

LCO

LER

LPRM

NCV

NMPC

NRC

NYNOC

NYPA

ODCM

OSC

QA

QARSE

RCA

RCIC

RG

RH

RMS

RWP

SBLOCA

SORC

SRO

SRAB

SSS

TS

TSC

UFSAR

VIO

Deviation/Event Report

Drywell (containment)

Drywell Equipment Drain Tank

Drywell Floor Drain

Enforcement Action

Emergency Diesel Generator

Emergency Operations Facility

Emergency Preparedness

Flow Control Valve

Generic Letter

gallons per minute

High Efficiency Particulate Air

High Pressure

Core Spray

High Radiation Area

Inspection and Enforcement

Inspector Follow Item

Inspection Report

Instrumentation

and Control

Joint News Center

Limiting Condition for Operation

Licensee Event Report

Local Power Range Monitor

Non-Cited Violation

~ Niagara Mohawk Power Corporation

Nuclear Regulatory Commission

New York Nuclear Operating Company

New York Power Authority

Offsite Dose Calculation Manual

Small Break Loss of Coolant Accident

Station Operations Review Committee

Senior Reactor Operator

Safety Review and Audit Board

Station Shift Supervisor

Technical Specification

Technical Support Center

Updated Final Safety Analysis Report

Violation

Operations Support Center

Quality Assurance

Qualified Applicability Reviewer/Safety Evaluator

Radiologically Controlled Area

Reactor Core Isolation Cooling

Regulatory Guide

Relative Humidity

Radiation Monitoring System

Radiation Work Permit

WO

Work Order

A-3

7