ML17059B782

Insp Repts 50-220/97-07 & 50-410/97-07 on 970810-1004. Violations Noted.Major Areas Inspected:Opertions,Maint, Engineering & Plant Support

ML17059B782
Person / Time
Site:	Nine Mile Point
Issue date:	11/24/1997
From:	Doerflein L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML17059B780	List: ML17059B779 ML17059B781 ML17059B782
References
50-220-97-07, 50-220-97-7, 50-410-97-07, 50-410-97-7, NUDOCS 9712090013
Download: ML17059B782 (80)

See also: IR 05000220/1997007

Text

U.S. NUCLEAR REGULATORYCOMMISSION

REGION I

Docket/Report Nos.:

50-220/97-06

50-410/97-06 i

License Nos.:

DPR-63

NPF-69

Licensee:

Niagara Mohawk Power Corporation

P. O. Box 63

Lycomnin, NY 13093

Facility:

Nine Mile Point, Units

1 and 2

Location:

Scriba, New York

Dates:

August 10 - October 4, 1997

Inspectors:

B. S. Norris, Senior Resident Inspector

T. A. Beltz, Resident Inspector

L. L. Eckert, Radiation Specialist

J. T. Furia, Senior Radiation Specialist

M. L. Hart, NRR Intern

J. R. M'Fadden, Radiation Specialist

T. A. Moslak, Project Engineer

L. A. Peluso, Radiation Physicist

R. A. Skokowski, Resident Inspector

Approved by:

cx

Lawrence T. Doerflein, Chief

Projects Branch

1

Division of Reactor Projects

l i /P 'I /1 "1

Date

97i20900i3 97ii28

PDR

ADOCK 05000220

8

PDR

TABLE OF CONTENTS

TABLE OF CONTENTS

page

EXECUTIVE SUIVIMARY

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VI

SUMMARYOF ACTIVITIES...

1

Niagara Mohawk Power Corporation (NMPC) Activities

1

Nuclear Regulatory Commission (NRC) Staff Activities ..............

1

I. OPERATIONS

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Conduct of Operations

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01.1

General Comments

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01.2

NMP1 Reactor Shutdown due-to Emergency Cooling (EC)

Condenser Tube Leak................

02

Operational Status of Facilities and Equipment

02.1

NMP2 Standby Liquid Control System Engineered Safety Feature

Walkdown.... ~................

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02.2

Plant Walkdowns..................................

08

Miscellaneous Operations Issues .....

08.1

(Closed) IFI 50-220/96-07-18 5 50-410/96-07-18:

Material

Condition Discrepancies Identified in Several Areas ..........

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II. MAINTENANCE

M1

Conduct of Maintenance...

M1.1

General Comments......

M1.2

Repairs to NMP1 Emergency Cooling Condensers

M1.3

NMP2 Maintenance Activities on Offsite Power Supply

M7

Quality Assurance

in Maintenance Activities ..

M7.1

Missed Surveillance Test of the NMP1 Control Room Ventilation

Radiation Monitor ..

MB

Miscellaneous Maintenance Issues

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M8.1

(Closed) URI 50-220/96-07-04:

Procedure

Change Evaluation

Used to Change Intent of a NMP1 Procedure

M8.2

(Closed) LER 50-410/97-06:

Plant Shutdown Due to Rising

Unidentified Leakage

M8.3

(Closed) LER 50-410/97-07:

Failure to Calibrate Hydrogen

Recombiner Instruments as Required by Technical Specifications

Due to Procedure Omission

III. ENGINEERING......... ~...... ~..........

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E1

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Conduct of Engineering ~...... ~.................

E1.1

General Comments... ~...

EB

Miscellaneous Engineering Issues

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E8.1

(Closed) EA 96-079/VIO 1013:

Design Control Measures

Inadequate

during Calculations for Establishing Reactor Building and

Turbine Building Relief Pressure

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Table of Contents (cont'd)

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E8.2

(Closed) URI 50-220/96-05-01:

NRC Staff Review of Revised

Reactor Building and Turbine Building Blowout Panel Relief

Pressure

Calculations ..

E8.3

(Closed) IFI 50-220/96-05-02:

Inconsistencies

in the NMP1

UFSAR and IPE with respect to the Reactor Building and Turbine

Building Blowout Panel Relief Pressure Setpoints.............

15

E8.4

(Closed) LER 50-220/97-07:

Potential Control Room Emergency

Ventilation System Operation Outside the Design Basis due to

Inadequate

Evaluation

16

IV. PLANT

R1

R2

R3

R5

R7

S1

F2

SUPPORT

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Radiological Protection and Chemistry (RP&C) Controls .............

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R1.1

General Comments.... ~...

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R1.2

Radiological Protection Program ..

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R1.3

Transportation and Radiological Waste Programs.............

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R'l.4

Shipment of Radioactive Material to an Unlicensed Facility . ~.... 21

Status of RP&C Facilities and Equipment ................

23

R2.1

Radiological Protection Facilities and Contamination Controls

Instrumentation ~... ~, ~....,

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PR&C Procedures

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

23

R3.1

Shipment of Wrong Radwaste Material

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Staff Training and Qualifications .... ~................. ~.... 25

R5.1

Training of Staff Involved in Radioactive Material Transportation

and Radwaste Processing........ ~........ ~..........

25

Quality Assurance

(QA) in RP&C Activities...................

25

R7.1

QA in Radiation Protection Activities

.

25

R7.2

QA in Radiological Transportation and Radwaste Activities ..'.... 26

Conduct of Security and Safeguards Activities

27

S1.1

General Comments

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S1.2

Unusual Event - Discovery of a Suspicious Package...... ~.... 28

Status of Fire Protection Facilities and Equipment

.

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F2.1

Control Room Fire Suppression

System and Operator Response

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V. MANAGEMENTMEETINGS....

X1

Exit Meeting Summary .....

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. 30

ATTACHMENT1

- PARTIALLIST OF PERSONS CONTACTED

- INSPECTION PROCEDURES USED

- ITEMS OPENED, CLOSED, AND UPDATED

- LIST OF ACRONYMS USED

EXECUTIVE SUMMARY

Nine IVlile Point Units 1 and 2

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

August 10 - October 4, 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 an eight-week period of inspections and reviews by the resident inspectors,

and

regional specialists in the areas of radioactive waste processing, radioactive material

transportation and radiation protection.

PLANT OPERATIONS

The questioning attitude of a Nine Mile Point Unit 1 (NMP1) chemistry technician and the

heightened sensitivity of the NMP1 staff to the possibility of an emergency cooling (EC)

condenser tube leak were good.

During the ensuing reactor shutdown, the control room

operators'se

of alarm response

procedures, three-part communications, and self/peer

checking were noticeably improved.

Special simulator training resulted in good operating

crew performance during the manual reactor shutdown.

The system walkdowns and performance history reviews indicated that the material

condition of the Nine Mile Point Unit 2 (NMP2) standby liquid control system was good,

and that the system has demonstrated

a high level of reliability. The knowledge level of

the technicians and operators during the performance of an observed surveillance test was

good.

However, operators stepping on small diameter piping and using a pipe wrench to

assist in the manual valve manipulation indicated poor work practices, in that their actions

could potentially damage plant equipment.

NMP2 operators considered

a catch containment used to collect oil leaking from a gear box

on the reactor core isolation cooling pump to be a permanent installation.

However,

contrary to NMPC procedure,

a plant change request had not been initiated.

(NCV)

IVIAINTENANCE

During NMP1 emergency cooling condenser repair activities, foreign material exclusion

controls were appropriately maintained, in that material accountability and system

cleanliness were controlled.

Maintenance personnel adhered to work order requirements,

and all associated

procedures

and documentation were readily available and the current

revision.

During a pipe cutting evolution, a poor safety and radiological work practice was

identified, in that maintenance

personnel were using a rubber-gloved hand to remove metal

shavings.

Radiological controls were satisfactory.

Quality assurance

(QA) oversight of

ongoing maintenance activities was appropriate.

Inattention-to-detail and failure to self-check a completed surveillance test data sheet by

NMP1 radiation protection (RP) calibration staff resulted in the failure to perform a

ventilation radiation monitor instrument channel calibration within the technical

specification (TS) required frequency.

(VIO)

Executive Summary (cont'd)

The inspectors considered the discovery by the NMP2 instrumentation and control

technicians of the missing calibrations in the hydrogen recombiner system to be good.

However, this was another example of a missed TS surveillance.

(VIO)

ENGINEERING

An NRC review, in 1996, of the calculations to support the modification to bring the NMP1

blowout panels within the design basis identified minor calculational errors.

In addition,

NRC noted that corrective actions in early 1996 related to the NMP1 blowout panels

design control concern had not been fullyeffective.

(NCV)

An NMP1 operator's questioning attitude of the control room smoke purge system was

very good and resulted in an engineering operability evaluation of the impact on control

room emergency ventilation system (CREVS) operability. Notwithstanding, the interface

between the smoke purge system and CREVS was inadequately evaluated during

modifications in the early 1980s.

(NCV)

PLANT SUPPORT

The radiation protection (RP) program area was being well-implemented at both units.

The

NMP1 outage ALARA(as-low-as-reasonably-is-achievable)

goal was exceeded

due to

emergent work. Very good radiological housekeeping

was noted in NMP2. Effective

programs were implemented for contamination control and external dosimetry.

The quality

assurance

(QA) program for the above areas was well implemented; audits and self-

assessments

were of appropriate scope and technical depth.

At both units, a good program had been established for the processing of liquid and solid

radioactive waste (radwaste); although the Process Control Programs (PCPs) and

associated

procedures

have not been properly maintained.

(EEI) Also, the lay-up of the

NMP1 ¹11 waste concentrates

tank was questionable;

NMPC indicated they would review

this issue and provide the NRC with an action plan to deal with it.

(IFI) At NMP2, plant

conditions were generally very good relative to radiological housekeeping

in radwaste.

However, the QA program failed to identify fullythe defects within the unit specific PCPs,

and in one instance failed to ensure that corrective actions were taken to address

an

identified defect.

(EEI) Additionally, a number of required audits of vendors providing

transportation and/or waste services were not performed.

(EEI) The above apparent

violations are being considered for escalated enforcement, and are indicative of a lack of

attention by management

in this area.

On three different occasions during this inspection period, NMPC inadequately controlled

shipments of radiological material to facilities offsite.

(1) The shipment of a sample from

the NMP1 core shroud shifted during transport and caused the radiation levels in the

occupied space of the truck to exceed limits. (EEI) (2) A wrong liner of low-level radwaste

was shipped offsite for disposal.

(EEI)

(3) A sample from the NMP1 EC condenser was

shipped to an unlicensed facility; in addition, a similar occurrence happened

in 1995. (EEI)

Allof the examples appeared to be due to a lack of procedures describing radwaste

Executive Summary (cont'd)

operator activities, inattention-to-detail, and a lack of supervisory oversight.

The above

apparent violations are being considered for escalated

enforcement.

The response of the Nine Mile Point security personnel to a "suspicious looking" package

was acceptable.

The declaration of an Unusual Event by the NMP2 SSS was appropriate

and in accordance with the NMP2 Emergency Plan.

The inspectors noted that the concern associated with the automatic fire suppression

system actuation in the control room of another nuclear power plant did not exist at Nine

Mile Point.

Plant personnel appeared trained and equipped to combat a control room fire.

Additionally, procedures were in place should personnel evacuation of the control room be

required.

REPORT DETAILS

Nine Mile Point Units 1 and 2

50-220/97-06 8( 50-410/97-06

August 10 - October 4, 1997

SUIVIIVIARYOF ACTIVITIES

Niagara IVlohawk Power Corporation (NIVIPC) Activities

NMP1

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

On

September

15, 1997, the unit was shutdown due to indications of a tube leak in

emergency cooling (EC) condenser ¹122.

Subsequently,

tube leaks were identified in all

four EC condensers.

NMP1 was shutdown for the remainder of the inspection period while

NMPC investigated the root cause of the tube leaks and evaluated repair options.

NMP2

Nine Mile Point Unit 2 (NMP2) started the inspection period in the startup mode, following

a forced outage to repair a leaking flexible drain hose on the "8" recirculation flow control

valve.

NMP2 obtained 95% of rated full power on August 12, 1997; power was limited to

95% due to the moisture separator reheaters

being isolated. On September 7, power was

reduced to 55% for a feedwater pump exchange.

Power restoration was delayed due to

equipment problems with a feed water heater level control valve; repairs were completed

and 95% power was achieved on September 10, 1997.

NMP2 maintained essentially 95%

power for the remainder of the inspection period.

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 radioactive waste

(radwaste) processing, radioactive material transportation,

and radiation protection.

The

results of the specialist inspections are contained in the applicable sections of this report.

In addition, an inspection of the security program was completed near the end of this

period, the results of that inspection will be included in the IR 50-220 5 50-410/97-11.

Three other NRC inspections were completed during this period, and are documented

in

separate

inspection reports (IRs):

Corrective Actions Program:

IR 50-220/97-805 50-410/97-80

Engineering and Closure of Generic Letter 89-10 Issues:

IR 50-220/97-095

50-410/97-09

Emergency Preparedness

Program and Full Participation Exercise:

IR 50-220/97-10

5 50-410/97-10

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, with

exception of the radwaste program as described in Section R1.3 of this report.

I. OPERATIONS

01

Conduct of Operations (71707)

'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

NMP1 Reactor Shutdown due to Emer enc

Coolin

EC Condenser Tube Leak

a e

Ins ection Sco

e

The inspectors assessed

the licensee's actions in response to indications of a tube

leak in EC condenser ¹122. The assessment

included a review of the EC system

atmospheric vent radiation monitor data, chemistry sample results, operator logs,

applicable portions of the UFSAR, and discussions with various members of the

licensee's staff.

The inspectors observed control room activities during the reactor

shutdown, including a review of the applicable procedures

and technical

specifications (TS). Also, the inspectors monitored the initial actions of the licensee

to identify the location of the leak.

S stem Descri tion

The NMP1 EC system is a passive, standby system designed to remove decay heat

from the reactor, following a reactor scram, without the loss of reactor water

inventory.

The EC system is used as a heat sink when the main condenser

is not

available.

Upon initiation, steam from the reactor passes

through the EC condenser

tubes and returns to the reactor as water.

The EC system consists of two

independent

loops, with two condensers

per loop.

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

Individual reports are not expected to address

all outline topics.

The NRC inspection manual procedure or temporary instruction

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

Observations

and Findin s

On the evening of September

11, a NMP1 chemistry technician observed that the

steam vapor from the EC loop ¹12 atmospheric vent was slightly more than normal.

At 10:45 p.m., the chemistry technician further determined that radiation levels

were higher than normal in the area of the EC condensers.

The technician informed

the NMP1 Station Shift Supervisor (SSS) of the observation, and was directed to

sample the EC loop ¹12,

On September 12, at about 1:30 a.m., NMP1 control

room operators noted that the shell-side temperature for ¹122 had increased,

and

the vent radiation monitor reading for EC loop ¹12 had also increased slightly, both

indicative of a tube leak in an EC condenser.

Subsequently,

chemistry results

verified a tube leak.

Based on the indications, operators isolated EC loop ¹12, and

noted that the associated

vent radiation monitor reading returned to normal.

Deviation/Event Report (DER) 1-97-2669 was initiated to investigate the concern.

The inspectors considered the questioning attitude of the chemistry technician, and

the heightened sensitivity of the NMP1 staff to the possibility of EC condenser tube

leaks to be good.

Additionally, the inspectors found the actions taken for the

potential EC condenser tube leak to be appropriate, and consistent with the actions

described in the UFSAR.

On September

14, with EC loop ¹12 isolated from the reactor coolant system,

NMPC attempted to hydrostatically test the tubes in EC condenser ¹122, in

accordance with an approved procedure.

In preparation for the hydrostatic test,

operators began to fillthe tubes with water prior to pressurizing the system and

noted that the water level was rising in the shell side of the condenser.

This

confirmed that a tube leak existed in EC condenser ¹122.

Based on these

indications, NMPC decided further investigation was required and NMP1 was

shutdown on September 15.

The inspectors observed the NMP1 control room activities during the reactor

shutdown.

Control room operators performed the shutdown in accordance with

approved procedures,

and it was completed without incident. The inspectors noted

that the use of alarm response

procedures

and three-part communications,

in

addition to self/peer checking, was improved.

This was the first shutdown of NMP1, within approximately five years, using

manual insertion of all control rods.

Previously, planned shutdowns were completed

by inserting control rods to a power level of approximately 20%, at which time a

manual scram was initiated to complete the reactor shutdown.

NMPC performed

the shutdown without a manual scram to minimize impact on the control rod drive

(CRD) seals, and to determine whether CRD performance following this shutdown

would be better than after past manual scrams.

Due to the extended length of time

since the last manual reactor shutdown, the operating crew scheduled to complete

the evolution practiced the procedure on the simulator.

The inspectors considered

the simulator training to be of value, as evidenced by the good performance of the

operating crew during the actual reactor shutdown.

On September

16, using a boroscope,

NMPC identified a 1-inch break on an inlet

tube in EC condenser ¹122.

To obtain insights as to when the tube leak might have

initiated, the inspectors reviewed historical data for the EC system, particularly

chemistry sample and vent radiation monitor readings.

The inspectors reviewed the

gamma spectrum analysis data from water samples taken from the shell side of the

condenser,

and discussed the results with the NMP1 Chemistry Manager.

The data

included routine monthly samples for August and September,

and the sample drawn

on September

11 subsequent

to the event.

EC condenser vent radiation monitoring

strip recorder data was also reviewed by the inspectors.

The data included both

trains of EC condensers

from September 9 through September

11. The Loop ¹12

vent radiation monitor data indicated a noticeable increase

in radiation levels

beginning on the afternoon of September

11, an approximate 0.3 milliroentgen per

hour (mR/hr) increase.

The maximum indicated radiation level was 1.1 mR/hr on EC

condenser ¹122, the alarm setpoint is 5 mR/hr; the indicated radiation levels were

well below the allowed release limits Title 10 of the Code of Federal Regulations,

Part 50 (10 CFR 50), Appendix I. The inspectors noted that all of the data,

including the gamma spectrum analysis, indicated that the condenser tube failure

occurred sometime between September

9 and 11.

During a subsequent

hydrostatic test, NMPC also identified tube leaks in EC

condensers ¹111, ¹112, and ¹121. As of the close of this inspection period,

NMPC was in the process of determining the extent of the tube leaks, and

investigating the failure mode and the root cause of the tube leaks.

NMPC

management

indicated the repair and corrective actions would be based on results

of the investigation.

C.

Conclusions

The questioning attitude of the NMP1 chemistry technician and the heightened

sensitivity of the NMP1 staff to the possibility of an EC condenser tube leak were

good.

During the ensuing reactor shutdown, the operators'se

of alarm response

procedures, three-part communications, and self/peer checking were improved.

Special simulator training resulted in good operating crew performance during the

reactor shutdown.

02

Operational Status of Facilities and Equipment (71707)

02.1

NMP2 Standb

Li uid Control S stem En ineered Safet

Feature Walkdown

Ins ection Sco

e

The inspectors assessed

the ability of the standby liquid control (SLS) system to

perform its intended function. This assessment

included a visual inspection

(walkdown) of accessible

portions of the SLS system.

The inspectors observed

performance of one surveillance test and reviewed several completed surveillance

tests associated with the SLS system.

The inspectors reviewed the SLS "System

Health" report, and applicable sections of the NMP2 UFSAR, the TSs, the Individual

Plant Examination (IPE), and the operating procedures.

The inspectors also

reviewed the SLS system with respect to the Maintenance Rule, Title 10 of the

Code of Federal Regulations, Part 50.65 (10 CFR 50.65).

During the assessment,

the inspectors discussed the related issues with the system engineer, chemistry

department supervisor, operators,

Operations Management,

and the NMP2

Maintenance

Rule Coordinator.

S stem Descri tion

The NMP2 SLS system provides a method to chemically shutdown the reactor.

It is

used only in the event that a sufficient number of control rods cannot be inserted

into the reactor core to shutdown the reactor.

The SLS system shuts down the

reactor by injecting a neutron absorbing boron solution into the reactor coolant

system.

The

SLS system consists of a storage tank that provides the boron

solution to two divisions of components.

Each division includes a positive

displacement pump, an explosive valve, a motor-operated valve (MOV), and

associated

manual valves, piping and controls.

Both divisions use a common header

that connects to the high pressure core spray (HPCS) system, downstream of the

inboard containment isolation valve. The boron solution is discharged radially over

the top of the core through the HPCS sparger.

The SLS system can be manually

initiated from the control room, or automatically initiated by the redundant reactivity

control system.

Observations

and Findin s

The inspectors performed a walkdown of accessible

portions of the SLS system.

The inspectors compared plant drawings and Procedure N2-OP-36A, "Standby

Liquid Control System," Revision 4, to the actual valve positions; no discrepancies

were identified.

In general, the material condition of the equipment appeared to be

good.

The inspectors identified no current valve leakage; however, the inspectors

noted four manually-operated

valves with minor visible indication of boron

encrustation.

Subsequently,

the inspectors ascertained that the licensee had

already planned to clean and inspect two of these valves the following week.

The

inspectors provided the licensee with the other two valve numbers and the licensee

added them to their scheduled work. Housekeeping

and equipment labeling were

generally good.

The inspectors identified two valves without the standard

component identification label; upon informing the system engineer, actions were

taken to obtain the proper labels.

The inspectors compared the design of the SLS system to the description provided

in the UFSAR and identified no discrepancies.

The UFSAR states that the usable

volume of the SLS system boron solution storage tank is 5.1 inches above the

centerline of the tank outlet piping, rather than from the bottom of the tank.

The

inspectors verified that appropriate tank levels and volumes were considered

in

applicable chemistry procedures

and instrumentation calibration instructions.

The inspectors reviewed completed surveillance tests associated with the SLS

system.

The inspectors determined that the tests adequately included surveillance

and testing requirements described

in the TSs and UFSAR. The inspectors observed

SLS system surveillance test N2-OSP-SLS-0001, "Standby Liquid Control Pump,

Check Valve, Relief Valve Operability Test and 40 Month Functional Test,"

Revision 6, for Division II, performed September 2, 1997.

The surveillance test was

satisfactorily completed.

Based on the response to inspectors'uestions,

the

knowledge level of the operators and technicians performing the test appeared to be

good.

However, the inspectors noted two deficiencies during the performance of

the surveillance test:

~

The first was that the operators occasionally stepped on small diameter

piping, although no damage was done in this instance.

~

The second was that the operators used a pipe wrench to manipulate the

SLS pump flow test throttle valve (2SLS" HCV116). The condition of the

handwheel indicated that this had occurred in the past.

The inspectors discussed these concerns with the NMP2 Operations Manager.

He

agreed there was a potential for equipment damage,

and provided direction (via the

"Night Notes" ) to the operating crews, emphasizing the importance of (1) not

walking on small diameter piping, and!2) contacting the SSS if difficultyis

experienced during valve manipulations.

In addition, the system engineer issued a

problem identification (PID) report to investigate the difficultoperation of the valve.

The inspectors reviewed the current "System Health Report" for SLS, and discussed

system performance with the system engineer.

There was no indication of major

corrective maintenance for the system.

Additionally, the inspectors verified that the

SLS system was performing within the maintenance

rule-established

acceptance

criteria.

Conclusions

The system walkdowns and performance history reviews indicated that the material

condition of the SLS system was good, and that the system has demonstrated

a

high level of reliability. The knowledge level of the technicians and operators during

the performance of an observed surveillance test was good.

However, operators

stepping on small diameter piping and using a pipe wrench to assist in the manual

valve manipulation indicated poor work practices, in that their actions could

potentially damage plant equipment.

Plant Walkdowns

The inspectors conducted routine tours of both units during this inspection period.

Following the shutdown of NMP1, the inspectors toured the feedwater heater and

condenser bays and other areas normally inaccessible

during power operation.

Overall, the inspectors noted that equipment material condition and compartment

housekeeping

at both units were acceptable;

although, during the tours, some minor

discrepancies

were noted.

These discrepancies

were discussed with licensee

management

and corrected.

During a tour of the NMP2 reactor core isolation cooling (RCIC) room, the inspectors

noted a tygon tube directing oil leakage from a gear box to a metal catch

containment.

Although this was being tracked through the licensee's catch

containment program (catch containment 97-02-14), no PID or work order (WO) had

been generated to repair the leak.

Discussions with the onshift SSS indicated that

the operators emptied the containment as necessary

and accepted this as

permanent.

The inspectors discussed

the issue with the NMPC fire protection

supervisor and verified that the oil contained within the containment would not

cause the fire loading within the RCIC room to be exceeded.

The inspectors'iscussion

with the NMP2 General Supervisor of Operations (GSO)

and review of Procedure GAP-OPS-04, "Catch Containments," Revision 2, indicated

that permanently installed catch containments needed to be evaluated

as

modifications. Through the GSO, the inspectors ascertained that catch containment

97-02-14 was not evaluated as a modification. As a result of the inspectors

questions,

a plant change request was initiated by the system engineer.

The failure

to evaluate the catch containment as a modification is a violation of the TS 6.8.1,

regarding procedure adherence.

This failure constitutes

a violation of minor

significance and is being treated as a Non-Cited Violation (NCV), consistent with

Section IV of the NRC Enforcement Policy. (NCV 50-410/97-07-0'l)

08

Miscellaneous Operations Issues (90712,92700)

08,1

Closed

IFI 50-220 96-07-18 & 50-410 96-07-18: Material Condition

Discre ancies Identified in Several Areas

During the NRC Integrated Performance Assessment

Process

(IPAP) team

inspection, several material condition discrepancies

associated with the NMP1

shutdown cooling pumps, the NMP2 chilled water pumps, and the NMP2 emergency

diesel generators were noted.

The inspectors routinely tour all accessible

areas of

both units.

During this inspection period, the inspectors specifically examined the

above equipment, and identified no major discrepancies.

Minor problems and

general housekeeping

concerns were discussed with the onshift SSS and corrected.

This item is closed.

II. MAINTENANCEa

Conduct of Maintenance (61726, 62707)

General Comments

Using NRC Inspection Procedures 61726 and 62707, the resident inspectors

periodically observed plant maintenance activities and the performance of various

surveillance tests.

As part of the observations, the inspectors evaluate the activities

Surveillance activities are included under "Maintenance."

For examplo, a section involving surveillance observations

might

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

with respect to the requirements of the Maintenance

Rule, as detailed in Title 10 of

the Code of Federal Regulations, Part 50.65 (10CFR50.65).

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:

~

N2-ISP-HCS-R1 10

~

N2-CSP-SLS-M110

~

N2-CSP-SLS4112

~

N2-OSP-SLS-CS001

~

N2-OSP-SLS-Q001

~

N2-OSP-SLS-0002

~

N2-OSP-SLS-R001

~

N2-OSP-SLS-R002

~

N2-OSP-LOG-D001

~

WO 96-01 105-02

WO 96-01 530-02

~

WO 97-04407-00

~

WO 97-04407-23

~

WO 97-04629-08

~

WO 95-01432-08

Operating Cycle Channel Calibration of the Recombiner

Reactor Temperature Instrumentation

Standby Liquid Control Monthly Surveillance

Adjustment of SLS [Standby Liquid Control] Tank

Sodium Pentaborate

Concentration

SLS Injection Header Check Valve Reverse Flow Test

Standby Liquid Control Pump, Check Valve, Relief

Valve Operability Test and 40 Month Functional Test

Standby Liquid Control Valve Operability Test

Standby Liquid Control Manual Initiation Actuation and

40 Month Functional Test

SLS Heat Traced Piping and Storage Tank Heater

Operability Test

Daily Checks Logs

Pre-calibrate new [SLS system] relief valve to be

installed in RF-05

Pre-calibrate new [SLS system] relief valve to be

installed in RF-05

Tube Leak in Emergency Condenser

[EC] ¹122, Cut

Inlet/Outlet Piping and Eddy Current Testing

Remove and Evaluate Flow Indications in the Supply

Side of the Tubesheet for HTX-60-42

Tube Leak in ¹111 EC, Cut Inlet/Outlet Piping and

Hemihead

Tube Leak in ¹112 EC, Cut Inlet/Outlet Piping and

Hemihead

M1,2

Re airs to NMP1 Emer enc

Coolin

Condensers

a.

Ins ection Sco

e

The inspectors monitored maintenance

activities to repair the four NMP1 EC

condensers.

The inspectors reviewed WOs and associated

documentation,

monitored personnel to verify adherence to foreign material exclusion (FME)

controls, and discussed the work with maintenance

and radiation protection (RP)

personnel,

and quality assurance

(QA) observers.

0

b.

Observations

and Findin s

The inspectors observed NMP1 maintenance activities related to inspection and

repair of the EC condensers.

The inspectors noted that maintenance

and RP

personnel adhered to posted FME requirements; i.e., personnel were appropriately

logging material into and out-of the FME area, using the Material Accountability Log.

Additionally, the FME for cutting evolutions was controlled, in that weld cuts were

enclosed (i.e., taped over) when work was secured.

The inspectors noted that maintenance

personnel were adhering to the WO

requirements and all associated

procedures

and documentation were readily

available and current.

Hot-work permits were posted at the work site and were

updated daily. Radiological controls within the work area were generally

satisfactory; however, the inspectors noted some air lines running across the

contamination area boundary that were not properly secured

(taped down).

NMPC

RP personnel were informed and the lines were subsequently secured.

The inspectors discussed

ongoing activities with members of the QA staff.

The

inspectors determined that QA coverage of the EC condenser work was appropriate.

QA personnel were monitoring work activities during dayshift and backshift hours.

During observations,

both the NRC inspectors and QA staff noted a poor work

practice during a pipe cutting evolution. Specifically, maintenance

personnel were

observed removing metal debris and burrs using a rubber-gloved hand while the

cutting machine was in operation.

The inspectors considered this practice both a

safety concern, in that the rubber glove could potentially become entangled

in the

cutting machine and result in personnel injury, and a radiological concern, in that

using a rubber glove to remove metal shavings could potentially result in glove tears

and personnel contamination.

The work supervisor was informed of the concern

and maintenance

personnel were immediately instructed on alternate methods for

removing the material.

C.

Conclusions

During EC condenser repair activities, FME controls were appropriately maintained,

in that material accountability was maintained and system cleanliness was

controlled.

Maintenance personnel adhered to WO requirements

and all associated

procedures

and documentation were readily available and of the current revision.

During a pipe cutting evolution, a poor safety and radiological work practice was

identified, in that maintenance

personnel were using a rubber-gloved hand to

remove metal shavings.

Radiological controls were satisfactory.

QA oversight of

ongoing maintenance

activities was appropriate.

10

M1.3

NMP2 Maintenance Activities on Offsite Power Su

I

On September 30, 1997, NMP2 de-energized

Line 6 and reserve transformer "B" for

planned maintenance.

Line 6 is one of the two TS required 115 kV (kiloVolt)offsite

power supplies from the Scriba switchyard.

10 CFR 50.65 ("The Maintenance

Rule" ) requires an assessment

be made of all plant equipment that is out of service.

This assessment

is to determine the overall effect on the performance of safety

functions, and is to include equipment removed from service for preventive

maintenance activities.

To fulfillthis requirement, NMPC completed

a probabilistic

risk assessment

(PRA) of the planned maintenance activities and concluded that the

overall change in risk was small, and that the expected duration of the outage was

short enough such that the proposed activity did not represent

a significant risk

increase.

The inspectors reviewed the PRA and determined that it accurately

accounted for all equipment out of service at the time of the maintenance,

and

provided a thorough evaluation justifying the conclusion.

The work, including

approximately 48 previously deferred preventive maintenance items, was completed

on October 1, without incident.

Quality Assurance ln Maintenance Activities (61726)

M7.1

Missed Surveillance Test of the NMP1 Control Room Ventilation Radiation Monitor

a.

Ins ection Sco

e

The inspectors reviewed the failure of NMP1 to perform a TS-required surveillance

test within required periodicity, and discussed the event with the NMP1 RP

Manager.

b.

Observations

and Findin s

On August 18, a NMP1 RP calibration technician was preparing to perform a

quarterly instrument channel test for channel ¹11 of the control room (CR)

ventilation radiation monitor. While preparing for the work, the technician identified

that the instrument channel calibration for channel ¹11 had not been performed

within the required periodicity. Specifically, NMP1 TS, Table 4.2.6.I, requires the

instrument channel calibration to be performed once each operating cycle, not to

exceed 24 months.

Channel ¹11 CR ventilation radiation monitor was last

calibrated on August 3, 1995.

Channel ¹11 was declared inoperable on August 18, calibrated and returned to an

operable condition on August 20. The licensee identified the apparent root cause as

inattention-to-detail and failure to self-check the completed preventive maintenance/

surveillance test (PM/ST) data-sheet following completion of the channel ¹12

calibration on April 24, 1996. The PM/ST sheet used during this calibration was

erroneously updated as channel ¹11 by an RP technician and was subsequently

reviewed by supervision.

This information was entered in the PM/ST database,

which reset the 24-month instrument channel calibration clock for channel ¹11; the

actual due date of August 3, 1997, was canceled.

11

The NMP1 RP Manager informed the inspectors that a review of the RP Calibration

History Records and control room logs indicated that the channel ¹12 CR ventilation

radiation monitor instrument channel calibration had been satisfactorily completed

on April 24, 1996, and an instrument channel test and calibration were completed

in July 1997.

Thus, channel ¹12 was always operable and the TS-required

minimum number of channels had always been available.

The inspectors considered the licensee root cause determination to be reasonable.

The failure to complete the TS-required surv'eillance test for channel ¹11 CR

ventilation radiation monitor is a violation of NMP1 TS, Section 4.6.2.a, requiring

sensors

and instrument channels to be checked, tested and calibrated at least as

frequently as listed in Tables 4.6.2.a to 4.6.2.I.

(VIO 50-220/97-07-02) This

violation is not being considered

as non-cited because

missed surveillances have

been a repetitive problem.

C.

Conclusions

Inattention-to-detail and failure to self-check a completed PM/ST data sheet by

NMP1 RP calibration staff resulted in the failure to perform a ventilation radiation

monitor instrument channel calibration within the TS-required periodicity.

M8

Miscellaneous Maintenance Issues (90712, 92700, 92902)

M8.1

Closed

URI 50-220 96-07-04: Procedure

Chan

e Evaluation Used to Chan

e

Intent of a NMP1 Procedure

a.

Ins ection Sco

e

During the NRC IPAP team inspection, it was noted that temporary changes were

made to a surveillance test procedure which appeared to change the intent of the

procedure.

The inspectors reviewed the affected procedure, the procedure change

evaluation, and the associated

DER.

b.

Observations

and Findin s

During the NRC IPAP team inspection, it was noted than temporary changes were

made to an NMP1 surveillance test procedure (N1-ST-Q18, "Core Spray Loop 12

Pump and Valve Operability Test," Revision 4) that appeared to change the intent of

the procedure.

Changing procedure intent as a temporary change is not consistent

with the requirements of the NMP1 TS, Section 6.8.3.

At Nine Mile Point, temporary changes to procedures

are processed

in accordance

with Procedure

NIP-PRO-04, "Procedure Change Evaluations" (PCEs).

As

documented

in the DER (1-96-0822) disposition, NMPC determined that the PCE did

not change the intent of the procedure; although they did identify several

weaknesses

in the administrative processing of the PCEs.

The inspectors reviewed

12

the DER, the PCEs, and the respective safety evaluations,

and determined that the

NMPC conclusion was reasonable.

There was no violation of the TS.

c.

Conclusion

NMPC's implementation of a temporary change to a NMP1 surveillance test

procedure was acceptable,

although weaknesses

were identified by NMPC in the

administrative processing of the PCE.

M8.2

Closed

LER 50-410 97-06: Plant Shutdown Due to Risin

Unidentified Leaka

e

The event described

in this Licensee Event Report (LER) was discussed

in NRC IR

50-410/97-06,Section

02.1.

The description and analysis of the event, as

contained in the LER, were consistent with the inspectors'nderstanding

of the

event.

This LER is closed.

M8.3

Closed

LER 50-410 97-07: Failure to Calibrate H dro en Recombiner Instruments

as Re uired b

Technical S ecifications Due to Procedure Omission

a.

Ins ection Sco

e

NMP2 identified that several instruments in the hydrogen recombiner system (HCS)

had not been calibrated as required by TSs.

NMPC identified this as part of their

review in response to Generic Letter (GL) 96-01. The inspectors reviewed the event

notification, the LER, and the revised surveillance test procedures.

b.

Observations

and Findin s

On August 13, 1997, NMP2 instrumentation and control (IRC) technicians identified

that eight instruments in the HCS were not calibrated during the performance of

surveillance test procedure N2-ISP-HCS-R110, "Operating Cycle Channel Calibration

of the Recombiner Reactor Temperature Instrumentation," Revision 2.

NMP2 TS

surveillance requirement (SR) 4.6.6.1.b.1 requires a channel calibration at least

every 18 months.

The IRC technicians identified this while reviewing the

procedure,

in accordance with the NMPC response to GL 96-01, "Testing of Safety-

Related Logic Circuits." The missed calibrations were documented

on DER 2-97-

2395.

Since both trains of HCS were affected, the limiting condition for operation (LCO) in

TS Section 3.0.3 was applicable.

TS LCO 3.0.3 would require the reactor be

shutdown within twelve hours; however, TSSR4.0.3 allows up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for

completion of the surveillance.

NMPC processed

a procedure change to incorporate

the calibration of the missed instruments into N2-ISP-HCS-R110; after which,

Division I HCS was satisfactorily calibrated, and returned to service.

Shortly

thereafter, Division II was tested and declared operable.

In the LER, the root cause was identified as inadequate communication during initial

procedure development.

Also, a contributing cause was noted as poor work

13

practice during subsequent

revision of the procedure.

As one of the corrective

actions, NMPC stated that NMP2 willcontinue to review the logic circuits to ensure

that surveillance test procedures

are consistent with TS requirements.

In addition,

administrative procedures related to procedure reviews were revised to add

assurance

that procedures were technically adequate.

Notwithstanding, NMP2

violated TSSR 4.6.6.1.b.1, which requires a channel calibration of all HCS

instrumentation at least once every 18 months.

(VIO 5041 0/97-07-03) This

violation is not being considered

as non-cited because

missed surveillances have

been

a repetitive problem.

The inspectors reviewed the LER and found it to be timely and to accurately

describe the event.

The immediate corrective actions and actions to prevent

recurrence were appropriate.

This LER is closed.

c.

Conclusion

The inspectors considered the discovery by the NMP2 ISC technicians of the

missing calibrations in the HCS to be good.

However, NMPC continues to have

instances of missed TS surveillances,

as noted in this and previous inspection

reports.

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, including justifications for operability

determinations,

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.

E8

Miscellaneous Engineering Issues (90712, 92700, 93903)

E8.1

Closed

EA 96-079 VIO 1013:

Desi n Control Measures

Inade

uate durin

Calculations for Establishin

Reactor Buildin

and Turbine Buildin

Relief Pressure

The inspectors verified implementation of the corrective actions specified in the

licensee's response,

dated July 16, 1996, to the notice of violation. The actions

taken by NMPC to preclude a recurrence of design control inadequacies

included:

An independent review of a sample of 29 NMP1 structural engineering

calculations (that were originally performed by the engineer who incorrectly

calculated the initial blowout panel relief pressure) was completed in April

14

1996.

The independent reviewer, a NMP2 structural engineering supervisor,

found no similar technical errors.

The NMP1 engineering branch manager and structural engineering supervisor

emphasized to the structural group the importance of understanding the

function and behavior of a structural element before performing a calculation,

understanding the differences in the mathematical assumptions when

designing a component to fail rather than to provide structural support, and

in providing a clear and self-explanatory conclusion in the end of calculations

that does not require further interpretation of results.

~

A lessons learned transmittal was disseminated to other organizations to

communicate the facts and root cause surrounding the calculational error.

~

The engineers

and designers

in the structural group were retrained on

Procedure

NEP-DES-OB, "Calculations," to properly understand the role of a

preparer, checker, and approver related to a calculation.

~

The engineering branch revised the guideline used to perform a DER

Operability Supporting Analysis (NEG-1E-006) to emphasize the role of a

supervisor in checking the DER disposition with the results of the calculation,

particularly those associated with operability determinations and the potential

for reportability.

The inspectors reviewed the relevant documentation supporting completion of these

corrective actions and concluded that the actions taken were those as described in

the licensee's July 16, 1996 response.

This item is closed.

E8.2

Closed

URI 50-220 96-05-01: NRC Staff Review of Revised Reactor Buildin

and

Turbine Buildin

Blowout Panel Relief Pressure

Calculations

LER 50-220/95-05identified the existence of an initial construction deficiency and a

subsequent

1993 design calculation error associated with the reactor building (RB)

and turbine building (TB) blowout panels.

An enforcement conference was held

regarding this matter on April 12, 1996; a Notice of Violation (Severity Level III) and

Civil Penalty were issued on June 18, 1996.

In response to the event, NMPC

reanalyzed the upper bound pressure relief capacities of the RB and TB blowout

panels and the lower bound structural failure capacities of the buildings to

demonstrate that the panels would fail due to internal pressure prior to failure of the

buildings. This would achieve the intended pressure relief function, as stipulated in

the NMP1 UFSAR.

In reviewing the NMPC response,

the inspectors requested

assistance

from the NRC Office of Nuclear Reactor Regulation (NRR) to determine

the technical adequacy of the revised design calculations for the RB and TB blowout

panels.

On August 20, 1996, staff from the NRR Division of Engineering conducted

an audit

of the revised design calculations and performed a walkdown of the RB and TB

blowout panels.

This led to identification of additional items requiring licensee

V

response

and resolution.

In reviewing the NMPC calculations to support the re-

analysis, the NRC staff identified several errors.

Deficiencies included that the

structural dead load was not independently treated in computing the structural

failure capacity, and a high strain rate factor was inappropriately used in

determining RB and TB pressure capacity.

However, the staff judged the safety

consequence

of the errors to be low, since the correction of the errors would not

have appreciably affected the computed structural capacities or changed the

conclusion.

Subsequently

on November 15, 1996, NMPC submitted revised calculations.

The

NRR staff reviewed the licensee's submittal, and concluded that the panels would

perform their intended pressure relief safety function in a manner consistent with

the applicable licensing basis, as stated in the NMP1 UFSAR. The revised

calculations determined that the blowout panel upper bound pressure for the RB

was 65 pounds per square foot (psf), and for the TB was 62 psf. The recalculated

ultimate lower bound superstructure

capacities were 117 psf and 135 psf for the RB

and TB, respectively.

This showed that there was ample safety margin for pressure

relief of the buildings.

In addition, a concern was expressed

by the NRC staff during the enforcement

conference regarding the safety of the condensate

storage tanks housed in the TB,

in the event that a falling RB blowout panel impacted the TB roof. NMPC provided

calculations to demonstrate the structural integrity of the TB roof and to assure the

safety of the condensate

storage tanks.

The calculations provided for NRC review

were initiallyfound to be technically deficient with respect to the proper

assumptions for calculating the kinetic energy of a faIling panel.

NMPC submitted

revised calculations, which the staff found acceptable.

The results showed that the

safety of the condensate

storage tanks was not compromised, since the roof was

capable of absorbing the energy of a falling panel without rupturing or experiencing

large deformation.

Therefore, the safety consequence

of the errors was low.

The errors identified by the NRC indicated that the licensee's design control

measures,

in place prior to the NRC audit of August 20, 1996, were not fully

effective in assuring the accuracy of the revised calculations regarding this matter.

However, based on the low safety significance of the errors identified, and NMPC's

correction of the errors, this constitutes

a violation of minor significance, and is

being treated as a Non-Cited Violation, consistent with Section IV of the

enforcement policy.

(NCV 50-220/97-07-04)

Closed

IFI 50-220 96-05-02: Inconsistencies

in the NMP1 UFSAR and IPE with

res ect to the Reactor Buildin

and Turbine Buildin

Blowout Panel Relief Pressure

~Set oints

NMPC identified discrepancies

between the'various sections of the UFSAR regarding

the stated value of the pressure relief capacity of the RB and TB blowout panels.

In

reviewing the associated

event, the NRC identified similar inconsistencies within the

Individual Plant Examination (IPE) with respect to blowout panel relief pressure.

16

A Licensing Document Change Request (LDCR 1-96-UFS-035), with the supporting

10 CFR 50.59 Safety Evaluation (No.96-021), was approved by NMPC to revise

the RB and TB blowout panel relief pressure setpoints,

as described in the UFSAR.

The relevant tables and sections of the UFSAR have been revised to change the

failure load of the RB and TB blowout panels to 65 psf and 62 psf, respectively.

Also, the relevant UFSAR sections were revised to change the failure loads of the

RB and TB superstructures

to 117 psf and 135 psf, respectively.

In support of the UFSAR changes,

NMPC performed an evaluation to determine if an

unreviewed-safety-question

existed for the corrected parameters.

An evaluation of

the equipment qualification (EQ) analysis, using the revised relief pressures,

was

also

performed to determine if there was an increase

in the probability of equipment

malfunction.

It was concluded by the NMPC staff that equipment in the RB and TB

would remain qualified following the maximum temperature,

pressure,

and humidity

resulting from a high energy line break.

Through NMPC's Fuels and Analysis Group, the inconsistencies

in the RB and TB

blowout panel relief pressures

were evaluated to determine if the IPE results were

affected by the revised values.

Using a Modular Accident Analysis Program, the

blowout panel relief setpoint was varied from 0.01 psf (assumed to open early) to

infinite psf (assumed

never to open).

The results indicated that the IPE results were

not significantly changed due to other existing leakpaths and the postulated failure

of building ventilation systems.

The inspectors concluded that the licensee has taken the appropriate actions to

remove inconsistencies

regarding RB and TB blowout panel relief pressures

as

stated in the UFSAR and IPE. An evaluation using the revised parameters for EQ

analyses

has shown the results to be consistent.

The inspector had no further

questions.

E8.4

Closed

LER 50-220 97-07: Potential Control Room Emer enc

Ventilation S stem

0 eration Outside the Desi

n Basis due to Inade

uate Evaluation

ae

Ins ection Sco

e

The inspectors reviewed the DER and LER associated with the NMP1 control room

smoke purge system impact on the operability of the control room emergency

ventilation system.

The inspectors discussed the issue with a NMP1 SSS and the

NMP1 Plant Manager.

b.

Observations

and Findin s

On August 6, 1997, a NMP1 operator questioned the ability of the control room

emergency ventilation system (CREVS) to fulfillits accident mitigation function with

the control room smoke purge system (CRSPS) in operation.

Specifically, if a high

radiation signal resulted in an automatic initiation of the CREVS, and the CRSPS was

already in operation, the design function the CREVS to maintain control room air

quality would have been inhibited.

Outside air would continue to enter the control

17

room until the CRSPS was manually secured, since the CRSPS did not have an

automatic isolation feature.

The inspectors considered the questioning attitude of

the operator to be very good.

The licensee subsequently

issued

DER 1-97-2326 to

address the concern.

On August 15, following an engineering evaluation, the

licensee reported this issue to the NRC, in accordance with 10 CFR 50.72.

The CRSPS was designed to clear the smoke and maintain a habitable atmosphere

in the control room and auxiliary control room (i.e., relay room) in case of a fire.

However, the licensee also used the system during periods when the normal control

room ventilation was secured for maintenance.

The LER stated additionally that the

CRSPS had been operated at times other than its intended design and concurrently

when CREVS operability was required.

The inspectors reviewed the LER and found that it accurately described the event.

Licensee immediate corrective actions included placing administrative controls on

the CRSPS control switch to prevent operation without first considering the

potential impact on operability of the CREVS.

Long-term corrective actions were to

revise operating and test procedures for the CRSPS to ensure the system is

operated only for smoke removal, and to ensure that the system is tested only when

the CREVS is not required to be operable.

Additionally, the licensee planned to

review selected modifications performed in the 1980s for similar system interface

deficiencies.

The inspectors considered both the immediate and long-term

corrective actions to be appropriate.

The licensee root cause evaluation attributed the deficiency to an inadequate

evaluation of the CRSPS interface with the CREVS during modifications in.1980 and

in 1984. This is a violation of 10 CFR 50 Appendix B, "Quality Assurance Criteria

for Nuclear Power Plants and Fuel Reprocessing

Plants," Criterion III, "Design

Control." This licensee-identified and corrected violation is being treated as a Non-

Cited Violation, consistent with Section VII.B.3 of the NRC Enforcement Policy.

(NCV 50-220/97-07-05)

c.

Conclusions

An NMP1 operator's questioning attitude of the control room smoke purge system

was very good and resulted in an engineering operability evaluation of the impact on

CREVS operability. Notwithstanding, the interface between the smoke purge

system and CREVS was inadequately evaluated during modifications in the early

1980s.

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

I

18

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, 83750, 86750,

TI 2515/133)

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 that they 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

Radiolo ical Protection Pro ram

a.

Ins ection Sco

e

The inspectors reviewed the ALARA(as-low-as-is-reasonably-achievable)

post-

outage job reviews, personnel contamination reports, selected exposure evaluation

reports (EERs), and a vendor audit, under the National Voluntary Laboratory

Accreditation Program (NVLAP). In addition, the inspectors conducted tours

(including NMP2 lower reactor building rounds with a plant operator); and

interviewed station staff.

b.

Observations

and Findin s

Work scope additions to the extended

NMP1 fourteenth refueling outage (RFO14)

were responsible for the RFO14 ALARAgoal being exceeded.

The ALARAgoal was

set at 276 person-rem, actual exposure accrued was about 299 person-rem.

Major

work scope additions included inspection of five recirculation system welds, repair

of four valves after local-leak-rate-testing

failures, rolling four stub tubes under-

vessel, and additional core shroud inspections and tie-rod repairs.

This additional

work accounted for 36.2 person-rem,

and minor tasks contributed an additional

13.5 person-rem.

The licensee had budgeted

15 person-rem for emergent work.

Another important contributor to exceeding the original goal was that the work

scope increase extended the outage from a planned 35 days to 67 days.

Exposure

for the NMP2 RFO5 was less than the ALARAgoal.

The ALARAgoal was set at

215 person-rem, actual exposure was 182 person-rem.

The inspectors noted that

lessons learned in conducting work at both units had been captured for future

consideration.

No contamination events of regulatory concern were noted.

The

inspector assessed

that postings and labels were established

in accordance with the

licensee's program.

Thermoluminescent dosimeter (TLD) services were vendor-supplied; the vendor was

NVLAP approved, as required.

The inspectors reviewed the most recent NVLAP

assessment

of the vendor laboratory and discussed

the vendor's actions pertaining

to deficiencies and comments.

The Dosimetry Supervisor continued to oversee the

adequacy of the program.

No inadequacies

were noted in any of the EERs

reviewed.

As noted during tours, individuals were wearing the required dosimeters.

The inspectors noted that no contaminated

area entries were required of the NMP2

operator during the conduct of rounds in the lower reactor building. Also, the plant

operator had to make few high radiation area (HRA) entries, as the licensee had

installed cameras

in many HRAs, allowing the operators to take readings while

remaining outside the cubicles.

Very good radiological housekeeping

was noted in

NMP2.

Conclusions

The radiological protection program area was being well-implemented.

The NMP1

outage ALARAgoal was exceeded

due to emergent work. Very good radiological

housekeeping

was noted in NMP2. Effective programs were implemented for

contamination control and external dosimetry.

Trans ortation and Radiolo ical Waste Pro rams

Ins ection Sco

e

The inspectors reviewed the licensee's programs for the processing of liquid and

solid radiological waste (radwaste) and the transportation of radioactive materials,

including: the Process Control Program (PCP), shipping records, scaling factor data

(for compliance with 10 CFR 61.55), and system walkdowns in radwaste.

Observations

and Findin s

NMP1

The NMP1 radwaste processing program was described

in the NMP1 radwaste

Process Control Program, Revision 2, dated November 15, 1994.

The inspectors

noted that the NMP1 PCP lacked any specifics on the way the unit processed

wastes, and that it contained erroneous references to federal regulations,

specifically outdated versions of 10 CFR 20 (significantly revised in 1994) and 49

CFR (revised in 1996).

Failure to incorporate into the PCP the changes

in 10 CFR 20 and 49 CFR indicate that the PCP was not periodically reviewed and revised.

Failure to maintain the PCP is an apparent violation of NMP1 TS 6.8, which requires

that procedures specified in Regulatory Guide 1.33 be written, maintained and

adhered to for plant operations.

Regulatory Guide 1.33 includes procedures for the

processing of liquid and solid radwaste, for which the PCP is the core document.

(EEI 50-220/97-07-06)

20

The inspectors reviewed the shipping records for five shipments of radwaste and

radioactive material

~

In general, the documentation for shipping radioactive material

and radwaste was clear and complete and in accordance with 10 CFR and 49 CFR.

However, one of the shipments reviewed was noted not to be in compliance with

regulations.

On July 24, 1997, the licensee shipped two metal samples from the

core shroud to BWX Technologies,

Inc. Upon receipt, it was noted by BWX that

radiation levels in an occupied portion of the vehicle were 2.8 milliRem per hour

(mRem/hr), in excess of the regulatory limit of 2 mRem/hr, as specified in 49 CFR

173.441; this is an apparent violation.

(EEI 50-220/97-07-07)

The inspectors toured portions of the radwaste systems located in various buildings,

All facilities were found to be generally neat and orderly, and the conditions in these

facilities had noticeably improved during the past three years.

The inspectors noted,

however, that the ¹11 concentrated

waste tank still had concentrates

in it, even

though the ¹11 waste evaporator was taken out of service over 17 years ago.

The

NMP1 UFSAR for the tanks and vessels

in the radwaste system assumes that the

tanks regularly receive and discharge waste materials.

No analysis was performed

for wastes being indefinitely stored in one of the tanks.

The inspectors discussed

with the licensee the fact that the conditions in ¹11 concentrates

tank are not

described or analyzed in the UFSAR. The licensee agreed to conduct a detailed

evaluation and provide to the NRC the results of their review, including a plan of

action for ensuring the safe use of concentrates tank ¹11 or the removal of the tank

contents..

(IFI 50-220/97-07-08)

The inspectors also reviewed the NMP1 UFSAR, specifically Sections 11.2 (liquid

waste) and 11.3 (solid waste) and compared the systems and process descriptions

with current plant operations.

The inspectors determined that both sections were

significantly out-of-date and required revision.

The licensee provided documentation

that indicated that such a revision was currently underway for the UFSAR in

general, and that Sections 11.2 and 11.3 were included in this revision,

NMP2

The inspectors reviewed the licensee's

program for radwaste processing,

as

described

in the NMP2 radwaste Process Control Program, Revision 2, dated

November 15, 1994.

The inspectors identified that within this document,

references to 49 CFR were out of date, following the revisions to 49 CFR in April

1996.

Failure to maintain the PCP, is an apparent violation of Technical Specification 6.13.

(EEI 50-410/97;07-06)

The inspectors reviewed shipping records for radwaste and radioactive material

transportation.

All records reviewed were in compliance with regulations contained

in 10 CFR Parts 20, 61 and 71, and 49 CFR Parts 170-177.

The records reviewed

were clear and concise, and included documentation related to shipping manifests,

shipment classification, waste classification (where applicable), and emergency

notifications.

21

The inspectors toured the NMP2 radwaste facilities, and found them to be well

maintained, appropriately posted, and with only small areas kept as contaminated.

The inspectors also reviewed the NMP2 UFSAR and determined that Section 11.2

(liquid radwaste) and 11.4 (solid radwaste) had only minor discrepancies

relative to

current plant operations.

The licensee provided documentation indicating that

revisions to the UFSAR which willaddress the discrepancies

have already been

drafted.

Common

The inspectors reviewed the licensee's program for determining hard-to-measure

radionuclides, in order to comply with 10 CFR 61.55.

The licensee periodically

submitted waste stream samples to a vendor laboratory for total isotopic analysis,

and derived waste stream specific scaling factors from the results.

The inspector

reviewed the licensee's program for ensuring the applicability of the scaling factors,

and determined that the licensee's procedures

in support of this program were

vague.

The licensee agreed with the inspectors'bservations

and indicated that a

review of these procedures would be conducted to determine what additional

guidance would be appropriate.

c.

Conclusions

A generally effective radwaste program'had been established

at each unit; but

procedures

and associated

documentation

(PCP and UFSAR) have not been properly

maintained.

(EEI)

In addition, one shipment of radioactive material resulted in the

occupied portion of the vehicle exceeding allowed limits.

(EEI) Plant conditions

were generally very good relative to radiological housekeeping

in radwaste.

However, the lay-up of waste concentrates tank ¹11 at NMP1 is questionable;

NMPC stated that a written plan of action for dealing with it would be provided to

the NRC.

(IFI)

R1.4

Shi ment of Radioactive Material to an Unlicensed Facilit

a.

Ins ection Sco

e

The inspectors discussed the circumstances

surrounding a radioactive material

shipment to an unlicensed facility with the NMP1 radwaste supervisor and NMP2 RP

Manager.

b.

Observations

and Findin s

On September 25, 1997, a metal sample removed from a NMP1 EC condenser tube

sheet was shipped to BWX Technologies, Inc., in Lynchburg, Virginia, for laboratory

analysis.

This sample was prepared for shipment as a "limited quantity" in

accordance with 49 CFR 173.421.

A limited quantity is defined as the maximum

amount of a hazardous material for which there is a specific labeling or packaging

exception.

0

22

The radwaste supervisor informed the inspectors that the manifest had been

properly prepared and was properly addressed.

The package was sent to the

licensee's warehouse for shipment by common carrier.

Warehouse staff placed the

shipping label used by the common carrier (with the incorrect address)

over the

correct shipping address originally placed on the package.

The incorrect address

resulted in the package being delivered to the BWX Contracts Officer in an

administration office complex, in lieu of the laboratory facility. The shipment arrived

at the office complex on the morning of September 26. The Contracts Officer

realized the shipping error, did not open the package,

and notified NMPC of the

error.

The package was shipped to the laboratory facility on September 29 and

arrived on September 30. The BWX office complex was not specified on the

Material License Certificate for receipt of radioactive shipments.

During the inspection, the inspectors ascertained that on May 24, 1995, a similar

radioactive shipment error occurred.

Specifically, a source range detector was

shipped to the wrong General Electric (GE) location.

The shipment went to GE-San

Jose, California, rather than GE-Twinsburg, Ohio.

GE-San Jose did not have a

license to receive radioactive material.

GE informed NMPC, and the shipment was

redirected to the GE-Twinsburg facility in Ohio. As in the September 1997 event,

the manifests had been properly prepared, but warehouse

personnel sent the

package to the wrong address.

The inspectors discussed

both events with the NMP1 RP Manager.

The RP Manager

indicated that Nuclear Procurement Administrative Procedure NPAP-INV-210,

"Receipt, Test, Inspection and Processing of Materials, Parts and Services,"

Revision 8, defined the requirements for material shipments offsite.

In response to

the 1995 event, NPAP-INV-210 was changed to incorporate an independent

verification of the required documentation to assure the item was ready for

shipment.

The inspectors considered the corrective actions for the 1995 event to

be ineffective in preventing recurrence.

10 CFR 30.41 requires a licensee transferring radioactive material to verify that the

transferee's

license authorizes the receipt of the type, form, and quantity of

byproduct material to be transferred.

Contrary to the above, on two occasions,

NMPC shipped radioactive material to an unlicensed facility. This is an apparent

violation of NRC regulations.

(EEI 50-220/97-07-09)

c.

Conclusions

On two occasions,

personnel inattention-to-detail and inadequate verification

resulted in the transfer of radioactive material to a location not authorized to receive

such material.

Furthermore, the corrective actions for the first event were

ineffective in preventing recurrence.

(EEI)

23

R2

Status of RP&C Facilities and Equipment (83750)

R2.1

Radiolo ical Protection Facilities and Contamination Controls Instrumentation

a.

Ins ection Sco

e

The inspectors reviewed licensee changes to RCA access controls and the manner

in which contamination controls instrumentation had been calibrated.

b.

Observations

The inspectors noted that the licensee had assessed

the impact of the recent

10 CFR 61 scaling factors on the instrumentation program.

Radioisotopes chosen

for frisker (Eberline RM-14) source checks and calibrations were appropriate, based

on the licensee's

10 CFR 61 assessment.

The inspectors considered the licensee's

efforts in upgrading their small article monitors (SAM) to the equivalent of SAM

Model-9 to be a good initiative. The inspectors reviewed the SAM alarm set points

at NMP2 and found them appropriate.

Since the last inspection of this area, the licensee improved the RCA access point

by installing turnstiles.

This should help to ensure that workers have the correct

dosimetry to comply with the appropriate radiation work permit.

Bar codes have

been relocated from security badges to TLDs and the RCA turnstiles are unlocked by

inserting an operating electronic dosimeter into the turnstile resulting in computer

logging of an RCA entry.

This area was being well-implemented.

Installation of additional access control

devices has improved this program area.

R3

PR&C Procedures

and Documentation (71750)

, R3.1

Shi ment of Wron

Radwaste Material

a.

Ins ection Sco

e

NMPC personnel loaded and shipped an incorrect liner of low-level radwaste to a

facilityfor disposal.

The inspectors interviewed the personnel involved and their

management,

and reviewed the associated

procedures

and documentation.

b.

Observations

and Findin s

On September 5, 1997, NMPC informed the resident inspectors that an incorrect

liner of low-level radwaste was shipped for disposal.

During the unloading of the

liner, the recipient, Molten Metal Technology, noted that radiation levels in the area

of the liner were higher than expected.

24

During their investigation, NMPC discovered that on September 3, an NMP1

radwaste operator inadvertently loaded the wrong liner, consisting of dewatered

resin and charcoal filter material from NMP2, into the shipping cask for transport to

Molten Metal Technology.

The liner that was supposed to have been shipped was

filled in 1995, the liner that was actually shipped was filled in 1997.

The NMP1

radwaste facility is used for interim storage of all radioactive material awaiting

shipment from NMP. The radwaste shipment schedule had the wrong location for

the liner. Although each liner has a unique identffication number, the radwaste

operator failed to check the number on the liner with the number on the shipment

schedule,

using only the storage location number.

Before the truck left the NMP1 radwaste facility, an NMP1 radiation protection (RP)

technician conducted

a radiation survey of the cask and sent the results to the

NMP2 RP technician who authorized the shipment and signed the associated

shipping manifest.

The NMP2 RP technician did not review the radiation survey; if

he had, he would have noted that the radiation levels on the surface of the liner

were almost four-times those expected.

Readings for the 1995 liner were expected

to be about 800 milliRem per hour (mRem/hr); the actual survey showed 3,000

mRem/hr on contact with the liner.

The inspectors discussed the event with the Radwaste Supervisors for both units,

and reviewed the associated

documentation.

The discussions with the supervisors

confirmed that there were missed opportunities for the identification that the wrong

liner had been loaded.

In addition, the inspectors determined that there were no

procedures directly related to the loading of liners or the shipment of radwaste

material.

Immediate corrective actions included a requirement for plant manager

approval of all radwaste shipments.

10 CFR 20, Appendix G, "Requirements for Transfers of Low-Level Radioactive

Waste Intended for Disposal at Licensed Land Disposal Facilities and Manifests,"

Section I.B, requires the shipper [NMPC] of radioactive waste to provide information

regarding the shipment on the manifest, including the total radionuclide activity in

the shipment.

10 CFR 71, "Packaging and Transportation of Radioactive IVlaterial,"

Paragraph 71.5, requires each licensee [NMPC] who delivers licensed material to a

carrier for transport to comply with the requirements of 49 CFR 172. 49 CFR 172,

Paragraph

172.203, requires for shipments of Class 7 (radioactive) material to

include the activity contained in each package of the shipment.

Contrary to the

above, the shipping manifest did not accurately reflect the actual radionuclide

activity of the shipment; this is an apparent violation of 10 CFR 20 and 49 CFR

172.

(EEI 50-220/97-07-10& 50-410/97-07-10)

Conclusion

NMPC personnel loaded and shipped the wrong liner of low-level radwaste to a

facility for disposal.

(EEI)

In less than two months, three different shipments from

the Nine Mile site were inadequately controlled (also see Sections R1.3 and R

1 4 of

this report).

AII three appear to be due to a combination of a lack of procedures

25

describing shipping activities, inattention-to-detail on the part of the radwaste

operators,

and a lack of supervisory oversight.

R5

Staff Training and Qualifications (86750, Tl 2515/133)

R5.1

Trainin

of Staff Involved in Radioactive Material Trans ortation and Radwaste

~Processin

a.

Ins ection Sco

e

The inspectors reviewed the licensee's program for the training of personnel

involved with radwaste processing and radioactive material transportation.

b.

Observations

and Findin s

The licensee has established two distinct training programs for plant workers

involved in transportation and radwaste processing.

One program was presented to

workers involved in waste certification and shipping, in accordance with NRC

Inspection and Enforcement (IE) Bulletin.79-19. The second program was for

workers involved in the receipt or shipment of radioactive materials, in accordance

with 49 CFR 172.700.

This second program used

a tiered approach to training,

involving lesson plans of increasing difficulty, with the highest level of training given

to the workers who certify shipments.

For 1996, the lic'ensee sent a number of plant personnel to a vendor training

program to meet its IE Bulletin commitment and to satisfy the requirements of

49 CFR. This training was reviewed in advance by the Nine Mile Point training

department.

Appropriate documentation was contained in the training records for

the inspectors to determine that the vendor training was the equivalent of the

licensee's program.

C.

Conclusions

The licensee has established

a good and well documented training program for

workers involved in radwaste processing

and the shipment of radioactive materials.

R7

Quality Assurance (QA) in RP&C Activities (83750, 86750, TI 2515/133)

R7.1

QA in Radiation Protection Activities

a.

Ins ection Sco

e

The inspection consisted of reviews of DERs; the RP "First Quarter 1997

Radiological Engineering Self Assessment

Report for NMP2," performed in

accordance with "NIP-ECA-05, "Radiation Protection Branch Self-Assessment,

Radiation Worker Practices;" and QA Audit Number 96017, "Radiation Protection

Program."

In addition, the inspectors interviewed the RP managers.

26

Observations

and Findin s

The inspectors noted that RP self-assessments

were a good initiative and a tool for

augmenting QA audits/surveillances.

The assessments

were conducted by RP

department staff and were used to assess

and provide immediate feedback to

station workers on their radiation worker practices.

The department self-

assessments

were objective and self-critical.

A low threshold for RP-related DERs was noted.

A proper level of attention was

. placed on DERs depending on their significance and complexity. Corrective actions

were both timely and reasonable for the DERs reviewed.

The use of subject-matter

expert in the conduct of QA Audit 96017 was considered to be a good initiative.

No items of regulatory significance were noted during the inspectors'eview of the

DERs or the QA audit.

Overall, a very high level of attention has been placed in

improving human performance in the RP area.

C.

Conclusions

Those aspects of the QA program reviewed were well-implemented.

Audits and

self-assessments

were of appropriate scope and technical depth.

R7.2

QA in Radiolo ical Trans ortation and Radwaste Activities

a 0

Ins ection Sco

e

The inspectors reviewed the licensee's program for the assurance

of quality in

waste processing

and transportation of radioactive materials.

The inspectors

evaluated this program through the review of licensee conducted audits and

surveillances.

b.

Observations

and Findin s

NMP1 TS 6.5.3.8 and NMP2 TS 6.5.3.8 require that an audit be conducted every

24 months of the respective unit Process Control Program (PCP).

The inspectors

reviewed the licensee's audit of the PCP (Audit 96002, dated December 19, 1996).

This audit failed to identify out-of-date references to federal regulations contained in

both the NMP1 and NIVIP2 PCPs.

Additionally, while the audit did identify out-of-

date references to training procedures

in the PCPs, the DER issued to identify this

finding was closed without the PCPs being revised to correct the defect.

The

inspectors noted that 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action,"

requires that measures

be established to assure that conditions adverse to quality

are promptly identified and corrected.

The inspectors noted that the failure to

identify conditions adverse to quality, and the failure to ensure that such conditions

are corrected, are apparent violations of 10 CFR, Appendix B, Criterion XVI. (EEI

50-220/97-07-1

1 8( 50-410/97-07-1 1)

The inspectors also reviewed the licensee's program of vendor audits.

The licensee

could only identify one audit of a vendor, Chem Nuclear Systems, qualified to

27

supply NRC-certified shipping casks or waste processing services.

The licensee

does use NRC-certified casks from another vendor, SEG, Inc.; and uses both SEG

and Molten Metal Technologies as waste processors.

No audits of these vendors

were conducted.

Regarding the use of vendor shipping casks, the inspectors noted

that 10 CFR 71.12 allows the NRC to issue a general license to deliver for transport

radioactive material in a package for which the NRC has issued

a certificate of

compliance.

The general license requires that the licensee have in-place a QA

program, approved by the NRC, that satisfies the provisions of 10 CFR 71, Subpart

H (Quality Assurance).

10 CFR 71, Subpart H, requires, in part, that a

comprehensive

system of planned and periodic audits be conducted to verify

compliance with all aspects of the QA program.

The licensee transported

radioactive material in a shipping container owned by SEG, Inc., for which the NRC

has issued a certificate of compliance; however, the licensee had not conducted

periodic audits of SEG to verify compliance with all aspects of the vendors NRC-

approved quality assurance

program.

The inspectors noted that the failure to

conduct audits of suppliers of NRC-certified shipping casks is an apparent violation

of 10 CFR 71.12. (EEI 50-220/97-07-12& 50-410/97-07-12)

Regarding the use of vendor provided radwaste processing systems, the inspectors

noted that NMP1 TS 6.8 requires that procedures

and administrative policies for

activities listed in Appendix "A" of NRC Regulatory Guide (RG) 1.33 be established,

implemented and maintained.

RG 1.33, Appendix "A" lists procedures for the

processing of radioactive waste.

The NMP1 Radwaste

PCP, paragraph 3.1.1,

requires, in part, that radioactive waste may be processed

using approved vendor

equipment and procedures provided that the vendors have a QA program that meets

NRC requirements.

The inspectors noted that the failure to verify the QA program

of radwaste processing vendors is an apparent violation of TS 6.8.

(EEI 50-220/97-07-13)

Conclusion

The QA program failed to identify fullythe defects within the unit specific PCPs,

and in one instance failed to ensure that corrective actions were taken to address

an

identified defect.

(EEI) Additionally, a number of required audits of vendors

providing transportation and/or waste services were not performed.

(EEI)

Conduct of Security and Safeguards Activities (92904, 93702)

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

'ccordance

with the Nine Mile Point Security Plan.

28

S1.2

Unusual Event - Discover

of a Sus

icious Packa

e

a.

Ins ection Sco

e

The discovery of a suspicious looking package inside of the protected area perimeter

resulted in the declaration of an Unusual Event at NMP2.

b.

Observations

and Findin s

On August 18, 1997, a NMP security guard noticed a suspicious looking package

next to the NMP2 maintenance

building. As a precaution, the NMP2 SSS ordered

the maintenance

and operations buildings evacuated.

Shortly thereafter, plant

security personnel examined the package and determined that it was an empty box,

that had apparently blown out of a nearby trash receptacle.

Concurrent with security personnel examining the package, the SSS reviewed the

NMP2 Emergency Plan and procedures.

The SSS declared an Unusual Event, based

on EPIP-EPP-02, Attachment 1, "Emergency Action Level Matrix / NMP2," Revision

6, Category 8.1.1: "Any security event which represents

a potential degradation

in

the level of safety of the plant." After security personnel determined that the

package was not a threat, the SSS terminated the event.

The inspectors considered the response of the security personnel to be acceptable.

The actions by the SSS for the emergency declaration, and termination, were

appropriate and timely. The required notifications to the NRC and state/local officials

were in accordance with the NMPC Emergency Plan.

c.

Conclusion

The response of the Nine Mile Point security personnel to a "suspicious looking"

package was acceptable.

The declaration, by the SSS, of an Unusual Event was

appropriate and in accordance with the NMP2 Emergency Plan.

F2

Status of Fire Protection Facilities and Equipment (71750,92904)

F2.1

Control Room Fire Su

ression S stem and 0 erator Res

onse

a.

Introduction

In response to a recent event at another nuclear power station, the inspectors

reviewed the current fire suppression

systems installed for both NMP1 and NMP2

control rooms.

This included a review of TSs, applicable procedures,

and

surveillance tests.

The inspectors discussed the issues with fire protection

supervisors from both units.

~Back round

On August 7, 1997, an inadvertent actuation of the halon fire suppression

system

occurred in the control room and adjacent central alarm station (CAS) at the

Haddam Neck Nuclear Power Station.

Personnel evacuated

both areas, the control

room was unmanned for about one hour; the licensee declared an Unusual Event.

Just prior to the actuation, personnel were taking photographs of the halon

actuation panel.

Preliminarily, the licensee determined that the inadvertent actuation

was due to the camera flash causing the fire detection system to actuate.

Observations

and Findin s

The inspectors discussed the general area fire suppression

systems for both control

rooms with the Nine Mile Point fire protection supervision.

Neither control room has

an automatic fire suppression

system; they must be manually actuated.

Fire

extinguishers have been staged at several locations within the control rooms, both

carbon dioxide and water types.

Also, several manual hose stations were located

outside each control room.

Both control rooms have general area ionization-type

smoke detectors

in the overhead and inside the control panels, the detectors are for

alarm only.

The NMP1 auxiliary control room (relay room located below the main control room)

also has alarm-only ionization detectors inside relay-and-control panels.

However,

the NMP1 auxiliary control room also has an automatic cross-zoned total-flooding

halon system actuated by ionization detectors located in the overhead.

Cross-zoned

systems require a signal from at least one detector in two different zones to

automatically actuate the system.

The NMP1 auxiliary control room is separated

from the main control room by a fire door, and all penetrations

are sealed.

At

NMP2, the under-floor area of the control room has an automatic cross-zoned total-

flooding halon system.

The detection in this case is both ionization and thermal

detection.

One of each detector type must be actuated for halon suppression to

initiate. At NMP2, the under-floor area has access

panels that are covered by

carpet.

With the assistance

of operations personnel, the inspectors reviewed the fire

suppression

and detection systems in each control room, and identified no

discrepancies.

The inspectors discussed with the SSSs for both units and the fire

protection supervision to determine whether, in their opinion, actuation of the total-

flooding halon systems would require control room evacuation.

Although the

possibility existed for halon to seep into the control rooms, the leakage rate would

be slow and inhibited by the previously discussed

barriers.

The fire protection

supervisor stated that the potential for a distressful atmosphere would exist only if

the halon concentration became high or if it was breathed for, an unextended

period

of time.

In both cases,

halon system initiation should not affect control room

habitability to the extent that evacuation would be required.

However, if necessary,

both units have procedures

in place for control room evacuation.

Without a general

area automatic fire suppression

system specifically located in either control room,

30

the inspectors concluded that the concern associated with the Haddam Neck event

did not exist at Nine Mile Point.

Although there was no procedural guidance specifically directing operators to don

self-contained breathing apparatus

(SCBA), there could be situations when the use

of SCBAs by control room personnel would be necessary for short periods of time.

At both units, most control room personnel were trained and qualified to use

SCBAs; however, the SCBAs are primarily used by fire brigade members.

The

number of SCBAs and the number of spare bottles were specified in an Emergency

Plan Maintenance Procedure.

The equipment is surveilled monthly by fire protection

personnel to verify that the required number of usable SCBAs exist.

The inspectors

walked down the locations with fire protection personnel and reviewed the

applicable surveillance procedures to ensure that routine verifications were being

conducted.

If the control room staff needed to don SCBAs, there appeared to be a

sufficient quantity of SCBAs onsite.

The SCBAs, however, may need to be

obtained from locations other than directly outside the control room.

c.

Conclusions

The inspectors noted that the concern associated with the Haddam Neck automatic

fire suppression

system actuation did not exist at Nine Mile Point.

Plant personnel

appeared trained and equipped to combat a control room fire. Additionally,

procedures were in place should personnel evacuation of the control room be

required.

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 contained within this report

were conducted upon completion of their onsite inspection:

Transportation and Radwaste Program

Radiological Protection Program

August 15, 1997

August 29, 1997

The final exit meeting occurred on October 17, 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

R, Dean

A. DeGracia

S. Doty

K. Dahlberg

G. Helker

P. Mazzafero

L. Pisano

R. Randall

P. Smalley

R. Smith

R. Tessier

C. Terry

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, NMP2 Engineering

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

Manager, Training

Vice President,

Nuclear Safety Assessment 5 Support

Manager, NMP2 Technical Support

Manager, NMP2 Chemistry

Manager, Licensing

INSPECTION PROCEDURES USED

IP 37551:

IP 61726:

IP 62707:

IP 71707:

IP 71750:

IP 83750:

IP 86750:

IP 90712:

IP 92700:

IP 92903

IP 92903:

IP 92904:

IP 93703

TI 2515/133

On-Site Engineering

Surveillance Observations

Maintenance Observation

Plant Operations

Plant Support

'Occupational Radiation Exposure Program

Solid Radwaste Management 5 Transportation of Radioactive Material

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 - Maintenance

Followup - Engineering

Followup - Plant Support

Prompt Onsite Response to Events at Operating Power Reactors

Implementation of Revised 49 CFR Parts 100-179 and 10 CFR Part 71

A-1

Attachment

1

ITENIS OPENED, CLOSED, AND UPDATED

OPENED

50-410/97-07-01

NCV

Failure to evaluate catch containment as a permanent

modification

50-410/97-07-03

50-410/97-07-04

VIO

NCV

50-220/97-07-05

NCV

EEI

50-220 5

50-410/97-07-06

50-220/97-07-07

EEI

50-220/97-07-08

IFI

50-220/97-07-09

EEI

50-220 5

50-410/97-07-10

50-220 8L

410/97-07-1

1

50-220 5

410/97-07-1 2

50-220/97-07-1 3

CLOSED

50-220 5

41 0/96-07-1 8

50-220/96-05-02

EEI

EEI

EEI

EEI

IFI

IFI

50-220/96-07-04

URI

50-220/96-05-01

URI

50-220/

EA-96-079-101 3

VIO

50-220/97-07-02

VIO

Missed TS SR on Channel

11 control room vent radiation

monitor

Missed TS SR on HCS instrumentation

Errors in calculation to support 1995 RB/TB blowout

panel modification

Inadequate

design control associated with smoke purge

system and CREVS interface

Failure to maintain PCP up-to-date

Radioactive shipment exceeded 49 CFR 173.441 limits in

occupied space of vehicle

Review action plan to ensure safe use of concentrates

tank 0'1, or removal of contents

Shipments of radioactive materials delivered to

unlicensed facilities

Shipment of wrong radioactive waste material

Failure to identify and correct conditions adverse to

quality associated with the PCPs

Failure to conduct audits of suppliers of NRC-certified

shipping casks

Failure to verify QA programs of Radwaste processing vendors

Poor material condition in several areas

Resolve inconsistencies

in reactor building and turbine

building blowout panel relief pressure values that are

stated in the UFSAR and IPE

Procedure change evaluation used to change the intent

of a procedure

Review of revised reactor and turbine building blowout

panel relief pressure calculations

Design control measure inadequate during calculation for

establishing the reactor and turbine building relief

pressure

A-2

Attachment

1

50-410/97-07-01

NCV

Failure to evaluate catch containment as a permanent

modification

50-220/97-07-05

NCV

50-410/97-06

50-41 0/97-07

LER

LER

50-220/97-07-04

NCV

Errors in calculation to support 1995 RB/TB blowout

panel modification

Inadequate design control associated with smoke purge

system and CREVS interface

Plant Shutdown due to Rising Unidentified Leakage

Failure to Calibrate Hydrogen Recombiner Instruments as

Required by Technical Specifications due to Procedure

Omission

50-220/97-07

UPDATED

none

LER

Potential Control Room Emergency Ventilation System

Operation Outside the Design Basis due to Inadequate

Evaluation

LIST OF ACRONYMS USED

ALARA

CFR

CR

CRD

CREVS

CRSPS

DER

EA

EC

EEI

EER

EQ

FME

GE

GL

GSO

HCS

HPCS

HRA

IE

IFI

IPAP

IPE

IR

IS.C

As Low As Reasonably Achievable

Code of Federal Regulations

Control Room

Control Rod Drive

Control Room Emergency Ventilation System

Control Room Smoke Purge System

Deviation/Event Report

Enforcement Action

Emergency Cooling

Escalated Enforcement Item

Exposure Evaluation Reports

Equipment Qualification

Foreign Material Exclusion

General Electric

Generic Letter

General Supervisor of Operations

Hydrogen Recombiner System

High Pressure

Core Spray

High Radiation Area

Inspection and Enforcement

Inspector Follow Item

Integrated Performance Assessment

Process

Individual Plant Examination

Inspection Report

Instrumentation and Control

A-3

Attachment

1

kV

LCO

LDCR

LER

MAAP

MOV

mR/hr

mRem/hr

NCV

NMPC

NMP1

NMP2

NRC

NRR

NVLAP

PCE

PCP

PID

PM/ST

PRA

psf

QA

Radwaste

RB

RCA

RCIC

RFO

RG

RP

RWP

SAM

SCBA

SLS

SR

SRM

SSS

TB

TLD

TS

UFSAR

VIO

WO

tation Program

est

kiloVolt

Limiting Condition for Operation

Licensing Document Change Request

Licensee Event Report

Modular Accident Analysis Program

Motor-operated Valve

milliroentgen per hour

milliRem per hour

Non-Cited Violation

Niagara Mohawk Power Corporation

Nine Mile Point Unit 1

Nine Mile Point Unit 2

Nuclear Regulatory Commission

Office of Nuclear Reactor Regulation

National Voluntary Laboratory Accredi

Procedure Change Evaluation

Process Control Program

Problem Identification

Preventive Maintenance/Surveillance

T

Probabilistic Risk Assessment

pounds per square foot

Quality Assurance

Radioactive Waste

Reactor Building

Radiologically Controlled Area

Reactor Core Isolation Cooling

Refueling Outage

Regulatory Guide

Radiation Protection

Radiation Work Permit

Small Article Monitor

Self-contained Breathing Apparatus

Standby Liquid Control

Surveillance Requirement

Source Range Monitor

Station Shift Supervisor

Turbine Building

Thermoluminescent Dosimeter

Technical Specification

Updated Final Safety Analysis Report

Violation

Work Order

A-4

0