ML17059C621
| ML17059C621 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 04/09/1999 |
| From: | Crlenjak R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Mueller J NIAGARA MOHAWK POWER CORP. |
| References | |
| AL-98-07, AL-98-7, NUDOCS 9904190274 | |
| Download: ML17059C621 (76) | |
Text
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REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9904190274 DOC.DATE: 99/04/09 NOTARIZED: NO DOCKET FACIL:50-220 Nine Mile Point Nuclear Station, Unit 1, Niagara Powe 05000220 50-410 Nine Mile Point Nuclear Station, Unit 2, Niagara Moha 05000410 AUTH.NAME AUTHOR AFFILIATION CRLENJAK,R.V.
Region 1 (Post 820201)
RECIP.NAME RECIPIENT AFFILIATION MUELLER,J.H.
Niagara Mohawk Power Corp.
SUBJECT:
Discusses results of Plant Performance Review of Nine Mile
(
Point Units 1
6 2 completed on 990223.Forwards historical listing of plant issues that were considered
& advises of 2
planned insp effort resulting from Nine Mile Point PPR.
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April 9, 1999 Mr. John H. Mueller Chief Nuclear Officer Niagara Mohawk Power Corporation Nine Mile Point Nuclear Station Operations Building, 2nd Floor P.O. Box 63 Lycoming, NY 13093
SUBJECT:
PLANT PERFORMANCE REVIEW - NINE MILE POINT UNITS 1 &2
Dear Mr. Mueller:
On February 23, 1999, the NRC staff completed a Plant Performance Review (PPR) of Nine Mile Point Units 1 8 2. The staff conducts these reviews for all operating nuclear power plants to develop an integrated understanding of.safety performance.
The results are used by NRC management to facilitate planning and allocation of inspection resources.
PPRs provide NRC management with a current summary of licensee performance and serve as inputs to the NRC's senior management meeting (SMM) reviews.
PPRs examine information since the last assessment of licensee performance to evaluate long term trends, but emphasize the last six months to ensure that the assessments reflect current performance.
The PPR for Nine Mile Point Units 1 8 2 involved the participation of all technical divisions in detailed evaluation of inspection results and safety performance information for the period April 1998 to January 15, 1999, and a review of long-term performance trend since your last Systematic Assessment of Licensee Performance (SALP). The NRC's most recent summary of licensee performance was provided in a letter of December 30, 1997, and was discussed in a public meeting with you on January 9, 1998.
I As discussed in the NRC's Administrative Letter 98-07 of October 2, 1998, the PPR provides an assessment of licensee performance during an interim period that the NRC has suspended its SALP program. The NRC suspended its SALP program to complete a review of its processes
~
for assessing performance at nuclear power plants. At the end of the review period, the NRC" willdecide whether to resume the SALP program or terminate it in favor of an improved process.
No automatic reactor shutdowns occurred during the assessment period. Nine Mile Point Unit 1 shut down in May 1998 due to an emergent problem with the control room emergency ventilation system.
After the problem was addressed, the unit returned to essentially full power for the remainder of the period. Unit 2 operated at full power following restart from the refueling outage in July until November 1998 when the unit was shut down to address a problem with a reactor recirculation system flowcontrol valve. Following repairs, the plant returned to full power operations.
9904L90274 990409 PDR ADQCK 05000220 PDR IE01
John H. Mueller Overall performance at both units was acceptable, but a few areas of weak performance were noted.
Operator control of plant evolutions was safe and conservative.
Human performance and work control were improving, but problems in these areas require continued management attention. The material condition of both units was generally good. Heightened engineering management involvement resulted in better problem identification and more critical plant design reviews; continued management attention to engineering backlogs is warranted.
Plant Support programs and their day-to-day implementation continued to be a station strength.
The corrective action program improved as a result of increased management focus but some inconsistencies in program implementation require continued attention.
Operators continued to respond well to reactor plant power changes and equipment degradation issues, such as the Unit 2 recirculation flowcontrol valve problem. The number of Unit 1 operations staff errors was reduced from that which occurred earlier in the period as a result of aggressive management oversight.
Site management was observed to be proactive in the area of self assessments and mentoring, and was more focused on improving human performance.
However, a November 1998 Unit 1 reactivity management error indicated the need for continued commitment in this area.
The normal NRC core inspection program is planned with some increased emphasis on corrective action program effectiveness.
Maintenance staff performance continued to be acceptable with only a single forced outage at Unit 2 related to an equipment problem.
Maintenance personnel responded well to emergent equipment issues.
The Maintenance Rule was appropriately implemented and circuit breaker maintenance problems that occurred early in the assessment period were effectively addressed by program revisions.
The development of a work activity risk monitor from the enhanced Probabilistic Risk Assessment model was a positive work planning attribute.
However, a few incidents of poor work planning and control resulted in safety system configuration errors.
Material condition at both units was good. The normal NRC core inspection program is planned with some increased emphasis placed on the area of work control and configuration control.
Engineering performance has improved, including more thorough responses to industry events and system design deficiency identification. Early in the inspection period, a poor evaluation of
~ a degraded Unit 1 core spray pump and untimely corrective actions for a.Unit 2 emergency diesel generator fuel line degradation illustrated a lack of rigor by the engineering support staff.
In contrast, recently performed engineering reviews of the control room emergency ventilation systems at both units resulted in the timely identification and correction of system design deficiencies.
The design and installation of the new emergency core cooling system pump suction strainers at Unit 2 represented sound engineering practices and the continued identification of logic system testing deficiencies illustrated critical reviews and good problem identification. Independent Safety Engineering Group assessments were thorough.
Management has taken action to address the engineering backlog.
However, continued attention is needed to improve work prioritization and backlog reduction efforts. The NRC plans to perform the normal core inspection program.
In addition, initiative engineering inspections are planned to review the installation of modifications, engineering support activities, and logic.
system functional testing deficiencies.
Site programs in radiation protection, security, and emergency preparedness were well implemented.
Total accumulated radiation exposure at Unit 1 for 1998 was the lowest in unit history, as the result of a number of enhanced work processes.
Self-assessment efforts were effective in identifying problems and determining improvement measures in the Plant Support
C.
John H.,Mueller area.
Radiological effluent and monitoring programs were effectively implemented and maintained.
Previously identified deficiencies involving radioactive material transportation activities were appropriately addressed.
Emergency preparedness programs were generally strong with good procedural controls, and the facilities and equipment were well maintained.
The security program was well managed and implemented.
The NRC plans to perform the normal core inspection program.
Enclosure 1 contains a historical listing of plant issues, referred to as the Plant Issues Matrix (PIM), that were considered during this PPR process to arrive at an integrated view of Nine Mile Point performance trends.
Please note that the PIM was in two different formats due to a program change effective on October 1, 1998. The PIM included items summarized from inspection reports or other docketed correspondence between the NRC and Niagara Mohawk Power Corporation. The NRC does not attempt to document all aspects of licensee programs and performance that may be functioning appropriately.
Rather, the NRC'only documents issues that the NRC believes warrant management attention or represent noteworthy aspects of performance.
In addition, the PPR may also have considered some pre-decisional and draft material that does not appear in the attached PIM, including observations from events and inspections that had occurred since the last NRC inspection report was issued, but had not yet received full review and consideration.
This material willbe placed in the Public Docket Room as part of the normal issuance of NRC inspection reports and,other correspondence.
This letter advises you of our planned inspection effort resulting from the Nine Mile Point PPR.
It is provided to minimize the resource impact on your staff and to allow for personnel availability and scheduling conflicts to be resolved in advance of inspector arrival onsite. details our inspection plan for the next six months. The rationale or basis for each inspection outside the core inspection program is provided so that you are aware of the reason for emphasis in these program areas.
Resident inspections are not listed due to their ongoing and continuous nature.
Because of the anticipated changes to the inspection program and other initiatives, this inspection schedule is subject to revision. Any changes to the schedule willbe discussed promptly with your staff. Ifyou have any questions, please contact G. Scott Barber at 610-337-5232.
Sincerely, ORIGINAL SIGNED BY:
Richard V. Crlenjak, Deputy Director
~ Division of Reactor Projects Docket Nos.
50-220, 50-410 License Nos.
Enclosures:
- 1. Plant Issues Matrix
- 2. Inspection Plan
John H. Mueller cc w/encls:
G. Wilson, Senior Attorney M. Wetterhahn, Winston and Strawn J. Rettberg, New York State Electric and Gas Corporation P. Eddy, Electric Division, Department of Public Service, State of New York C. Donaldson, Esquire, Assistant Attorney General, New York Department of Law J. Vinquist, MATS, Inc.
F. Valentino, President, New York State Energy Research and Development Authority J. Spath, Program Director, New York State Energy Research and Development Authority
John H. Mueller Distribution w/encls:
H. Miller, RA/J. Wiggins, DRA (1)
W. Travers, EDO S. Collins, NRR J. Zwolinski, NRR B. Boger, NRR J. Lieberman, OE (OEMAIL)
A. Blough, DRP W. Lanning, DRS R. CrlenjakDRP W. Ruland, DRS D. Screnci, PAO W. Dean, Chief, NRR/DISP/PIPB G. Tracy, Chief, OEDO/ROPMS T. Boyce, NRR/DISP/PIPB S. Barber, DRP W. Cook, DRP NRC Resident Inspector R: Ragland, DRS S. Chaudhary, DRS P. Frechette, DRS D. Silk, DRS M. Oprendek, DRP R. Junod, DRP Region I Docket Room (with concurrences)
Nuclear Safety Information Center (NSIC)
PUBLIC Distribution w/encls: (VIAE-MAIL)
M.-Tschiltz, Rl EDO Coordinator G. Hunegs - Nine Mile Point S. Bajwa, NRR D. Hood, NRR M. Campion, Rl Inspection Program Branch (IPAS)
R. Correia, NRR DOCDESK Distribution w/encls: (VIAE-MAIL)
Region I Staff (Refer to the RAPPR Drive)
John H. Mueller DOCUMENT NAME: G:hPPR3-99)NMP4-1.WPD To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Co with attachment/enclosure "N" = No co OFFICE RI/DRP RI/DRP RI/DRP RI/
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> a.a PLWr rSsUaS lmruX Date 8/4/98 8/11/98 Type Positive NCV Positive Source IR 98-17 IR 98-13 NCV 98-13-01 and 02 N
OPS 2B 3A 3C N
OPS 5A 3A 5C ID SFA Code Item Description The Unit 1 simulator configuration and management controls, including the computer upgrade, were implemented properly. The simulation facilitywas maintained and operated as certified in accordance with the requirements of 10 CFR 55.45 and ANSI/ANS 3.5-1985, as endorsed by Regulatory Guide 1.149, Rev. 1. Training department personnel routinely briefed trainees on simulator deficiencies that may affect planned training evolutions. Overall, there was no evidence of negative training as a result of simulator deficiency problems and of untimely or uncorrected simulator deficiencies.
The licensee appropriately resolved past inspection findings and appropriately identified and acted on violations dealing with senior reactor operator duties in the control room.
8/11/98 Positive IR 98-13 N
. OPS 8/11/98 Positive IR 98-13 N
OPS 8/11/98 Positive IR 98-13 N
OPS 8/11/98 Positive IR 98-13 N
OPS 1C 3A 3C
.1A 3B 1A 3A 3A 1A Operations department management was proactive in initiating quality assurance surveillances and establishing the mentoring program. The self-assessment and quality assurance audits were effective in identifying the recent decline in operations performance.
The assessment of DER trends, the mentoring program, and quality assurance's 1997 audit of operations and recent surveillance collectively provided a thorough assessment of the operations organization performance.
The shift supervisor provided appropriate oversight of shift activities and pre-evolution briefs were well managed.
Operations management was observed providing appropriate oversight of control room activities.
Control room and plant operators demonstrated appropriate knowledge of plant systems and administrative requirements necessary to safely operate the plant. Alloperations and testing evolutions observed were conducted in a safe and controlled manner.
Operators implementing several surveillance tests exhibited good procedure adherence skills.
Operators interviewed were fullyaware of management's expectations for verbatim procedure compliance.
8/11/98 Positive IR 98-13 N
OPS 2B 3A 1C Appropriate procedure guidance was available for the risk significant operator actions reviewed. The procedures were walked down in the field with licensed operators and the operators were found to have a thorough understanding of the procedure guidance.
The sunreillance procedures used for the tests observed were of good quality.
FROM: 10/1/97 TO: 10/1/98 1 of24 April 9, 1999
NINE MILEI 6 2 PLANT ISSUES MiATRIX Date Type 8/11/98 Positive Source IR 98-13 N
OPS 2B 3C 3A ID SFA Code Item Description The administrative guidance for temporary modifications, control room deficiencies, and operator work-arounds was appropriate.
However, the effectiveness of the implementation of the programs could not be determined, as operators were still in the process of developing a comprehensive list of deficiencies and work-arounds.
8/11/98 Negative IR 98-13 8/11/98 Positive IR 98-13 6/26/98 VIO IR 98-11 VIO 98-11-02 6/26/98 Negative IR 98-11 6/26/98 Negative IR 98-11 8/11/98 Positive IR 98-13 N
OPS 5A 5C 3A N
OPS 2B 1A N
OPS 3C 1A 1C N
OPS 5A 5B 5C 3B N
OPS 5B 5C N
OPS 3A 3C 5A Plant operators were effective in identifying deficient plant equipment and had established appropriate thresholds for including deficiencies in the corrective action program.
- However, the inspectors noted that a poor interface existed between operations and the work planning organization in identifying and resolving deficient or incomplete work packages.
The administrative guidance governing safety and configuration tagging was appropriate to protect workers and the integrity of safety-related systems.
The implementation of the safety and configuration tagging administrative requirements by plant operators was effective.
The management standards and expectations for plant operators were appropriate and clearly documented in the Operations Manual. Operations personnel consistently adhered to expectations regarding communications, control room access, control board awareness, and shift turnovers.
Log keeping and annunciator response were acceptable.
Operations personnel were effectively tracking technical specification equipment status but operators were unclear as to management expectations on the'equipment status log entries.
The identification of FCV 80-118 as a primary containment isolation valve by the systems engineer was good, but the oversight by the operations staff of this valve's primap containment isolation function reflects poorly on their systems knowledge and sensitivity to containment integrity monitoring. The failure to maintain primary containment integrity for 3.5 days was a violation of the Unit 1 Technical Specification 3.3.0. (VfO50-220/03-1 1-02)
~
The licensee's immediate action to conduct control panel system line-up verifications without referring to the system operating procedures was a poorly founded decision based upon the control room operators not having identified the flowcontrol valve out-of-position for 3.5 days by relying on unaided memonj of proper systems'onfiguration.
Between April7 and 11, over sixty control panel walkdowns were unsuccessful in identifying this containment spray system mis-positioned valve. This was a significant operations staff oversight and indicative of a lack of attentiveness to safety system configuration.
In contrast, the in-plant operator's identification of the breaker open/closed indicating lights deficiency demonstrated good attention to detail, proper awareness of plant conditions, and prompt and appropriate response to a deficient condition.
FROM: 10/1/97 TO: 10/1/98 2of24 Apnl 9, 1999
F
@ma Mn.E j. a. a pr.mT'SSvxS MATMx Date 7ype 6/26/98 VIO Source IR 98-11 VIO 98-11-01 ID SFA Code L.
OPS 3A 3C 1A Item Description A Unit 1 reactor operator failed to followthe operating procedure for restoration of the containment spray system to its standby configuration resulting in the system being in a degraded condition for 3.5 days. This was a violation of Technical Specification 6.8.1, involving the failure to implement procedures, as written. (VIO50-220/98-11-01) 8/5/98 NCV IR 98-06 Positive NCV 98-06-01 8/5/98 Negative IR 98-06 8/5/98 Positive IR 98-08 L
OPS 4C 5A SC N
OPS 3A 3B 3C N
OPS 3A 1A During the Unit 1 planned shutdown on April28, the licensee determined that the rod block function of the rod worth minimizer had not been properly tested since a 1974 Technical Specification change.
This licensee identified and corrected violation of TS surveillance requirements was not cited.
Licensee response to the May 11, 1998 engineered safety feature actuation was appropriate.
The cause of the event was poor work package and tagout development and a subsequent poor plant impact assessment by the Station Shift Supervisor prior to re-energizing the Division II trip unit power supplies.
During sustained Unit 1 control room observations, operators'ttentiveness, procedure adherence, shift tumovers, log keeping, and control of activities were found to be acceptable.
Supervisory oversight and communication were good, particularly during a control rod drive pump post-maintenance test and a feedwater pump swap. In-plant operators were knowledgeable of system and equipment functions. Material condition in the reactor building was acceptable.
7/7/98 Negative IR 98-05 N
OPS 1A 3A 7/7/98 VIO IR 98-05 L
OPS 1A VIO 98-05-01 3A 5A While transferring a double blade guide (DBG) from the spent fuel pool to the reactor vessel, the DBG became disengaged from the grapple and came to rest in the fuel transfer canal.
NMPC determined that the root cause was the refueling crew did not properly verify engagement of the grapple.
NMPC's root cause investigation was methodical and thorough, the root cause determination was technically sound, and the corrective actions adequately addressed th5 cause.
During performance of a Unit 1 surveillance test, the containment spray raw water inter-tie check valve did not open with the required torque and the station shift supervisor (SSS) failed to enter the core spray system TS 3.1.4.d action statement, as required by the surveillance test. The relieving SSS identified the procedural non-compliance and took prompt and appropriate action to comply with the surveillance procedure.
The failure to property implement the surveillance test is a violation of TS 6.8.1.
FROM: 10/1/97 TO: 10/1/98 3 of24 April 9, 1999
Date rape Source ID SFA Code Item DescrIption 2/17/98 Negative IR 98-03 N
OPS 1A 3B An assessment review of the initial examination submittal of November 19, 1997 consisting of the written, job performance measures and operating tests found that the submittal was inadequate.
NRC staff concerns were noted in a letter dated December 2, 1997 and the examination was postponed until the week of January 20, 1998. A revised examination was resubmitted and another assessment indicated that the submittal did not require additional modifications. NRC inspection report 50-410/97-08 (OL) documented significant areas of difficultyidentified by NRC staff of an NMP-2 initial license written examination submittal of April7, t 997. There was apparent ineffective corrective actions to improve the quality oi initial examination submittals that resulted again in the postponement of the examination.
5/27/98 Negative EEI IR 98-02 L
EEI 98-02-04 OPS 3A 5A 3C The inspectors determined the applicants were well prepared for the examination and met all regulatory eligibilityrequirements.
LER 50-410/98-02 appropriately documented the circumstances involving a Unit 2 reactor operator who left the "at-the-controls" area of the control room. The NRC staff's disposition of this apparent TS violation remains under review.
5/27/98 Positive NCV IR 98-02 L
NCV 98-02-03 OPS 1A 5A 5B 5C A non-conservative operating philosophy resulted in exceeding the Unit 1 maximum allowable core thermal power during the eight-hour shift-average.
The computer program which calculated and reported the shift-average power did not provide a sufficiently accurate readout of reactor power to assist the control room staff. NMPC's investigation identified seven other instances since the beginning of the year where the TS limitof 1850 MW~was exceeded.
This licensee identified and corrected TS violation was not cited.
5/27/98 Negative IR 98-02 N
NCV NCV 98-02-02 OPS 5A 5C The NRC noted several degraded conditions in the Unit 1 control room which were not formally identified as Control Room Deficiencies.
However, the operators and system engineers were aware of the problems and actions were in-place to address them. This minor procedural non-compliance was not cited.
5/27/98 Positive NCV IR 98-02 N
NCV 98-02-01 2/14/98 Negative IR 98-01
. N OPS 2B 5A OPS 1A 2A 5A The Unit 2 residual heat removal system walkdown and performance history reviews indicated that the material condition of the system was good, and that the system demonstrated a high level of reliability. However, two minor discrepancies were identified which differed from the design contained in the UFSAR and were not cited due to their minor safety consequence.
The quarterly reviews of extended markups at Unit 1 were weak in that the reviewers failed to identify numerous markup discrepancies that were later identified by the inspectors.
Unit 1 management was aware of the weaknesses, and proposed corrective actions appeared appropriate.
FROM: 10/1/97 TO: 10/1/98 4of24 April 9, 1999
Date ape Source iD SFA Code Item Description 2/14/98 NCV IR 98-01 N
Negative NCV 98-01-02 OPS 5A 1C Most catch containments installed in Unit 1 were adequately installed and maintained.
However, many designated as 'permanent" did not have an engineering evaluation to determine ifa plant change or modification was required. The most recent semi-annual catch containment review lacked depth, in that NMPC failed to fullyevaluate whether catch containments should be removed or that those designated as "permanent" had the required engineering evaluation. This minor procedure violation was not cited.
2/14/98 NCV IR 98-01 Negative NCV 98-01-01 OPS 3A 5A During an inspection in the Unit 2 residual heat removal pump rooms, the inspectors Identifie~
inadequate separation between conduits for safety-related temperature elements of different M divisions. A breakdown in communications between an Assistant Station Shift Supervisor and a system engineer resulted in a one week delay in recognizing the impact that inadequate conduit separation had on the operability of safety-related plant equipment.
This minor 10 CFR 50, Appendix B, violation was not cited.
2/14/98 Positive 1/23/98 NCV Positive 2/14/98 -
Positive IR 98-01 N
IR 98-01 N
LER 98-01 IR 97-12 L
LER 97-11 NCV 97-12-03 OPS 4B 5A OPS 1A OPS 1A 3B Routine monitoring of the Unit 2 refuel reliabilityindex allowed NMPC to identify a reactor fuel leak early, before it degraded any further. The fluxtilting and power suppression evolution was methodical and well-controlled due, in part, to good communication and coordination among all involved organizations.
NMPC took aggressive actions to prevent further leak degradation.
Unit 2 operators responded appropriately to the failure of the Division II containment atmosphere gaseous/particulate radiation monitor that occurred while the Division I monitor was inoperable for maintenance.
Station Operations Review Committee members maintained the proper safety focus during the meeting to discuss the basis for requesting enforcement discretion. A Notice of Enforcement Discretion (NOED) was issued to preclude a unit shutdown while working to restore the Division I radiation monitor to an operable status.
The Unit 1 operations and reactor engineering staffs'nitiative to perform a procedure review prior to an infrequently performed evolution, (reactor shutdown by fullcontrol rod insertion),
was appropriate.
This review was good in that it identified the need for some procedural enhancements.
The review also identified that, in the past, on several occasions the mode switch was placed in REFUEL contrary to the TS. This licensee identified and corrected violation was not cited.
1/23/98 NCV IR 97-12 N
Negative NCV 97-12-02 OPS 3A 1A 1C Unit 2 licensed control room operators were not aware that the posted surveillance test data for standby liquid control was out of date and that the surveillance was potentially overdue.
A chemistry technician failed to post the surveillance summary sheet after completion of the surveillance, as required by procedure.
FROM: 10/1/97 TO: 10/1/98 5 of24 April 9, 1999
NINE MILEI R. 2 PLANT ISSUES MiATRIX Date Type 1/23/98 Positive Source IR 97-12 ID SFA Code N
OPS 2B 3A 1A Item Description The Unit 1 shutdown safety verification procedure was considered a valuable aid for the control room operators to assist in monitoring plant conditions and assuring that safety functions were sufficiently available during shutdown conditions.
Periodic briefings of safety function status during work control meetings and shift turnover was good, in that,,it ensured
" personnel awareness of system status and allowed for feedback of any current or potential deviations.
1/23/98 Negative IR 97-12 1/23/98 Negative IR 97-12, N
OPS 2A 4A 3C N
OPS 5C 4B Following the inspectors'dentification of the Unit 1 hydrogen/oxygen analyzer cabinet doors ~
being improperly secured, the licensee completed a technically sound and extensive analysis~
to determine that operation in this condition did not adversely impact the equipment operability. However, past operations with the cabinet doors improperly secured indicated a poor questioning attitude on part of the Unit 1 operators, in that they failed to recognize the potential safety concern associated with the condition.
Upon identification that the SRV position indication at the Unit 2 remote shutdown panel (RSP) was unreliable during a control room fire due to a portion of the cabling and components being contained with the control room fire-zone, NMPC engineering staff recommended the incorporation of a caution in the RSP procedure regarding the potential unavailability of the indication. Since the loss of SRV position indication could have been confusing to the operators during a plant shutdown from the RSP, the inspectors considered the time to the scheduled procedure revision date to be excessive, and the licensee promptly incorporated the caution statement.
1/23/98 NCV Positive IR 97-12 NCV 97-12-01 L
OPS 4A 5B NMPC identified that the Unit 2 condensate storage tank building temperatures were not being maintained in accordance with the UFSAR, and took appropriate corrective action to change the temperature control switches to the proper set point. Additionally, NMPC identified that the capacity of the building heaters needed upgrading to maintain desired temperature; this was appropriately evaluated and adequate compensatory actions were established.
This licensee identified and corrected violation was not cited.
1/23/98 Positive IR 97-12 N
OPS 1A 3A The shift brief for the newly-installed emergency cooling condenser keepfull modification was synergistic and provided sufficient detail on the system hardware and operation.
The conduct of control room activities during the Unit 1 plant startup following repairs to the condensers was good and improved compared to previous startups.
The overall reactor startup appeared'o run smoother than previous startups due to the improvement in control rod drive performance.
FROM: 10/1/97 TO: 10/1/98 6 of 24 April 9, 1999
I.
NINE MILE 1 R. 2 PL'WT ISSUES MATRIX Date TYpe Source ID SFA Code Item Description 1/23/98 Positive IR 98-03 N
OPS 3B The inspectors determined the Unit 1 applicants were well prepared for the examination and met all regulatory eligibilityrequirements.
1/23/98 Negative IR 98-03 N
OPS 1/23/98 Negative IR 98-03 N
OPS 11/8/97 Negative IR 97-11 L
OPS 3B 3C 3B 3C 5B 4B NRC IR 97-08(OL) documented significant areas of difficultyidentified by NRC of an NMP-2 initial.license written examination.
There was apparent ineffective corrective actions to improve the quality of subsequent initial examination submittals.
An assessment of the initial examination submittal consisting of the written, job performancet measures and operating tests found that the submittal was inadequate.
A revised examination did not require additional modification.
NMP1 operations staff operability evaluation for the channel 12 GEMAC, though reasonable, did not probe deep enough into all potential reference leg leakage paths.
11/8/97 Positive IR 97-11 L
OPS 2A 3C An NMP2 SSS's oversight 8 questioning attitude was good & identified improper APRM gain setting adjustments.
11/8/97 Positive IR 97-11 N
OPS 1A 3C Control room activities during an NMP2 shutdown were well-coordinated, with good supervisory command &control.
10/4/97 Positive IR 97-07 N
OPS 2A 3A System walkdowns & performance history reviews indicated that the material condition of NMP2 SLCS was good, and that the system has demonstrated a high level of reliability. The knowledge level of the technicians and operators observed during the performance of a test was good. Some minor poor work practices were observed.
10/4/97 Positive IR 97-07 N
OPS 1A Special simulator training resulted in good operating crew performance during the 9/15/97 3B manual reactor shutdown at NMP1. During the unit shudown, CROs'se of alarm response 3A procedures, 3-part communications, &self/peer checking were noticeably improved.
9/10/98 EEI IR 98-09 L
EEI 98-09-01 MAINT 1A 3A 3C During preparations for maintenance on the Unit 1 containment spray system, the markup for isolation of the system was inadequate, resulting in a breach of the primary containment integrity. This issue remains open pending the NRC inspectors'eview of NMPC's completed root cause analysis and determination of corrective actions to prevent recurrence.
7/23/98 Strength
. IR 98-12 N
7/23/98 Positive IR 98-12 N
. MAINT MAINT 5A 5B 5C 3B 3C The licensee's self assessment, provided substantial improvements to the MR program. An aggressive program was in place to continue self monitoring by the licensee.
System engineers and operations department personnel were knowledgeable of the MR, and their associated duties and responsibilities were adequate to ensure it's implementation.
FROM: 10/1/97 TO'0/1/98
=7 of24 April 9, 1999
Date Type Source
/D SFA Code Item Description 7/23/98 Positive IR 98-12 N
2B MAINT 1C 1A The licensee used appropriate administrative controls for the conduct of on-line maintenance.
A review of completed and planned on-line work activities identified thorough risk assessments for the activities reviewed.
Responsible work control staff interviewed demonstrated good knowledge and use of the risk assessment computer software.
7/23/98 Strength IR 98-12 N
2B MAINT 3A The licensee's systematic approach to the development of the risk monitor from the enhanced PRA model was considered a strength.
The team concluded that integrating the individual plant examination of external events (tPEEE) and containment functions into the current PRA~
model made it a comprehensive risk evaluation tool.
7/23/98 Positive IR 98-12 N
MAINT 2B The licensee's approach to balancing unavailability and reliabilityadequately contributes to preventing failures of SSCs while minimizing unavailability as required by the MR.
7/23/98 Positive IR 98-12 N
2B MAINT 5A The periodic assessment was timely and adequate.
7/23/98 NCV IR 98-12 L
Positive NCV 98-12-01 2B MAINT 5A 5C The licensee's SSC scoping, function identification, and system boundary descriptions were acceptable.
However, the licensee added 13 SSCs to the MR scope after the required implementation date of July 10, 1996. The licensee was credited with identifying and correcting a violation of 10 CFR 50.65.
7/23/98 Positive IR 98-12 N
2B MAINT 5C 7/23/98 Positive IR 98-12 N
2B MAINT 1C 8/5/98 Positive IR 98-06 N
4C MAINT 3A 1C SSC performance criteria for reliabilityand unavailability were conservatively established, and-were directly related to the failure rates assumed in the PRA. Appropriate corrective actions were taken when an SSC failed to meet its goal, performance criteria, or experienced a functional failure. The condition monitoring program, for structures, was good and the overall material condition of the SSCs walked down was good.
The licensee's approach to performing risk ranking of structures, systems and components (SSCs) for the Maintenance Rule (MR) was acceptable.
Performance criteria for reliability and unavailability was commensurate with the assumptions in the enhanced probabilistic risk assessment (PRA) model for the sampled systems.
Decisions by the expert panel, regarding performance criteria, and their knowledge of online and shutdown risk assessment were appropriate to effectively implement the requirements of the maintenance rule.
The Unit 2 post-refueling hydrostatic test procedure was well written, and provided good instructions for control of activities. The inspections performed by NMPC during the test were comprehensive, and the licensee made the required repairs to reduce the total leakage to within specified acceptance criteria. The licensee took the necessary actions to request and obtain NRC approval for relief from the ASME Code requirements for noted leakage.
FROM: 10/1/97 TO: 10/1/98 8of24 Apnl 9, 1999
Date Type Source
/D SFA Code Item Description 8/5/98 Positive IR 98-06 N
4C MAINT 3A 1C The second ten-year inservice inspection plan for Unit 2 was updated to reflect industry operating experience.
The bases for selected relief requests were valid and accurate.
Core shroud inspections were conducted in accordance with industry guidelines.
NDE personnel were trained in accordance with the industry standards.
7/7/98 VIO IR 98-05 L
VIO 98-05-02 2B MAINT 4B During this inspection period, the NMPC staff self-identified that the TS required service test of the Unit 2 Division I battery was not completed during the previous two refueling outages.
NMPC had improperly credited the battery cyclic performance test for satisfying the requirements of the service test. NMPC requested and was granted a Notice of Enforcemen Discretion (NOED) to avoid the consequential TS required shutdown. The NOED was exited on May 2, 1998 upon the unit achieving Cold Shutdown conditions and the service test was completed satisfactorily on May 7, 1998. Notwithstanding, the failure to have properly service tested the Division I battery, since April 1995, is a violation of TS 4.8.2.1.d.
5/27/98 Positive IR 98-02 N
2A MAINT 3A 2B The recent lubrication procedure improvements at both units were good. Program enhancements at Unit 2 have been effective in eliminating component unavailability related to the lubrication program. The inspectors considered that past operator training and lubrication procedures at both units were weak and that some individuals exercised poor judgement when adding grease.
Overall, the lubrication programs at both units were acceptable.
5/27/98 VIO 2/14/98 VIO IR 98-02 N-VIO 98-02-05 IR 98-01 N
VIO 98-01-03 3A MAINT 5B 2B 2B MAINT 5A During troubleshooting of the Unit 1 control room ventilation system temperature control valve, an unanticipated repositioning of the control room ventilation system dampers occurred.
This resulted in the control room emergency ventilation system being declared inoperable.
The inspectors determined that the planning for the troubleshooting should have identified the impact on the dampers.
The failure to have identified this plant impact during the work order preparation was a violation of TS 6.8.1. (VIO 50-220/98-02-05)
Based upon the NRC inspector's questions, NMPC management declared the Unit 1 liquid poison system inoperable.
Portions of the system piping had not been periodically flow tested and NMPC was uriable to readily ascertain whether the piping from the liquid poison tank to the pump suction valves was obstructed.
NMPC's decision to declare the liquid poison system inoperable and commence a shutdown was conservative, and the actions taken to test the system were appropriate.
The special evolution brief was thorough. Although the previous Unit 1 liquid poison system surveillance testing met TS, the testing was inadequate to verifysystem operability. This was a violation of 10CFR50, App B, Crit XI.
2/14/98 Positive IR 98-01 N
MAINT 5B NMPC appropriately evaluated the impact of a leaking fuel delivery valve on the operability of the Unit 2 emergency diesel generator.
FROM: 10/1/97 TO: 10/1/98 9 of24 April 9, 1999
Date ape Source ID SFA Code Item Description 1/23/98 Positive IR 97-12 N
LER 97-14 MAINT 5B Licensee's actions were appropriate in response to an unexpected isolation of the Unit 1 vent and purge system that occurred during radiation monitor troubleshooting.
The licensee's root cause of the event was reasonable and the Station Operating Review Committee's review of the event maintained the proper safety focus.
1/23/98 Negative IR 97-12 S
1/23/98 Positive IR 97-12 N
1/23/98 Positive IR 97-12 N
11/8/97 Negative IR 97-11 N
IR 97-06 VIO 97-06-01
.11/8/97 Positive IR 97-11 N
MAINT MAINT MAINT MAINT MAINT 3A 2B 3A 1C 2B 3A 10 3A 3C 2B 5C 3C 2A Due to inattention during a surveillance test, a Unit 2 technician inadvertently inserted a circuit card extender upside down, causing a reactor protection system half-scram signal.
In addition, the surveillance test procedure did not contain a precautionary note which could have warned the technician of the potential plant impact ifthe card were incorrectly inserted. ~
Pre-evolution briefs for the Unit 1 emergency cooling condenser capacity test were detailed and safety-focused.
Operators demonstrated a questioning attitude and the briefs were synergistic. The control room environment was very good and clear and formal three-part communications were consistently used.
A Unit 1 emergency cooling condenser hydrostatic test pre-evolution brief was adequate.
Communications during the test were good, in that formal three-way communications were consistently used.
Operations and inservice testing supervision provided good oversight.and assistance, which resulted in a well-coordinated evolution.
An I&Ctechnician incorrectly performed a step in a calibration procedure and this was not identified during supervisory review. A 1995 NMP1 main steam break instrument trip channel calibration procedure change was in error and received an inadequate review.
In addition,.
the wrong APRM was adjusted during an NMP2 reactor shutdown. These violations were t additional examples of the violations cited in IR 97-06.
NMP2 SW system surveillance tests were performed in a controlled manner.
ASSS effectively coordinated testing activities 8 provided a detailed brief. Operators &technicians used clear three-part communications & adhered to the test procedures.
11/8/97 Positive IR 97-11 N
MAINT 2B 3C NMP1 forced outage work scope was adequately managed & appropriately safety-focused.
10/4/97 VIO IR 97-07 L
VIO 97-07-03 LER 97-07 MAINT 2B 3A 11/8/97 Positive IR 97-11 N
MAINT 2A Material condition of the NMP1 CRD housing support & MSL flow restrictor piping and instrumentation was very good.
The discovery by the NMP2 l&Ctechnician of the missed calibration of NMP2 H2 recombiner system components was good, however, the failure to perform TS 4.6.6.1.b.1 was a violation.
FROM: 10/1/97 TO: 10/1/98 10 of24 April 9, 1999
Date 7ype Source ID SFA
.Code Item Descr/pt/on 10/4/97 Negative IR 97-07 N
MAINT'C During a NMP1 EC condenser pipe cutting evolution, a poor safety 8 radiological work practice was identified, in that, maintenance personnel were using a rubber-gloved hand to remove metal shavings.
9/1 0/98 NCV IR 98-09 NCV 98-09-02 10/4/97 Positive IR 97-07 N
MAINT 3A 5A 2B 2A L
ENG 4A 4C During NMP1 EC condenser repair activities, maintenance personnel adhered to work order requirements &all associated procedures &documentation were readily available &the revision current. QA oversight of activities was appropriate.
FME controls were appropriately maintained.
Material accountability 8 system cleanliness were well controlled.
At Unit 1, an inadequate engineering evaluation of a 1997 configuration change resulted in a non-conformance with the 10CFR50, Appendix R, Safe Shutdown Analysis, by opening the core spray high point vent valves to address GL 96-06 thermal over-pressurization concerns.
Upon identification, NMPC took prompt and appropriate corrective actions. This licensee identified and corrected violation of Appendix R was not cited. (NCV 50-220/98-09-02 9/10/98 NCV IR 98-09 NCV 98-09-03 L
ENG 4A 4C During Unit 2 surveillance testing, NMPC identified that both control room air conditioning units were running in parallel, contrary to the intended design. This design vulnerability could have potentially resulted in the system being inoperable, under certain design basis accident scenarios.
This licensee identified and corrected violation of 10CFR50, Appendix B, Criterion III, Design Control, was not cited.
(NCV50410/98-09-03) 7/31/98 Positive IR 98-10 8/5/98 NCV Positive IR 98-06 NCV 98-06-05 7/31/98 Positive IR 98-10 N
ENG 5A 5C N
ENG 5B 5C L
ENG 5A 5B 4C The Quality Assurance (QA) audits and Independent Safety Engineering Group (ISEG) assessment were thorough and of good quality.
The licensee's corrective actions and preventive actions for recurrence for six escalated enforcement items, two violations, and four unresolved items and one inspector followup ite were found acceptable.
All 13 items were closed.
During their Generic Letter 96-01 review of safety-system logic testing, NMPC identified that portions of the Unit 2 service water pump loss of offsite power (LOOP) automatic start sequencing and the LOOP/loss of coolant accident manual start interlock logic circuit were not being tested as required by TS. Prompt and appropriate actions were taken to demonstrate logic system operability. This licensee identified and corrected surveillance testing deficiency was not cited.
FROM: 10/1/97 TO: 10/1/98 11 of24 April 9, 1999
Date Type Source ID SFA Code Item Description 8/5/98 NCV IR 98-06 L
Positive NCV 98-06-04 ENG 5A 5B 4C During the review of Unit 2 safety system logic testing per Generic Letter 96-01, NMPC identified that a number of logic circuits were not being tested as required by TS. Specifically,
.these circuits were not being properly test with the alternate offsite supply breaker supplying the divisional bus. Prompt and appropriate actions were taken to demonstrate logic system operability. This licensee identified and corrected surveillance testing deficiency was not cited.
8/5/98 NCV IR 98-06 L
Positive NCV 98-06-03 ENG 5A 5B 4C.
Unit 1 engineering staff identified that since 1990, the reactor vessel level instrumentation could have been indicating as much as 6.5 inches higher than actual. This resulted in the lo~
reactor water level trip settings being non-conservative and outside the allowable values provided in the TS. This licensee identified and corrected violation was not cited.
8/5/98 NCV IR 98-06 L
Positive NCV 98-06-02 7/7/98 Positive IR 98-05 N
7/7/98 Positive IR 98-05 L
NCV NCV 98-05-05 7/7/98 Positive IR 98-05 L
NCV NCV 98-05-04 7/7/98 Positive IR 98-05 N
ENG 4A 5A 5C ENG 5A 2B 5B ENG 5A 4B 4C ENG 2B 4B 5A ENG 4A 3A The Unit 1 design deficiency involving the control room emergency ventilation system and interfacing auxiliary control room fire dampers (reference LER 98-1 2) was properly identified by the licensee and promptly corrected.
Accordingly, this violation of 10 CFR 50, Appendix B, Criterion III, "Design Control," was not cited.
The inspectors observed that NMPC's follow-up of the Part 21 report concerning GE SBM-type control switches and their identification of the susceptible switches at Unit 1 was thorough and an example of an improving questioning attitude by the engineering staff.
During a review of the control room emergency ventilation system initiation logic, NMPC determined that the system would not automatically initiate, as required. Specifically, the system would not automatically start as a result of a main steam line break or a loss of coolant accident. This licensee identified and corrected violation of 10CFR50, Appendix B, Criterion XI, "Test Control," was not cited.
During a review of Unit 1 operating procedures, NMPC identified that the normally open vent valves on the containment spray raw water heat exchangers violated secondary containment integrity, in tPat it provided a potential release path from the reactor building to the environment. This licensee identified and corrected violation of secondary containment integrity requirements was not cited.
The design and installation of the new ECCS pump suction strainers appeared adequate to ensure sufficient net positive suction head for the pumps in the event of a loss of coolant accident (LOCA).
FROM: 10/1/97 TO: 10/1/98 12 of24 April 9, 1999
Date Type 7/7/98 VIO 5/27/98 Positive NCV Source IR 98-05 VIO 98-05-03 IR 98-02 NCV 98-02-15 N
ENG 4A 4B 4C L
ENG 4C 5A 4B ID SFA Code
= Item Description During surveillance testing of the Unit 2 Division II EDG, a fuel leak developed between the
. fuel filterand the fuel injectors. NMPC determined that the leak was caused by vibration of the fuel supply piping, which caused fretting of the pipe at a pipe support.
Subsequent licensee investigation identified notable, but less severe, fretting on the Division I EDG fuel supply piping. The fuel line supports were installed in 1993, but the specific design change to install a protective grommet was not adequately incorporated into the final design package.
This is a violation of 10CFR50, Appendix B,'Criterion III, "Design Control."
Prior to October 1993, NMPC failed to perform TS logic system functional testing of the reactor vessel high water level main turbine trip at Unit 2 in accordance with an established surveillance test procedure.
Fortuitously since October 1993, NMPC has tested this trip function per a repetitive work order. This licensee identified and corrected violation was not cited.
5/27/98 Positive NCV'R 98-02 NCV 98-02-11 5/27/98 Positive IR 98-02 NCV NCV 98-02-14 L
ENG 5A 4B 4C L
ENG 4C 4B 3A At Unit 2, probabilistic risk arguments were incorrectly used to justify less restrictive pipe stress limits in seismic qualification analyses for temporary shielding. Based on the analyses, the temporary shielding installed during refueling outages in 1992, 1993, 1995, and 1996, resulted in four systems exceeding allowable pipe stresses.
This licensee identified and corrected violation was not cited.
The engineering calculations, supporting analyses, temporary modifications, and safety evaluations associated with the operability determination for the degraded condition of the Unit 1 control room emergency ventilation system (CREVS) were generally well prepared.
The inspectors identified that 1991 calculations projected, under worst case conditions, that the CREVS may not have been able to maintain the control room temperature below the UFSAR value of 75.'F. This minor 10 CFR 50, Appendix B, Criterion XVIviolation was not cited.
5/27/98 VIO IR 98-02 VIO 98 08,09,10 N
ENG 4A 4B 4C NMPC's failure to properly maintain the control room emergency ventilation system design attributes and to properly'test the system to demonstrate operability in accordance with the UFSAR is a violation of 10 CFR 50, Appendix B, Criteria IIIand XI. (VIO 50-220/98-02-08,-
09, and -10). The immediate actions taken by the NMPC staff to initiate a detailed design review, implement interim compensatory measures, and to report this problem in accordance with 10 CFR 50.72 and 50.73 were determined to have been appropriate.
FROM: 10/1/97 TO: 10/1/98 13 of 24 April 9, 1999
Date Type Source ID SFA Code Item Descr/ptlon 5/27/98 Positive NCV IR 98-02 L
NCV 98-02-07 ENG 5A 5C 4C During their Generic Letter 96-01 review of safety-system logic testing, NMPC identified that portions of the loss of power/degraded voltage circuitry at Unit 2 were not being tested as required by TSs. Prompt and appropriate corrective actions were taken to demonstrate logic system operability. This licensee identified and corrected surveillance testing deficiency was not cited.
2/14/98 Positive 2/14/98 Positive IR 98-01 N
Part 21 IR 98-01 N
ENG 4B 3C ENG 5A 4B 3A NMPC responded quickly and appropriately to a vendor notification related to a possible failure of spring-return switches used in the emergency cooling and containment spray systems at Unit 1. Control room operators were aware of the potential failure mode; howeve~
the associated operating procedures were not revised to include a precautionary note related to the concern.
The licensee's actions at both units to address an industry concern with potentially defective emergency diesel generator air start solenoid valves was timely and technically sound.
2/14/98 2/14/98 NCV IR 98-01 L
Negative NCV 08-01-09 LER 97-16 NCV IR 98-01 L
Negative NCV 98-01-07 NCV 98-01-08 LER 97-13 ENG 2B ENG 5B 3C NMPC identified that a portion of the Unit 2 testing for the recirculation pump trip in response to an ATWS was not completed in accordance with the TS. Specifically, the logic system functional testing failed to include the high reactor pressure trip of the low frequency motor generator.
In addition, the failure to specify an acceptability range for the lower frequency motor generator time delay in the subsequent procedure change procedure indicated weaknesses in the procedure and in the review of the associated procedure change.
Furthermore, in December 1996, NMPC missed an opportunity to identify the inadequate surveillance test due to a non-conservative interpretation of the UFSAR. This licensee identified and corrected violation was not cited.
Prior to April30, 1992, Unit 2 operated with circuit breakers in the racked out position, and failed to recognize the adverse impact on switchgear seismic qualification and, therefore, switchgear operability. Although NMPC took appropriate actions in 1992 to preclude future operations with breakers in the racked out position, they failed to recognize that they were in an unanalyzed condition, and that the condition was reportable.
This licensee identified and corrected violation was not cited.
FROM: 10/1/97 TO: 10/1/98 14 of24 April 9, 1999
Date Type 2/1 4/98 VIO IR 98-01 N
VIO 98-01-06 ENG 5B 3C 2A Source ID SFA Code Item Description The inspectors identified that the temperature control valve for the Unit 1 control room emergency ventilation system had been inoperable since 1983. The administrative controls to disposition the failed valve had not been properly implemented; i.e., the controlled drawings did not indicate the inoperable valve, nor was an engineering evaluation performed, as required by procedures, to determine if continued operation with the degraded condition was acceptable.
This was a violation of TS 6.8.1.
1/23/98 NCV IR 98-01 N
Negative NCV 98-01-05 2/14/98 NCV IR 98-01 L
Positive NCV 98-01-04 1/23/98 Positive IR 97-.12 N
Part 21 Notification ENG 5A 3C ENG 3A 2B 4B ENG 4B 5B The inspectors identified that NMPC failed to perform a design change for permanently installed scaffolding. This minor procedural violation was not cited.
As a result of a good questioning attitude by a system engineer, NMPC identified that maintenance on the Unit 1 SW drag valve in the reactor building violated secondary containment integrity. Past maintenance on the valve exceeded the allowable LCO outage time, and a reactor shutdown had not been initiated in accordance with TS. This licensee identified and corrected violation was not cited.
The licensee's review of an industty concern regarding possible communication between the drywell and the wetwell was appropriate, and their evaluation of other possible evolutions which created a drywell-to-wetweii flow path was good. Actions taken at both units to address identified discrepancies were adequate.
1/23/98 VIO IR 97-12 L
ENG 4B VIO 97-12-07 5A LER 97-12 ENG 5A 4B 5B 1/23/98 NCV IR 97-12 L
Negative LER 97-12 NCV 97-12-06 The 1997 engineering review of the Unit 1 Safe Shutdown Analysis and Fire Protection Engineering Evaluation documents was good, in that it disclosed'previous engineering deficiencies, particularly that emergency lighting required to support alternate shutdown of the plant was missing. However, earlier reviews of these documents were weak in that they failed to identify these deficiencies.
This was a violation of 10CFR50, Appendix R.
Prior to September 1996, NMPC failed to monitor the Unit 2 relay room temperature, as required by TS. Furthermore, when the licensee identified this issue in 1996, they incorrectly
,dispositioned it, resulting in a failure to recognize that the condition was reportable, and missed an opportunity to identify other subsequently identified concerns related to the UFSAR description of the control room envelope.
This licensee identified and corrected violation was not cited.
1/23/98 VIO IR 97-12 L
VIO 97-12-05 LER 97-14 ENG 3A 4B 5A A Unit 2 reactor operator demonstrated a good questioning attitude in identifying that a TS required surveillance test for the rod sequence control system was inadequate.
This was a violation of TS4.1.4.2.b.1.
FROM: 10/1/97 TO: 10/1/98 15 of24 April 9, 1999
n
Date Type Source ID SFA Code Item Description 1/23/98 NCV IR 97-12 L
Negative LER 97-15 NCV 97-12-04 ENG 5A 5C 4B At Unit 2, NMPC's identification of a breach between an equipment qualification classified
. harsh environment area and a mild environment area, an original construction deficiency, was considered good. Particularly noteworthy was the recognition that in the event of a high energy line break, the breach could result in the potential loss of several safety-related systems.
Once identified, the licensee took appropriate actions to repair the breach and to verify no other similar openings.
This licensee identified and corrected violation was not cited.'/23/98 Positive 11/8/97 Positive IR 97-12 N
IR 97-11 L
ENG 4A 4B ENG 4B 11/8/97 NCV 11/8/97 VIO 11/8/97 VIO IR 97-11 L
NCV 97-11-05 IR 97-11 L
VIO 97-1 1-04 IR 97-11 L
VIO 97-1 1-05 LER 97-11 ENG 4A 2B ENG 2B 4A ENG 4B 2B 11/8/97 Positive IR 97-11 N
ENG 5A The Unit 1 modification of the EC keepfull system was well designed.
The modification was installed according to the drawings, and adequately tested.
An engineering safety analysis identified a NMP1 GEMAC level instrument reference leg leakage path which was appropriately resolved within the TS allowed outage time.
'APRM gain setting adjustments at both units were not performed in accordance with the respective TSs. This licensee identified violation of TS was not cited.
A design review team identified that the positive pressure surveillance test for the NMP2 control room envelope did not include the relay room. This was a violation of TS 4.7.3.e.2.
The discovery by NMP2 system engineers of missed surviellance testing of APRMs indicated a good questioning attitude; however, the failure to perform these surveillance tests was a cited violation of TS 4.3.1.2.
r NMPC's self-assessment of procurement activities was critical & in-depth.
10/4/97 NCV IR 97-07 L
NCV 97-07-05 LER 97-07 10/4/97 NCV IR 97-07 N
Negative NCV 97-07-04 ENG 2B 4A 5A 2A ENG 4C The interface between NMP1 smoke purge system and CREVS was inadequately evaluated during modifications in the early 1980s.
NMP1 operator's questioning attitude of the control room smoke purge System was very good & resulted in an engineering operability evaluation of the impact on control room emergency ventilation system operability.
Review in 1996 of the calculations to support the modification to bring the NMP1 blowout panels within the design basis identified minor calcuiational errors & corrective actions in early 1996 related to the NMP1.blowout panels design control concern had not been fullyeffective.
This violation of 10CFR50, Appendix B, Criterion IIIwas not cited.
10/4/97 Positive IR 97-07 N
ENG 4B NMP2 PRA associated with de-energizing one.of the two offsite 115 kVsupplies for planned maintenance accurately accounted for all equip out of service at the time of maint, 8 provided a thorough evaluation justifying the conclusion.
FROM: 10/1/97 TO: 10/1/98 16 of24 April 9, 1999
Date Type
~
Source ID SFA Code Item Description 10/4/97 NCV IR 97-07 N
Negative NCV 97-07-01 ENG 28 3A NMP2 ops considered a catch containment used to collect oil leaking from a RCIC pump gear box to be a permanent installation; however, contrary to NMPC procedure, a plant change.
request had not been initiated. This minor procedural violation was not cited.
8/5/98 Positive IR 98-06 N
PS 4C 5A 5C The licensee established, implemented, and maintained an effective ventilation system surveillance program.
8/5/98 Positive IR 98-06 N
PS 4C 28 3A The licensee established, implemented, and maintained an effective radiation monitoring system program with respect to electronic calibrations, radiological calibrations, system reliability, and tracking and trending.
7/7/98 Positive IR 98-05 N
PS 1C 5A 58 5C The DER system and the self-assessment program were effective in their use to identify,
'evaluate, and resojve radiological program deficiencies.
7/7/98 Positive IR 98-05 N
PS 1C 5A 5C The contractor laboratory continued to implement effective QA/QC programs for the REMP, and continued to provide effective validation of analytical results. The laboratory demonstrated the ability to accommodate and incorporate difficultmedia and geometries into the program. The programs are capable of ensuring independent checks on the precision and accuracy of the measurements of radioactive material in environmental media.
7/7/98 Positive IR 98-05 N
PS 7/7/98 Negative IR 98-05 N
4-PS 7/7/98 Positive IR 98-05 N
PS 7/7/98 Positive IR 98-05 N
PS 1C 28 3A 28 5A 3C 3C 1A 2A 1C ALARAgoals were effectively used as a tool to aid radiological planning to minimize radiation exposure.
Numerous ALARAinitiatives including publication of a pre-outage report, use of cameras, use of temporary shielding, planned reactor vessel nozzle hydro washes, and an attempt fo chemically decontaminate the reactor recirculation system demonstrated management support and a commitment to maintaining radiation exposures ALARA.
Procedure S-RPIP-5.4, "Dose Tracking and Timekeeping," lacked clarity with regard to the method for determining the available administrative extremity exposure, and several examples of inaccurate determinations of available administrative extremity exposure were identified.
Radiological controls for outage work were well planned and health physics personnel maintained close oversight of work.
Housekeeping was adequate in that aisles and walkways were clear and free of debris, radiological boundaries and postings were clear, and access controls to radiologically controlled areas. were effective.
FROM: 10/1/97 TO: 10/1/98 17 of24 April 9, 1999
xmE Mn.E > a.a PLY ISSUES Mxrlx Date Type 7/7/98 VIO Source ID SFA Code IR 98-05 N
VIO 98-05-06 PS 2B 3A 5A 7/7/98 Positive IR 98-05 N
PS 1A 2B 3A 3C 5/27/98 Positive IR 98-02 N
PS Item Descr1pt/on Overall, the licensee effectively maintained meteorological monitoring system operability, and satisfactorily performed channel calibrations and channel functional tests for the meteorological instrumentation, with the exception of the wind speed channel.
The failure to perform the channel calibration of the wind speed channel according to the channel calibration definition in TS 1.4, in that the accuracy of the entire wind speed channel was not measured from the sensor to the channel output, constitutes a violation of Unit 2 TS 3/4.3.7.3.
The licensee effectively maintained and implemented the Radiological Environmental Monitoring Program in accordance with regulatory requirements.
The licensee performed a comprehensive review of an anomalous indication of Iodine 131 in an environmental milk sample.
Radiological controls for the Unit 1 1998 Fuel Pool clean out project were thorough and sound, and included lessons learned from industry events and close health physics oversight.
5/27/98 Positive IR 98-02 N
PS 2B Radioactive calibration and check sources were well controlled in that procedural guidance for 3C the control and issuance of radioactive sources was clear, storage cabinets for radioactive sources were securely locked, sources were stored in a neat and orderly fashion, and source issuance records for 1998 were complete.
4/21/98 Positive IR 98-08 N
PS
. 1C 2A The licensee was conducting security and safeguards activities in a manner that protected public health and safety in the areas of access authorization, alarm stations, communications, and protected area access control of personnel and packages.
This portion of the program, as implemented, met the licensee's commitments and NRC requirements.
4/21/98 Positive IR 98-08 N
PS 4/21/98 'ositive IR 98-08 N
PS 4/21/98 Positive IR 98-08 N
PS 2A 2B 3A 3B 1A 1C The licensee's security facilities and equipment in the areas of protected area assessment aids and personnel search equipment were determined to be well maintained and reliable and~
were able to meet the licensee's commitments and NRC requirements.
The security force members (SFMs) adequately demonstrated that they have the requisite knowledge necessary to effectively implement the duties and responsibilities associated with their position. Security force personnel were being trained in accordance with the requirements of the Plan and training documentation was properly maintained and accurate.
The level of management support, in general, was adequate to ensure effective implementation of the security program, and was evidenced by adequate staffing levels and the allocations of resources to support programmatic needs.
FROM: 10/1/97 TO: 10/1/98 18 of24 April 9, 1999
J
Date Type 4/21/98 EEI Source IR 98-08 EEI 98-08-01 EEI 98-08-02 4/21/98 NCV IR 98-08 Negative NCV 98-08-03 ID SFA Code N
PS 5A 5C N
PS 1C 5A Item Description The effectiveness of licensee management controls relative to the administration of the security program was a weakness.
Management's less than aggressive actions to address and resolve the issues associated with the improper control and storage of SGI resulted in two apparent violations of NRC requirements.
The first apparent violation was as a result of the licensee's failure to properly control, store, and classify safeguards information (SGI) and the second apparent violation was as a result of the licensee's failure to properly report the violation in accordance with the requirements of 10 CFR 73.21.
In 1996 and 1997, the licensee failed to conduct unannounced drug and alcohol testing at an annual rate equal to at least 50% of the work force as required by 10 CFR 26.24(a)(2).
However, the NRC has determined to exercise discretion and refrain from issuing a violation but willissue an NCV.
3/13/98 VIO IR 98-04 VIO 98-04-02 S
PS 1C 3C One violation of transportation regulations (10CFR71.5) was identified involving the release of vehicle (flat-bed trailer) for unrestricted use, that exceeded the radiation limits specified in 49CFR173.443.
3/13/98 Positive IR 98-04 1/23/98 Negative IR 98-01 N
PS 1C N
PS 1C 3A 5A A generally effective program for the collection, processing and return to the plant of liquid wastes, and for the collection, processing, storage and transportation of radwaste was established.
Control room and fire brigade personnel appropriately responsed to numerous Unit 1 fire alarm actuations, and the investigation efforts appeared adequately coordinated.
- However, the failure to fullyinvestigate and resolve previous similar false fire protection system actuations was a weakness and likelycontributed to the recent event. Although Unit 1 fire suppression system operabiiity did not appear to be affected by degraded components, the impact of the deficiencies could hinder plant personnel responding to an in-plant fire due to potential multiple false alarms.
1/23/98 VIO IR 97-12 VIO 97-12-09 LER 97-13 S
PS 3A An inadvertent automatic isolation of the Unit 1 drywell vent and purge lines, occurred due to 1C
personnel inattention-to-detail, particularly a failure to followprocedure.
This was a violation of TS 6.8.1.
1/23/98 Positive IR 97-12 N
PS 2A 1C An inspection of normally inaccessible areas of the Unit 2 reactor water cleanup system found the material condition of the equipment to be satisfactory, with the condition of the equipment in the valve aisle to be particularly good. Housekeeping in the areas inspected was acceptable, and appropriate radiological controls were established.
FROM: 10/1/97 TO: 10/1/98 19 of24 April9, 1999
Date Type 11/8/97 Negative Source IR 97-11 URI 97-11-08 ID SFA Code N
PS 2A 4C Item Description NMP2 radwaste facilityfire-door removed for over 3 years without being evaluated as a permanent modification. This was considered a weakness in the licensee's breach permit program to have allowed this permit to remain open. This issue was left unresolved pending further NRC review.
11/8/97 NCV IR 97-11 Negative NCV 97-11-07 11/8/97 Positive IR 97-11 N
PS 1C L
PS 3A 1C A QA audit of the security program was comprehensive in scope &depth. NMPC security &
safeguards programs were effective & received management support.
Inattentiveness to postings within the RCA resulted in an NMP2 employee &three visitors entering a posted HRAwithout authorization.
This licensee identified and corrected violation was not cited.
11/8/97 Positive IR 97-11 N
PS 3B 3C 11/8/97 Positive IR 97-11 N
PS 3A NMP2 operator performance during examinations was generally good, although communications &.command/control were noted weaknesses.
NMP2 licensed operator requalification training program was effective &the remedial training program remained strong.
During NMP2 LORT event recognition 8 diagnosis, understanding 8 interpreting alarms, board manipulations, TS usage, event classification performance were good. Facility evaluator's assessments were objective &thorough.
10/4/97 Positive IR 97-07 N
PS 1C 3C Plant personnel were trained 8 equipped to combat a control room fire.
10/4/97 Positive 10/4/97 SL-III 10/4/97 Negative IR 97-07 IR 97-07 EA 97-530 IR 97-07 EA 97-530 N
PS 1C 1B S
PS 5A 3A 3C N
PS 5A NMP security personnel response to a 'suspicious looking" package was acceptable.
Declaration of an UE by the NMP2 SSS was appropriate & in accordance with the NMP2 Emergency Plan.
On three different occasions, NMPC inadequately controlled shipments of radiological material to facilities offsite. 1) shipment shifted during transport &caused radiation levels in occupied space of truck to exceed limits; 2) a wrong liner of low-level radwaste was shipped offsite for disposal; 3) a sample was shipped to an unlicensed facility-a similar occurrence happened in 1995. Allof the examples appeared to be due to a lack of procedures describing radwaste operator activities, inattention-to-detail, &a lack of supervisory oversight.
(Escalated Enforcement docketed per NRC letter dated 1/22/98, Violations 97-530-1013, 1023, 1033, and 1034 issued.
EEls 97-07-07, 09, and 10 closed.)
A number of required audits of vendors providing shipping casks were not performed, indicative of a lack of attention by management oversight.
(EEls 97-07-1 2 and13 withdrawn, 1/22/97)
FROM: 10/1/97 TO: 10/1/98 20 of24 April 9, 1999
k,
Date ape Source ID SFA Code Item Description 10/4/97 Negative IR 97-07 N
EA 97-530 PS 5C 1C QA program failed to identify the defects within the unit specific PCPs, 8 in one instance failed to ensure that corrective actions were taken to address an identified defect, indicative of a lack of attention by management.
(EEI 97-07-11 withdrawn, 1/22/97) 10/4/97 Positive IR 97-07 N
PS 2A At NMP2, plant conditions were generally very good relative to radiological housekeeping in radwaste.
10/4/97 Negative IR 97-07 N
EA 97-530 10/4/97 Negative IR 97-07 N
PS 3C
.2A PS 5A 3A 3C The lay-up of the NMP1 N11 waste concentrates tank was questionable.
Indicative of lack of attention by management.
The Process Control Programs and associated procedures have not been properly maintained.
Indicative of a lack of attention by management.
(EEI 97-07-06 withdrawn, 1/22/97) 10/4/97 Positive IR 97-07 N
PS 1C 10/4/97 Positive IR 97-07 N
PS 5A At both units, good programs have been established for the processing of liquid &solid radwaste.
QA oversight of the RP, ALARA,contamination control, & external dosimetry programs was well implemented; audits 8 self-assessments were of appropriate scope &technical depth.
10/4/97 Positive IR 97-07 N
PS 1C RP program area was being well-implemented at both units.
10/4/97 VIO IR 97-07 L
VIO 97-07-02'S 3A NMP1 RP staff inattention-to-detail &failure to self-check a completed surveillance test data sheet resulted in the failure to perform a ventilation radiation monitor instrument channel calibration within the required frequency. This was a violation of TS 4.6.2.a.
10/4/97 Positive IR 97-07 N
PS 1C 5A 10/4/97 Positive IR 97-07 N
PS 1C-t Radiological controls during NMP1 EC condenser repair activities were satisfactory.
Questioning attitude of NMP1 chemistry tech & heightened sensitivity of NMP1 staff to the possibility of an EC condenser tube leak were good.
FROM: 10/1/97 TO: 10/1/98 21 of 24 April9, 1999
ABBREVIATIONSUSED IN PIM TABLE C~VS EC As~ as 9i'easonaNjAct'u'evade Average Tower +ange >Monitor Code offederal gepd'ations Control'god'&riv Control goom Kmergnuy'Venfi(ation System Emergency Cooing goreijn 5lktenal Kgfusion hydrogen Xjh9i'adiation gaea Instrumentation O'Control'ine%ik Power Corporation guc/ear 9i'egu/atoryConunission
&obabalisticgisg~essment
@pa(i ty~rance Standky Liquid'Control'System Senior ShiftSupervisor GnusuaE Event Anticipated'transient without scram
'technical'Speci~'ions DmitingCondi'tionforOperation Service Dater Safetygdief 'Valve FROM: 10/1/97 TO: 10/1/98 22 of 24 April 9, 1999
C9i'0 9i'enate S/rutdownPanel Condensate Storage 9ara(
Controtgoom Operator Gpdated'ginalSafety rbralysis 9i'@port FROM: 10/1/97 TO: 10/1/98 23 of24 April 9, 1999
Date Type Source ID SFA Code Item Description GENERAL DESCRIPTION OF PIM TABLECOLUMNS r
The actual date of an event or significant issue for those items that have a clear date of occurrence (mainly LERs), the date the source of the information was issued (such as for EALs), or the last date of the inspection period (for IRs).
The categorization of the item or finding - see the Type/Findings Type Code table, below.
The document that describes the findings: LER for Licensee Event Reports, EALfor Enforcement Action Letters, or IR for NRC Inspection Reports.
identification of who discovered issue: N for NRC; Lfor Ucensee; or S for Self Identifying (events).
SALP Functional Area Codes: OPS for Operations; MAINTfor Maintenance; ENG for Engineering; and PS for Plant Support.
Template Code - see table below.
Details of NRC findings on LERs that have safety significance (as stated in IRs), findings described in IR Executive Summaries, and amplifying information contained in EALs.
TYPE/ FINDINGS CODES TEMPLATE CODES ED Strength Enforcement Discretion - No Civil Penalty Overall Strong Licensee Performance Operational Performance: A - Normal Operations; B - Operations During Transients; and C - Programs and Processes Weakness Overall Weak Licensee Performance 2
Material Condition: A-Equipment Condition or B - Programs and Processes EEI
'lo NCV DEV Positive Negative Escalated Enforcement Item - Waiting Final NRC Action Violation Level I, II, III,or IV Non-Cited Violation Deviation from Licensee Commitment to NRC Individual Good Inspection Finding Individual Poor Inspection Finding Human Performance: A-Work Performance; B - Knowledge, Skills, and Abilities/
Training; C - Work Environment 4
Engineering/Design: A-Design; B - Engineering Support; C - Programs and Processes 5.
Problem Identification and Resolution: A-identification; B - Analysis; and C-Resolution NOTES LER URI" Licensee Event Report to the NRC Unresolved Item from Inspection Report Licensing Licensing Issue from NRR MISC Miscellaneous - Emergency Preparedness Finding (EP),
Declared Emergency, Nonconformance Issue, etc. The type of all MISC findings are to be put in the Item-Description column.
EEls are apparent violations of NRC requirements that are being considered for escalated enforcement action in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Action" (Enforcement Policy), NUREG-1600.
However, the NRC has not reached its final enforcement decision on the issues identified by the EEls and the PIM entries may be modified when the final decisions are made.
Before the NRC makes its enforcement decision, the licensee willbe provided with an opportunity to either (1) respond to the apparent violation or (2) request a predecisional enforcement conference.
URls are unresolved items about which more information is required to determine whether the issue in question is an acceptable item, a deviation, a nonconformance, or a violation. However, the NRC has not reached its final conclusions on the issues, and the PIM entries may be modified when the final conclusions are made.
FROM: 10/1/97 TO: 10/1/98 24 of24 April 9, 1999
Page:
63 of 104 tNCLUDES DRAFT lTEMS Region I
NINEMILEPOINT United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Dare: u.uuu.>>>>
Time: 13:57:03 Functional Date Source Area 01/02/1999 1998019 Prl: OPS Sec:
Template ID Type Codes NRC POS 'ri:1B Sec: 3A Ter:
item Title item Description Good operator performance.
On November 24, 1998, Unit 2 was shutdovm to troubleshoot and repair the reactor recirculation system flow control valve. During the plant shutdown and subsequent startup, the operators'erfonnance was geneaiiy good as evidenced by clear three-way communications, appropriate use of procedures and sufficient management oversight and control.
(Section 01.4) 01/02/1999 1998019 Prl: OPS Sec:
Self POS Prl: 1B Sec: 3A Ter.
Inadvertent control rod Insertion well responded to by opeators.
On December 30, 1998, a control rod inadvertently inserted as a result ofa failed component associated with the control rod drive system.
Unit 2 operators responded very well to the abnormal. combination ofalarms that were received and took conservative actions.
Good communication between operators and good management oversight were noted.
(Section 01.5) 01/02/1999
. 1998019 Prl: OPS Sec: MAINT NRC POS PrL18 Sec:
Ter.
Good focus on shutdown risk.
A good focus on shutdown risk was evident during the Unit2 forced outage to repair the reactor recirculation system flowcontrol valve. (Section 02.1) 01/02/1999 199801941 Prl: OPS Ucensee NCV Prl: 1B Sec: MAINT Sec:
Ter.
Failure to complete JS sruvelliance test forSRMs and IRMs during shutdown.
On November 23, 1998, Unit 2 failed to complete the required technical specification suiveillance tests for source range monitors and Intermediate range monitors during a plant shutdown.
Sufficient controls were not in place to ensure that requirements were met; specifically the shutdown procedure was weak. This licensee-identified and corrected noncompliance is being treated as a Nonunited Violation. (NCV 50-410/98-1941) (Section 08.2) 11/21/1998
. 1998015 Prl: OPS
'RC POS Sec:
Prl: 1A Sec:
Ter.
Loop recovery preps were good.
Unit 2 preparations forthe recovery from single loop operations that resulted from the November 13, 1998 recirculation fiowcontrol valve failure were well performed. The use ofsimulator training for Unit 2 operators in anticipation of recovery from single loop operations was considered good. (Section 01.3) 11/21/1998 1998015 Prl: OPS NRC POS Pri: 1B
. Sec:
Sec:
Ter.
Control room operator response to reclrc flowcontrot valve closure On November 13, 1998, the Unit 2 "B"reactor recirculation flowcontrol valve failed closed. Control room operator response to the rapid reduction in power vras good. The operators demonstrated a good awareness of the potential for power oscillation due to the power-to-flow condition resulting from the transient.
(Section 01.2) 11/21/1998 1998015 Prt: OPS Sec:
NRC POS Prl: 1B Sec:
Ter.
Operator response to single rod scam good Operator response to a single control rod scram on November 11, 1998 at Unit 2 was good. Technical speciTication and procedure requirements were appropriately implemented. (Section 02.1)
~ii.i r. ~ ~nin1rcag/I To 01/15/1999
Page:
64of104 INCLUDES DRAFT ITEMS Region I
NINEMILEPOINT United States Nuclear Regulatory Commission
. PLANT ISSUE MATRIX By Primary Functional Area Date: 03/02/1999 Time: 13:57:03 Date Source Functional
. Area Template ID Type Codes Item Title Item Description 11/21/1998 199801541 Prl: OPS Licensee NCV Pri:
Sec:
Sec:
Ter.
UNIT 1 POOR REACTIVITYMANAGEMENTDURING ROD SEQUENCE EXCHANGE.
Poor reactivity management at Unit 1 resulted ln a control rod being established in an incorrect position during a control rod sequence exchange.
Specifically, personnel error during the development of the control rod movement sheets caused the control rod to be ln a position that was not as previously planned.
The licensee identiTied and corrected violation ls being treated as a Non<ited Violation (NCV), consistent with Section VILB.1 of the NRC Enforcement Policy. (NCV50-220/98-1541)
(Section 01.4) 11/21/1998
- 199801542 Prl: OPS Sec:
NRC NCV Sec:
Ter.
UNIT2 STANDBYLIQUIDCONTROL SYSTEM INOPERABLE DUE TO A VALVEINADVERTENTLYLOCKED CLOS On September 11, 1998, the Unit 2 operations staff identified and promptly corrected the improper positioning of a manual isolation valve to the suction of the Division II standby liquid control system pump. The licensee determine~
that the valve was locked dosed vice locked open, since the performance of surveillance testing on August 27, 199~
This licensee identiTied and corrected violation ofTechnical Specification 3.1.5.a.1 (reference LER No. 5M10/98-25) is being treated as a Nonited VIolation (NCV), consistent with Section VII.B.1 of the NRC Enforcement Policy. (NCV 50410/98-1542) (Section 08.1) 01/02/1999 1998019 Prl: MAINT NRC
~
NEG
'rl:
'ec:
Sec:
Tel".
Weak surveillance test procedures.
During routine observations ofsurveillance testing at Unit 2, two surveillance test procedures were determined to be weakin that specific procedure steps lacked clarity. Personnel were capable of completing the procedures; however, there was the potential to misunderstand what the required actions were. (Section M3.1) 11/21/1998 1998015 Prl: MAINT NRC NEG Prl: 2A Sec:
Sec:
Ter:
Material condition of reclrc flowcontrol system poor.
The material condition ofthe Unit 2 reactor recirculation flowcontrol system was poor as evidenced by the numerous deficiencies identiTied by Niagara Mohawk Power Corporation during troubleshooting of the November 13, 1998, flow controI valve failure. (Section M1.3) 11/21/1998
. 1998015 Prl: MAINT NRC POS Sec:
Prl: 3A Sec:
Tef:
Troubleshooting ofsingle rod scram reasonable.
Unit 2 troubleshooting efforts for the single control rod scram on November 11, 1998 were reasonable.
Although a~
definite cause could not be determined, corrective and preventive actions were appropriate.
(Section M1.2) 10/14/1998 1998018 Prl: MAINT NRC NEG Pri: 2B Sec:
Sec: 2A Ter:
IN 95-22 lack of follow-up was a missed opportunity.
Satisfactory progress had been made in refurbishing safety-related 4.16 kV Magne-Blast breakers.
Although the licensee's planned actions to refurbish safety-related ABB Type HK breakers and safety-related ABB K-Line breakers on an accelerated basis were acceptable, the licensee's previous poor review of Information Notice 95-22 reflected a missed opportunity to establish a more timely refurbishment program. As a result, many ABB K-Line breakers exceeded the 10-year recommended interval for refu*ishment and showed indication of lubrication degradation.
(M2.3) 10/14/1998 1998018 Prl: MAINT NRC Sec:
NEG Prl: 2B Sec: 5A Ter.
Licensee's operating experience review program was weak.
The licensee's operating experience review (OER) program to review industry events and problems was weak.
In many cases, the reviews were narrowly focused, without considering generic applicability. Some reviews were performed by personnel not familiarwith plant equipment, resulting ln inappropriate conclusions.
Although some of the weak reviews were identified by the licensee ln their self-assessment audits, the team identified additional examples.
The past incomplete reviews missed the opportunities to prevent two breaker failures. The OER program procedure did not provide guidance fordetail reviews to determine generic applicability of NRC INs. (M6.1)
Page:
55 of 104 INCLUDES DRAFT ITEMS Region I
NINEMILEPOINT United States Nuclear Regulatory Commission PLANTlsSUE MATRIX By Primary Functional Area Date: 03/Od1 999 Time: 13:57:03 Date Source Functional
'rea Template ID Type Codes Item Title Item Description 10/14/1998 1'9'98018 Prl: MAINT NRC NEG Sec:
Prl: 2B Sec: 5A.
Te r.
Vendor Interface was weak.
The licensee's vendor interface program for medium-voltage and low-voltage breakers was weak. The vendor manual binders were poorly organized, incomplete and contained Irrelevant materials. The licensee's "periodicintact" of breaker vendors was ineffective. There were cases where incorrect vendor department or Inappropriate vendor personnel were contacted.
Although many ofthe examples were identified by the licensee ln their self-assessment audits, others were identified by the NRC team.
(M6.2) 10/14/1998 1998018 Prl: MAINT NRC POS Sec:
Prl: 2A Sec:
Ter.
Physical condition of breakers good The physical condition ofsafety and nonsafety-related breakers was good. The switchgear was located In dean, weil maintained and adequately lighted areas.
The technicians performing breaker testing were knowledgeable and familia with breaker test requirements.
The safety-related breakers at NMP2 had performed acceptably dunng the past five years. (M2.1 ~ M2.2) 1 0/14/1 998 1 99801 8 Prt: MAINT NRC POS Sec:
Prl: 2B Sec:
Ter:
Treatment of breakers under the Maintenance Rule was consistent with Industry practise The licensee's treatment ofpower circuit breakers under the Maintenance Rule (MR)was consistent with MR requirements and industry practices The licensee's dose review of breaker performance by class associated with standard-MR-performanceeonitoring had helped to identify and to provide prompt corrections of common breaker problems caused by inadequate preventive maintenance in the past.
(M6.3) 10/14/1998 1998018 Prl: MAINT NRC
~
POS Prf: 2B Sec:
Sec: 3A
'I Ter.
PM program for med-voltage and Iow-voltage breakers was generally good.
The licensee's PM programs for medium-voltage and low-voltage breakers were generally good and had incorporated most vendor-recommended preventive maintenance actions, and recommendations identified in NRC Information Notices (IN). The Magna-Blast breaker procedures had been recently improved to Indude reduced~ntrol-voltage" testing. Examples In which procedures deviated from accepted Industry practices were identified. During the inspection, the licensee initiated acUons to Indude further Improvements to the procedures.
(M3.1. M3.2) 10/14/1S98 1998018 Prl: MAINT Sec:
NRC
'POS Prl: 2B Sec: 5A Ter.
Seifcssessments ln the area of med-and low-voltage breakers were good.
The licensee's self-assessment audits for the medium-voltage and low-voltage breakers program were good, resulting in many significant findings in the operating experience review and breaker vendor interface areas.
The audit reports w~
ofgood quality. However, at the time ofthe inspection, Ne resolutions for most of the audit findings were not yet complete. Also, the team Identified additional examples of problem in areas identified by the licensee as being weak.
(M7.1) 10/14/1998 1998018 Pri: MAINT NRC Sec:
POS Pri: SA Sec: 5C Ter.
WRs and DERs Involving breakers were well documented.
The work requests and Deviation/Event Reports (DER) were well documented.
Corrective actions were appropriate and timely. The. root cause evaluation and apparent cause evaluations were well documented, thorough, and contained appropriate recommended corrective actions. (M4.1) 01/02/1999 199801942 PrL ENG Ucensee NCV Prl: 4B Sec:
Sec:
I Ter.
DINcultles ln controlling Unit 2 reactor vessel water level during startup.
An inadequate review associated viiththe Unit 2 depleted zinc oxide injection modification, installed in June 1998, resulted In an unexpected rise in reactor vessel water level during the November 30, 1998, plant startup. This licensee identified and corrective violation ofdesign control was treated as a no~ed violation. (NCV5M10/98-1S42) The Unit 2 review ofthe unexpected rise in reactor vessel water level was technically sound and NMPC appropriately revised the operating procedures to prevent recurrence.
However, a weakness was noted with the documentation of corrective action In the deviation/event report in that the evaluation did not Indude the ongoing evaluation of the modification process.
(Section E1.2)
~<<<<l(hho Tp ri$r$ qgaaq
Page:
68 of 104 INCLUDES DRAFT ITEMS Region I
- NINE MILEPOINT United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Date: 03/02/1999 Time: 13:57:03 Date Source Functlonal-Area Template ID Type Codes Item Title Item Description 01/02/'1999 1'99801944 Prl: ENG Ltcensee NCV Prl: 4A Sec:
Sec: 4C Ter.
Systems did not meet design requirements due to pIpe stresses.
Niagara Mohawk Power Corporation demonstrated a good questioning attitude when they identified that the weight of 522 safety-related valves at Unit 2 was greater than the weight shown on the vendor valve drawings.
Following a comprehensive and thorough evaluation, the licensee determined that a total of five valves within residual heat removal, reactor core isolation cooling and reactor building floordrain systems caused the associated piping not to meet design requirements under all conditions.
01/02/1999
'199801945 Prl: ENG.
Licensee NCV Prl: 4A Sec:
Sec: 4C Tef:
11/21/1998
'1998015 'rl:ENG NRC NEG Prt: 4B Sec:
Sec: 5A Ter. 5C RCIC logic design deficiency.
Niagara Mohawk Power Corporation demonstrated a good questioning attitude during their Generic Letter 9641 revi by identifying an unrelated discrepancy assodated with three motorwperated valves within the Unit 2 reactor core isolation cooling system.
Spedfically, the seaHn contacts within the control circuits of these valves were in series overload relay contads.
Should the overload relays trip ln conjunction with a transitory RCIC Initiation signal, the seal-in function would have been lost, rendering the system incapable of performing the design function. This discrepancy existed from initialplant staitup until itwas unknowingly corrected by an unrelated modification in December 1993.
Poor management oversight to complete timely repaIrs The failure to complete timely repairs to the Unit2 redrculatton system fiowcontrol valve isolation coils indicated poor management oversight. Work priorithatton failed to recognize the impact that the faited recirculation system hydraulic power unit isolation coils could have on reactivity control. (Section E1.1) 11/2'I/1998 '998015 Prl: ENG Sec:
NRC POS Prt: 4B Sec:
Ter.
Engineering troubleshooting of reclrc flowcontrol valve methodtcaL Unit 2 troubleshooting was methodical, thorough and provided a technically sound explanation of the failure of the redrculation system flowcontrol valve to lock in the as-is position during the event.
However, the initiating cause of the event was not positively ldentiTied. (Section E1.1) 11/21/1998 199801543 Prl: ENG Sec:
NRC NCV Sec:
Ter.
UNIT2 SINGLE FAILURECRITERION FOR SPENT FUEL POOL COOLING.
White this inconsistency represented a violation of 10 CFR 50, Appendix B, Criterion III,"Design Control," it was no condition that could have reasonably been prevented by corrective actions for previous similar violations.
This licen identified and corrected violation ls being treated as Non<ited Violation consistent with Section VII.B.1 of the NRC Enforcement Policy. (NCV5$410/98-1543) 11/21/1998 199801544 'rl:ENG Sec:
NRC NCV Pri:
. Sec:
Ter.
UNIT2 INOPERABLE GASEOUS EFFLUENT MONITORINGSYSTEM.
From September 29, 1998 unUI October 8, 1998, the Unit 2 main stack effluent monitoring instrumentation portion of the
~
gaseous effluent monitoring system was inoperable. The cause was that an alternate power supply had been established to facititate maintenance, but was inadequate.
NMPC determined that a tack of rigor during the technical review process contributed to the problem.
Proper corrective actions were taken. The inadequate development of the alternate power suppty was determined to be a violation of.10 CFR 50, Appendix B ~ Criterion III,"Design Control.
However, this licensee identified and corrected violation is being treated as a Non-Cited Violation, consistent with Section VII.B.1 ofthe NRC Enforcement Policy. (NCV5M10/98-1544) (Section E8.3)
~
iathaot heal T hll4ClihhO
Page:
57 of 104 INCLUDES DRAFT ITENIS Region I
NINEMlLEPOINT United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Do.e: C~W81999 Time: 13:57:03 Functional Date Source Area 11/02/1998 199S01641 Prl: ENQ Sec:
11/02/1998 199801642 Prl: ENQ Sec:
10/26/1998 1998016 Prl: ENG Sec:
Template ID
=
Type Codes NRC URI Pri: 4A Sec: 4C Tef:
NRC VIO IV Prl: 4B Sec: 5A Ter.
NRC
- POS Pri: tC Sec: 3A Ter.
Item Title Item Descrlptlon Licensee evaluation did not consider potential Issues associated with a change involving an unrevlewed safety The safety evaluations for several plant modiTications and procedure changes reviewed by the team were appropriately performed. Appropriate screenings were performed to determine ifthe changes required further evaluation in accordance with 10 CFR 50.59. Safety evaluations were thorouqh and provided good bases that supported the condusions.
However, one notable exception, which was associated with a core spray system moddication, was identified by the team. The safety evaluation for this modification did not fullyconsider issues that may result from operating with the test return valve in the open position during redrculation. These issues induded human factor considerations for new operator actions, Impact of potential bypass flow on the torus and piping to the torus, and the potential forwater hammer In the core spray piping. This Issue was left unresolved pending further review of the Nine Mile Unit 1 licensing basis.
(URI 50-220/9801641) (Section E1.3)
Failure of licensee to Identify and correct a lowflowcondition to a core spray pump motor cooler.
The team concluded that the engineering response to emergent issues documented in DERs was generally effective.
In general, the DERs reviewed by the team were appropriately resolved, and drawings, procedures and other documents were updated, as needed.
However, the evaluaflon of Indications of reduced motor cooler flow, as documented in DER 1-98 2185, was not timely or effective. Although multiple opportunities since March 4, 1996, were available, the flcensee did not Identifythat this deficiency resulted in pump inoperability until questioned by the NRC.
The failure to identify and implement prompt corrective acUons is a violation of 10 CFR 50, Appendix B, Criteria XVI, Corrective Action. (VIO50-220/9841642) (Section E1.7)
Engineering adequately assured design and licensing basis was met.
Engineering adequately assured that the systems inspected met the design and license bases and regulatory requirements.
Design inputs and assumptions were appropriate, engineering work was technically correct and engineering outputs were translated into the applicable drawings and procedures.
Several surveillance test procedures, which were reviewed, were appropriately apphed to meet the technical specification requirements and consistent with their respective design bases documents. (Sections E1.1 and E1.4) 10/26/199S 1998016 Prl: ENG.
Sec:
NRC:
POS Prl: 4C Sec:
Ter.
Design, Implementation, and testing ofmodlfications has been generally effective.
The design, implementaUon and testing of modmcations has been generally effective. However, two design deficiencies related to the Unit 2 gas treatment system, which were designated by the hcensee as low priority, were longstanding and have resulted in unnecessary operator burdens and reduced system availability. (Section E1.2) 10/14/1998 1998018 Prl: ENG Sec:
NRC NEG Pri: 4B Sec: 3A Ter.
Control circuitvoltage drop calculations were weak.
The licensee's contro&ircuit-voltage4rop calculations were weak. The calculations required several corrections during the team's reviews. The basis for assuring safety-related breakers had sufficient control-voltage for proper breaker operations was Initiallynot well developed, and required the development of an operability determination and additional ~
revised testing of the breakers.
(E8.1) 11/21/199S-1998015 '
Prt: PLTSUP NRC NEG Sec:
Prl: 3A Sec:
Ter.
June 17 security event-performance weakness.
On June 17, 1998, a security force member lett a post prior to ensuring that the intrusion detection aids were functioning properly. The inspector concluded, based on observation of the area in question, discussions with security supeivlsion, and procedural reviews, that there was no violation of NRC requirements as security was not compromised.
However, procedural weakness were noted which were associated with the deactivating and securing of intrusion detection aMs. (Section S2) n.
~..
~i -<<r. ~ cnun anon Athor't Fmm 10/01/1998 To 01/15/1999
I
Page:
68 of 104 INCLUDES DRAFT ITEMS Region I
NINE MILEPOINT United States Nuclear Regulatory Commission PLANTISSUE MATRIX By Primary Functional Area Date: 03102/1999 Time: 13:57:03 Functional Template Item Title Date Area ID Type Codes Item Description 4
11/21/1998 1998015 Prl: PLTSUP NRC POS Prl: 1A Sec:
Sec:
Tel.
Outage ALARAwas good+
Unit 2 effectively planned and implemented specific ALARAinitiatives during the shth refueling outage Including hot spot and system flushes, reactor vessel nozzle hydrowashes, and temporary shielding. However, the overall ALARA goal for 1998 was exceeded due to deflcfendes in planning, coordination and communication of outage work; a 24%
increase ln outage scope growth; and cancellation of a planned chemical decontamination of the recirculation system.
(Section R1)
'11/21/1998 1998015 Prl: PLTSUP NRC POS Prl: 1C Self assessments In the RP area effective.
Sec:
Sec:
Deviation event reports, self-assessments, and quality assurance audits were effectively used to identify a dedining trend in the radiation dosimetry program and to initiate corrective actions.
(Section R7 Ter.
11/21/1998 1998015 Prf; PLTSUP NRC POS Prl: 2B Sec:
Sec:
Ter.
Good ALARAnoted.
Unit 1 exhibited effective performance in maintaining radiation exposures as low as is reasonably achievable (AIARA)
In 1998 as evidenced by being on pace to recehre the lowest collective dose in station history ln spite of significant challenges Indudlng a forced outage, a deanup ofthe spent fuel pool, and on-'line level sviitch work in feedwater heater bays. (Section R1) 1 1/21/1 998 1 998015 Prl: PLTSUP
. NRC POS Sec'rl:
2B High Rad access control good, and housekeeping effective.
Sec: 2A Access to high radiation areas was effectively controlled with radiation work permits, health physics briefings, and locked doors. Housekeeping was effecUveiy maintained as evidenced by dear aisles and walkways ln both Unit 1 and 2 reactor buildings. Efforts to Improve material condNons ln the Unit 1 No. 1 1 concentrated waste tank room was effective in that encrusted concentrates had been removed from floors and piping, and the room was cleared of loose
, debris Including paper, trash, and asbestos.
(Section R2) 11/21/1998 1998015 Prl: PLTSUP NRC POS Prl: 4C DERs effectivel used to address RP problems.
Sec:
Sec: 5A Deviation event reports were effectively used to document, evaluate, and resolve radioactive waste and transportatio issues as evidenced by thorough reviews, accurate causal analyses, and corrective actions which specifically addr T<<5C identified root causes.
(Section R7) r n,,
PHL A cw~ ~nrn<naon Tn 01/15/1999
ENCLOSURE 2 NINE MILEPOINT INSPECTION PLAN INSPECTION IP 86750 IP 37700 IP 83750 IP 73753
', TI 2515-Y2K IP 61725 IP 37750 IP 84750 IP 83750 IP 71001 IP 37550 U01255 U01255 TITLE/PROGRAM AREA Solid Rad. Waste Management and Trans ortation of Radioactive Material Design Changes and Modifications Occupational Radiation Exposure Outa e
Inservice Inspection Review of Year 2000 Readiness for Computer Systems at Nuclear Power Plants Surveillance Testing and Calibration Control Pro ram Engineering Radioactive Waste Treatment, and Effluent and Environmental Monitorin Occupational Radiation Exposure Non-Outa e
Licensed Operator Requalification Pro ram Evaluation Engineering Initial Operator License Examination Pre arations Initial Operator License Examinations PLANNED DATE 04/05/99 04/12/99 04/12/99 04/1 9/99 05/31/99 TBD 08/23/99 09/06/99 09/1 3/99 11/01/99 11/15/99 11/15/99 12/06/99 INSPECTION TYPE Core Ins ection Regional Initiative Core Ins ection Core Ins ection Safety Issue Review Regional Initiative Core Team I'ns ection Core Ins ection Core Ins ection Core Ins ection Regional Initiative Operator Licensin Operator Licensin
)
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