ML18018B077

Letter Replying to Notice of Violation as Contained in NRC Inspection Report 50-220/97-07 and 50-410/97-07

ML18018B077
Person / Time
Site:	Nine Mile Point
Issue date:	12/29/1997
From:	Conway J Niagara Mohawk Power Corp
To:	Document Control Desk
References
IR 1997007
Download: ML18018B077 (12)

Text

ACARA MOHAWK C E N E RAT I 0 N NINE MILE POINT NUCLEAR STATION/lAKEROAD, P.o. BOX 63. LYCOMING. NEW YORK 13093/TELEPHONE (315) 34M213 BUSINESS CROUP FAX (315) 349.2605 JOHN T. CONWAY Vice President Nuctear Engineering December 29, 1997 NMP1L 1278 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 RE: Nine Mile Point Unit 1 Nine Mile Point Unit 2 Docket No. 50-220 Docket No. 50-410

Subject:

Reply to Notice of Violation as Contained in NRC?nspection Report 50-220/97-07 and 50-410I97-07 Gentlemen:

Niagara Mohawk Power Corporation's reply to the subject Notice of Violation is enclosed in the Attachment to this letter. Much of the information provided with respect to violation 97-07-03 was previously provided to the NRC in Nine Mile Point Unit 2 Licensee Event Report 97-07, which was submitted on September 12, 1997. We do not dispute these violations..

Very truly yours,

/

John T. Conwa Vice President - Nuclear Engineering JTC/GJG/cmk Attachment xc: Mr. H. J. Miller, Regional Administrator, Region I Mr. A. W. Dromerick, Acting Director, Project Directorate I-l, NRR Mr. B. S. Norris, Senior Resident Inspector Mr. D. S. Hood, Senior Project Manager, NRR Records Management

NIAGARAMOHA%KPOWER CORPORATION NINE MILEPOINT UNIT 1 AND UNIT 2 DOCKET NO. 50-220/50-410 DPR-63/NPF-69 "REPLY TO NOTICE OF VIOLATION,"AS CONTAINED IN INSPECTION REPORT 50-220/97-07 AND 50-410/97-07 A.

(1) NMP1 Technical Speci6cations (TS) Surveillance Requirement 4.6.2.a requires sensors and instrument channels to be checked, tested, and calibrated at least as frequently as listed in Tables 4.6.2.a to 4.6.2.1.

NMP1 TS, Table 4.6.2.1, requires an instrument channel calibration to be performed once each operating cycle, not to exceed 24 months, for the control room ventilation radiation monitor.

Contrary to the above, as of August 18, 1997, the contxol room ventilation radiation (CRVR) monitor channel ¹11 had not been calibrated within the previous 24 months. The CRVR monitor was last calibrated on August 3, 1995.

On August 18, 1997, while preparing to perform a quarterly calibration of CRVR monitor

¹11, the radiation protection technician reviewing the Radiation Protection (RP) Calibration Maintenance History Log (a department record of radiation monitor calibration and maintenance history) discovered that the CRVR monitor ¹11 channel calibration had been last performed on August 3, 1995. An immediate review of procedure recoxds confirmed the last channel calibration to be greater than 24 months old.

Investigation of this deviation has determined that on April 24, 1996, following corrective maintenance (detector replacement) and channel calibration of CRVR monitor ¹12, the Preventive Maintenance/Surveillance Test (PM/ST) database was erroneously updated to reflect the CRVR monitor ¹11 channel calibration having been performed rather than the CRVR monitor ¹12 channel calibration.

The exact reason for the erroneous PM/ST database update could not be determined, but it is concluded that either the incorrect PM/ST update data sheet was manually generated (containing the incorrect equipment piece number) and completed by the technician and t approved by the RP supervisor, or a data entry error was made and not identified by

independent verification when the computer database was updated. Because the update data sheet was not retained in permanent plant files (data sheets generated for other than regularly scheduled surveillances were routinely discarded after being used to update the PM/ST computer database), it is indeterminable as to whether the correct data sheet was generated. In either case, the cause of the deviation, and hence this violation, is personnel error due to inattention to detail and inadequate self checking.

The following corrective actions were taken when NMPC discovered the missed TS Surveillance Requirement:

1. Technical Specification (TS) 3.6.2.a was reviewed for impact on operability of the Control Room Ventilation System. It was determined there was no impact since only one (1) ventilation radiation monitor is required per TS Table 3.6.21, which was fulfilled by CRVR monitor ¹12 at the time.

2. Channel calibration of CRVR monitor ¹11 was completed on August 20, 1997.

3. CRVR monitor ¹12 was verified to have been operable for the period of August 3, 1997 through August 20, 1997, the period of inoperability of CRVR monitor ¹11.

4. A comparison of Radiation Protection Calibration Surveillance completion dates in PM/ST with completion dates in the Radiation Protection Calibration maintenance history log was completed. There were no other discrepancies identified.

The following actions have been taken to prevent recurrence:

Following the determination of the possible causes of this event, the Radiation Protection Manager discussed the importance of self checking with the department supervisors when reviewing work. Additionally, the Radiation Protection Calibration Supervisor discussed this event with the equipment technicians and clerical staff, and reinforced the importance of attention to detail and self checking when completing PM/ST data sheets and inputting the data into the computer database.

2. The Manager, Work Control/Outage Management briefed the PM/ST scheduling specialist on the importance of attention to detail when reviewing PM/ST data sheets and database entries.

3. This event will be reviewed with all departments at Nine Mile Point Units 1 & 2 that have surveillance program responsibilities. This action will be completed by February 28, 1998.

Full compliance was achieved on August 20, 1997 when CRVR monitor 111 was successfully calibrated and restored to service.

B.

(2) NMP2 TS Surveillance Requirement 4.6.6.1.b.1 requires the calibration of all hydrogen recombiner system instrumentation at least once every 18 months.

Contrary to the above, as of August 13, 1997, eight hydrogen recombiner system instruments had not been calibrated since the initial operation of NMP2 in July 1987.

During a review of electrical schematic drawings and corresponding TS Surveillance Requirements (SR), NMPC determined that eight instruments (four instruments in each division) had not been calibrated as required by TS. A review of test procedure development history revealed that the control portions of the instrument loops were calibrated during initial construction in 1986 as part of the original loop calibration reports, which were used to establish the "as-built" data. When the corresponding calibration procedure was written and later issued in 1986, it did not include provisions to calibrate the control portions of these instrument loops, The subsequent two full revisions of the procedure (1987 and 1992) did not identify the missing test requirements. These full revisions should have identified the inadequate procedure.

The root cause of the event was inadequate written communications when the procedure was initially developed in that the control portions of these instrument loops were omitted. A contributing cause was poor work practices in that the deficiency was not identified during the subsequent f'ull revisions of the procedure.

1. Both divisions of the Hydrogen Recombiner System (HCS) were declared inoperable.

TS Limiting Condition for Operation (LCO) 3.0.3 was entered but actions were delayed based on TS SR 4.0.3, which allows delaying the Action requirements for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to permit the completion of the surveillance.

2. The surveillance procedure was revised to incorporate calibration of the control portions of instrument loops 2HCSWE20A and 20B. Testing was completed and verified that all circuits were within their required tolerances and were capable of performing their intended design functions.

NMP2 is currently reviewing logic circuits based on the commitments made in our April 18, 1996 and August 14, 1996 letters to the NRC in response to GL 96-01. One of the actions is to compare electrical schematic drawings and logic diagrams to plant surveillance procedures to ensure that TS requirements are met. It was via these ongoing review activities that this deficiency was identified.

Similar reportable deficiencies in the technical content of surveillance procedures have been previously identified. Preventive actions implemented previously that address this type of discrepancy were described in LER 94-003. These actions included specific program upgrades and included the following procedurally controlled programs:

NIP-SEV-01, Applicability Reviews and Safety Evaluations NIP-PRO-03, Preparation and Review of Technical Procedures P%M-PRO-0105, Technical Procedure Verification and Validation These procedural enhancements, as well as general management emphasis regarding the level 'f detail of these reviews, provide added assurance that procedures are technically accurate and adequate.

Another activity that is pertinent to this violation is the "Back to Basics" training that was held with various site departments in 1995 and 1996. Although tMs training was not directly related to this violation, the aspects of compliance with the design and licensing basis, the need for heightened awareness and attention to detail during work activities, and the'importance of a questioning attitude were addressed and will also provide added assurance of procedure accuracy. Therefore, no further corrective or preventative actions are required at this time.

Full compliance was achieved on August 14, 1997, after both divisions of HCS were successfully tested and declared operable.