ML18038A439
| ML18038A439 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 02/01/1989 |
| From: | Lainas G Office of Nuclear Reactor Regulation |
| To: | Burkhardt L NIAGARA MOHAWK POWER CORP. |
| Shared Package | |
| ML18038A440 | List: |
| References | |
| CON-IIT07-617-91, CON-IIT7-617-91 NUREG-1455, NUDOCS 8902080440 | |
| Download: ML18038A439 (16) | |
See also: IR 05000220/1988201
Text
~ p'~
t
I
< ~~p,tt ttEgti
Cqp
O~
A
1
0O
I
It
ltt
9 r
+y
~O
+a*++
UNITED STATES
NUCLEAR REGULATORY COMMISSION
WASHINGTON, D. C. 20555
February
1,
1989
Docket No. 50-220
Mr. Lawrence Purkhardt III
Executive Vice President-Nuclear
Operations
Niagara
MIohawk Power Corporation
301 Planifield Road
Syracuse,
J3212
Dear Yr. Burkhardt:
SUBvECT:
SAFETY, SYSTEM FUNCTIONAL INSPECTION (50-220/88-201)
This letter forwards the report on the safety system functfona1 inspection
performed
by an
NRC team during the period from September
12,
1988 through
October 7, 1988, involving activities authorized
hy Operating License
for Nine Mile Point Unit 1.
The inspection
was conducted
by members of the
Office of Nuclear Reactor Regulation,
the Region I Office and
NRC contractors.
At the conclusion of the inspection,
we discussed
the findfngs with you and
the members of vour staff identified fn Appendix
A of the enclosed
inspection
report.
The
NRC effort involved an assessment
of the operational
readiness
and
functionality of the high pressure
coolant injection mode of the feedwater
(HPCI/Fll) system
and the core spray system.
Particular attention
was directed
to the details of modifications
and design control, maintenance,
operation,
and testing of the applicable
systems.
Adoftionally, the programs for assuring
quality fn these
areas
were reviewed to determine their effectiveness.
At an inspection follow-up meeting held at our headquarters
office on
November 17,
1988, you provided your preliminarv plans for addressing
the
issues identified in our October 26,
1988 letter.
In addition, you provided
calculations
and written responses/commitments
for these
issues
in your
letters
dated
December
8 and
December
16,
1988.
Subsequently,
your planned
corrective actions for each of these
was incorporated i>>to the Nine Mile Point
I Restart Action Plan submitted to the
NRC on December
22,
1988.
Two documents
are enclosed with this letter:
the executive
suIIIIary which
provides
an overview of the inspection
team's findfngs in each area
reviewed
I
890~080440
890201
ADOCK 05000220
I
6
The inspection
team concluded that design information for both the core spray
and
HPCI/FM systems
was not adequately controlled or supported
by sufficiently
detailed analyses.
As a result, significant concerns
were identified with
your Technical Specifications,
Emergency Operating
Procedures,
surveillance
testing
and design of these
two systems.
Collectively, these
concerns
prevented
the team from determining whether the core spray
and
HPCI/Fl4 systems
would func-
tion as stated in licensing documents.
Additionally, it dfd not appear that
you were adequately
evaluating reportable
events
and available industry
information.
As a result of these findings,
a letter summarizing the maior
areas of concern
from the inspection
was sent to you on October 26,
1988.
Nr. Lawrence Burkhardt III
-2-
and the inspection report which provides
a more detailed explanation of the
team's findings.
The report includes unresolved findings that are currently
under review for potential
enforcement action.
These unresolved
items are
listed in Appendix
C to the enclosed
inspection report and may be the subject
of separate
correspondence
from the
NRC Region
I Office.
The enclosed
inspection report and unresolved
items list reflects the results
of our onqoing review of the additional information that you provided to
date.
The inspection report includes
two unresolved
items that were not
included in our October 26,
1988 letter.
These
issues
concern
design
documentation deficiencies
(50-220/88-201-0<>
and the adequacy of operating
aids
and procedures
(50-220/88-201-06).
You are requested
to respond to the
unresolved
items within 30 days from the date of this report.
For the
unresolved
items that were responded
to in your earlier correspondence,
for
which no updates
or changes
are necessary,
you may re~erence
your previous
responses.
In accordance
with 10 CFR 2.790(a)
a copy of this letter and the enclosure
will be placed in the
NRC Public Document
Room.
Should you have any questions
concerning this inspection,
we would be pleased
to discuss
them with you.
Sincerely,
Enclosures:
1.
Executive
Summary
2.
Inspection
Report 50-220/88-201
cc:
See next page
gu-
Gus
C. Lainas, Acting Director
Division of Reactor
Projects I/II
Office of Nulcear Reactor Regulation
Mr. Lawrence Burkhardt III
CC:
Mr. Troy B. Conner, Jr., Esquire
Conner
8 Wetterhahn
Suite
1050
1747 Pennsylvania
Avenue,
N.W.
D.C.
20006
Mr. Frank
R. Church, Supervisor
Town of Scriba
R.D.
<<2
Oswego,
13126
Mr. James
L. Willis
General
Supt.-Nuclear
Generation
Niagra Mohawk Power Corporation
P.O.
Box 32
Lycoming,
13093
Resident
Inspector
U.S. Nuclear Regulatory Comnission
P.O.
Box 126
Lycoming,
13093
Mr. Gary D. Wilson, Esquire
Niagra
Mohawk Power Corporation
300 Erie Boulevard West
Syracuse,
13202
Regional Administrator, Region I
U.S. Nuclear Regulatory
Commission
475 Allendale
Road
King of Prussia,
19406
Mr. Kim A. Dahlberg
Unit
1 Station Superintendent
Nine Mile Point Nuclear Station
P.O.
Box 32
Lycoming,
13093
Mr. Petter
E. Francisco,
Licensing
Niagra
Mohawk Power Corporation
301 Plainfield Road
Syracuse,
13212
Charlie Donaldson,
Esquire
Assistant Attorney General
New York Department of Law
120 Broadway
10271
Hr. Paul
D.
Eddy
New York State Public Service
Commission
9th Floor
3 Emprie State
Plaza
Albany,
New Yor k
12223
Ms.
Donna
Ross
New York State
Energy Office
2 Empire State
Plaza
16th Floor
Albany,
12223
Institute of Nuclear
Power Operations
1100 Circle 75 Parkway
Suite
1500
Atlanta, Georgia
30339
Mr. Lawrence Burkhardt III
Distribution
50-.III
DRIS R/F
RSIB R/F
BGrimes,
CHaughney,
JDyer,
NRP,
EImbro,
KRR
JKonklin,
SVarga,
DCrutchfield,
NRP.
FMiraglia,
HHaughey,
RBenedict,
BBoger,
RCapra,
TMurley,
JSniezek,
JDurr,
RI
JJohnson,
RI
WKane,
RI
TMartin, RI
EWenzinger,
RI
RSpessard,
BClayton,
OEDO
ACRS (3)
OGC (3)
LPDR
1S Distribution
February
1,
1989
- SEE PREVIOUS
CONCURRENCE
NAME :JDyer
WWW&
W5
WWA&
DATE :01
/89
- CHaughney
- 01 13 89
- BGrimes
- G
nas
- 01/13/89
- 01
/89
%MAW
W&
W&WW&&W
ww + mum~ ~ wmwmm~w
~
wow
-4-
February
1,
1989
Distribution
50-220
DRIS R/F
RSIB R/F
BGrimes,
CHaughney,
JDyer,
NRP.
EImbro,
NRP.
JKonklin,
SVarga,
DCrutchfield,
FYiiraglia,
HHaughey,
RBenedict,
BBoger,
RCapra,
TNurley,
JSniezek,
JJohnson,
RI
WKane,
RI
EWenzinger,
RI
RSpessard,
BClayton,
OEDO
ACRS (3)
OGC (3)
PDP,
LPDR
1S Distribution
VlE:Jgyer gg~
ATE :01/y
89
- CFaugheeyjg:B
me
- 01//5/89: 01/L
89
- GCLainas
- 01/
/8
,I.
P eC
1l
eie,. ~(
1
EXECUTIVE SUMMARY
INSPECTION
REPORT 50-220/88-201
NINE MILE POINT UNIT I
A team of NRC inspectors
and contractor personnel
conducted
a Safety System
Functional
Inspection
(SSFI) at Nine Mile Point Unit 1, to assess
the opera-
tional readiness
of the core spray system
and the high pressure
coolant
injection mode of the feedwater
(HPCI/FW) system.
The assessment
was
accomplished
by a thorough review of the design,
maintenance,
operations,
quality assurance
and testing of the systems.
The following paragraphs
summarize
the significant findings and conclusions
made
by the inspection
team:
1.
The inspection
team could not determine whether the core spray system
would function as stated in the licensing
documents for the following
reasons:
a.
The Technical Specification limiting condition for operation
(LCO) which allowed continued plant operations for up to seven
days with an inoperable
core spray loop appeared
to be an unanalyzed
condition.
b.
Analysis showing that adequate
net positive suction
head
(NPSH)
existed for the core spray
pumps did not accurately reflect conditions
that could be expected
during
a large-break
loss-of-coolant accident
(LOCA) with containment
sprays in operation.
c.
Pump vortexing analysis did not account for the interactive
effects of the two pump suctions >>hich are in close proximity
to each other.
Calculations
performed after the onsite inspec-
tion indicated that
pump vortexing would not be
a problem.
d.
System resistance
curves did not account for all the components
in the system.
e.
System
pump curves did not appear to be controlled or validated
by testing over the full range of expected
flows.
f.
Potential flow diversion from the reactor through the combined
pump discharge relief valve was not considered
in any safety
analyses.
g.
The system alarm setpoints
and procedural
responses
appeared
inappropriate for the core spray
pump low suction
and discharge
pressure
alarms, strainer high differential pressure
alarm and
pump high discharge
pressure
alarm.
h.
Emergency Operating
Procedures
(EOPs) did not appear to provide
adequate
guidance for core spray system operations
in accident
conditions.
The design of the core spray
keep fill system did not appear
to completely fill the piping down stream of the topping pumps.
As a result,
the core spray system
appeared
susceptible
to water
hammer problems during large-break
LOCA situations.
j.
The range of control
room flow instrumentation for the core
spray system
was not adequate
to measure
the full range of
expected
system flows.
2.
The inspection
team could not determine
whether the
HPCI/FW system would
function as stated
in the licensing
documents for the following reasons:
Independent
calculations
performed
by the team indicated that
the condensate
and booster
pumps would not provide the flow
specified in the Technical Specification
Bases at a reactor
pressure of 450 psig.
b.
c ~
d.
No analysis
was available to show that necessary
water levels
in the condensate
storage
tank could be adequately transferred
to the hotwell without vacuum to support
HPCI/FW pump flows.
Calculations
performed after the onsite inspection indicated
that adequate
flow would be achieved
from the condensate
storage
tank to the hotwell to support
HPCI/FW system operation.
The
pump curves
used for HPCI/FW testing appeared
to be
uncontrolled,
and applied only to the motor-driven feedwater
pumps (excluding the booster
and condensate
pumps).
The motor-driven feedwater
pumps were not designed
to support the
frequent starting that may be required
by HPCI/FW system reactor
water level control modifications
and operating
procedures.
3.
The electrical
system design
appeared
adequate
to support core spray
and
HPCI/FW systems
operations.
The licensee
had previously initiated
actions to reconstitute
the electrical
system design
bases.
4.
The inspection
team
made the following observations
about licensee
programs:
a 0
b.
C.
Examples
were found where Surveillance Test Program data collection,
results
review,
and acceptance
value determination
would not ade-
quately support
system operability decisions.
This weakness
appeared
to be
a direct result of poorly defined system design requirements.
Internal
responses
to industry information such
as
NRC Information
Notices,
GE Service Information Letters
and
INPO information did
not always appear to be timely or sufficiently researched.
Investigation into problems
and assessment
of reportability in
accordance
with 10 CFR 50.72
and
10 CFR 50.73 did not always
appear to be adequate.
d.
The written periodic maintenance
program did not include all
recommended
maintenance activities of the equipment
vendor
manuals
or
the actual periodic maintenance
being performed
on safety systems
during the outage.
A maintenance
self assessment
conducted
by the
licensee
appeared
to be
a thorough review of the maintenance
program
and identified areas for improvement.
Motor-Operated valve testing
appeared
to be
a strength.
e.
The gA Audit Program concentrated
on programmatic
issues
and would
not necessarily
be ahle to identify significant technical
issues
with safety
system operation, testing,
design or maintenance.
The
(A Surveillance
Program appeared
to be more technically oriented
and identified significant issues for resolution before restart.
f.
System operating
procedures
had several
deficiencies
indicating
a lack of attention to detail.
However, operators
demonstrated
an excellent level of knowledge about the plant and system opera-
ting characteristics
during system walkdowns
and procedure
walkthroughs.
The capabilities of the site specific simulator also
appeared
to be
a strength.