ML18040A264
| ML18040A264 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 06/16/1997 |
| From: | Abbott R NIAGARA MOHAWK POWER CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-410-97-02, 50-410-97-2, NMP2L-1711, NUDOCS 9706250170 | |
| Download: ML18040A264 (14) | |
Text
Nl ARA MOHAWK C EN ERATI ON BUSINESS CROUP RICHARD B. ABBOTT Vice President and General Manager - Nuclear NINE MILEPOINT NUCLEAR STATION/LAKEROAD. P.O. BOX 63, LYCOMING.NEW YORK 13093/TELEPHONE (315) 349-1812 FAX(315) 349.4417 June 16, 1997 NMP2L 1711 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 J
RE:
Nine MilePoint Unit 2 Docket No. 50-410
Subject:
Reply to a Notice of Violation Dated May 16, I997 Gentlemen:
This letter responds to the Notice of Violation dated May 16, 1997 regarding the failure at Nine MilePoint Unit 2 (NMP2) to adequately perform response-time testing in accordance with Technical Specifications (TS) and to comply with written procedures pertaining to the control room deficiency program.
The attachment to this letter addresses the specific items required by the Notice of Violation (NOV). Much of the information provided in the attachment with respect to NOV 97-02-02 was previously provided to the NRC in NMP2 Licensee Event Report (LER) 97-01 which was submitted on April25, 1997.
Sincerely, R. B. Abbott Vice President and General Manager - Nuclear RBA/TWP/cmk Attachment n "g V
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Mr. H. J. Miller, Regional Administrator, Region I Mr. B. S. Norris, Senior Resident Inspector Mr. A. W. Dromerick, Acting Director, Project Directorate I-l, NRR Mr. D. S. Hood, Senior Project Manager, NRR Records Management
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Niagara Mohawk Power Corporation Nine MilePoint Unit 2 Docket No. 50-410 NPF-69 REPLY TO NOTICE OF VIOLATIONDATEDMAY16, 1997 AS CONTAINEDININSPECTION REPORT 50-220/97-02 AND 50-410/97-02 Unit 2 Technical Specifications, Section 4.3.3.3, requires the response-time of each emergency core cooling system (ECCS) to be demonstrated at least once per 18 months.
Each test is to include at least one channel per trip system, so that all channels are tested at least once per "N times 18 months," where "N" is the total number of redundant channels in a specific ECCS trip system.
Unit 2 Technical Specifications, Section 1.12, defines ECCS response time as that time interval from when the monitored parameter exceeds its actuation setpoint at the sensor, until the ECCS equipment is capable of performing its safety function (i.e., the valve achieves the required position, pump discharge pressure reaches the required value, etc.). Where applicable, times are to include delays associated with the diesel generator starting and sequence loading. The response time may be measured by a series of sequential, overlapping, or total steps, such that the entire response time is measured.
Contrary to the above, on or before March 26, 1997, the response time of the high pressure core spray (HPCS) system (a required ECCS system), was not demonstrated at least once per 18 months.
Specifically, response-time-testing for HPCS actuation instrumentation was last performed:
Channel 1 drywell pressure - high Channel 1 reactor water level - low/low" Channel 2 drywell pressure - high Channel 2 reactor water level - low/low November 16, 1990 September 28, 1990 April 19, 1992 April 17, 1992 Additionally, one relay (E22A-Kl1) downstream of the trip units for reactor water level - low/low had not been response-time-tested for an unknown period of time prior to June 21, 1993.
This is a Severity Level IVviolation (Supplement 1).
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Niagara Mohawk admits to the violation. LER 97-01, submitted April25, 1997, described the TS violation, cause and corrective actions taken after Niagara Mohawk identified this issue.
Additional information beyond that discussed in this response can be found in this LER.
There are two aspects to this violation. One deals with the lack of response time testing of relay E22A-K11 in the HPCS initiation logic. A previous evaluation was performed by NMP2 in 1993 to determine which components of the HPCS system logic were subject to the response time testing requirements of Surveillance Requirement (SR) 4.3.3.3.
At that time, the HPCS response time was determined by combining the response times obtained from four different procedures covering different portions of the logic system.
While the subject relay was actuated during these tests in order to demonstrate an acceptable Logic System Functional Test, the relay was not timed in accordance with SR 4.3.3.3.
The interim disposition of this 1993 evaluation resulted in the temporary revision of the procedure and the satisfactory response time testing of the relay.
During the course of the investigation, it was later determined that relay E22A-K11 did not require response time testing and thus, testing of the relay was not permanently incorporated into the procedure.
The second aspect of this violation deals with the failure to response time test the HPCS actuation instrumentation, in particular, drywell pressure - high and reactor water level - low/low. The 1993 evaluation concluded that response time testing was not required for either the relay or the actuation instrumentation, based on information contained in the Nuclear Steam Supply System (NSSS) vendor specification and accident analysis.
Specifically, the NSSS information stated that "the HPCS system shall be capable of starting and delivering rated flow into the vessel within 27 seconds following receipt of the initiation signal." This information was also noted to be the basis for the system response times contained in TS Table 3.3.3-3, "Emergency Core Cooling Response Times." Further information from the NSSS vendor indicated that the 27 seconds assumed in the analysis began with actuation of the system logic initiation relays and did not include instrumentation response time.
Considering this information, the 1993 evaluation incorrectly concluded that response time testing for components upstream of the system initiation relays was not required.
The cause of the failure to response time test relay E22A-K11 prior to 1993 was determined to be inadequate written communications in that the test procedures did not provide for measurement of the response time of this relay. The interim surveillance procedures, developed and used prior to receipt of the initial.operating license, did provide for measurement of the response time for relay E22A-K11. When the procedures were revised in 1986, inadequate technical review resulted in the procedures failing to include the response time measurement of this relay.
The cause of the failure to response time test the actuation instrumentation and to not permanently incorporate the testing of relay E22A-K11 into procedures was determined to be inadequate managerial methods in that the 1993 evaluation of surveillance requirements was
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incorrect.
The evaluators failed to understand the significance of the TS definition of ECCS Response Time, and incorrectly concluded that it was acceptable to deviate from the definition set forth in TS because of the total system response time as stated in the TS Response Time Table (Table 3.3.3-3), the assumptions in the safety analysis, anB the discussions held with the NSSS vendor.
The immediate corrective actions taken included declaring the HPCS system inoperable,.
revising the test procedures and performing the appropriate response time testing of relay E22A-K11. In addition, the actuation instrumentation was also tested, however, NMPC later determined that the instrumentation had in fact been operable as a result of implementing the testing requirements of NEDO-32291 in 1996.
The HPCS system was restored to an operable status.
The procedures associated with HPCS response time testing were reviewed against the design drawings to ensure that no other untested portions of the circuit existed.
No other areas of TS non-compliance were identified.
The Division 1 and 2 ECCS response time tests were reviewed to ensure that no similar problems existed.
No other areas of TS non-compliance were identified during these reviews.
Preventive actions have already been taken to address instances of inadequate managerial methods, relative to technical procedure preparation and review. Specifically, a corrective action described in LER 94-003 dealt with upgrading specific programs whose purpose is not only to ensure that adequate procedures are written, but also to ensure the review of these procedures is carried out in a manner that should eliminate events such as these.
These included, but were not limited to, the following procedurally controlled programs:
NIP-SEV-01, ApplicabilityReviews and Safety Evaluations NIP-PRO-03, Preparation and Review of Technical Procedures PWM-PRO-0105, Technical Procedure Verification and Validation As a result, NMP2 believes that mechanisms are in place to ensure adequate review of procedures.
Full compliance was achieved when the appropriate response time testing was completed and HPCS was declared operable at 1438 hours0.0166 days <br />0.399 hours <br />0.00238 weeks <br />5.47159e-4 months <br /> on March 28, 1997.
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'nit 2 Technical Specifications, Section 6.8.1, which references NRC Regulatory Guide 1.33, "Quality Assurance Program Requirements (Operation), Revision 2, requires written procedures to be established and implemented.
Unit 2 Operations Administrative Procedure N2-ODP-OPS-0001, "Conduct of Operations," Revision 4, Step 3.3.7, requires: (1) that when a work order (WO) is generated for repair of a control room deficiency, an action code of "X"is to be used to denote a control room deficiency; (2) a transparent green dot be placed on or near the affected component or indication; (3) the Station Shift Supervisor (SSS) ensure that the green dot is removed when the deficiency is repaired and the WO is closed; and (4) a quarterly review of control room deficiencies.
Contrary to the above, on March 20, 1997, (1) WO 96-13381, associated with the drywell radiation monitor chart recorder in the control room, was not coded "X"to reflect the control room deficiency; (2) transparent green dots were not placed on or near the control room deficiencies for the control rod and detector display module cooling fan (2CEC~PNL603), or for the turbine controls chart recorder (2TMI-ZR136); (3) the,SSS did not remove the green dots for the drywell area temperature chart recorders (2CMS*TRY130 and 2CMS'TRX130) after the WO was closed; and (4) there was no indication that quarterly reviews were performed.
This is a Severity Level IVviolation (Supplement 1).
Niagara Mohawk admits to the violation. The cause of the violation was inadequate change management in that departmental interactions were not considered when work control process changes were made.
The NMP2 Operations department has utilized the NMP2 work control software (WCMOSSE) to track items identified as control room deficiencies since the implementation of WCMOSSE at NMP2 in 1993.
Over time, opportunities for additional tracking mechanisms were
. identified by station personnel and changes to WCMOSSE were implemented to allow other work groups to also track work control items of interest.
As WCMOSSE tracking codes were expanded and the software for the work control process was modified to allow the station to track additional work control items, station personnel were allowed to change the tracking codes.
Personnel routinely changed the tracking codes to categorize the nature of the repair required to correct the deficiencies.
These personnel worked outside the Operations department and therefore were not using the procedural guidance developed for Operations personnel (N2-ODP-OPS-0001) regarding coding of control room deficiencies.
An additional cause of the violation was inadequate managerial methods in that the methods for periodically assessing compliance with the program were not clearly defined.
As a result, assessments were informal in nature and not sufficiently critical to identify program implementation deficiencies for needed corrective action.
Immediate corrective action was to verify all control room deficiencies were appropriately coded on the work control software system and were identified with green dots. Allnoted deficiencies were corrected.
The following actions were taken to prevent recurrence:
As an interim measure, NMPC Procedure N2-ODP-OPS-0001 was revised to add a special tracking code in a "limited access" WCMOSSE field to ensure that control room deficiency identification is not changed in the work control process.
Alloutstanding deficiencies were updated to reflect this additional tracking code.
Appropriate station personnel have been verbally instructed on the control room deficiency program, including the need to include a step in the applicable work order to remove the green dot when all work is complete.
The quarterly audit requirement has been replaced by a monthly review. The future periodicity of this review willbe determined based upon the effectiveness of the corrective actions.
Control room deficiency reviews are now automatically scheduled by the work control computer program and are built into the station work schedules.
In order to verify the completion of these reviews, they have also been included in the station surveillance tracking system.
An off-shift Station Shift Supervisor has been assigned the responsibility of evaluating the program and proposing comprehensive changes to ensure compliance.
This evaluation is in progress and any resultant corrective actions willbe incorporated into the appropriate procedures for both units. This willbe completed by October 15, 1997.
Overall, the control room deficiency program has been effective in reducing the number of deficiencies and increasing the focus of resources on the importance of functional controls in the control room.
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0 Full compliance was achieved on May 20, 1997 after the procedure was revised and the outstanding control room deficiencies were updated to reflect the procedure changes.