ML20052D120

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IE Insp Rept 50-220/82-04 on 820301-0403.Noncompliance Noted:Failure to Implement Calibr Procedures & Failure to Follow Radiation Protection Procedures
ML20052D120
Person / Time
Site: Nine Mile Point 
Issue date: 04/19/1982
From: Doerflein L, Sharon Hudson, Kister H
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20052D112 List:
References
50-220-82-04, 50-220-82-4, NUDOCS 8205060292
Download: ML20052D120 (12)


See also: IR 05000220/1982004

Text

{{#Wiki_filter:. . . DCN: 50220-820222 f_ffff U.S. NUCLEAR REGULATORY COMMISSION Region I Report No. 82-04 50-220 Docket No. OPR-63 C -- License No. Priority Category Licensee: Niagara Mohawk Power Corporation 300 Erie Boulevard West Syracuse, New York 13202 Nine Mile Point Nuclear Station, Unit 1 Facility Name: Inspection at: Scriba, New York Inspection conducted: March 1 - April 3, 1982 b. 9/'/ 2. Inspectors: S. D. Hudson, Resident Inspector 'date signed ~ f~k2- 4' - ' L. T. Doerflein, Residdnt Inspector diate signed date signed , Approved by: bN[ f [ -[[/7h2__ Ki er,Ciiief,Rea P jects jfiate/ signed Inspection Summary: Inspection on March 1 - April 3, 1982 (Inspection Report No. 50-220/82-04) Areas Inspected: Routine, onsite regular and backshift inspections by the resident inspectors (160 hours). Areas inspected included: licensee action on previous inspection findings, operational safety verification, physical security, plant tours, surveillance tests, safety system verification, maintenance activities, refueling, followup on significant event, licensee event reports, and periodic reports. Results: No violations were identified in nine of the eleven areas examined. One violation was identified in each of two areas. (Failure to implement calibration procedures and failure tt follow radiation protection procedures) i i Region I Form 12 t o m, Anril 77) $ g OCK 05000220 o292 820420 0 PDR \\ .

. . DETAILS 1. Persons Contacted J. Aldrich, Supervisor, Operations W. Chambers, Security Investigator K. Dahlberg, Site Maintenance Superintendent W. Drews, Technical Superintendent J. Duell, Supervisor, Chemistry and Radiation Protection E. Leach, Superintendent of Chemistry and Radiation Management T. Perkins, General Superintendent, Nuclear Generation R. Raymond, Supervisor, Fire Protection T. Roman, Station Superintendent B. Taylor, Supervisor, Instrument and Control The inspectors also interviewed and talked with other licensee personnel during the course of the inspection including shift supervisors, administrative, operations, health physics, security, instrument and control and contractor personnel. 2. Licensee Action on Previous Inspection Findings _ (Closed) UNRESOLVED ITEM (81-03-01): Determine the level of qualification necessary to verify the placement of jumpers. In a letter to Niagara Mohawk dated February 12, 1982, the NRC addressed its review of the TMI Action Plan Item I.C.6. The use of instrument and control technicians or electricians in lieu of licensed operators for verification of safety related activities, namely the installation or removal of jumpers and the return to nonnal of > instrument and control devices after surveillance testing,is considered acceptable. (Closed) VIOLATION (81-01-03): Control of access to high radiation areas. The licensee has changed the locks on the doors to the areas where radiation levels of greater than 1000 mrem /hr exist to the XR series. A specific XR key allows access to only a specific area of the plant. These keys are issued by the Station Shift Supervisor or his assistant for each entry. The keys are maintained in a cabinet in the Control Room when not in use. The inspector reviewed the key control log to verify implementation of the system. The inspector also examined locks on the doors to the MSIV room, condenser area, and off-gas recombiner area to verify that these locks had been changed to the XR series. (Closed) VIOLATION (81-01-04): Failure to follow administrative procedures for jumpers. The inspector verified that the sixteen jumper log sheets were properly signed inoicating correct installation and independent verification. . An entry was also made in the Control Room Log Book documenting the installation l of the jumpers. The administrative controls of jumpers is routinely examined by the resident inspector. No further violations have been identified. (Closed) VIOLATION (81-01-05): Improper removal from service of #111 Main Steam Line Radiation Monitor. The inspector reviewed Administrative Procedure APN-7A, " Placement of Jumpers or Blocks or Lifting of Leads," Revision 7, dated January 11, 1982. The procedure now requires that the Shift Supervisor i .-_ - -

. . 3 determine that application of jumpers or lifting of leads is in compliance with Technical Specifications prior to granting approval for the application. The jumper log sheet has been revised to docrent this approval. It also now requires that both Shift Supervisor and the Chief Shift Operator grant permission prior to the application. This ensures a two-man control by two - licensed operators for jumpers, blocks and lifting of leads. The inspector also reviewed a memorandum to all Shift Supervisor's and Assistant Shift Supervisor's dated February 20, 1981 describing the violation and infonning them of the changes to APN-7A. (Closed) INSPECTOR FOLLOWUP ITEM (81-06-01): Review licensee action regarding water leakage in the Reactor Building, elevation 318 ft. The inspector examined the area in question in the Reactor Building, elevation 318 ft. The licensee had cleaned up the water and decontaminated the area. A small amount of residual contaminatior. (700 dpm/100 cm2) remains in the area. The licensee believes that this is due to contamination that is slowly bleeding out of the concrete floor. When the inspector examined the area, it was found to be recently surveyed and properly posted. (Closed) UNRESOLVED ITEM (80-14-02): Calibration procedure for conductivity monitor to be revised to include the technician's signature and supervisory review. On February 3, 1981, Revision 1 of Laboratory Instrument Procedure No. IV.A.20, " Operation of the L&N Model 4866 Conductivity Monitor," was issued. This revision requires the technician to sign the calibration check data sheet anc' supervisory review. However, when examined by the inspector on March 4,1! 82, the procedure had not been fully implemented in that the supervisory rt. view of the monthly calibration check data had not been performed from February 1981 to March 1982. The inspector also noted that section 4.3.2 of Procedure No. IV.A.20 requires that the calibration of the conductivity meter be checked using three resistors from a list of a 10 megaohm, 1 megaohm, 100 kilo ohm, 10 kilo ohm, and 1 kilo ohm resistors. Of the 10 resistors used to check the instruments' calibration, none were from the required list. Technical Specification 6.8.1 states in part: " Written procedures and administrative policies shall be established, implemented, and maintained ...." The failure to implement the requirements of Laboratory Instrument Procedure No. IV.A.20 is a violation. (50-220/82-04-01) When brought to the licensee's attention, the correct resistors were placed on order. 3. Operation Safety Verification a. Control Room Observations Routinely throughout the inspection period, the inspector independently verified plant parameters and equipment availability of engineered safeguard features against a plant specific checklist to ensure the following items were observed: Proper control room manning; -- Availability and proper valve line-up of safety systems; --

4 . . Availability and proper alignment of onsite and offsite -- emergency power sources; Reactor control panel indications and bypass switches; -- Core Themal limits; -- Primary containment temperature and pressure;' -- Drywell to suppression chamber differential pressure; -- Stack monitor recorder traces, and -- Liquid poison tank level and concentration. - Selected lit annunciators were discussed with control room operators to verify that the reasons for them were understood and corrective action, if required, was being taken. Shift turnovers were observed to ensure proper control room and shift manning on both day and backshifts. Shift turnover checklists and log review by the oncoming and off-going shifts were also observed by the inspector. On March 19, 1982, the plant was shutdown for a scheduled maintenance outage. The inspector witnessed portions of the reactor cooldown by bypassing steam to the main condenser and the initiation of forced cooldown using the shutdown cooling system. The inspector verified that the operations were conducted in accordance with approved procedures and that the Technical Specification limit for cooldown rate was not exceeded. b. Review of Logs and Operating Records The inspector reviewed the following logs and instructions for the period March 1, 1982 through April 3, 1982: Cnntrol Room Log Book -- Station Shift Supervisor's Log Book -- Station Shift Supervisor's Instructions -- Licensee Event Report Log -- Reactor Operating Log -- The logs and instructions were reviewed to: Obtain infomation on plant problems and operation; --

. . g . Detect changes and trends in performance; -- Detect possible conflicts with technical specifications or -- regulatory requirements; , Determine that records are being reviewed as required; -- Assess the effectiveness of the communications provided by the -- logs and instructions, and Determine that the reporting requirements of technical -- specifications are met. No violations were identified. 4. Observation of physical Security The inspector made observations and verified during regular and off-shift hours that selected aspects of the plants physical security system were in accordance with regulatory requirements, physical security' plan and approved procedures. The following observations relating to physical security were made: The security force on both regular and off-shifts were properly manned -- and appeared capable of performing their assigned functions. Protected area barriers were intact - gates and doors closed and locked -- if not attended. Communication checks were conducted. Proper communication devices were -- available. Isolation zones were free of visual obstructions and objects that could -- aid an intruder in penetrating the protected area and during periods of darkness, the protected area had sufficient illumination.

Persons and packages were checked prior to entry into the protected area. -- Vehicles were properly authorized, searched and escorted or controlled -- within the protected area. Persons within the protected area displayed photo-identification badges, -- persons in vital areas were properly authorized, and persons requiring escort were properly escorted. Compensatory measures were implemented during periods of equipment -- failure. No violations were identified.

_ _ . . 5. Plant Tours During the inspection period, the inspector made multiple tours of plant areas to make a independent assessment of equipment conditions, radiological conditions, safety and adherence to regulatory requirements. The following areas were among those inspected: Turbine Building -- Auxiliary Control Room -- Vital Switchgear Rooms l -- Yard Areas -- ! Radwaste Area ) -- Diesel Generator Rooms ' -- Screen House -- Reactor Building , -- 1 Drywell -- The following items were observed or verified: a. Radiation Protection: Personnel monitoring was properly conducted. -- Randomly selected radiation protection instruments were calibrated -- and operable. Radiation Work Permit requirements were being followed. -- Area surveys were properly conducted and the Radiation Work Pennits -- were appropriate for the as-found conditions. The inspector witnessed the performance of radiation survey #N63188 on the Reactor Building 318 ft. elevation and survey #62658 on the Turbine Building 261 ft. elevation. b. Fire Protection: Randomly selected fire extinguishers were accessible and inspected -- on schedule. Fire doors were unobstructed and in their proper position. -- Ignition sources and combustible materials were controlled in -- accordance with the license.e's approved procedures. _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ .

. . 7 . c. Equipment Controls: Jumpers and equipment tag outs did not conflict with Technical -- Specification requirements. Conditions requiring the use of jumpers received prompt licensee -- attention. Selected jumpers had been properly installed. -- The inspector independently verified that tag outs #RMU 134106 on --

  1. 12 Emergency Condenser Make Up Tank and #RMU 134090 on the

Emergency Condenser Steam Supply Drain Isolation Valves had been properly placed. The inspector independently verified that BMU-64752 had been -- properly cleared and that the blocking valve to Dnergency Condenser

  1. 12 level controller was locked open.

d. Vital Instrumentation: Selected instruments appeared functional and demonstrated -- parameters within Technical Specification Limiting Conditions for Operation. e. Radioactive Waste System Controls: Gaseous releases were monitored and recorded. -- The radioactive waste system was operated in accordance with -- approved procedures. The inspector witnessed the survey of radioactive waste shipment

  1. NMP-HW-0382-1 prior to its departure from the site to verify that

applicable Federal limits were not exceeded. f. Housekeeping: Plant housekeeping and cleanliness were in accordance with approved -- licensee programs. l No violations were identified. 6. Surveillance Tests During the inspection period, the inspector witnessed the performance of various surveillance tests. Observations were made to verify that: Surveillance procedures conform to technical specification requirements -- and have been properly approved. Test instrumentation is calibrated. -- l l ! l ! -- , .-

. . . Limiting conditions for operations for removing equipment from service -- are met. Testing is performed by qualified personnel. -- Surveillance schedule is met. -- Test results met technical specification requirements. -- Appropriate corrective action is initiated, if necessary. -- Equipment is properly restored to service following the test. -- The following tests were included in this review: ISP-RPS-TP, " Reactor Protection System-High Reactor Level Turbine Trip, -- Low Reactor Level Scram," Revision 10, dated December 3,1981. .SP-RPS-TP, " Reactor Protection System-Main Steam Line Break," -- Revision 10, dated December 3, 1981. ' 1 ICP-608, " Emergency Cooling Level Control," Revision 1, dated October 31, -- 1980. The inspector witnessed the calibration of transmitter IG06B. SP-7, " Stack Sampling," Revision 0, dated February 14, 1977. The -- inspector witnessed the weekly stack gas Marinel,li sample. ISP-NEU-1, " Source Range Monitor Instrument Surveillance," Revision 1, -- dated October 30, 1980. The inspector witnessed the instrument channel calibration of channel #12. No violations were identified. 7. Safety System Operability Verification On a sampling basis, the inspector directly examined selected safety system trains to verify that the systems were properly aligned in the standby mode. This examination included: , Verification that each accessible valve in the flow path is in the -- l correct position by either visual observation of the valve or renote ' position indication. Verification that power supply breakers are aligned for components that -- must actuate upon receipt of an initiation signal. Visual inspection of the major canponents for leakage, proper lubrication, -- cooling water supply, and other general conditions that might prevent fulfillment of their functional requirements. Verification by observation that instrumentation essential to system -- actuation or performance was operational, i - - _ -

__ _ _ _ _ . . 9 During this inspection period, the following systems were examined: 125VDC Batteries and Battery Board Rooms -- Control Room Emergency Ventilation System -- Control Rod Drive System -- No violations were identified. 8. Plant Maintenance The inspector examined portions of various safety related maintenance activities. Through direct observation and review of records, he detennined that: Redundant components were tested to ensure operability prior to -- starting the work. These activities did not violate the limiting conditions for operation. -- Required administrative approvals and tag outs were obtained prior to -- initiating the work. Approved procedures were used or the activity was within the " skills - -- of the trade". Appropriate radiological controls were nroperly implemented. -- Equipment was properly tested prior to returning it to service. -- During this inspection period, the following activities were examined: Repair of Electromatic Ralief Valve #121. -- Replacement of the fuel grapple proximity switch. -- Troubleshooting turbine trip relay 11K30. -- Uncoupling of control rod 06-35. -- The uncoupling of control rods is performed from under the reactor vessel. The radiological controls were specified in Radiation Work Permit (RWP) #7403 dated April 2, 1982. The "special instructions" section of this RWP stated: " Wear dosimetry on head while working under vessel." On April 2,1982, the inspector noticed that four individuals, including one designated as the leadman, working under the reactor vessel were wearing their dosimetry on their chests instead of their heads.

. . 10 Technical Specifications 6.11 states: "Proceduresfor personnel radiation protection shall be prepared consistent with the requirements of 10 CFR 20 and shall be approved, maintained, and adhered to for all operations involving personnel radiation exposure." Radiation Protection Procedure RP-2, " Radiation Work Permit Procedure," Revision 1, dated February 13, 1979 states in Section 5.4: "The leadman is responsible for familiarizing personnel with all instructions on the permit, and insuring that these instructions are strictly followed." This failure to follow the requirements of an RWP is a violation. (50-220/82-04-02) When notified of this violation, the licensee instructed the workers to wear their dosimetry as specified. Subsequently, the licensee conducted a test that showed that measured exposures were 20% to 30% greater when dosimetry is worn on the head rather than on the chest (when working under the reactor vessel). A licensee representative, at the access control point, stated that individuals working under the vessel on April 5 were observed to be wearing their dosimetry as specified on the RWP. Except as noted, no other violations were identified. 9. Refueling Activities The inspector witnessed portions of the full core off load to verify that the fuel handling operations were being performed in accordance with the Technical Specifications and procedures N1-0P-34, " Refueling Procedure," N1-FHP-27, "Whole Core Off Load-Reload," and N1-IMP-44.1, "One Rod Permissive Rod Block Removal." The verification included, but was not limited to, the following: The control room and refuel floor were properly manned. -- Continuous communications were maintained between the control room -- and the refuel floor. Fuel moves within the core were directly monitored by a member of the -- reactor analyst group. The source range monitoring instruments were operable. -- Secondary containment integrity was maintained. -- i Jumpers to bypass the input from each control rod to the refueling -- interlocks were properly installed. The mode switch was in the REFUEL position. -- No violations were identified. ! i

. . 11 10. Followup of Sianificant Event On March 23, 1982, the resident inspector witnessed the perfomance of a reactor vessel hydrostatic test. At test pressure of 900 psig, the inspector observed water leakage from the vicinity of the reactor vessel nozzle for the suction of #15 recirculation (recirc) pump. During a subsequent inspection at 600 psig, while reducing hydro pressure, licensee personnel visually examined all the reactor vessel nozzles for the recirc pumps for water leakage. Only #11 discharge nozzle appeared to be leaking. As part of their investigation, the licensee conducted a radiochemical analysis of the leakage and detemined that it was reactor water. Next, the insulation was removed from these two nozzles. One pin hole leak was found in the heat affected zone of the reactor vessel nozzle safe end for

  1. 15 recirc pump suction near the safe end to pipe weld and two pin hole

leaks and a half inch long thru wall crack were found in the heat affected zone of the reactor vessel nozzle safe end for #11 recirc pump discharge near the safe end to pipe weld. These leaks were reported to the NRC by the licensee as Licensee Event Report 82-09. There was no environmental significance since the cracks merely weep when the reactor is depressurized. On March 26, 1982, the inspector witnessed an ultrasonic (UT) examination of #11 recirc pump discharge safe end. The examination was perfomed in accordance with Nuclear Energy Services Procedure #80A2308, Revision 1, " Ultrasonic Examination General Requirements," and Procedure #80A2818, Revision 1, " Ultrasonic Examination of Stainless Steel Piping for Irter- granular Stress Corrosion Cracking." In addition to the thru wall ieaks, this examination showed 3 circumferential indications and 5 clusters of axial indications in the safe end near the safe end to pipe weld. All indications appeared to be located at the inside surface of the safe end and are distributed almost unifomly around the inner radius of the safe end. On March 31, 1982, the inspector witnessed the UT examination of #13 recirc pump discharge safe end. This nozzle had not been leaking during the vessel hydrostatic test and is located about 1800 around the vessel from the leaking nozzle. The examination revealed a large circumferential indication from about the 12 o' clock to 3 o' clock position (looking in towards the vessel) and a small indication at both the 7 and 8 o' clock positions. These indications are also located along the inner radius of the safe end. The , safe ends are furnace sensitizied Type 316 stainless steel. The licensee had perfomed a UT examination of all recirc safe ends during both the Spring 1979 and Spring 1981 refueling outages. No indicatior.s had been previously detected. The licensee has ten replacement safe ends available and currently plans to replace all affected safe ends. A full core off-load and other preparations for this repair are in progress. A metallurgical analysis is planned to help detemine the cause of the cracks. 11. Review of Licensee Event Reports (LER's) a. LER's submitted to NRC:RI were reviewed to verify that the details were clearly reported, including accuracy of the description of cause

. - 12 and adequacy of corrective action. The inspector determined whether further information was required from the licensee, whether generic implications were indicated, and whether the event warranted onsite followup. The following LER's were reviewed: LER No. Event Date Subject 82-06 February 25, 1982 Plant discharge temperature exceeded limit by 20F 82-07 February 22, 1982 Failure to meet radiation detection sensitivity limit for fish samples No violations were identified. 12. Review of Periodic Reports The following reports were revi ved to determine that the reporting requirements of Technical Specifications are being met and that plant operations are accurately reported: Monthly Operating Reports for February 1982. -- No violations were identified. 13. Exit Interview At periodic intervals during the course of the inspection, meetings were held with senior facility management to discuss the inspection scope and findings. l }}