ML20081A979

Responds to NRC Re Violations Noted in IE Insp Rept 50-220/83-16.Corrective Actions:Valve Operators on Listed Valves Removed,Closed & Modified & Seismic Calculations Performed on Cooling Lines

ML20081A979
Person / Time
Site:	Nine Mile Point
Issue date:	09/01/1983
From:	Lempges T NIAGARA MOHAWK POWER CORP.
To:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20081A957	List: ML20081A967 ML20081A979
References
NUDOCS 8310270217
Download: ML20081A979 (3)

Text

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1' M Y NIAGARA nuMOHAWK NlAGARA MOHAWK POWER CORPORATION /300 ERIE BOULEVARD WEST, SYRACUSE, N.Y.13202/ TELEPHONE (315) 4741511 September 1, 1983 Mr. Thomas T. Martin, Director Division of Engineering and Technical Programs U.S. Nuclear Regulatory Comission Region I 631 Park Avenue King of Prussia, PA 19406 Re: Docket No. 50-220 Inspection Report No. 83-16

Dear Mr. Martin:

This refers to the special safety inspection conducted by Mr. L. Briggs of your office on July 12 to 15, 1983 at Nine Mile Point Unit 1, Scriba, New York and Niagara Mohawk Corporate Offices, Syracuse, New York of activities authorized by NRC License No. DPR-6', and to the discussions of your findings held by Mr. Briggs with Mr. C. V. Mangan of our staff at the conclusion of the inspection.

ITEM A Criterion III, Appendix B of 10CFR50 requires that design control measures shall be applied to items such as stress analysis.

Contrary to the above, design control measures were not applied to ensure that a piping system analysis was conducted to evaluate the additional weight (985 pounds) and moment effect of the installation of air operators on 6 inch containment spray system bypass / test valves 80-40, 80-41, 80-44 and 80-45.

8310270217 salots PDR 0

ADOCK 05000220 PDR

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RESPONSE

i As a result of your July 13, 1983 Confirmatory Action Letter, the following i

steps were performed. Valve operators on valves 80-40, 80-41, 80-44 and 80-45 were removed and the valves were closed. Since the original handwheels and shafts were not available, a modified configuration was later added to the valves to allow for manual operation. Prior to installation, an evaluation was performed which showed that the modified configuration would not cause any loads, including seismic, significantly greater than the original handwheel configuration. This action assured the seismic operability of both the containment spray systems.

Seismic calculations on the containment spray test / alternate torus cooling lines containing valves 80-40, 80-41, 80-44 and 80-45 were performed in accordance with the criteria outlined in the Niagara Mohawk Final Safety Analysis Report for Nine Mile Point Unit 1. It was concluded that the stresses in the containment spray piping and valve bodies due to the combination of normal and seismic loads and considering the effects of the addition of the valve operators, were within Final Safety Analysis Report allowable limits, without additional seismic support.

Prior to installation of the subject modification, an Appendix B determination was performed by Niagara Mohawk licensing personnel. The Appendix B determination concluded that the modification was non-safety related.

Subsequent to the Appendix B determination, a safety evaluation per 10CFR50.59 was written. Since the modification had already been classified as non-safety related, the safety evaluation was written presuming that no further analyses were required (now known to be an incorrect presumption). Based on the safety evaluation analysis and results, no additional design control measures were initiated.

l The situation regarding the lack of design control design measures for this unique situation has been reviewed with design and licensing personnel. In addition, a new procedure regarding the preparation and use of safety evaluations per 10CFR50.59 for modifications is being developed. This new procedure will provide additional direction in the preparation of safety evaluations for future modifications. Currently, preparation of safety evaluations is discussed in Engineering Procedure 050 Work Initiation.

Niagara Mohawk licensing personnel have also taken a licensing training ,

course, developed specifically for Niagara Mohawk by a consultant. One specific topic in this training course dealt with the preparation of safety evaluations per 10CFR50.59. In addition, Niagara Mohawk's "in-house" annual Engineering Training Program will specifically address this occurrence when discussing design control measures.

Due to these actions, Niagara Mohawk Power Corporation is presently in full compliance.

Septemb;r 1, 1983

• Ptga 3 ITEM B Criterion III, Appendix B of 10CFR50 and Engineering Procedure EP090 require independent design review to verify the adequacy of design.

Contrary to the above, a design review was not conducted to verify design adequacy when emergency condenser high point vent to torus motor operated valves were installed.

RESPONSE

Design review is documented by completing Attachment EP 090-1 in accordance with Engineering Procedure EP090 Control of Design and Design Verification. A thorough search of the project document records for the installation of the emergency condenser high point vent to torus motor operated valves has produced the required Attachment EP 090-1. This attachment (EP090-1) was completed and reviewed in accordance with Engineering Procedure EP090 in 1981. Due to a filing error, Attachment EP090-1 was inadvertently left out of the project file.

Due to this action, Niagara Mohawk Power Corporation is presently in full compliance.

Very truly yours, T. . emp d#

Vice President

Nuclear Generation TEL/MTG

djm Attachments l

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