ML20108B858
| ML20108B858 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 04/29/1996 |
| From: | Abbott R NIAGARA MOHAWK POWER CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NMP1L-1066, NUDOCS 9605060078 | |
| Download: ML20108B858 (2) | |
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NIAGARA MOHAWK GENERATlON NINE N MNT NUCLEAR STATIOfttAKE ROAD. P O BOX 63. LYCOMING. NEW YORK 13093/ TELEPHONE (315) 3491812 SUSINESS GROUP April 29,19%
! mcHARD B AB8OTT NMP1L 1066 Vice President and General Manager - Nuclear l
U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 RE:
Nine Mile Point Unit 1 Docket No. 50-220 l
Subject:
RESPONSE TO NOTICE OF VIOLATION NRC Inspection Report No. 50-220/95-24 and 50-410/95-24 i
Gentlemen:
l The purpose of this letter is to supplement our response to Notice of Violation 95-24-01 l
submitted on February 22,1996. In addition, this letter responds to your letter dated April 10,1996. The preventative actions taken for each of the identitled causes are as follows:
ITEM 1 l
The cause for not replacing the 68 NE Agastat relays was attributed to lack of a thorough review of the Wyle report. The corrective action addressed only EQ relays. Our preventative action with regard to the non-EQ relays is as follows:
The service life of the newly installed non-EQ and EQ normally energized Agastat GP series relays (4.5 years) as well as the normally de-energized relays (21.94 years) has also been incorporated into the Preventative Maintenance and Surveillance Test (PMST) database to facilitate tracking the end of the service life.
ITEM 2 The analysis of relay failures due to age and thermal degradation was based on a position
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paper. The preventative action with regard to this position paper is as follows:
1 The relevant aspects of the January 1988 position paper for Surveillance and Maintenance l
programs for safety-related equipment located in a mild environment has been included in the j
following procedures: NDD-MAI, " Maintenance" issued 6/93, NDD-REL, " Station i
Reliability" issued 12/94 and GAP-MAI-05, " Preventative Maintenance Program
- issued 1/95.
9605060078 960429
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l Today, if a service life problem similar in nature to the Agastat GP series relay issued is identified via an Information Notice, a Deviation / Event Report (DER) would be generated. Part t
l of the DER's preventive actions would be to update the PMST database with the component's updated service life to facilitate replacement and to revisit the technical evaluation of the component's preventive maintenance frequency as defined by Procedure NDD-MAI,
" Maintenance."
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ITEM 3 l
The preventative action taken with regard to inadequate management oversight is as follows:
l A lessons learned transmittal was issued for NMPC's failure to properly evaluate operating experience concerns. The lessons learned were communicated to applicable departments. The management expectation of providing the necessary oversight for operatmg experience concerns was ertphasized.
ITEM 4 l
The failure to address OE items was attributed to the fact that AP-4.3.2, " Operating Experience Assessment" did not require low level OE reports to be evaluated. The preventative action with regard to the evaluation of OE items is as follows:
The evaluation of operating experience information has also improved significantly since Procedure AP-4.3.2, " Operating Experience Assessment" was in effect. Experienced personnel are more sensitive to industry events as they may apply to Nine Mile Point. The Deviation / Event Report (DER) system is now used to evaluate and track operating experience information on a formal basis. Procedure NIP-ECA-01 requires action plans / corrective actions and preventative actions to be developed to address applicable issues. These corrective actions are reviewed and approved by appropriate levels of management prior to implementation and are tracked until completion. A lessons learned has been issued to reinforce management expectations regarding the generation of DERs for applicable operating experience items.
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We trust that this supplement addresses your request for additional information.
Very truly yours, i
R. B. Abbott Vice President and General Manager - Nuclear i
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RBA/TPM/ kap i
f xc:
Regional Administrator, Region I l
Mr. B. S. Norris, Senior Resident Inspector Mr. D. S. Hood, Senior Project Manager, NRR j
Records Management
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