IR 05000220/2004007

IR 05000220-04-007 and IR 05000410-04-007, on 08/16/2004 - 09/30/2004, Nine Mile Point, Units 1 and 2; Safety System Design and Performance Capability

ML042920516
Person / Time
Site:	Nine Mile Point
Issue date:	10/18/2004
From:	Doerflein L NRC/RGN-I/DRS/SB
To:	Spina J Nine Mile Point
Norris B, NRC/DRS, (610)337-5111
References
IR-04-007
Download: ML042920516 (27)

Text

ber 18, 2004

SUBJECT:

NINE MILE POINT NUCLEAR STATION NRC INSPECTION REPORT 05000220/2004007 and 05000410/2004007

Dear Mr. Spina:

On September 3, 2004, the US Nuclear Regulatory Commission (NRC) completed an engineering team inspection at the Nine Mile Point Nuclear Station, Units 1 and 2. The enclosed report documents the results of that inspection, which were discussed with you and members of your staff, at the exit meeting on September 3, 2004.

This inspection examined activities conducted under your licenses as they relate to safety, and compliance with the Commissions rules and regulations and with the conditions of your licenses. The inspection consisted of system walkdowns, examination of selected procedures, drawings, modifications, calculations, surveillance tests, and maintenance records, and interviews with station personnel.

Based on the results of this inspection, there were three NRC-identified findings of very low safety significance (Green), all of which were determined to involve violations of NRC requirements. However, because of their very low safety significance, and because they are entered into your corrective action program, the NRC is treating these three findings as non-cited violations (NCVs) consistent with Section VI.A of the NRC Enforcement Policy. If you contest any NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, D.C. 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, and the NRC Resident Inspector at the Nine Mile Point Nuclear Station.

Mr. In accordance with 10 CFR 2.390 of the NRCs "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Public Electronic Reading Room Web-site at http://www.nrc.gov/reading-rm/adams.html.

Sincerely,

/RA/

Lawrence T. Doerflein, Chief Systems Branch Division of Reactor Safety Docket Nos.: 50-220, 50-410 License Nos: DPR-63, NPF-69 Enclosure: Inspection Report 05000220/2004007, 05000410/2004007 w/Attachment: Supplemental Information

M

SUMMARY OF FINDINGS

IR 05000220/2004007 and IR 05000410/2004007; 08/16/2004 - 09/03/2004; Nine Mile Point,

Units 1 and 2; Safety System Design and Performance Capability This report is for an engineering team inspection, conducted by six Region I inspectors. Three Green non-cited violations (NCVs) were identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection manual Chapter 0609,

Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.

Cornerstone: Mitigating Systems

C Green: The inspectors identified a Non-Cited Violation of the NMP1 Technical Specifications (TS), Section 6.4, Procedures, regarding a May 2004 surveillance test of the NMP1 High Pressure Coolant Injection (HPCI) system that was incorrectly evaluated as satisfactory due to a controlled document not being maintained current for a TS and risk-significant system.

The performance deficiency was that NMP1 did not ensure that the most recent revision of a controlled document was used during a TS surveillance test of the HPCI system.

The finding is more than minor since it is associated with the maintenance and testing procedures attribute of the Mitigating Systems cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). The issue was determined to be of very low safety significance (Green) because it was not a design or qualification deficiency that resulted in a loss of function per Generic Letter 91-18.

C Green: The inspectors identified a Green Non-Cited Violation of 10CFR50, Appendix B,

Criterion V, Instruction, Procedures, and Drawings, for NMP1's failure to maintain current the Technical Basis Document for the Unit 1 Emergency Operating Procedures (EOPs). Specifically, the basis for the Anticipated Transient Without a Scram (ATWS)

EOP did not discuss the Fuel Zone reactor water level indication, and the use of the associated correction table.

The performance deficiency was that NMP1 did not maintain the EOP Technical Basis Document (a controlled procedure) consistent with the plants EOPs. The finding is more than minor because it affects the procedure quality attribute of the Mitigating Systems cornerstone objective to ensure that availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e.,

core damage). The finding was determined to be of very low safety significance (Green), because the EOP technical basis document did not represent a design or qualification deficiency that resulted in a loss of function per Generic Letter 91-18.

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Cornerstone: Barrier Integrity

C Green: The inspectors identified a Non-Cited Violation of 10CFR50, Appendix B,

Criterion XVI, Corrective Action, for NMP2s failure to promptly identify and correct a condition adverse to quality concerning a valve that had dual position indication.

Specifically, the operators did not recognize that the dual position indication was a degraded condition relative to the ability to close a primary containment isolation valve (CIV). In addition, engineering did not adequately evaluate the continued operability of the valve, and closed the associated Deviation/Event Report and operability determination without implementing the identified compensatory actions.

The performance deficiency was that NMP2 did not properly identify and take adequate actions to address a condition adverse to quality; namely, a degraded primary containment isolation valve. The finding was more than minor because NMP2 failed to adequately evaluate a degraded condition with the potential to impact the Barrier Integrity cornerstone objective of providing reasonable assurance that the containment barrier protects the public from radio nuclide releases caused by accidents or events.

Specifically, the issue involved the design control attribute of maintaining functionality of containment. The significance of the finding was evaluated using Manual Chapter 0609,

Significance Determination Process, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations. The finding was determined to be of very low safety significance (Green), because the degraded valve did not represent an actual open pathway in the physical integrity of reactor containment or an actual reduction of the atmospheric pressure control function of the reactor containment. The inadequate evaluation of the dual indication of a CIV and the failure to address the recommended compensatory actions for potential pipe voiding concerns was an example of a cross-cutting issue in problem identification and resolution.

Licensee-Identified Violations

None-iii-

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R21 Safety System Design and Performance Capability

a. Inspection Scope

The inspectors selected the Nine Mile Point Unit 1 (NMP1) high pressure coolant injection (HPCI) mode of the feedwater system, and the low pressure coolant injection (LPCI) and shutdown cooling (SDC) modes of the Nine Mile Point Unit 2 (NMP2)residual heat removal system (RHS) for their review of the design and performance capability of risk-significant systems at the Nine Mile Point Nuclear Station. The inspection also included a review of the NMP1 electromatic relief valves (ERVs) and the NMP2 safety relief valves (SRVs); these components incorporate the function of the automatic depressurization system (ADS) which is used to reduce the pressure in the reactor coolant system (RCS) to allow injection by the low pressure systems.

Additionally, the inspectors reviewed an event tree at each unit: an anticipated transient without a scram (ATWS) at NMP1, and a small break loss of coolant accident (SBLOCA) at NMP2. The purpose of the review of the events was to determine if the selected systems and components supported a successful mitigation strategy to prevent core damage. The systems and components were selected because of their risk-significance related to initiating events, mitigating systems, and barrier integrity. In addition, the risk insights and probabilistic risk assessment (PRA) information relative to the selected systems were used to focus inspection activities on components and procedures that would mitigate the effects of the selected events. The inspection procedure used for this effort was IP 71111, Attachment 21.

The inspectors reviewed licensing and design basis documents for the NMP1 HPCI system and the NMP2 LPCI/SDC modes of the RHS system, and for the ERVs and SRVs for the functional requirements during normal operation and accident mitigation.

The design and licensing documents reviewed for the systems included the Updated Final Safety Analysis Reports (UFSARs), Technical Specifications (TSs), and the applicable design basis documents for each system and component.

In addition, the inspectors reviewed the associated vendor manuals, engineering analyses and calculations, equipment qualification records, instrument set-points, system modifications, piping and instrument drawings, electrical schematics, instrumentation and control drawings, and logic diagrams. The inspectors reviewed completed Deviation / Event Reports (DERs), which are the licensees corrective action documents. The review also included a review of completed corrective and preventive maintenance packages, post-maintenance tests, and surveillance tests to determine the operational readiness, configuration control, and material condition of the systems and components. The applicable system health reports were reviewed to evaluate the current status of the systems and components and any maintenance rule actions being taken, as required by 10CFR50.62. The inspectors reviewed selected industry operating experience for applicability to Nine Mile Point, and their associated disposition.

The inspectors reviewed applicable operating procedures, abnormal and alarm response procedures, and the emergency operating procedures associated with the selected events. The inspectors reviewed the applicable training lesson plans and simulator scenarios to evaluate the consistency between the assumptions made in the design basis and the expected system response. The inspectors conducted detailed walkdowns of the accessible portions of the plant to independently assess the physical condition of the systems and components, and to ensure that availability, reliability, and functional capability had been maintained.

The electrical aspects of the systems were reviewed to assure adequate voltage existed at the components of the selected systems and components. Electrical control and logic diagrams were reviewed for the major components and valves to assure that interlocks and permissive logic were in accordance with system requirements. Short circuit calculations were reviewed to assure that circuit breakers were of adequate capacity.

The mechanical inspection of the systems included a walkdown of the accessible portions of the equipment to assess the material condition and confirm the existence of adequate controls over nonconforming material and any hazards that could potentially compromise the design function of systems and components.

The inspectors reviewed how design change work had been implemented and controlled, particularly with regard to system operability status, and to verify system and component availability for the performance of design functions. In addition, field inspections were conducted with particular emphasis upon train separation, physical independence, and other common mode concerns that the design features were intended to address.

The inspectors reviewed training material associated with the operation and maintenance of the selected systems and components, assessed the NMP1 and 2 control room simulators for simulator fidelity with specific plant controls, particularly where field modifications had been effected. The inspectors interviewed applicable personnel responsible for operation and maintenance of the systems, licensing basis controls, and the development and implementation of modifications affecting the systems.

b. Findings

1. Failure to Maintain a Controlled Document Current Resulted in a Surveillance Test Being Erroneously Considered Satisfactory

Introduction:

The inspectors identified a Green non-cited violation (NCV) of the NMP1 TS, Section 6.4, Procedures, regarding a May 2004 surveillance test of the NMP1 HPCI system that was incorrectly evaluated as satisfactory due to a controlled document not being maintained current for a TS and risk-significant system.

Description:

The inspectors identified that a May 7, 2004, surveillance test of the NMP1 HPCI system pump #11 was incorrectly evaluated. Nine Mile surveillance test procedure N1-ST-Q3, High Pressure Coolant Injection Pump and Check Valve Operability Test, measured flow rate and differential pressure of pumps #11 and #12; and the values were plotted on a pump performance curve (MDC-11, Mechanical Design Criteria) for acceptability. The inspectors reviewed the surveillance test and independently plotted the results for the two pumps, and determined that pump #11 failed to meet the allowable degradation curve. The inspectors learned that the operators used an outdated revision of MDC-11 when they evaluated the test results.

Specifically, the copy of MDC-11 in the NMP1 control room was Revision 10, which allowed for a 10% pump degradation; the revision in effect at the time of the surveillance was Revision 12, which allowed for only a 7% pump degradation. Subsequently, station engineering determined the pump was operable based on a calculation which re-established the 10% degradation curve as being acceptable. During Constellations extent of condition review of the issue, they identified an additional 103 NMP1 documents that were not properly controlled, 3 of which were not current.

Analysis:

The performance deficiency is that NMP1 did not ensure that the most recent revision of a controlled document was used during a TS surveillance test of the HPCI system. The finding is more than minor because it is associated with the maintenance and testing procedures attribute of the Mitigating Systems cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). The finding was evaluated using Manual Chapter 0609, Significance Determination Process, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations.

The issue was determined to be of very low safety significance (Green) because it was not a design or qualification deficiency that resulted in a loss of function per Generic Letter (GL) 91-18.

Enforcement:

The NMP1 TS, Section 6.4.1, requires written procedures and administrative policies be established, implemented, and maintained. Contrary to the above, MDC-11 was not maintained current, which resulted in a surveillance test of the HPCI system being incorrectly evaluated as satisfactory. This finding is a violation of TS 6.4.1. However because of the very low safety significance (Green) and because the finding was entered into the NMP corrective action program (DER 2004-3752), it is being treated as a NCV consistent with Section VI.A of the NRC Enforcement Policy.

(NCV 50-220/2004-07-01)

2. Inadequate Operability Evaluation of a Degraded NMP2 Primary Containment Isolation

Valve

Introduction:

The inspectors identified a Green NCV 10CFR50, Appendix B, Criterion XVI, Corrective Action, for NMP2s failure to promptly identify and correct a condition adverse to quality concerning a valve that had dual position indication. Specifically, the operators did not recognize that the dual position indication on 2ICS*V157 was a degraded condition relative to the ability to close a primary containment isolation valve (CIV). In addition, engineering did not adequately evaluate the continued operability of the valve and closed the associated DER and operability determination without implementing the identified compensatory actions.

Description:

During a NMP2 control room panel walkdown on August 17, 2004, the inspectors noticed dual position indication on 2ICS*V157 (reactor core isolation cooling head spray 6" check valve). Control room operators stated that they believed the indication was valid, and that the valve was slightly off its closed seat. The inspectors independently verified that the UFSAR listed this valve as an inboard (inside the drywell)primary CIV that is normally closed and has position indication lights in the main control room to verify its position. Based on the design basis, the inspectors reviewed NMP2s evaluation and corrective actions for the degraded condition.

The operators had previously identified (April 24, 2004) the dual position indication on 2ICS*V157 during the plant startup following the refueling outage. The operators initiated DER 2004-2129 to address this condition. The engineering support analysis (ESA) assumed the valve was just off the closed seat. The inspectors reviewed the DER and noted that:

(1) the associated operability determination did not adequately assess continued operation for a degraded primary CIV that could not be closed;

(2) the operators did not recognize that the plant was in a TS limiting condition for operation for a degraded primary CIV (TS 3.6.1.3);

(3) the operability determination was closed even though the degraded condition still existed; and

(4) the compensatory measures identified by engineering in the ESA, to address potential pipe voiding concerns, were not implemented. Subsequently, the licensee revised the operability determination and the associated operating procedures until the issue can be resolved. The operable but degraded determination of 2ICS*157 was based on the valve being slightly off its closed seat, and that the differential pressure developed across the valve during a line break would be sufficient to close the valve. In addition, there are two other normally closed isolation valves in this line outside of containment.

Analysis:

The performance deficiency was that NMP2 did not properly identify and take adequate actions to address a condition adverse to quality; namely, a degraded primary containment isolation valve. The finding was more than minor because NMP2 failed to adequately evaluate a degraded condition with the potential to impact the Barrier Integrity cornerstone objective of providing reasonable assurance that the containment barrier protects the public from radionuclide releases caused by accidents or events.

Specifically, the issue involved the design control attribute of maintaining functionality of containment. The significance of the finding was evaluated using Manual Chapter 0609, Significance Determination Process, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations. The finding was determined to be of very low safety significance (Green), because the degraded valve did not represent an actual open pathway in the physical integrity of reactor containment or an actual reduction of the atmospheric pressure control function of the reactor containment. The inadequate evaluation of the dual indication of a CIV and the failure to address the recommended compensatory actions for potential pipe voiding concerns was an example of a cross-cutting issue in problem identification and resolution.

Enforcement:

10CFR50, Appendix B, Criterion XVI, Corrective Action, requires that measures be established to assure that conditions adverse to quality be promptly identified and corrected. Contrary to the above, prior to August 2004, NMP2 did not promptly identify and take actions to correct a degraded primary containment isolation valve. Because this issue is of very low safety significance (Green) and has been entered into the NMP corrective action process (DER 2004-3992), this violation is being treated as an NCV, consistent with Section VI.A of the NRC Enforcement Policy.

(NCV 50-410/04-07-02)

3. Failure to Maintain the NMP1 EOP Technical Basis Document Current

Introduction:

The inspectors identified a Green NCV of 10CFR50, Appendix B, Criterion V, Instruction, Procedures, and Drawings, for NMP1's failure to maintain current the Technical Basis Document for the Unit 1 EOPs. Specifically, the basis for the ATWS EOP did not discuss the Fuel Zone reactor water level indication, and the use of the associated correction table.

Description:

As part of the review of the NMP1 EOP for an ATWS scenario (N1-EOP-3, Failure to Scram), the inspectors reviewed the associated technical basis document (N1-ODP-PRO-0305, EOP/SAP Technical Basis, Revision 0, a TS required procedure). The inspectors noted that the current EOP was not consistent with the basis document. Specifically, the basis document did not discuss the purpose or use of the correction table for the Fuel Zone level indication.

The Level branch of the ATWS EOP refers the operators to the Fuel Zone Water Level Correction Table (Figure X) to determine the actual reactor vessel water level. The table provides a correction factor to the indicated water level, dependent on reactor power. The correction factor ranges from zero to minus 50 (0 to -50) inches. Per the EOP, the actual level is calculated by subtracting the correction factor (already a negative number) from the indicated level. Example: Assuming 10% reactor power and an indicated water level of -80 inches, the correction factor would be -13 inches.

Depending on how the operators applied the correction factor, the resultant actual level could be calculated as either -67 inches (-80 -(-13)) or -93 inches (-80 -13). The operators subsequent actions rely on the corrected level, which is assumed to be indicative of the actual reactor water level. The inspectors referenced the EOP basis document to understand how the table was to be used and how the operators were trained on the use of the EOP and the associated table.

During NMP1's review, they identified that a DER written in 2001 (DER 2001-2574) had documented the same issue, that N1-ODP-PRO-0305 was not current with the most recent revision of the NMP1 EOPs. The DER indicated that corrective action #2, to revise the EOP Basis Document, was completed; however, the revision was never issued. A new DER was initiated, DER 2004-3686. Subsequently, NMP1 identified eight other discrepancies between various EOPs and the basis document and they initiated DER 2004-4017. The additional discrepancies included: undocumented deviations from the Plant Specific Technical Guidance for the EOPs, conflicting steps within the EOPs, and potential improper implementation of the BWR Owners Group Emergency Procedure Guidelines.

Analysis:

The performance deficiency was that NMP1 did not maintain the EOP Technical Basis Document (a controlled procedure) consistent with the plants EOPs.

The finding is more than minor because it affects the procedure quality attribute (EOPs)of the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). The significance of the finding was evaluated using Manual Chapter 0609, Significance Determination Process, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations. The finding was determined to be of very low safety significance (Green), because the EOP technical basis document did not represent a design or qualification deficiency that resulted in a loss of function per GL 91-18.

Enforcement:

10CFR50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires that activities affecting quality be prescribed by documented procedures and that the activities be accomplished in accordance with the procedures.

Contrary to the above, the NMP1 EOP Basis Document (a support procedure to the EOPs) did not contain the required information to explain the use of the Fuel Zone Water Level Correction Table in the NMP1 EOP for an ATWS (N1-EOP-3). Because this issue is of very low safety significance (Green) and has been entered into the NMP corrective action process (DERs 2004-3684, 2004-3686, and 2004-4017), this violation is being treated as an NCV, consistent with Section VI.A of the NRC Enforcement Policy. (NCV 50-220/2004-007-03)

4OA2 Identification and Resolution of Problems

a. Inspection Scope

The inspectors reviewed the licensees effectiveness in identifying and resolving problems associated with the NMP1 HPCI system and ERVs, and the NMP2 LPCI and SDC systems and the SRVs. The inspectors reviewed DERs, Licensee Event Reports, maintenance work orders, and engineering service requests to assess plant performance and licensee corrective actions. This review was to verify that identified issues were appropriately entered into the corrective action program and resolved in a timely manner. In addition, the inspectors reviewed DERs associated with the licensees audits and self-assessments of these systems. Prior to the beginning of the inspection, the licensee performed extensive self-assessments of the selected systems, components, and the events.

1. The inspectors reviewed the licensees Safety Function Validation Reports, which were

their pre-inspection evaluations of the selected systems, components, and scenarios.

The team considered the effort to be a beneficial reconstitution of the design basis and an opportunity to identify a number of problems. Their effort resulted in the initiation of 34 DERs, and about 15 engineering support analyses and licensing change documents, before the team began the inspection. During the inspection, there were several additional DERs generated as a direct result of the inspectors questions, many of which required substantial engineering effort to determine the significance of the issues. Nine Mile management recognized the significance of the large number of problems identified and initiated DER 2004-4044 to analyze the collective significance of the DERs.

2. Cross-Reference to PI&R Findings Documented Elsewhere

Section 1R21 describes a NCV for ineffective corrective action associated with a containment isolation valve that could not be confirmed to be closed because of dual position indication. The plant operators had identified this issue several months earlier but had not properly evaluated the condition.

4OA4 Cross Cutting Aspects of Findings

Three NRC-identified NCVs are described in Section 1R21 of the report. One of the three NCVs was directly related to a failure to identify or correct an unacceptable condition. The other NCVs had attributes of ineffective corrective action.

4OA6 Exit Meeting Summary

On September 3, 2004, at the conclusion on the inspection, the inspectors presented the inspection findings to Mr. James Spina, Vice President NMPNS, and members of his staff, who acknowledged the findings. The inspectors confirmed that the inspection report does not contain proprietary information.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Nine Mile Point:

M. Conway, General Supervisor, NMP2 Operations

L. Dick, NDE & Inspection Supervisor

P. Doran, System Engineering Manager

T. Evans, Manager, Training

A. Giverson, General Supervisor, Engineering Services

W. Holston, Manager, Engineering Services

G. Honma, Licensing Consultant

A. Julka, Director, Quality Assurance and Performance

T. Kulczyky, Principal Reliability Engineer

S. Leonard, General Supervisor, Licensing

T. Mogren, General Supervisor, Design Engineering

T. OConnor, Plant General Manager

R. Randall, Assistant to Manager, Engineering Services

R. Sanaker, General Supervisor, NMP1 Operations

J. Spina, Vice President, Nine Mile Point

NRC

J. Trapp, Branch Chief, DRP, Region I

G. Hunegs, Senior Resident Inspector, NMP

LIST OF ITEMS

OPENED & CLOSED Opened and Closed:

05000220/2004007-01 NCV Failure to Maintain a Controlled Document Current Resulted in a Surveillance Test Being Erroneously Considered Satisfactory

05000410/2004007-02 NCV Inadequate Operability Evaluation of a Degraded NMP2 Primary Containment Isolation Valve

05000220/2004007-03 NCV Failure to Maintain the NMP1 EOP Technical Basis Document Current