iide

C

II

UNITCD /TATfS

NUCLt:AA ftEGULATORY CONVIISSIOBLtGIOPI I

C31 PARK AVCN)CKING Of PRU551A, PENNSYLVANIA 19400

REACTOR FACILITIES BRANCP.FILE COPY

Niagafra Hohawk Power Corporat:ionAttention: Hr. R. R. Schneider

Vice PrcsidenLElectric Operations

300 Erie Boulevard VestSyracuse, New York 13202

I'CENT~ 319?5License No. DPR-63Inspection l:o. 75-19Docket No. 50-220

Gentlemen:

This refers to the inspection conducted by ifr. T. Shedloslcy of thisoffice on September 22-26, 1975 at the Nine "Hile Point Unit 1 Nucle rSt:ation, Scriba, New York of activities authorized by NRC License No.DPR-63 and to the discussions of our findings held by Hr. T. Shedlosky'with Hr. Lempges and others of your staff- at the conclusion of theinspection and to a subsequent telephone discus ion betcseen Hr. Pe'rkinsof your st:aff and H ssrs. tJ. Baunack, T. Shedlosky a'nd T. Hartin of thisoffice on October 21, 1975.

Areas examined during this inspection are described in the Office ofInspect:ion and Enforcement Inspection Report which is enclosed with thi.slet:ter. Within these areas, the inspection consisted of select:iveexaminati.ons of procedures and representative records, interviews withpersonnel, measurements made by the inspect:or, and observations by theinspector.

Based on the results of this inspection, it appears that one of youracgivities was not conducted in full compliance with hRC requirements,as 'set forth in the Notice of Violation, enclosed herewith as AppendixA. This item of noncomplianc'e has been categorized into the level'sdescribed in our correspondence to you dated December 31, 1974. Thisnotlj.ce is sent to you pursuant to the provisions of Section 2.201 of theXI'RC'.s "Rules of Pr,.ctice", Part 2, Title 10, Code of Federal Regulat:ions.Section 2.201 requires you t:o submit to this office, within twenty (20)days of your receipt of this not:ice, a writ:ten statement or explanationin reply including: (i) corrective steps which have been taken by youand ~the results achieved; (2) corrective steps which will be tal'en toavoild furt:her items of noncompliance; and (3) the date when full com-plia'nce will be achieved. Vith your response include a copy of yoursurveillance t:est data and evaluat:ions of control rod drive performancefor events occurring on June 29-30, 1974, October 13, 1974, December 21,1974 'and Fcl>ruary ll, 1974. This data will be returned to you followingour .review.

Dt OTIC

're.1oac'

', Niagara Hohawk Power Corporation

m you in thzs regard m.than the speplaced in the Public Document Room.fied period, the report will be

In accordance with Section 2.790 of the NRC's "Rules of Practice", Part2, Title 10, Code of Federal Regulations, a copy of this letter and theenclosures will be placed in the NRC's Public Document Room. If thisreport contains any information that you '(or your contractor) believe tobe proprietary, it is necessary that you make a written applicationwithin 20 days to this office to withhold such information from publicdisclosure. Any such application: must include a full statement of thereasons on the basis of which it is claimed that the information isproprietary, and should be prepared so that proprietary informationidentified in thc application is contained in a separate part of thedocument. If we do not hear fro ci—

Should you have any questions cqncerning this inspection, we will bepleased to discuss them with yod.

3

Sincerely,

/gLl o i J. Brunner, ChiefRe tor Operations Branch

Enclosures:l.2.

CC;

Appendix A, Notice of ViolatzonIE:I Inspection Report Ão. 50-220/75-19

T. E. Lempges, General Superintendent, Nuclear GenerationT. J. Perkins, Plant SuperintendentC. L". Stuart, Operations, SupervisorE. B. Thomas, Jr., EsquireA, Z. Roisman, Counsel for Citizens Committee for

Protection". of the Fnvironment ('4'ithout Report)

bcc: 'i

lIE Hail & Files (For Appropriate~ D'stribution)PDRLocal PDRNSICTIC l

REG:I Reading RoomRegion Directors (II, III, IV) (A.eport Only)State of New YorkA. Z. Roisman, Counsel for. Citizens Committee for

Protection of the Environment

APPENDIX A

NOTICE OF UIOLATION

Niagara Hohawk Power CorporationDocket No. 50-220License No. DPR-63

Based on the results of the hRC inspection conducted on September 22-26,1975, it appears that one of your activities was not conducted in fullcompliance with the conditions of your license as indicated below:

Contrary to Technical Specification 6.S.l, which requires thatwritten procedures and administrative policies be established andimplemented, Administrative Procedure AP-16A, "Placement of Jumpers/Blocks or Lifted Leads" had not .been implemented to control thoseitems.

This item is a Deficiency.

Other deficiencies identified through your internal management controlsyst: em, which were reported in a timely manner. and corrected, are s'etout in the attached report. No additional information is needed forthese items at this time.

0-

E:I'Form 1?'.Jan 75) (Rev)

U S ?iUCLE>& REGU>~'STORY CO'.~>>ISSION

Or FICE OP INSPECTION A)V) EiÃORCPIENT

REGION I

Inspection Report No.

icen ee:

300 Erie Boulevard, 4'est

Syracuse, New York 13202

Niagara Hohawk Power Corporation

Docket No. 50-220

License .No:

Priority:

Category'.

tion. ine Nile Point 1 Nuclear Station, Scriba, New York

SafeguardsGroup.

Zips of Lie'>noee: BL R, 1850 Ndt (GE)

September 22-26, 1975

Ro ti , U a o d

tes of ~Inspection.

ates of Previous Inspection. September 15-18, 1975

Raportinp Inspector: —,.w1e,,.~f c,=~T. Sne lose, Reactor Inspector

\

j > I )''> //cmpanying Inspectors:

D. 3;. Caphton, Chief, Bl R Projects Section

\tI

DATE

i. /:DATE

DATE

Other Acconpanying Personnel:

ap>ton, >acr, ~i erogects section/ t' '.

t

SUMMARY OF FINDINGS

Fnforcement Action

A., Items of Noncom liance

1. Violations

None

2. Infractions

None

3. Deficiencies

Contrary to'Technical Specification 6.8.1, which requires thatwritten procedures and administrative policies be establishedand implemented, Administrative Procedure AP-16A, "Placementof Jumpers/Blocks or Lifted Leads" had not been implemented tocontrol those items.

H. Deviations

None

Licensee Action on Previousl Identified Enforcement Items

Not inspected

None identified

Unusual Occurrences

Not inspected

Other Si nificant Findin s

A. Current Findin ~s

1. Acce table Areas

(These are areas which were inspected on a samplinp basis anddid not involve an Item of Noncompliance, Deviation or anUnresolved Item.) P

t'

75-19-1 Radiation protection controls — "Self Monitoring"practices at radiation protection control points and theAdministration Building Portal monitor did not meet reasonablestandards'for an individual to detect contamination. (Detail2.,b)

75-19-2 Hechanical Blocking — Possible damage to contacts insafety related instruments caused by mechanically blockingcontacts. (Detail 4.c)

75-19-3 Surveillance Testing — Refueling Interlocks Procedureneeds to be approved prior to refueling. (Detail 4.d)

75-19-4 Occurrence Reports - Reports have not yet received a

review by the QC organization. (Detail 7)

5. Deficiencies Identified b the Licensee

a ~ Contrary to Technical Specification 3.6.2.a — Primazycontainment hign pressure instruments were found withsetpoints beyond Technical. Specifications allowed valueson two occasions. (i~fPC repor ts to Region I da ted June 2

and July 1, 1975, Subj ect: AO 75-12 and 75-17. )

b. Contrary to Technical Specification 3. 6. 2. f — Reactorlow-low-low water level instruments were found withsetpoints beyond Technical Specification allowed valueson two occasions. (h~fPC reports to Region I dated June 3

and July 1, 1975, Sub j ec t: AO 75-13 and 75-16. )

ce Contrary to Technical Specification 4.3.6.c(1) — Quarterlysurveillance testing did not include a calabration checkof pressure suppression chamber - reactor building vacuumbreaker instrumentation. (h~iPC report to Region I datedAugust 4, 1975, Subject: AO 75-19.)

d. Contrary. to Environmental Technical Specification 3.2.c-Hilk samples were not analyzed for Iodine 131 within therequired confidence limits. (Ni')PC report to Region Idated September 3, 1975, Subject: AP 75-23.)

Management Interview

A management interview was conducted on Septem'ber 26, 1975 with Mr. T.H. Lempges, General Superintendent — Nuclear Generation, Mr. T. J.Perkins, Station Superintendent, Hr. >J. M. Bryant, Supervisor, QualityControl, Operations, and Mr. R. Norrix. Items discussed are summarizedbelow:

A. General

The inspectors summarized the scope of the routine inspectionrelative to a review of plant operations, logs and records, afacility tour and surveillance testing prior to refueling opera-tions. A review of Abnormal Occurrences reported since the lastinspection and a review of the licensee's Abnormal OccurrenceReview s stems wire also conducted.

!

y

3. ~Ins ection Findinp~s

The items listed above under Items of. Noncompliance, UnresolvedItems and Follow-up Items were identified and discussed.

The inspector noted that the surveil3;ance procedures reviewed inthe areas of Chemistry, and Instrument and Control had been re-vised. The procedures and the records of completed testing selectedmet the requirements of ANSI N18.7 — 1972 and AP'-17A. However,those selected records and procedures concerning testing by Opera-tions and Reactor Engineering indicated that a significant amountof work remains to meet the licensee's commitment to ANSl N18.7—1972.

Licensee representatives stated that they were confident that testdata was available and was within specifications fo'r those itemsdescribed in Detail 4.a and b. The inspectors agreed to considerthese items as unresolved and review that data during future in-spections.

I

DETAILS

1. Persons Contacted

Hr. T.Hr. T.Hr. C.Mr. J.Mr. R.Hr. R.Hr. T.Hr. J.Hr. P.Hr. V.Hr. S.Hr. B.Mr. J.

Hr. R.

F,. Lempges, General Superintendent — Nuclear GenerationJ. Perkins, Station SuperintendentL. Stuart, Jr., Operations SupervisorC. Aldrich, Training Supervisor

Baker, Haintenance SupervisorA. Burns, Radiochemistry and Radiation Protection SupervisorJ. Dente, Reactor Analyst SupervisorJ. Shea, Station Shift SupervisorC. Lilly, Station Shift Supervisor

AuClair, Shift Operating ForemanDamago, Nuclear Auxiliary:.operatorTaylor, Assistant Instru...ent and Control SupervisorDuell,'Assistant Radiochemistry and Radiation Protection

SupervisorTessier, Reactor Analyst Technician

2. Pacilit Tour

A tour ~~as conducted of accessible areas of the reactor and turbinebuilding. The following observations were made:

a. Instrumentation — The inspector noted that the process instru-mentation monitoring the SLC syst: em indicated within technicalspecification allowed values.

b. Radiation protection controls — The inspector noted generalconformance with established radiation protection controls.However, several areas in the turbine and reactor buildingswere posted as being surface contaminated. Several werewithout 'the step off pads and containers for discarded protective

. clothing.

The inspectors observed the "self-monitoring" practices atthe control point at the exit from the Turbine Building to theAdministration Building (rad protection office and locker room).About 60% of the people passing .through that point did not takeproper care in performance of that monitoring in that:

(1) hands were not checked prior to picking up the probe,

(2) surveys consisted only of a quick survey of the bottomsof shoes.

These observations were discussed with plant management.Act:ions taken included additional. instructions to supervisorsconcerning the care taken during "self-monitoring" and instruct-ions to radiation protection personnel t:o monitor act:ivit:iesat check points more closely.

c. Plant housekeeping — The inspect:or did not identify housekeepingconditions which may have constituted a fire hazard. ~

'd. Fluid leaks — No significant fluid leaks were noted during t:heplant tours.

System lineups — The inspector verified the lineup of the SLCsystem per Technical Specification and Operating Procedure 12.

Control Room annunciators — The status of annunciators wasdiscussed with shift personnel, who were knowledgeable as totheir condition.

Cont:rol Room manning was verified to be in conformance withthe Technical Specifications.

a. Station Shift Supervisor and Shift Operating Foreman logs werereviewed for the selected period of August 24, 1975 throughSeptember 13, 1975 (Hooks 8138, 3.39, and 148, 149, 150 re-spectively). These logs were reviewed per the requirement:s ofthe Technical Specifications and Administrative Procedure.,

b. Jumper Log - The "Electrical Jumper Log" was reviewed for theperiod of March 8, 1975 through September 23, 1975. The logwas being maint:ained per the superseded "Standing Order for.placement of Jumpers/Blocks or Lifted Leads." The requirements

I

of Administrative Procedure AP-1GA "Placement of Jumpers/Blocks or Li.fted Leads" has not been implemented. The presentrecords do not identify the persons approving the placement ofa jumper or= lifted lead and do not reference the procedurerequiring the jumper or lifted lead. A description of thefuncti.on of the jumper was not always given as relating toloss of equipment protective functions, interlocks and impacton Technical Spe'cification requirements.

C ~ Standing Orders — Standing ordex's for the Site" and for NineNile,Point 1 wexe reviewed in accordance with the requirementsof the Technical Specifications and Administrative ProcedureAP-9. Those standing orders in effect which were reviewedwere:

APSO-1Ni'APSO-2Vi'PSO-3NHP S0-4h~iPSO-5hRPSO-6h~fPSO-7SSO-1SS0-2

Load CurtailmentControl Room ProcedureShift Secuiity PatrolPatrol InstructionsShift Surveillance TestingRock Blasting OperationsOperation of Track B y Extension Door D.198Shift Transition4 VV Breakers

The inspector had no questions concerning these standingorders.

d. Station Shift Supervisor Instructions — Station Shift Super-visor instructions (Night Orders) were xeviewed through September23, 1975 per the requirements of tne Technical Specificationsand Admi.nistrative Procedure AP-15 "Procedure for SpecialOrders and Instructions." The inspector had no questionsconcerning these instructions.

e. Occurrence Reports — The inspector reviewed occurrence reportsthrough those dated September 13, 1975. None resulted inreportable events which had not been -the subject, of an Abnor-mal Occurrence Report.

Surveillance Testin

The inspector selected the following limiting conditions for operationand their respective surveillance testing fox'he -purpose of verifyingprocedural coverage to meet the requirements of the Technical Speci-fications, ANSI N18.7 — 1972> and Administrative Procedure AP-17:

Report 50-220/75-07 contains a licensee committal for proceduralcompliance with ANSI N18.7 — 1972 by December 1975.

~ I

-8- .

3.6.2.a/4.3.5.2/4.5.3.6.1.b/4.3.6.3.a/4.3.6.3.b/4.

6. 2.a,2

6.1.b6.3.a6. 3.b

3.1.3/4.1.3.1.4/4.1.

3.2.5/4.2.53.2.7/4.2.7.83. l.1/4. 1. 1. c (2)3. 1. 2/4. l. 2. b3. 6. 2. a/4. 6. 2. a,

Reactor Coolant System Leakage RateReactor Coolant System I.,olation ValvesControl Rod Insertion Times (Scram)Liquid Poison System (Boron Solution Checks)Table a Item (11) Turbine Stop Valve Closure,

ScramTable a Item (12) Load Rejection, ScramRefueling Platform InterlockHechanical Vacuum Pump Auto IsolationEmergency Power, EDG Auto StartEmergency Power, EDG Rated Load Test andBattery TestingEmergency Cooling SystemCore Spray System

The latest reviqfile and selectdfollowing items 'w

a. Timin of P

ion of approved surveillance test procedures ond test data was reviewed by the inspector,. Theere noted:

eactor Coolant Isolation Valves 4.2.7.a

This procedure was completed during the last refueling outageunder, Licegse DPR-17. It has not yet been revis d to meet therequiremenLs of ANSI Nl&.7 — 1972 in that:

/(1) Prerequisites are not complete.

/(2) Return to normal not included.

I

(3) Data Sheet steps are not keyed to the procedure body andprovide blanks for initials or signatures as required.

It

(4) Data Sheet does 'not sign off data, a sign off. sheet isnot '.used. t

(5) There is no certification that the acceptance criteria issatisfied.

(6) Change made to procedure was not properly approved.

(7) The procedure does not require testing of the followingvalves:

J

(a) Hain Steam — Emergency Cooling Vents (2 lines, 2valves per line)

(b) Emergency Cooling — Steam Leaving Reactor (2 lines,1 valve per linc:)

This is an unresolved item. The licensee has committed tocomply with ANSI N18.7 — 1972 by December 1975.

b. Control Rod Insertion Times (Scram Insertion)

(1) Data for this surveillance test was reviewed for timeperiods covering DPR-17 and DPR-63. Tne review wasconducted in light of requirements and controls in effectat those times. Generally, insertion times could not beverified to have been accomplished becaiise:

(a) There is no procedure to cover this requirement.

(b) Records are kept for a few of the scrams but only onscratch paper.

(c) Revi.ew of SCRQi Reports reveals that although thereis a place to ce:tify'equirements have been met, itis missing from reports dated 6/29/74>', 10/12/74~:,12/9/74<; 12/24/74-', 1/12/75, 1/18/75 and 2/3/75.

(d) Review of the Short form Pre Startup Checklistreveals the foregoing certification missing orinconsistencies as follows:

1. 7/27/75 Scram Report certified insertion times,however, Pre Startup Clecklist stated it wasnot applicable.

2. 1/12/75 Checklist noted "Branch Recorder Operated"but not data as being satisfactory.

3. 7/1/74*, 6/30/74~, and 6/28/74>'o not listcertification.

(e) Results of SCRAH INSERTION TEST — June 29-30, 1974»indicated that 5 rods exceeded the 50% max insertiontimes. Available records could not prov'ide assurancethat control rods wi.thin nine rod square arraysaround these rods met the conditions for operation.

(f) Evaluations w'ere not available to provide an analysisof the following occurrences:

Sera'm Insert l)ata Comment

s'0/13/740Eight rod mean 90% rod insertion timeexceeded the range of 2.4-3.1 scc.average = 2.339.

12/21/74~ Eight rod mean 90% rod insertion timeexceeded the range of 2.4-3.1 sec.average = 3.70.

1 rod (not numbered} exceeded 50%maximum insert time of 2.12 seconds.

20 of 27 rods exceeaed the single rodrange of 1.9-3.6 seconds.

2/11/75 Rod 34-51 on data sheet states thereading is bad; however, informationin reactor physics log indicatesproblems with a value and noted itto'ok 2.5 se . prior to any rod motion.

C ~

This is an unresolved item and will be followed up onduring a future inspection.

Instrumentation Surveillance of Scram Initiatin Iqstrument

Generator Load Re ection

Nl-TSP-IC-23 and 02-13 were reviewed and discussed <eith licen-see. Both procedures require minor modifications tb meetSurveillance Test Procedures criteria.

t

would review the procedure to determine the feasg.baliet. of conducting the IC-23 tests concurrently with 02-13

so that the devices will operate as designed. The in-spector had no other questions.

(1) Instrument Surveillance Procedure — 23 require that fortests below 45% Reactor Por:er, the Turbine Anti,cipatoryTrip Bypass Reactor Scram contacts be mechanically block-

Ied open. The inspector pointed out this could 'possiblydamage or cause the instrument trip points to be changedwithout a recheck or calibration. 'The licensee stated he

y

+DPR-17

-11-

d. Auxiliary~S stem - Testing of the Refueling Platforms Interlock

(1) At the present time there is no procedure for conductingsurveillance tests of the refueling platform interlock.A procedure'is required to test the interlock prior tothe moving of fuel during the present refueling outage.This is an open item and will be reviewed during subse-quent inspections during this refueling.

e. ~En ineered Safety Features — Emergency Cooling System HeatRemoval Capability

(1) Procedures and data for this surveillance requirementwere reviewed. This test was .completed during the last-refueling outage under License DPR-17. It has not yetbeen revisdd to meet the requirements of ANSI N18.7—1972, but is required only every five- years. Itemsidentified include:

(a) Data sheets do not provide for recording of data andfor evaluating and reviewing the results, as tomeeting acceptance criteria.

(b) Data sheets paragraphs are not keyed to the pro-cedure body.

(c) „ Sign off sheets are not used or the sign off dataincluded on the data sheets.

(2) Records available were raw data and rough computations.There is no evidence the data has been reviewed; however,a review of the data by the inspec'tor with licensee per-sonnel revealed the data is sufficient for a properreview and did meet the acceptance criteria.

(3) Records did not indicate a refueling outage automaticactuation and functional system testing as being com-pleted during previous (1974) outage:".

This is an unresolved item to be followed up on in accord-ance with the licensee's commitment to revise proceduresby December, 1975.

*DPR-„17

-12-

5. Review of Nonroutihe Event Reports

Licensee Event Reports of Abnormal Occurrences werc reviewed throughreport AOR 75-23 dated September 3. Of these reports the followingwere inspected: AOR 75-5, 8, 12, 13, 16, 17, 18, 19 and 22. Theinspection consisted of verification of the details of the report,and inspection of the corrective action taken, including the required

,review by safety committees. The circumstances surrounding theoccurrence were reviewed to determine if Technical Specificationlimits were exceeded.

a. Failure of Emergency Ventilation System (75-5).

A failure of redundant solinoid'perated air valves preventedthe operation of the emergency ;".~ntilation system commonisolation valve. The valve was manually opened. One SOV wasfound to hav'e a broken stem; the second was filled with metaloxide. Both valves were repaired and the system returned to a

. standby status. The inspector had no other questions.

b. Turbine Trip RPS Logic (75-8).

Relay 12K30 which is normally energized during reactor opera-tion failed due to a shorted coil. This caused a trip in RPSChannel 12. All components except relay 12K30 operated asrequired. The licensee considers this failure was expected .

due to the high usage of the relay coil. The inspector had noother questions.

Ce Drywell High Pressure (75-12 and 17).

On two occasions, the trip points of drywell high pressure,instruments were found beyond the Technical Specificationlimit of 3.5 psig +0. 053 psi. AOR 75-12 reported that instru-ments A, B and D tripped beyond the limit of= 3.553 psig at 3.7psig. Instruments B and D are in RPS Channel 12 and instru-ment A is in RPS Channel 11. AOR 75-17 reported that instru-ment C tripped at 3.7 psig and instrument D tripped at 3.75psig. Instrument C is in RPS Channel 11 and D is in Channel12. In both cases the licensee took credit for the protectionoffered by reactor water'level instruments. The inspector hadno other questions.

-13-

Reactor Low Pater Level.

On two occasions the trip points of reactor low-low-low waterlevel instruments were found beyond the Technical Specifica-tion limit of 7'll" below minimum normal water level at eleva-tion 302'9", +2.6 inches of water. AOR 75-13 reported the setpoint drift of instruments D, A and C. These tripped at124.5", 132" and 124" respectively (based on this instrumentzero the required trip is 125.4" to 130.6"). The licenseenoted that although these three instruments are beyond technicalspecification limits, three of four instruments would actuatesooner than required. His safety analysis concludes that therequired protective function was provided. Instruments A andC are in RPS Channel ll; instrument D is in Channel 12. AOR

75-16 reported the set point drift of instruments A, B and C.Instrument A was found at 8'2", B at 8'3.5" and C at 7'll".The required trip point is the range 7'8.4" to 8'1.6". Instru-ments A and C are in RPS Channel 11 and instrument B in RPS

Channel 12. The licensee has included that the protectivefunction would operate as required as one channel in each tripsystem was found with its set point to actuate sooner thanrequired. The inspector had no other questions.

e. Emergency Cooling System Vent Radiation Monitor.

The licensee reported that during reactor operations, a com-ponent failure in the emergency condenser vent radiation mon-itor caused the monitor to fail upscale and isolate the emerg-ency condenser system. This operated in accordance with .

design. The monitor was then replaced. The licensee did haveseven days to return an inoperative emergency cooling'ystemto service. The inspector had no other questions at thistime.

f. Torus/Reactor Building Vacuum Breaker.

The licensee reported the failure to include a calibration ofTorus to Reactor Building vacuum breaker instrumentation inquarterly surveillance testing. System operability had beenchecked, but additional requirements contained in the TechnicalSpecifications of the full term operating license had not beenincorporated. The licensee has completed this testing. Theinspector had no other questions at this time.

8. Review of Annual-Re orts

The inspector reviewed the first annual report of operation of NineNile Point Unit 1. The review was conducted based on the require-ments of the Technical Specifications and Regulatory Guide 1.16.The inspector found that these reporting requirements were met andthat the events reported correlated with facility records. Theinspector had no other questions.

e

~iQ~PVr,.gag~~'f;0:.yygif ig „l;.f>~~I ~"P',I~~ak~erov.t !~q~g.~~~1~~;~ @Mr rw~p~rv~REACTOR FACILITIES BRANCH

UNITED Sl ATES

NUCLEAR REGULATORY COMMISSIONREGION I

631 PARK AVENUEKING OF PRUSSIA, PENNSYLVANIA 19406

FILE COPY

~"

Niagara Mohawk Power CorporationAttention: Mr. R. R. Schneider

Vice President,'lectric Operations300 Erie Boulevard WestSyracuse, New York 13202

License'No. DPR-63Inspection No. 50-220/75-15Docket No. 50-220

Reference: Your letter dated October 3, 1975In response to our letter dated September 12, 1975

. Gentlemen:

Thank you for informing us of, the corrective and preventive. actions youdocumented in response to.our correspondence. These actions willbeexamined during a subsequent inspection of your licensed program.

Your cooperation with us is appreciated.

.Sincerely,

Eldon J. Brunner, ChiefReactor Operations Branch

cc: T." E.T'.C. L.E. B.A.'.

Lempges, .General Superintendent, Nuclear .GenerationPerkins, Plant SuperintendentStuart, Operations SupervisorThomas, Jr., EsquireRoisman, Counsel for Citizens Committee for

Protection of the Environment

~ I~

Dec: PDRLocal PDRNSICTICREG:I Reading RoomState of New YorkIE Mail & Files (For Appropriate

~ . g~~ + ~ 11

Distribution)

1

NIAGARA MOHAWKPOWER CORPORATIONgl<f

'IAGARA'OHAWK

300 ERIE BOULEVARD. WEST

SYRACUSE. N. Y. I3202

O~beIc 3, 1975

hPc. ELdon, 3. Rcunnm, Ctu.efR~ox Op~coca BunchhMed S~u NucL~ Regulatory CommissionRegion I631 Pan,k Avenue,Kmg og Pluuak a, Pa. 19406

RE- Sock& No. 50-220Inhpe~n RepoM 75-15

SeaIc hM. Rcunne/c:

Ne have, icevLeved Iwpe~n RepoM No. 75-15 )ojc Nine NLe Po~UnLf: II1 and Pnd ~ an eftfcoa exes& in Appendix A, ICem C, "ANSI N45.2.12".TELE 6houLd aead, "ANSI N45.2.11" p~jc 4o pLaeenent in Ae NRC PuMLe.Voeument'oom. ConeWIu.ng We aLLedged ingm~one and degeieneiuidej~ped in Append A W youfc hepoM, Ae (oLLouLQIgLb hub~ed pu4buantCo 10 CFR 2 Sation 2.201-.

A.

RESPONSE:

"Co~y A 10 CFR 50, AppencKx 8, C~~n III and XVI, and AFSAR SuppLemeet TcveLve, a~n Co eomeet Che inadequacies, &~-+ed by See Licensee aucKt on deign and mocLi+~on eo~oL, hasnoC been eompL&ed oe ackeduLed foe compL~n nojc me pjcoeeckucmpeavided Xo awuee ~eLy eorvce~ve a~on on aucKt gncLcnga. R

Deign and modcgeatian eo~L hm been impLemeJ<ed piquant WAP-20, Plcoceduft,e )oh. PLa&/S~n WoN,P~n, and eiLL be,

eLoaeLy mo~ced by We gua&ty Co>~L o~aru.z~n at NcepLant. In aden, a, ~et date. o$ Januucjc 1, 1976 hah beeneckxbMshed foe Che compLetion o$ aLL mo&geathn $ oenh euvceet

Ae mode pea.ban pIcogjcesa. INLET expeMed Chat ~ a~nuccXt'. eLiIninate (cvcthn pjIobLeme in ~ gaea and guLL compLiane,e

expected by 3'anuaIcy 1, 1976. Reg~g Che. pico@,edccIcaL in-adequaeiu, Ckue cIccLL be, eomeMed by November 15, 1975 W ic~u,ireeeome~ve a~n 4o be. eompLeted +it'Mn 30 de oe a, aehedcILeesWbM bed and a. foLLox-up fcepojct by She aucKted oJcganz~on.

Page. 2

"Co~y W 10 CFR 50, Appenckx 8, CPLtetu.on V, and W FSAR

SuppLemeet Twelve and QCP 16. 0, Ae paocedutcse me noC bmngJoLEotved k~ Jcebponee W audit (wiNnga."

RESPONSE:

A copy o$ 4m ceps has been M~b«ed W aLL plant gimu~ Wm~u6 upon Chem Che aeq~em~ W aupond W a, noncon$ owMyrcepoM okrt&n 15 Koafu,ng day o$ She date og Che ceps. ICelf.'e. $~hn empfuumed Chuung pe& me~gh teil pLcmCsupanvLeom Niat adh~nce Co gCP lb.0Le aeq~ed and, expected.The. above, a~on tcKL @came 4he avoidance o$ $~hW Meme o(noncompliance nz CRQ matte. FuLL comp&ance f ah been, acfu.eved.

"Co~y N 10 CFR 50, Appendix 8, Cekt'elean III and the TeeLJWSuppj'emeute W Ae FSAR, Die eng~neetm~g and plant'eocedhucu havenoC ~ncoliporcated aLL &e rceq~em~ Ln We FSAR combine&ANSI N45.2.12."

RESPONSE:

The goLLou@tg congas tccXL be. made. W &e Eng~eeu,ng Paoceckuru by2amuucy 31, 1976:

a,. The, aeq~emeets o$ Patcagmpks 6.1, 6.2, 6.3, 6.3.2 and6.3. 3 o$ ANSI N45. 2.11 v~ be mcLuded cn subsequentcev~Lons o$ Che Engkne~ng Paocedmu. Tks'se ceqc&ce-men45 deaLing utah dmin veau.+cation and methods +K'e~ncLuded ~n Die appmpu,ate p4ocedMeh.

b. The. 28 dee~gn ~npat6 o( PutagMph 3.2 W be, consMMedLnChe deveLopment o$ a dmin afiaLL be ~ncoapo>~ed n<o WeappMpu~e EngmeeJmtg PMceckuce. These inp~ couLdmoat (avombLy be. ~netuded ae a check&54.

c,. The. rceq~emmQ o$ P~gmph 8.2 aerating W aevaev andappeovaL o$ dmin changers ahaLL be.kucLuded zn Die netcev~mn o$ Ae appM~~e Eng~neemrg Pcocedmae.

AP-20 AM, be, cfuwged W ~cLude Nce ~uLeiava og ANSI N45.2.11by 3'anally 31, 1976.

"Co)~y Che rceq~emeJM og 10 CFR 50.54 (x-1) and Nze approvedOpetuuu< RequaU.Pnx&an Piugruvn:

a,. mo><fly <evanesce o$ She ~Mng mammQ had noC been con-ducted

b. annuaL otutl, exmia>Mons had noC been,conduced fox We MiceopMatom selected $oz rcev~ev."

RES POh!$ E:

a. ALL eevieoe zeq~ed bg She approved Op~o< Requaki Pc~onPaog~ tvett,e compL&e on September 30, 1975. F~e revivesteiLL be, conduced in accordance ~h She above, pttog~n.FuLL compLiance 4u been achieved on ChL6 Mem.

RESPONSE:

b. The. Xhfcee seLe&ed op~os annuaL o~ examinatiane tttwe.conduced and compL&ed on September 26, 1975, Cheftebg,achieving .compMince on 4l~ &em. ALL op~os. rceqtu'fiedxevietos me scheduLed Co be. compL&ed Lately, CALe geut. inaccordance uLth Xhe pjtogruun. The au~ o$ Whee cevievstciLL be. usted in evaL~ng She ~ogden etI)mtivenuh and inpLanning She (~e peog~.

"Co~g Co Ae heqtuAeme~. o( 10 CFR 50, Appendix 8, C~etuan V

and Se~n 2.3 o$ Appendix 8 Co Paocedutte AP-21, one. o$ Xhe Chh,eeempLogeee aeLe&ed two'eviev had not ieceived ate- eeq~ed aecueLty~ning."

The, individuaL ide~ped in. porn ceps tea given aectu~tl Stat. ningon September 23, 1975. 7n ad~on, a. eevietv um conducted o( aLLempLogem .to, d&etuw.ne i$ aLL had been given the cecity ~ning.The i~u~ indicated Chat 925 had ceceived Xhe Waining. The. jte-maining 8'5 teil be, dcheduLed $ o< ~ning. FuLL compLiance mexpeMed bg hlovembn 30, 1975.

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