United States Nuclear Regulatory Commission - Protecting People and the Environment

ACCESSION #: 9506010461

                               ENCLOSURE 1
         EVALUATION OF DEVIATION, DEFECT, FAILURE TO COMPLY FORM

PART I - REPORTING

NINE MILE POINT UNIT 1 (affected unit)       DER NO. 1-95-0275
                                             DATE OF DISCOVERY
3/29/95

TYPE OF CONDITION

     A.   Deviation                     B.   Defect

          1.   Basic Component     ()        1.   Deviation       
   ()

               a.   Structure      ()        2.   Other Condition 
   ()

               b.   System         ()   C.   Failure to Comply

               c.   Component      ()        1.   Atomic Energy
Act   ()

               d.   Design         ()        2.   Rule            
   ()

               e.   Inspection     ()        3.   Regulation      
   ()

               f.   Testing        ()        4.   Order           
   ()

               g.   Consulting               5.   License         
   ()
                      Service      ()

          2.   Other Condition     ()

DESCRIPTION:  Wyle Lab report 17655-ARY-1.1 which was used to
establish
the service life of various Agastat relays was found to be
deficient.

PART II - EVALUATION CHECKLIST

A deviation related to a Basic Component or a failure to comply
shall be
evaluated to determine if it presents a substantial safety
hazard.  A
condition is a substantial safety hazard if it causes a major
reduction
in the degree of protection to the public.  Criteria for
determining
substantial safety hazards include:  a) Moderate exposure to or
release
of licensed material; b) Major degradation of essential
safety-related
equipment; and c) Major deficiencies involving design,
construction,
inspection, test or use of license facilities or materials (see
NUREG-
302).

The following check list is used to determine if a major
reduction in
safety exists.  If the answer is "yes" to any of the following,
it may be
reportable per 10 CFR Part 21 and requires further evaluation.

                                                            
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                         ENCLOSURE 1 (continued)

PART II - EVALUATION CHECKLIST (continued)

                    CONSEQUENCE                             YES   
   NO

1.   Exposures received in excess of 10CFR20 limits for           
   X
     immediate notification.

2.   Exposure of an individual in an unrestricted area in         
   X
     excess of 10CFR20 limits.

3.   Release of radioactive material to an unrestricted area      
   X
     in excess of 10CFR20 limits.

4.   Exceeding a safety limit as defined in the facility          
   X
     technical specifications.

5.   A condition which could disable or prevent operation   X
     of a system required for safe shutdown, emergency
     core cooling, post accident containment heat removal
     or post accident containment atmosphere cleanup.

6.   A condition which could disable or reduce the safety         
   X
     margins for the reactor coolant pressure boundary,
     core or reactor internals, functions or operation.

7.   A condition which could disable or prevent operation         
   X
     of the spent fuel storage pool cooling and storage
     including the fuel racks.

8.   A condition which could disable or prevent operation         
   X
     of redundant Class IE electrical systems, including
     electric and mechanical devices and circuitry.

9.   A condition which could disable or prevent operation   X
     of the reactivity control systems; that is, control
     rods, control rod drives, and boron injection systems.

10.  A condition which could disable or prevent operation         
   X
     of radioactive waste systems that could recreate
     offsite doses greater than Part 100.

11.  A condition which could disable or prevent operation         
   X
     of the primary and secondary containment.

                                                            
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                         ENCLOSURE 1 (continued)

PART II - EVALUATION CHECKLIST (continued)

                    CONSEQUENCE                             YES   
   NO

12.  A condition which could disable or prevent operation         
   X
     of structures, components, or systems whose continued
     function is not required, but whose failure, could
     reduce or disable systems that are required.

13.  A condition involving the security system which could        
   X
     cause a substantial safety hazard.

14.  Other deviations in Basic Components or failures to          
   X
     comply which cause a substantial safety hazard.

15.  A condition that creates an unreviewed safety question       
   X
     (10CFR50.59).

16.  A condition which does not meet a rule, regulation,          
   X
     license or order and creates a substantial safety hazard.

PART III - EVALUATION    (to be checked by Nuclear Licensing)
                         (check applicable category)

()   Condition does not meet criteria for a potential defector
failure to
     comply because (attach additional sheets as necessary):

()   Condition does not involve a substantial safety hazard
because
     (attach additional sheets as necessary):

()   Condition involves a potential substantial safety hazard
(attach
     additional sheets as necessary):

()   Condition does not meet criteria for Potential Defect or
Failure to
     Comply, but is reportable under 10CFR50.9.

                                                            
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                         ENCLOSURE 1 (continued)

PLANT:  Nine Mile Point Unit 1          DER NO.  1-95-0275

TITLE:  Wyle Lab Report

DESCRIPTION OF CONDITION:  Niagara Mohawk has determined that the
service
life established for various Agastat GP Series relays was based
on a
deficient Wyle Laboratories report.  Specifically, a service life
of 26.3
years for these relays was implemented by Niagara Mohawk based on
Wyle
Laboratories Report 17655-ARY-1.1, Revision A, dated March 31,
1988.  As
indicated in this report, the activation energy used in
calculating the
life of the relay bobbin material (i.e., Zytel 101) was 1.17 eV,
which
was based on the materials electrical characteristics.  To have
been
conservative, the calculation should have been based on the
activation
energy of the mechanical properties of the Zytel material.  An
activation
energy of 0.84 eV is typically used for aging when the
application/

failure parameter is mechanical.  Consequently, the calculated
service
life and the relay change out frequency, (which is based on the
service
life), were non-conservative.  Accordingly, significant
degradation of
any or all of the subject relays could have occurred resulting in
the
Agastat GP relays becoming inoperable.  The subject Agastat GP
relays
were located in various Nine Mile Point Unit 1 systems including
the Core
Spray System, Reactor Protection System and ATWS/ARI System.  The
subject
relays and their specific function are tabulated in Attachment 1
to this
evaluation.

In summary, use of Wyle Report 17655-ARY-1.1 resulted in the
calculation
of a non-conservative service life, and consequently a
non-conservative
change out frequency of various Agastat GP relays.  These relays
are
located in essential NMP1 systems and their degradation and
subsequent
failure could have rendered the systems inoperable.

EVALUATION:  The potential existed for the Nine Mile Point Unit 1
Core
Spray System to have become inoperable assuming the failure of
certain
normally energized Agastat GP relays.  A Part 21 notification to
the NRC
is required if the condition would have resulted in a substantial
safety
hazard, Criteria for determining if a substantial safety hazard
exists
includes a major degradation of essential safety related
equipment.  A
loss of core spray would be considered a major degradation of
essential
equipment.  Therefore, although it is unlikely that multiple core
spray
Agastat GP relays would fail simultaneously due to age related
degradation, the potential existed and a Part 21 notification is
required.  In addition, failure scenarios involving other relays
identified on Attachment 1, could have affected the ability of
the plant
to SCRAM.

RECOMMENDED CORRECTIVE ACTION (if reportable): Immediate
corrective
action was to replace the subject Agastat GP relays.  Further
corrective
actions were, in part, to establish, strengthen, enhance or
rewrite
preventive maintenance/surveillance testing activities by
September 1,
1995 for inspection and replacement of the subject relays.

                                                            
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                         ENCLOSURE 1 (continued)

PLANT:    Nine Mile Point Unit 1             DER NO.  1-95-0275

TITLE:    Wyle Lab Report

EVALUATION PREPARED BY:
                         Signature                              
Date

CONCURRENCE BY:
                         General Supervisor Fuels and Analysis  
Date

CONCURRENCE BY:
                         Manager Engineering                    
Date

EVALUATION REVIEWED BY:
                         Supervisor Licensing Support           
Date

CONCURRENCE BY:
                         Manager Licensing                      
Date

                                                            
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Table "ATTACHMENT 1, REPLACED AGATSTAT RELAYS, 2/12/951:08 PM", 2
pages,
omitted.

Table "REMAINING AGASTAT POPULATION TO BE REPLACED, 2/12/951:08
PM", 3
pages, omitted.

*** END OF DOCUMENT ***

Page Last Reviewed/Updated Thursday, March 29, 2012