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