United States Nuclear Regulatory Commission - Protecting People and the Environment

ACCESSION #: 9607250114

NIAGARA
MOHAWK

NINE MILE POINT NUCLEAR STATION
P.O.  BOX 63, LYCOMING, NEW YORK 13093

FAX COVER LETTER
NINE MILE POINT UNIT 2

FROM:     FAX TELEPHONE NUMBER: (315) 349-1400

          NAME:

          DEPARTMENT: LICENSING/ENVIRONMENTAL

          TELEPHONE NUMBER:

                                             FAX #

TO:

TOTAL NUMBER OF PAGES FAXED (INCLUDING COVER LETTER):

DATE:               TIME:

MESSAGE:

6.3.3     Obtain the concurrence of the appropriate Vice President or
          designated alternate that notification is required.  If no Vice
          President (Nuclear) or other responsible Corporate Officer
          (Nuclear) is available, within two (2) working days, make the
          NRC notification required by Section 6,3.5 and inform the
          appropriate Vice President or other responsible Corporate
          Officer (Nuclear) of the condition when they are available.

6.3.4     Notify the Supervisor of Site Licensing of reportable
          conditions and jointly determine if the written notification is
          to be submitted as a 10CFR21 report or as part of a report
          submittal under other reporting requirements (e.g. 10CFR50.9,
          10CFR50.72, 10CFR50.73, 10CFR73.71).

          If the NRC has been previously notified in writing by another
          reporting method (e.g. vendor or other utility Part 21,
          10CFR50.9, 10CFR50.72, 10CFR50.73, 10CFR73.71), then the
          reporting requirements of 10CFR21 have already been met.

6.3.5     If required, inform the NRC Operations Center by facsimile at
          (301)492-8187 (preferred method) or by telephone at (301)951-
          0550 of the condition that results in a substantial safety
          hazard or Significant implication for public health and safety
          or common defense and security within two (2) calendar days of
          informing the appropriate Vice President or other responsible
          Corporate Officer (Nuclear).  Verification that the facsimile
          has been received should be made by calling the NRC Operations
          Center.

6.3.6     When oral notification to the NRC is made (by facsimile or
          telephone), ensure that a written report is submitted to the
          NRC Document Control Desk within thirty (30) calendar days
          after the appropriate Vice President or other responsible
          Corporate Officer (Nuclear) is informed that a substantial
          safety hazard exists.  A copy must also be sent to the Regional
          Administrator, Region I.

6.3.7     If required, prepare a written notification per NIP-IRG-01
          containing the following information (required by 10CFR21.21
          (b)(3)] as a minimum:

          a.   Name of Niagara Mohawk Officer informing the NRC and the
               Niagara Mohawk address.

          b.   Identification of the Unit, the activity or the basic
               component that contains a defect, deviation, or fails to
               Comply.

          c.   Identification of the firm supplying the component or
               activity.

                                 Page 7                     NLAP-IRG-140
                                                            Rev 01

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

PART I - REPORTING

Nine Mile Point  2 (Affected Unit)      DER No. 2-96-1058
                                        Date of Discovery 5/23/96

TYPE OF CONDITION

A.   Deviation                          B.   Defect

     1.   Basic Component  [x]               1.  Deviation         [x]

          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: Standby Gas Treatment System valve 2GTS*MOV3B failed to a
potential manufacturing process deficiency which allowed pin affixing the
sub to the disk to fall out.

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 checklist 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 10CFR part 21 and requires further evaluation.

                                 Page 10                     NLAP-IRG-140
                                                             Rev. 01

                           ENCLOSURE 1 (Cont)

PART II - EVALUATION CHECKLIST (Cont)

          CONSEQUENCE                             YES            NO

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

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

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

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

5.   A condition which could disable or
     prevent operation 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 margins for the reactor
     coolant pressure boundary, core or
     reactor internals, functions or operation.

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

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

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

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

                                                             NLAP-IRG-140
                                Page 11                      Rev. 01

                           ENCLOSURE 1 (Cont)

PART II - EVALUATION CHECKLIST (Cont)
CONSEQUENCE YES NO

12.  A condition which could disable or prevent
     VI operation 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 cause a substantial safety hazard.

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

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

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

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

[]   Condition does not meet criteria for a potential defect or 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.

                                                             NLAP-IRG-140
                                Page 12                      Rev. 01

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

PLANT: Nine Mile Point Unit 2           DER NO. 2-96-1058

TITLE: Potential Manufacturing Process Deficiency in 2GTS*MOV3B

DESCRIPTION OF CONDITION:

During pre-planned maintenance activities associated with Standby Gas
Treatment System (GTS) Clow valve 2GTS*MOV3B, the valve's stub shaft
dowel pin fell out of its hole and into the GTS discharge piping.
Although the ensuing investigation did not positively identify a root
cause, Engineering conservatively dispositioned the associated Deviation
Event Report (DER) indicating that the cause of this event was a
manufacturing process deficiency (Niagara Mohawk believes this is an
isolated event based on the number of Clow valves inservice and years of
service without a similar failure).  Specifically, this deficiency was
identified as the failure to fully peen over the dowel pin hole in the
valve disk.  Consequently, the valve stub shaft failed to rotate
respective to the main shaft, thus preventing the valve limit switches
from property displaying valve position.  These valve limit switches are
used as input permissives for the GTS train start logic.

EVALUATION:

The GTS is designed to prevent leakage of radioactive gases and
particulates to the environment during accidents by maintaining a
negative pressure on the Reactor Building.  The GTS consists of two
parallel and redundant air filtration assemblies with associated duct
work, dampers, controls, and exhaust fans.  The discharge of each fan has
a normally closed isolation valve (2GTS*MOV3A/3B) which will open upon
receiving a GTS start signal.  Once 2GTS*MOV3A/3B is fully open, the GTS
filter train fans (2GTS*FN1A/1B) are given a permissive signal to start.

In the event the GTS was called upon to function, discharge valve
2GTS*MOV3B would have received an open signal.  If the dowel pin had
already or were to fall out prior to the valve fully opening, the valve
would still have opened.  However, the valve stub shaft, which positions
the valve limit switches, would not have rotated as the valve moved to
the open position.  Since limit switches indicating the discharge valve
in the open position is a permissive to GTS operation, the respective fan
would not have started resulting in an inoperable GTS.  Assuming a single
failure in the redundant GTS train, both trains were potentially
inoperable, Therefore, a substantial safety hazard existed.

RECOMMENDED CORRECTIVE ACTION (IF REPORTABLE):

1) The redundant GTS train was started and verified operable.  Both
trains are subject to Technical Specification required surveillance
testing to verify operability.  2GTS*MOV3A will be inspected in RFO5.  2)
Maintenance personnel reinstalled the dowel pin that fell from 2GTS*MOV3B
and re-peened the dowel hole, restoring the valve to operable status.

EVALUATION PREPARED BY:
                         Signature                     Date

CONCURRENCE BY:
                         Manager Engineering           Date

EVALUATION REVIEWED BY:
                         Supervisor Licensing Support  Date

CONCURRENCE BY:
                         Manager Licensing             Date

                                                             NLAP-IRG-140
                                Page 13                      Rev.01

                               ENCLOSURE 2
             GUIDELINES/CRITERIA FOR DETERMINING REPORTABLE
                     CONDITIONS UNDER 10CFR50.9 FORM

                                        DER NO.  2-96-1058

1.   Does the condition have significant implication for public health
     and safety?

          Yes,           No

2.   Does the condition have significant implication for common defense
     and security?

          Yes,           No

3.   Information regarding the condition has been/will be provided to the
     NRC by other reporting or updating requirements.

          Yes,           No

     If the answer to question 1 or 2 is "YES" and the answer to question
     3 is "NO", the condition is reportable under 10CFR50.9 and Procedure
     Steps 6.3.2, 6.3.3 and 6.3.5 must be completed.

COMPLETED BY:  Signature                DATE:
               (Title)

                                                             NLAP-IRG-140
                                Page 14                      Rev- 01

                               ENCLOSURE 3
                         REPORTING SUMMARY FORM

                                        DER NO. 2-96-1058

A.   RESULT OF EVALUATION:

     REPORTABLE UNDER 10CFR21:     YES,      NO

     REPORTABLE UNDER 10CFR50.9:   YES,      NO

B.   REPORTED BY OTHER REPORTING REQUIREMENT.     NO        YES:

     Letter No.          Reported Per        Date

C.   NOTIFY NMPC RESPONSIBLE OFFICER/DIRECTOR:

     NAME: C. D.  Terry

     TITLE: Vice President - Nuclear Engineering

     DATE NOTIFIED: 7/22/96

     CONCURRENCE WITH EVALUATION:       YES       NO

     If NO.  Explanation:

     (No further action required).

D.   NOTIFY - NRC

     NRC CONTACT:                                 BY:

                    NAME                               NAME

     HOW:      Oral           Written

     DATE:     (Must be within two calendar days of date in C above).

     If NRC is notified orally, a written report must be submitted within
     thirty (30) calendar days of the date in Section C above for
     reportable conditions under 10CFR21 only.

     DATE:               LETTER NO.

E.   COMPLETED BY: (Signature)               DATE.

                                                             NLAP-IRG-140
                                Page 15                      Rev. 01

*** END OF DOCUMENT ***

Page Last Reviewed/Updated Thursday, March 29, 2012