IR 05000247/1997008
| ML20217H332 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 10/07/1997 |
| From: | Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Bram S CONSOLIDATED EDISON CO. OF NEW YORK, INC. |
| Shared Package | |
| ML20217H335 | List: |
| References | |
| 50-247-97-08, 50-247-97-8, EA-97-367, NUDOCS 9710150141 | |
| Download: ML20217H332 (5) | |
Text
October 7, 1997
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF civil PENALTIES -
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$110,000 (NRC Inspection Report No. 50 247/97-08)
Dear Mr. Bram:
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This letter refers to the NRC inspection conducted batween June 16,1997, and July 21, 1997, at your Indian Point 2 nuclear facility. During the inspection, apparent violations of NRC requirements were identified and were discussed with you and members of your staff at an exit meeting on July 29,1997. The inspection report was sent to you on August 8,1997.
On September 5,1997, a Predecisional Enforcement Conference was conducted with you and members of your staff, to discuss the violations, their causes, and year corrective actions.
Based on the information developed during the inspection, and the information provided during the September 5,1997, enforcement conference, five violations of NRC requirements are being cited and are described in the enclosed Notice of Violation and Proposed imposition of Civil Penalties (Notice).
The first three violations are set forth in Section I of the enclosed Notice.. These violations, identified through NRC questioning during observation of control room activities, relate to the Overpressure Protection System (OPS) being inoperable for approximately two and one half days in June 1997 while the reactor was shutdown. The OPS is designed to provide pressure relief of the Reactor Coolant System (RCS) while at low temperatures to protect the reactor vessel during overpressure transients. Since the OPS was inoperable, and there was not a required minimum vent area, Technical Specification (TS) Figure 3.1.A-3, required pressurizer level to be less then or equal to 30% and the actual reactor coolant system temperature and pressure to be maintained within acceptable limits. This TS figure was not adhered to by the operations crew in that pressurizer level was as high as 80%. The OPS was inoperable in that the power operated relief valve (PORV) control switches were in the trip-pull out position ar.d their associated block valves were closed, t ereby defeating its pressure relief capability.
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An inadequate procedure for performing the Reactor Coolant System filling and venting d
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operations cor.tributed to the violation of the technical specifications, in that the procedure did not refer to, or require verification of the operability of, the OPS prior to or during the RCS fill and vent evolution, in addition, although the inoperability of the OPS constituted a condition adverse to quality that existed for approximately two and a half days, this adverse condition j
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Consolidated Edison Company of
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was not identified by your staff despite numerous opportunities to do so, including: (1)during
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surveillance tests of pressurizer pressure and level as required by your technical specifications;
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(2) during several operators' shift turnover reviews of the reactor operator turnover logs
(which docments whether OPS is required oc not); and (3) during several senior watch
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' supervisors' reviews, each shift, of the reactor operator logs. In addition, although the control l
room board provided indications of OPS inoperability, the RCS parameters of temperature, j
pressure and pressurizer level were not properly assessed with respect to technical j
= specification surveillance requirements.
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Collectively, these three violations raised questions, not only regarding the quality of j
procedures at your facility, particularly " infrequently used" procedures as occurred in this
case, but also the adequacy of operator training, as well as control of equipment configuration l
st the facility, it is of particular concern that these violations were not identified until the NRC
questioned your operations staff regarding this matter. As such, these violations set forth in j
- Section I collectively represent a significant lack of attention towards licensed responsibilities i
and therefore are classified in the agCregate as a Severity Level lli problem in accordance with
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the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600 (Enforcement Policy).
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The fourth violation, which is set forth in Section 11 of the enclosed Notice, involved the poor response by management to (1) a significant reduction in the observed differential head of one e
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of the recirculation pumps in 1989, and to (2) an engineer's identification in 1995 of this reduction in performance. The pump's differential head, which had been trending around 520 feet during the tests conducted each outage prior to 1989, was observed to have decreased significantly to 480 feet during the 1989 outage, only 5 feet above the limit. Following restart
- from the 1995 refueling outage, one of your engineers identified that the pump barely met the minimum engineering acceptance limit during the 1995 test, and based on his subsequent review of past performance data on the pump, the engineer informed site management that a significant decline in the pump performance had occurred, especially since 1989. The engineer also stated to managers that he believed the pump would not pass the next scheduled surveillance test during the 1997 refueling outage. However, the engineer's concern was not entered into the site corrective action system and, therefore, did not receive a formal evaluation. As a result, the pump remained in service without further testing until the 1997 outage, at which time it failed the test and was replaced.
Subsequent inspection of the pump revealed a 25 foot section of hose wrapped around the impeller. That hose, which likely entered into the system during refueling outage testing in 1989, was the likely cause of the degraded pump performance, raising questions regarding the adequacy of your foreign materials exclusion program at the time. After the engineer
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raised his concern in 1995, your attention to this matter focused on whether it was acceptable to lower the test limit, rather than determine the cause of the reduced pump performance.
Two years later, when the recirculation pump failed its surveillance test during the 1997 outage, your initial response again was to perform analysis to see if the acceptance limit could be lowered, rather than determine the cause of the reduced performance trend, and the pump was not replaced until the symm engineer, who had raised concerns in 1995, provided additional arguments for replacing the pump. Given the fa iure tu resolve the degradation of this safety related system sooner, despite the opportunities to do so, this violation is also
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Consolidated Edison Company of
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classified at Severity Level lli in accordance with the " General Statement of Policy and 4'
Procedure for NRC Enforcement Actions," NUREG 1600.
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A common thread among the violations in Sections I and ll was your failure to identify and
correct the existing adverse conditions despite several clear opporionides to do so.
Furthermore, these failures involved more than one discipline, including the operations staff i
who did not identify the inoperable OPS system until the NRC began questioning the matter
in June 1997, as well as the engineering staff and management who did not aggressively deal
with the engineer's identification of the reduced differential head for one of the recirculation
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pumps. The f ailure to identify the OPS issue occurred in June 1997, subsequent to the May j:
1997 civil penalty, and demonstrates that concerns remain regarding your ability to identify
and correct problems.
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The NRC recognizes that the recirculation pump problem actually occurred prior to the NRC issuance of a $205,000 civil penalty on May 27,1997, and this is another example of the fundamental performance problem for which the May 1997 civil penalty was issued, namely, the failure to aggr3ssively pursue anomalous conditions. Nonetheless, this finding regarding your ineffective resolution of the recirculation pump anomaly provides additional insight into the scope and depth of the perfomiance problem that has existed at Indian Point 2. In addition, this violation was identified when the pump failed its surveillance test in May, rather than via an aggressive review to look for any other anomalous conditions after the problems that resulted in the May 1997 civil penalty had been identified by the NRC in late 1996 and early 1997. As such, it appears that you had not aggressively questioned your staff, following those previous findings, as to whether they were aware of other significant anomalous conditions at tha f acility. Even at the recent enforcement conferenco on September 5,1997, there were no indications that you had taken action to further seek from your staff whether any other similar anomalies exist at Indian Point 2 that ccdd significantly impact the operability of equipment.
A base civil penalty in the amount of $55,000 is considered for each Severity Level lil violation or problem. Since Indian Point 2 has been the subject of escalated enforcement actions within the last 2 years,' the NRC considered whether credit was warranted for
/dentification and Corrective Action in accordance with the civil penalty assessment process in Section VI.B.2 of the Enforcement Policy for each of the Severity Level illissues. Credit for identification is not warranted in any.of these cases. With respect to the violations in Section I, credit for identification is not warranted because the violations were identified by the NRC. With respect to the violation in Section ll. credit for identification is not warranted because of the prior opportunity in 1995 to identify the degradation that likely occurred in 1989. Credit was given for your corrective actions. These actions included (1) revisions of procedures, including those that are not performed frequently; (2) planned retraining of operators and engineering personnel regarding the technical specifications; (3) outage logic sequencing for OPS; (4) programmatic review of vendor safety evaluations; (5) replacement
' e.g., A Notice of Violation and Proposed Imposition of Civil Penalty in the amount of $205.000 was issued on May 27,1997 for numerous violations of NRC requirements, including several violatio s of failure to identify and correct problems at the facility.
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of the recirculation pump; and (6) performing a root cause analysis of the handling of the recirculation pump issue. The NRC plans to continue to follow your actions closely to determine the effectiveness of your actions in precluding future problems.
Based on the above, separate $55,000 civil penalties are warranted for the Severity Level lli problem in Section 1 and the Severity Level lil violation in Section ll of the enclosed Notice.
With respect to the violation in Section ll, the NRC considered exercising discretion and not proposing a civil penalty for that violation because it occurred prior to the NRC issuance of the May 1997 civil penalty that principally focused on that same performance problem. However, the staff has decided not to exercise discretion, given this violation raised serious concerns regarding the scope and depth of your prior corrective actior.c, particularly with respect to putsuing and raising anomalous conditions. While the NRC recognizes that the problems that led to the May 1997 civil penalty are deep rooted cultural issues that take time to correct, the NRC would have expected that all engineers and staff had been apprised of the importance of surfacing any anomalous conditions they were aware of, as well as continually looking for others, and that this issue would have been raised before the test failure.
Therefore, to emphasize the importance of promptly identifying and correcting problems atthe f acility, I have been authorized, after consultation with the Office of Enforcement, to issue the enclosed Notice of Violation and Proposed imposition of Civil Penalties (Notice) in the cumulative amount of $110,000 for the violations.
One other violation identified during the inspection, involving the failure to consider the effects of ambient tsmperature during the testing of pressurizer code safety' valves, has been classified at Severity level IV and is described in Section lli of the enclosed Notice.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. In your response, you should specifically describe (1) what confidence you have that there are not other anomalies involving safety-related systems that may exist at Indian Point 2 and are being handled informally without being entered into your formal corrective action systems, and (2) plans to ensure your staff understands the need for promptly entering new safety-related issues, when they arise, into the formal systems, in this regard, your response should indicate the extent of your discussions with all engineers and staff to determine whether they are aware of such anomalous conditione at Indian Point 2. The NRC will use your responst., in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements, in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," e copy of this letter,its enclosure, and your response will be placed in the NRC Public Document Room (PDR).
Sincerely,
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Mbert J. Miller Regional Administrator i
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Consolidated Edison Company of
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Docket No. 50-247 License No. DPR 26 Enclosure: Notice of Violation and Proposed imposition of Civil Penalties cc w/ encl:
P. Kinkel, Vice President, Nuclear Power C. Jackson, Manager, Nuclear Safety and Licensing B. Brandenburg, Assistant General Counsel C. Falson, Director, Nuclear Licensing C. Donaldson, Esquire, Assistant Attorney General, New York Department of Law
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Director, Electric Division, Department of Public Eervice, State of New York W. Stein, Secretary - NFSC F. William Valentino, President, New York State Energy Research and Developmei.:. thority J. Spath, Program Director, New York State Energy Research and Development Authority
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Consolidated Edison Company of Now York inc.
DISTRIBUTION:
PUBLIC SECY
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CA LCallan, EDO AThadani, DEDE JLieberman, OE HMiller, RI FDavis, OGC l
SCollins, NRR RZimmerman, NRR Enforcement Coordinators
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Rl,Ril,Rlll,RIV
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BBeecher, GPA/PA GCaputo, Of DBangart, OSP H 6 ell, OlG TMartin, AEOD TReis, OE OE:EA (2) (Also by E Mail)
NUDOCS DScrenci, PAO RI J
NSheehan, PAO RI LTremper, OC Nuclear Safety Information Center (NSIC)
NRC Resident inspector -Indian Point Unit 2 m
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