IR 05000286/1997080
| ML20217R327 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 08/19/1997 |
| From: | Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Barrett R POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| Shared Package | |
| ML20217R328 | List: |
| References | |
| 50-286-97-80, EA-97-294, NUDOCS 9709050059 | |
| Download: ML20217R327 (5) | |
Text
August 19, 1997
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF civil PENALTY
- $55,000
(NRC Inspection Report No. 50-286/97-80)
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Dear Mr. Barrett:
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This letter refers to the NRC engineering team inspection conducted at the Indian Point 3
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facility between April 7 and May 1,1997, the results of which were discussed with you at f-,
exit meetings on May 1,1397, and June 10,1997. During the inspection, one apparent violation of NRC requirements was identified. The inspection report was sent to you on
[L June 19,1997. On July 30,1997, a predecisional enforcement conference was conducted
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with Mr. J. Knubel, Chief Nuclear Officer, yourself, and members of your staff to discuss the fl apparent violation identified during the inspection, its causes, and your corrective actions.
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Based on our review of the inspection findings, and information provided during the f
conference, one violation of NRC requirements is being cited and is described in the enclosed l
Notice of Violation and Preposed imposition of Civil Penalty (Notice). The violation involves l I three examples where design basis information was not correctly translatad into Emergency l
Operating Fiocedures (EOPs). The examples include: (1) no technical basis for operating with qj
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the component cooling water (CCW) heat exchanger service water outlet valves throttled i
during sump recirculation when the heat exchanger is placed in service following a postulated
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d accident; (2) no instructions for thrcttling the recirculation pump discharge valve to prevent
pump runout under certain conditions; and (3) {nadequate instructions for isolating nonsafety-
.i related CCW loads, i
, l In the first case, the EOP for transferring to cold leg recirculation did not require operators to I
prcperly re-position the CCW heater exchanger service water outlet valves prior to entering f
l the recirculation phase of a postulated design basis accident. These valves are normally
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j throttled to maintain acceptable CCW temperatures. Either the EOP should have required that I
the valves be re positioned (to their analyzed position), or an analysis should have been (4 performed to demonstrate that the CCW system would perform its intended safety function during the initial transition to recirculation with the valves in their normally throttled position.
The CCW system functions to remove decay heat from the reactor core and provides cooling to other safety-related emergency core cooling equipment. Poor communications between site
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and corporate organizations, as well as inadequate engineering involvement in procedure changes, contributed to th!s deficiency in that important design information regarding the function of the service water system was not properly trenstated into the EOPs.
9709050059 970819 yg][jlll]'l]lgly]l
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PDR ADOCK 05000286
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New York Power Authority
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in another case, the EOP for transferring to cold leg recirculation, directed the operator to adjust total recirculation flow to less than 6000 gpm to entisfy the not positive suction head requirements, with both recirculation pumps running. However, no guidance was provided in that ECP to reduce flow to less than 3000 gpm in the event that only one recirculation pump was operatirg, so as to prevent runout in a single pump configuration. While a step to throttle pump flow during these conditions had previously been included in that EOP, that step was
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inadvertently omitted during a procedure revision which was approved in September 1996, l
and the elimination of that step was not documented in the change history form. Insttent!on to detail, a lack of a questioning attitude, and no written standard regarding the use of the history forms, contributed to this violation.
In the third case, the EOP directed the operator to isolate CCW flow to the non-regenerative neat exchanger by closing an air-operated outlet temperature control valve (TCV) to prevent diversion of CCW flow to other safety-related components. The EOP further instructed that if the TCV cannot be closed, the operators were to isolate CCW flow to the non-regenerative heat exchanger by closing manual isolation valves in accordance with the system operating procedure. However, this EOP was deficient since the instrument air system supplying air to
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the TCV is nonsafety related, and therefore, cannot be relied upon to function. Therefore, credit could not be taken for the availability of this air supply. Without a reliable source of air supply, the TCV can fall to its open position after being successfully closed early in the event, resulting in diversion of CCW flow from safety-related components during the recirculation phase of the accident. A previous revision of this procedure correctly directed the closure of a manual valve to isolate the non regenerative heat exchanger; however, a 1995 procedure revision inappropriately incorporated a vendor recommendation to first attempt to close the TCV, and close the manualisolation valve as a contingency. Contributing to this deficiency was your acceptance of the recommendation without an adequate review.
These three examples represent a significant regulatory concern because they are indicative of inadequate-controls to properly incorporate design basis information into the EOPs.
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Apparently, your process did not require sufficient reviews of EOPs by engineeri~ staff.
Furthermore, all three of these examples were identified by the NRC, raising.,nificant
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- questions regarding the adequacy of your self assessments of EOPs. As such, these violations
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represent a br2akdown in control of licensed activities, and raise questions both of the adequacy of your EOPs, as well as the effectiveness of the ECP reviews. Therefore, the violation has been categorized at Severity Leveilllin accordance with the " General Statement
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of Policy and Procedure for NRC Enforcement Actions,"(Enforcement Policy), NUREG 1600.
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New York Power Authority
2 In accordance with the Enforcement Policy, a base civil penalty in the amount of $55,000 is considered for a Severity Levelill prob!em or violation. Your facilities have been the subject of escalated enforcement actions within the last 2 years'. Therefore, the NRC considered whether credit was warranted for /denti// cation and Corrective Action in accordance with the civil penalty assessment process in Section VI.B.2 of the Enforcement Policy. Creoit is not warranted for /dentification since all three examples of the violation were identified by the NRC. The NRC also considered your corrective actions, as described at the enforcement conference. These actions included, but were not limited to, (1) revision to the affected EOPs; (2) plans to perform a broad review of procedures, including a review by design engineering; (3) plans to review all EOPs, to determine if applicable design information has been incorporated; (4) plans to change the relevant administrative procedure to ensure an engineering review of proposed EOP revisions prior to implementation to ensure that the revisions do not result in the omission of pertinent procedural steps; and (5) training of engineers performing EOP reviews, as well as developi. ant of a program to qualify individuals performing EOP reviews.
Therefore, to emphasize the importance of appropriately factoring design information into your EOPs, as well as critically self assessing all aspects of your program to ensure such deficiencies, when they exist, are promptly identified and correctsd by your staff, rather than by the NRC, I have been authorized, after consultation with the Director, Office of Enforcement, to propose civil penalty of $55,000 for this Severity Level 111 problem.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure complianca with regu'atory requirements.
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in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, its enclosure, and your response will be placed in the NRC Public Document Room (PDR),
Sincerely,
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Hu ert J. Miller Regional Administrator Docket No. 50 286 License No. DPR 64 Enclosure: Notice of Violation and Proposed imposition of Civil Penalty
' 4 Notice of Violation and Proposed Imposition of Civil Penaltyin the amount of $50,000
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was issued to New York Power Authority on January 2,1996, for the Indian Point 3 facility exiting the cold shutdown facility with the control switches for the recirculation and containment spray pumps in the trip pullout condition.
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l7 New York Power Authority-
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C. Rapployea, Chairman and Chief Executive Officer -
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R. Schoenberger, President and Chief Operating Officer
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J. Knubel,-Chief Nuclear Officer and Senior Vice President
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H. Salmon; Jr., Vice President of Nuclear Operations
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- W. Josiger, Vice President Engineering and Pcoject Management
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lJ. Kelly, Director - Regulatory Affairs and Special Projects T. Dougherty, Director - Nuclear Engineering R. Deasy, Vice President - Appraisal and Compliance Services R. Patch, Director - Quality Assurance
G. Goldstein, Assistant General Counsel TC.LFaisoni Director, Nuclear Licensing, NYPA.
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. K. Peters, Licensing Manager
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- A. Donahue, Mayor, Village of Buchanan
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C. Jackson, Nuclear Safety and Licensing Maneger (Con Ed) '.
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' C. Donaldson, Esquire, Assistant Attorney General, New York Department of Law
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. Chairman, Standing Committee on Energy, NYS Assembly Chairman, Standing Committee on Environmental Conservation, NYS Assembly
. T. Morra, Executive Chair, Four County Nuclear Safety Committee
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Chairman, Committee on Corporations, Authorities, and Commissions The Honorable Sandra Galef, NYS Assembly
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i P. Eddy,- Director, Electric Division, Department of Public Service, State of New York I
G. Goering, Consultant, New York Power Authority-
J. Gagliardo, Consultant, New York Power ' Authority
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E. Beckjord, Consultant,- New York Power Authority
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F. William Valentine, President, New York State Energy Research and Development Authority
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JJ..Spath, Program Director, New York State Energy Research and Development Authority Ip i
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New York Power Authority DISTRIBUTION:
PUBLIC SECY CA LCallan, EDO AThadani, DEDE JLieberman, OE HMiller, RI FDavis, OGC SCollins, NRR RZimmerman, NRR Enforcement Coordinators RI, Ril, Rlli, RIV BBeecher, GPA/PA GCaputo, 01 DBangart, OSP HBell, OlG Dross, AEOD OE:EA (2 copies) (Also by E-M*ll)
OE:Chron OE:EA DCS NUDOCS DScrenci, PAO-Ri NSheehan, PAO RI Nuclear Safety Infortnation Center (NSIC)
Resident Inspectoi -Indian Point 3 LTremper, OC i