IR 05000286/1998005

Discusses Insp Rept 50-286/98-05 on 980528-0612 & Forwards NOV & Proposed Imposition of Civil Penalty in Amount of $55,000.Most Significant Violation Involved Failure, Following Design Mod in Oct 1997

ML20237D130
Person / Time
Site:	Indian Point
Issue date:	08/19/1998
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
ML20237D132	List: IR 05000286/1998005 ML20237D138
References
50-286-98-05, 50-286-98-5, EA-98-336, EA-98-344, NUDOCS 9808250086
Download: ML20237D130 (5)

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y \ p, UNITED STATES NUCLEAR REGULATORY COMMISSION ti j REGION I

$ g 475 ALLENDALE ROAD KING OF PRUSSIA, PENNSYLVANIA 19406-1415

%,***** ,d August 19,1998 EA 98-338 EA 98-344 Mr. Robert Site Executive Officer New York Power Authority Indian Point 3 Nuclear Power Plant

- Post Office Box 215 Buchanan, NY 10511 -

SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY

- $55,000 (NRC Inspection Report No. 50-286/98-05)

Dear Mr. Barrett:

This refers to the special inspection conducted from May 28,1998 through June 12,1998, at the Indian Point 3 Power Plant, the results of which were discussed with you at an exit meeting on June 19,1998. During the inspection, apparent violations of NRC requirements were identified associated with the loss of normal power to a 480 volt bus on May 28,1998.

The inspection report was sent to you on June 30,1998. A predecisional enforcement conference (conference) was held on July 24,1998, with you and members of your staff to discuss the apparent violations identified during the inspection, their causes, and your corrective actions.

Based on the information developed during the inspection and the information that you provided during the conference, the NRC has concluded that two violations occurred. The

. most significant violation involved the failure, following a design modification in October 1997, to have adequate design measures to ensure that the emergency diesel generator (EDG)

auxiliaries would perform within the design basis. That violation is described in Section I of the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) and the circumstances surrounding it are described in detail in the subject inspection report. The NRC is particularly concerned %at personnel responsible for the modification did not provide

! adequate design reviewa.

The specific design change in October 1997 realigned the essential power supplies to the EDG auxiliary support systems for two of the EDGs. The support systems include EDG room ventilation, the fuel oil transfer pump, and the crankcase exhaust blower. In designing the power supply modification, your staff failed to recognize a pre-existing undervoltage trip function that was installed in the spare breaker compartments that were used to supply

{l electrical power to the new motor control centers (MCCs) that supply the EDG auxiliaries.

9808250086 990819 PDR ADOCK 05000286

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New York Power Authority 2 Subsequently, when normal power was lost to a 480 volt bus on May 28,1998, although one of the EDGs started as designed, the EDG auxiliary MCC supply breaker tripped on undervoltage, and operator action was required to restore power to the support systems, contrary to system design.

l This failure to remove the undervoltage trip function and the resultant impact on the EDG auxiliary support systems, represents a significNt concern because two of three EDGs would not have functioned as designed on a loss of offsite power. Specifically, the EDGs would i have failed due to room overheating or loss of fuel oil unless operators recognized the loss of 2 l power to the auxiliaries and took appropriate action to manually restore power. Although, in l this instance, operators successfully restored power to the auxiliaries on May 28,1998, there l was no assurance that the degraded condition of the EDGs would have been identified and corrected prior to failure of the EDGs during a more complex event when multiple annunciator alarms are received in the control room that require operator action. This violation had '

significant potential safety consequences, since the EDGs could not be relied upon to run for the required period of time without the auxiliary support systems; therefore, it has been categorized at Severity Level 111 in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600 at Severity Level lli.

In accordance with the Enforcement Policy, a base r'ivil penalty in the amount of $55,000is

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considered for a Severity Level lil violation. Because your facility has been the subject of escalated enforcement ection within the last 2 years', the NRC considered whether credit was

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warranted for / dent /fication and Corrective Act/on in accordance with the civil penalty assessment process in Section VI.B.2 of the Enforcement Policy. Credit is not warranted for identification because the design error for the emergency diesel generator auxiliaries was

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identified as a result of an event and your staff had a prior opportunity, but failed, to identify the error during post-modification testing (PMT). As a result of the inadequate PMT, the existence of the undervoltage trip function was not recognized. Credit is warranted for corrective action because your actions, as described at the enforcement conference, were considered prompt and comprehensive. These actions included, but were not limited to: (1)

removal of the undervoltage trip function from the power supply breakers; (2) review of the design change package; (3) reviews of the circuitry in similar MCCs not affected by the design change and other breakers installed in spare compartments; (4) addition of a requirement to perform cross-checks of drawings when new schematics or wiring diagrams are developed; and (5) training to improve translation of safety requirements into test requirements.

Therefore, to emphasize the importance of assuring that the design bases are maintained when performing design modifications, and in recognition of your previous escalated enforcement action, I have been authorized, after consultation with the Director, Office of Enforcement, to issue the enclosed Notice of Violation and Proposed imposition of Civil Penalty in the base amount of $55,000.

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'A Notice of Violation and Proposed imposition of Civil Penalty in the amount of

$55,000 was issued to New York Power Authority on August 19,1997, for failure to  ;

translate design basis information into the Emergency Operating Procedures (EA 97-294). ,

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New York Power Authority 3 The second violation is described in Section ll of the enclosed Notice and is ca*.sgorized at Severity Level IV in accordance with the Enforcement Policy. The violation involved ineffective and untimely corrective actions to preclude spurious closures of the reactor coolant pump (RCP) thermal barrier heat exchanger outlet valve (FCV-625) during routine system manipulations. Spurious closures of FCV-625, which supplies component cooling water (CCW) to the RCP seals, were documented in the problem identification system since September,1997; however, effective corrective actions had not been taken as of May 28, 1998. On May 28,1998, the inadvertent closure of FCV-625 in conjunction with loss of a charging pump resulted 8.i a momentary loss of all RCP seal cooling. This was an additional challenge to the operators during the loss of power event. The apparent cause for ineffective corrective actions was a lack of appreciation for the significance of this deviation during postulated events, and a conditioned acceptance to the spurious closures.

The inspection report also describes an apparent violation of 10 CFR 50.59 related to the '

operation of FCV-625. Based on the information provided at the conference, the NRC has concluded that no violation of NRC requirements occurred.

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 compliance with regulatory requirements.

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,

,

bert J. Miller l Regional Administrator Docket No. 50-286 License No. DPR-64 l

Enclosure: Notice of Violation and Proposed imposition of Civil Penalty i i

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e New York Power Authority 4 cc w/ encl:

C. Rapplayea, Chairman and Chief Executive Officer E. Zeltmann, President and Chief Operating Officer R. Hiney, Executive Vice President for Project Operations J. Knubel, Chief Nuclear Officer and Senior Vice President H. Salmon, Jr., Vice President of Engineering W. Josiger, Vice President - Engineering and Project Management J. Kelly, Director - Regulatory Affairs and Special Projects T. Dougherty, Director - Nuclear Engineering

R. Deasy, Vice President - Appraisal and Compliance Services l R. Patch, Director - Quality Assurance G. Goldstein, Assistant General Counsel C. Faison, Director, Nuclear Licensing, NYPA K. Peters, Licensing Manager

- A. Donahue, Mayor, Village of Buchanan '

l C. Jackson, Nuclear Safety and Licensing Manager (Con Ed)

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C. Donaldson, Esquire, Assistant Attorney General, New York Department of Law Chairman, Standing Committee on Energy, NYS Assembly Chairman, Standing Committee on Environmental Conservation, NYS Assembly T. Morra, Executive Chair, Four County Nuclear Safety Committee Chairman, Committee on Corporations, Authorities, and Commissions The Honorable Sandra Galef, NYS Assembly P. Eddy, Electric Division, Department of Public Service, State of New York G. Goering, Consultant, New York Power Authority l J. Gagliardo, Consultant, New York Power Authority E. Beckjord, Consultant, New York Power Authority F. William Valentino, President, New York State Energy Research and Development Authority

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J. Spath, Program Director, New York State Energy Research and Development Authority

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New York Power Authority DISTRIBUTION:

PUBLIC SECY CA LCallan, EDO WTravers, DEDE JLieberman, OE HMiller, Rl FDavis, OGC SCollins, NRR RZimmerman, NRR

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Enforcement Coordinators

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Rl, Ril, Rlli, RIV BBeecher, GPA/PA t GCaputo, 01 '

DBangart, OSP HBell, OlG TMartin, AEOD

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OE:Chron OE:EA DCS {

i NUDOCS l DScrenci, PAO-RI NSheehan, PAO-RI LTremper, OC Nuclear Safety information Center (NSIC)

NRC Resident inspector - Indian Point 3 JRogge,RI RBarkley, RI

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