ML19343B694
| ML19343B694 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 12/19/1980 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML100191222 | List: |
| References | |
| EA-81-004, EA-81-4, NUDOCS 8012300109 | |
| Download: ML19343B694 (2) | |
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O APPENDIX A NOTICE OF VIOLATION Consolidated Edison Company of New York, Inc.
Docket No. 50-247 EA-81-04 This refers to the inspection conducted by the Resident Inspector at the Indian Point Nuclear Generating Station Unit 2, Buchanan, New York, of activities authorized by NRC License No. DPR-26.
During this inspection conducted on September 24-25, 1980, the following apparent item of noncompliance was identified.
10 CFR Part 50.59 (a) (1), states in part, "the holder of a license author-izing operation of a production or utilization facility may...(ii) make changes in the procedures as described in the safety analysis report...with-out prior Commission approval, unless the proposed change, test or experi-ment involves a change in the Technical Specifications incorporated in the license or an unreviewed safety question."
10 CFR Part 50.59 (a) (2), states in part, "A proposed change...shall be ceemed to involve an unreviewed safety question...(iii) if the margin of safety as defined in the basis for any Technical Specification is reduced."
Ine Bases for Technical Specifications, Section 3 states in part, "in the event of a Design Basis Accident, three charcoal filters (and their asso-ciated recirculation fans) in operation, along with one containment spray pumo and sodium hydroxide addition, will reduce airborne organic and molecular iocine activities sufficiently to limit off-site doses to acceptable values.
These constitute the minimum safeguards for iodine removal...."
Contrary to the above, on May 10, 1977, a change in a procedure was made without Commission approval which was contrary to Technical Specification 3.3.B.1.b and which involved an unreviewed safety question.
Specifically, an addition of paragraph 3.11 was made to Procedure 10.6.2, " Containment Entry and Egress," (Revision 1) which called for placing the two containment spray pump control switches in the trip pull-out position when containment was entere:
Tnis action rendered the automatic startup feature of the Containment Spray System inoperable and thus reduced the margin of safety as defined in tne Bases for Technical Specifications, Section 3.
This unauthorized change resulted in Limiting Condition for Operation to be exceeded each time the procedure was implemented during reactor operation.
Inis violation had the potential for causing or contributing to an occurrence relatea to safety (Civil Penalty - 55,000).
8 01230 \\cM
Appsodix A (Continued) 1, This Notice of Violation is sent to Consolidated Edison Company pursuant to the provisions of section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations.
Consolidated Edison Company is hereby required to submit to this office within twenty five (25) days of the receipt of this notice, a written statement or explanation in reply, including for each item of non-compliance:
(1) admission or denial of the alleged item of noncompliance; (2) the reasons for the item of noncompliance if admitted;-(3) the corrective steps which have been taken and the results achieved; (4) corrective steps which will be taken to avoid further items of noncompliance; and (5) the date when full compliance will be achieved.
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