ML19347C565

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Forwards Notice of Violation & Proposed Imposition of Civil Penalty & Notice of Deviation Based on NRC 801022-1121 Investigation of 801017 Event Re Leakage in Fan Cooler Unit Resulting in Svc Water Flooding of Reactor Vessel Pit
ML19347C565
Person / Time
Site: Indian Point Entergy icon.png
Issue date: 12/11/1980
From: Stello V
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To: Hauspurg A
COMMONWEALTH EDISON CO.
Shared Package
ML100340756 List:
References
EA-81-011, EA-81-11, NUDOCS 8012310096
Download: ML19347C565 (3)


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Docket No. 50-247 EA 81-11 g y; g q

Consolidated Edison Company of j

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New York, Inc.

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Mr. Arthur Hauspurg

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7 New York, New York 10003 Gentlemen:

On October 17, 1980, the operators at Indian Point Unit 2 discovered that leaks in a fan cooler unit had resulted in service water flooding of the reactor vessel pit and vapor containment floor.

This further resulted in the wetting of the lower part of the hot reactor vessel by cold river water which contained a high concentration of chloride ions.

The matter was brought to our attention by your telephone notification to our Senior Resident. Inspector on October 20, 1980.

Based on a subsequent telephone conversation on October 21, 1980, as documented in our letter to you dated October 22, 1980, you agreed to make certain determinations regarding the causes of the occurrence, report these determinations to us, and obtain NRC concurrence prior to restart of Indian Point Unit 2.

From October 22, 1980 to November 21, 1980, the NRC conducted an investigation of the circumstances surrounding this event.

At a public meeting in White Plains, New York, on November 5,1980, you stated that the plant would remain shutdown for correction of identified problems, including replacement of the cooling coils for the five fan cooler units, until approximately June, 1981.

Theresultsofourinvestigation,whichincludeidentificationofviolations which directly contributed to the flooding event, show that the management control system at Indian Point Unit 2 was not functioning in an acceptable manner.

Your failure to evaluate modifications to the service water piping by the long term use of epoxy materials, identify and correct the root cause of the numerous leaks in this system, identify the potential significance of the flooding on plant operations, evaluate the consequences of the flooding prior to reactor startup on October 20, 1980, and promptly report the flooding to the NRC, show that management at all levels is not directing the proper level of attention to cperation of Indian Point Unit 2.

Failure by management to identify and address the problems associated with these items is viewed as a serious matter.

CERTIFIED MAIL RETURN RECEIPT REQUESTED 4

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Consolidated Ediscn Company of New York, Inc.

DEC 11 1980 (Indian Point 2)

Further, our review of the circumstances surrounding the flooding event identi-fied four unreviewed safety questions; ie, (1) partial submergence of the hot reactor vessel in cold brackish river water, (2) partial submergence of the stainless pteel incore instrument conduits in brackish river water, (3) potential post-Loss of Coolant Accident (LOCA) water levels in containment in excess of the assumptions used in the Safety Analysis Report (SAR), and (4) potential post-LOCA water boron concentrations less than the assumptions used in the SAR.

Your response to this letter should include a description of the results of your investigation and resolution of these issues, assuming (1) plant conditions dis-covered on October 17, 1980, and (2) plant conditions which could have developed, had the plant again been returned to power without discovery of the leakage and flooding problems.

We propose to impose civil penalties in the amount of $210,000 for the violations described in Appendix A.

These violations have been categorized into the levels described in accordance with the Interim Enforcement Policy as published in Federal Register Notice (45 FR 66754) dated October 7, 1980.

The history of fan cooler unit service water leaks at Indian Point Unit 2 indicates that addi-tional occurrences of leakage should have been expected.

Detection of these leaks required routine vapor containment inspection or maintaining the vapor containment sump pumps operable.

Your failure to identify and correct the causes of leakage, to require routine vapor containment inspections, or to establish adequate controls to insure Sump Pump operability, led directly to the flooding event.

Since management coulc reasonably have been expected to have taken effective corrective measures anc did not, civil penalties have been increased by 25 percent above those listec in Tacle I of the Interim Enforcement Policy with respact to the violations enumerated in Section II of Appendix A.

Civil penalties have also been assessed for your failure to notify the NRC of the conditions associated with the flooding event within the time limits prescribed by law.

Also, civil penalties have Deen assessed for violations with respect to the use of Shift Technical 'dv,isors as outlined in Appendix A.

A Notice of Deviation is enclosed wnich describes the failure to maintain the containment sump pump floats in accorcance sith the manufacturer's instructions and periodic operation of the pumps with their discharge valves closed.

The failure to maintain a proper guide for the lowe-float rod resultec in a mal-function of the float for one pumo, an event wh'cn contributec to tne flooding of containment.

Your response to this letter should emphasi:e and include a detailed description of plans and actions to improve your manage ent control system.

Your written reply to this letter, combined with our evaluation of your response to questions previously requested of you regarding the flooding event, will be considered in determining whether any further enforcement action, such as modification, suspension, or revocation of your license, may be required to assure future compliance.

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j 3-DEC 111580 Consolidated Edison Company of N:w York, Inc.

(Indian Point 2)

You are required to respond to this letter and in preparing your response, you should follow the instructions in Appendices A and B.

In accordance with Section 2.790 of the NRC's " Rules of Practice", Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosures will be placed in the Commissioner's Public Document Room.

Sincerely, Victor Stello, 4fr.

Director Office of Inspection and. Enforcement

Enclosures:

1.

Appendix A - Notice of Violation and Proposed Imposition of Civil Penalty 2.

Appendix B - Notice of Deviation cc w/encis:

L. O. Brooks, Project Manager, IP Nuclear W. Monti, Manager - Nuclear Power Generation Department M. Shatkouski, Plant Manager:

J. M. Makepeace, Director, Technical Engineering W. D. Hamlin, Assistant to Resident Manager (PASNY)

J. D. Block, Esquire, Executive Vice President - Administration Joyce P. Davis, Esquire Brent L. Brandenburg, Assistant General Counsel i

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