ML20002E287
| ML20002E287 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 01/13/1981 |
| From: | Sniezek J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Lewis M AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML20002E288 | List: |
| References | |
| IEB-80-24, NUDOCS 8101270190 | |
| Download: ML20002E287 (2) | |
Text
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.2 JAN 131981 50-2'l?'
Mr. Marvin Lewis 6504 Bradford Terrace Philadelphia, PA 19149
Dear Mr. Lewis:
I an: pleased to respond to your letter to Victor Stello, Jr., Director of NRC's Office of Inspection and Enforcement.
In your letter you requested a copy of our letter to Consolidated Edison Company of New York regarding the leakage of river water into the containment building at the Indian Point Unit 2 Nuclear Power Plant (IP-2).
I believe the correspondence to which you refer is our letter to Consolidated Edison, dated December 11, 1980, regarding the event which forwards a notice of violation and proposes imposition of a civil penalty.
Enclosed is a copy of our December 11, 1980 letter and Consolidated Edison's response.
You also asked if the NRC was getting a project going to avoid repetition of the flooding event at other plants. As a result of the incident at IP-2, the NRC issued IE Bulletin No. 80-24, Prevention of Damage Due to Water Leakage Inside Containment (copy enclosed).
The purpose of the bulletin is to direct all licensees of nuclear power plants to take action and to report information to the NRC. Information reported will be used by the NRC to formulate any long
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term generic corrective actions that may be necessary. The bulletin requires short term actions which will preclude IP-2 type events at other plants in the interim pending identification and accomplishment of any longer term generic actions.
I trust that the above information and enclosures are responsive to your request.
Sincerely, t
J. H. Sniezek, Director Division of Resident and Regional Reactor Inspection, IE
Enclosures:
1.
Letter to Consolidated Edison Co. of NY, dated 12/11/80 2.
Response from Consolidated Edison Co. of NY, dated 1/5/81 3.
IE Bulletin 80-24 4' s ce, Q e,vio n (ome c e RRRI:IE
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PDR 50-247 LPDR 50-247 NTIC J. H. Sniezek, IE l
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A Yg - ((( j NUCLEAR REGULATOR COMMISSION
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4......j Docket No. 50-247 r
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EA S1-11 Consolidated Edison Company of New York, Inc.
ATTN:
Mr. Arthur Hauspurg President 4 Irving Place 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 vesse-pit and vapor containment floor.
This further resulted in the wetting of the loser part of the hot reactor vessel by colc river water which contained a hign ccncentration of chloride ions.
The matter was brought to our attention by your telephone notification to our Senior Resident Inspector on October 20, 1950.
Based on a subsequent telephone conversation on October 21, 1980, as documented in our letter te you dated October 22, 1980, you agreed to make certain ceterminations regarding the causs; of tne occurrence, report th'ese determina.icas to us, and obtain NRC concurrence prior to restart of Indian Point Unit 2.
Fror October 22, 1980 to November 21, 1980, the NRC conducted an investigation cf 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.
The results of our investigation, which include identification of violations which directly contributed to the flooding event, show that the managemen.t 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
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term use of epoxy materials, identify and ccrrect the root cause of the numerous leaks in this system, identify the potential significance of the flooding on I
plant operations, evaluate the consequences of the flooding prior to reactor I
startup on October 20, 1980, and promptly report the flooding to the NRO, show that management at all levels is not directing the proper level of attention to operation of Indian Point Unit 2.
Failure by management to identify and address the problems associated with these items is viewed as a serious matter.
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1 CERTIFIED MAIL RETURN RECEIPT REOUESTED 0
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of New York, Inc.
(@ndian 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 steel 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 65754) 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 f ailure 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 could reasonably have been' expected to have taken effective corrective measures and did not, civil penalties have been increased by 25 percent'above those listed in Table I of the Interim Enforcement Policy with respect 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 been assessed for violations with respect to the use of Shift Technical Advisors as outlined in Appendix A.
.s A Notice of Deviation is enclosed which describes the failure to maintain the containment sump pump floats in accordance with the manufacturer's instructions and periodic operation of the pumps with their discharge valves closed.
The failure to maintain a proper guide for the lower float rod resulted in a mal-function of the float for one pump, an event which contributed to the flooding of containment.
Your response to.this letter should emphasize and include a detailed description.
of plans and a:tions to improve your management 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.
a mm e
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oV Wew York, Inc.
J (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 2.79D of the NRO'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, f
.~
Victor Stello, Director Office of Inspection and Enforcement
Enclosures:
1..
Appendix A - Notice of Violation and Proposed Imposition of Civil Penalty 2.
Appencix B - Notice of Deviation cc w/encis:
L. D. Brooks, Project Manager, IP Nuclear W. Monti, Manager - Nuclear Power Generatien Department M. Shatkouski, Plant Manager' J. M. Makepeace, Director, Technical Engineering W. D. Hamlin, Assittant to Resident Manager (PASNY)
J. D. Block, Esquire, Executive Vice Presi:ent - Administration.
Joyce P. Davis, Esquire Brent L. Brandenburg, Assistant General Counsel i
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NOTICE OF VIOLATION AND DROPOSEC I". POSITION OF CIVIL PENALTY Consolidated Edison Company mm of New York, Inc 0
DpN Docket No. 50-247 id g
License No. DPR-26 g
Indian Point 2 66 EA 81-11 The NRC conducted an investigation into the flooding of containment at Indian' Point 2 on October 22, 1980 through November 21, 1980.
This investigation found that the management system, which is designed to prevent or mitigate a serious safety event, was not able to perform its intended function under the conditions preceding and during the containment flooding.
As a result, the NRC proposes to impose a civil penalty in accordance wi.h tne Interim Enforcement Policy as published in the Federal Register October 7, 1980 (45 FR 66754).
Pursuant to Section 234 of the Atomic Energy A:t of 1954, as amended (42 USC 22S2, P. L.95-295), and 10 CFR 2.205 of the Commissic..'s Regulations, in the amount set forth below for the followin; violations:
I.
The Commission regulations and the fa:ili y license require the licensee to report occurrences important te safety as indicated below.
A.
10 CFR 50.72(a), " Notification o' significant events ', requires that:
"Each licensee of a nu: lear pc.<er reactor, licensed under para. 50.21 or para. 50.22 shall notify the NRC Coeraticns Center as soon as possible and in all cases within one hour by telephone of the occur-rence of any of the followin; si;nificant events and shall identify that event as bein; repcrted pursuan to this section:
(3) Any event that results in t.e nuclear power plant not being in a controlled or expectec cenc'.ior while operating or shutdown."
Contrary to the above, the felic--ir.; condition was not reported within one hour of identificatio.9:
The discovery on 0:tober 17, ISSC cf unexpected conditions not specifically considered in the safety analysis report or technical specifications that required remediai action to proant existence or development of an unsafe conditi:n, specifically the existence of:
a flooded reactor vessel pi, accut four inches of river water on the vapor containment floor, anc steam exiting the instrument thimble holes.
The containment flooding conditien was found on October 17, 1980, but not reported to the NRC until Oct:ber 20, 1980, which did not comply with the one hour reporting require:nents of 10 CFR 50.72.
Each day that the violation continued constitutes a separate violation for the purpose of computing the civil penalty.
This is a Severity Level III vicia.icn (Supplement I.C.2 of the Interit Enforcement Policy)
Applying the civil penalty for each day that the violation continued results in a civil penalty of - $120,000.
B.
Technical Specification 6.9.1.7.1 states, in part, that:
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.APPEf0fX B NOTICE OF DEVXAT10N Consolidated Edison Company Docnet No. 50-247 of New York, Inc.
License No. DPR-26 Indian Point Unit 2 Based on the results of an NRC investigation conducted during the period October 22, 1980 to November 21, 1980, it appears that one of your activities was not conducted in accordance with standard industry practice or manufacturer's recer-mendations as indicated below:
Centrary to standard industry practice and the manuf acturer's Technical Manuai, "Goulcs Installation, Operation, and Maintenance Instructions for Vertical Sump Pumps, Models 3171. 3172. 3173. 3174" the centainment sump pump float rods were not attached or guided at the bottom frce October 17, 1980 through October 20, 1980.
This contributed to sump pump incperability during the containment flocc-ing incident.
Also, contrary to guidance on page 9 of the manuf acturer's Tech-nical Manual, the pumps were not prevented from running against a shutoff heac on September 14, 1980 and September 15, 1950 and at various times from October 17, 1980 to October 29, 1980 when the pump discharge valves were shut and power tc the pumps was not secured.
In reply, please comment on this item, including a description of all actions tnat have been or will be taken to correct the item and prevent recurrence at the date when these actions tavs been or will be completed.
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