ML20062G076
| ML20062G076 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 07/16/1982 |
| From: | Otoole J CONSOLIDATED EDISON CO. OF NEW YORK, INC. |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20062G036 | List: |
| References | |
| NUDOCS 8208120237 | |
| Download: ML20062G076 (4) | |
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John D. O' Tools vice Prewent Conschdated Ed son Compary of flew York. Inc 4 Irving Place. New York, NY 10003 Telephone (212) 460-2533 I
July 16, 1982 Re:
Indian Point Unit No. 2 Docket No. 50-247 Mr. Richard W. Starostecki, Director Division of Resident and Project Inspection U. S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, Pa.
19406
Dear Mr. Starostecki:
i This refers to I.E.
Inspection 50-247/82-09, conducted by Mssrs.
T.
l Rebelowski and P.
Koltay of your of fice on May 1-31, 1982 of activities authorized by NRC license No. DPR-26 at Indian Point Unit No.
2.
Your June 16, 1982 letter stated that it appea red that one of our activities was not conducted in full compliance with NRC requirements, as set forth in the Notice of Violation enclosed therewith as Appendix A.
Our response to the item of non-compliance is presented in Attachment A to this letter.
Our response is being provided pursuant to Section 182 of the Atomic i
Energy Act of 1954 as amended.
Should you or your staff have any questions, please contact us.
Ver/trulyyours,
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Notary Public THOMAS LOVE Motary Public State of New York No. 312409638 Quatffed in New Yom Canty Commisskon Expires March M.1-)d 3 8208120237 820805 PDR ADOCK 05000247 G
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U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Division of Reactor Operations Inspection Washington, D. C. 20555 Mr. T. Rebelowski, Senior Resident Inspector U. S. Nuclear Regulatory Commission P. O. Box 38 Buchanan, New York 10511
Attachment A Response to Notice of Violation Appendix A July 16, 1982 VIOLATION Technical Specification 6.8.1 requires that written procedures be established and implemented. Station Administrative Order No.127, Revision 3, Modifications to Indian Point Facilities, requires the licensee to revise affected operating procedures to reflect changes initiated by the modifications.
Contrary to the above, on May 20, 1982, the inspector found that operational procedures POP 1.1, Plant Heatup From Cold Shutdown Condition; POP 3.3, Plant Cooldown From Zero Power Condition to Cold Shutdown Condition; and the OPS Actuation Curves, were not revised to include a modification to the OPS setpoints completed in March,1981.
This is a Severity Level V Violation (Supplement 1).
RESPONSE
Upon determination that operating procedures and OPS actuation curves had not been revised under Maintenance Work Request (MWR) 2N54090 dated March 11, 1981, a temporary procedure change was immediately issued resulting in full compliance with Station Administrative Orders and Technical Specifications.
The process of properly implementing the procedure change included issuing to control room personnel detailed instructions concerning the new OPS settings.
The change implemented as a result of work performed under the MWR constituted a conservative shif t in the arming temperature and function generator output with respect to overpressurization protection. This included appropriate adjustment to advance alarms to alert the operator to impending actuation.
As such, there was adequate assurance that the health and safety of the public was maintained.
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A procedure is now in place that provides reasonable assurance that future violations of this type will be avoided. On November 16, 1981 the procedure for preparing Maintenance Work Requests was revised to include the requirement the Chief Operations Engineer shall normally authorize MWRs and in any case they shall only be authorized by managers in the operating (Nuclear Power Generation) department. The procedure for preparing MWRs in ef fect at the time the modification to the OPS setpoints was initiated authorized several personnel in organizations throughout the plant to submit MWRs.
Limiting the personnel authorized to submit MWRs to Nuclear Power Generation, normally the Chief Operations Engineer, will assure any changes to operating procedures required as a result of work performed under an MWR are identified and implemented.
Also, policy concerning procedure adherence and use has received increased management attention.
As a result, plant personnel have been reinstructed regarding the importance of assuring all changes that could impact on plant operation are properly reviewed and approved.
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