ML20070J106
| ML20070J106 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 10/18/1982 |
| From: | Otoole J CONSOLIDATED EDISON CO. OF NEW YORK, INC. |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20070J101 | List: |
| References | |
| NUDOCS 8212270361 | |
| Download: ML20070J106 (4) | |
Text
.
s John D. C'Toole {,_-
[S re Prescent N.
's Consohdated Edison Company of New York, Inc 4 try ng Place, New York, NY 10003 Telephone (212) 460 2533 Or.tobe r 18, 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 b ng of Prussia, Pc.
19406
Dear Mr. Stara',
tecki:
This refers to I.E.
Inspection 50-247/82-18, conducted by Messrs.
T.
Rebelowski and P. Koltay of your office on August 1-31, 1982 of activities authorized by NRC License No. DPR-26 at Indian Point Unit No.
2.
Your September 17, 1982 letter stated.that it appeared that one of our activities war 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 Energy Act of 1954 as amended.
Should you or your staff have any questions, please contact us.
Ver' truly yours,
/
/W /, /I y (7'[(
/
Subscribed and swo n to before ne this d ay of 0 er, 1982.
A f
- , A l
Noth g ublic M sA m
d MW M 239,23,,
Notry P
,2 rw.,.
g0 E.IiNJ l
y -. _ _ _
8212270361 821220
? PDR ADOCK 05000247 i
_M.
h attach.
cc:
U. 5. 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 l
l
~
. o c,._ 6
. s U,
O ATTACitMENT A RESPONSE TO NOTICF OF VIOLATION APPENDIX A VIOLATION 10 CFR 50, Appendix B, Criterion V, states in part, " Activities affecting quality shall be prescribed by documented instructions, procedures... of a type appropriate to the circunstances..."
The licet>ee's Quality f.ssurance Program for Operating Nuclear Plants, CI-240-1,Section X, requires that the licensee's procedures reflect and incorporate techni;al specification engineering requirements and paraceter limits applicable during the operation of the plant.
Technical Specifications, Section 1.7d, defines containment integrity as a condition which exists ahen all automatic containment isolation valves are either operable or in the closed position.
Technical Specifications, Section 3.6A does not provide for reopening failed automatic containment isolation valves.
Contrary to the above, Prccedure A-26, Loss of Containment Integrity, Revision 0, permits periodic reopening of a failed automatic containment isolation valve during plant operations.
This is a Severity Level V Violation (Supplement I).
RESPONSE
Upon making an initial determination that Section 5.4 of Procedure A-26, Loss of Containment Integrity, Revision 0 specified no time limit on loss of containment integrity beyond which corrective action would be required and thus appeared to be in conflict with the intent of Section 3.6 of the Technical Specifications, the procedure was reviewed that day at a meeting of the Station Nuclear Safety Committee.
The Committee recommended that the procedure be revised to eliminate that discrepancy with the Technical Specifications.
d o
o I
Technical Sr cification 3 6.A.4 states that "if containment integrity requirements are not met when the reactor is a bove cold shutdown, containment integrity shall be restored within four hours...".
Operations immediately issued Temporary Procedure Change, TPC-82-101, to Section 5.4 of Procedure A-26 to cisrlfy the requirements of the Technical Specifications.
For all Automatic Containment Isolation Valves, if the requirements of Technical Specification 1.7d are not met within the 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> permitted by Technical Specification 3.6.A4, the reactor shall be brought to the cold shutdown condition within the next 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />, utilizing normal operating procedures.
This corrective action eliminated the discrepancy between Procedure A-26 and Section 3.6A of the Technical Specifications and achieved full compliance with the requirements of the Technical Specifications and Corporate Instruction, CI-240-1, Quality Assurance Program for Operating Nuclear Plants.