ML20084B084

Discusses Adequacy of Applicant QA Program in Light of Recent AOs Re Valves Discovered Defective After Operation Began.No Further Operation of Plant Should Be Allowed Until QA Problem Resolved

ML20084B084
Person / Time
Site:	Indian Point
Issue date:	05/25/1973
From:	Roisman A CITIZENS COMMITTEE FOR PROTECTION OF THE ENVIRONMENT
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20084B088	List: ML20084B084 ML20084B098
References
NUDOCS 8304060104
Download: ML20084B084 (3)

Text

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May 25, 1973 USAEC hbb CGC SETHESDA yd>

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j James P. O'Reilly, Director Regulatory Operations, Region I U. S. Atomic Eacrgy. Commission E

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Newark, New Jersey 07102 j

Re:

Consolidated Edison Company f

e New York (Indian Point, Unit No. 2) j Docket No. 50-247 g

Dear Mr. O'Reilly:

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"46 P 4 'fy By letter dated May 23, to us a letter dated May 14, 1973, Applicant's counsel tr occurrence.

1973 with respect to an abnormal 4

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was discovered to be defective and must be replaced.The abnormality invo s

A cantly this same valve not only was subject to and passed all*/ Signifi-normal quality assurance procedures set up by the Applicant, Westinghc,use and the manufacturer, but also was subject to the allegedly thorough examination associated with verification that

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there were no tnin-walled valves.

Nonetheless, the defect was discovered after operation had commenced pursuant to an operating license although prior to certain hydrostatic leak tests and i

riticali ty.

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By letter dated May 21, 1973 and received by us on May 24, 1973, i

\\pplicant. reported another valve malfunction and subsequent valve eplacement.

The intermediate cause of the failure was i

'several key operations personnel" assumed that a valve was that ind did not actually verify that the valve was open.

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the neu valve meets all FSAR requireneilts' 01 i

'Y t shou 1G niso have wall thicknesses verified

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Mr. James P.

O'Reill May 25, 1973 Page two Both of these " abnormal occurrences" clearly raise serious questions about the adequacy of Applicant's quality assurance program.

The normal practice of disregarding the real under-lying cause of abnormal occurrences and focusing instead only on the narrow question of whether the defect itself has been repaired must not be followed here where the quality assurance l

program has already been shown to have substantial defects.

l The significance of the quality assurance program is under-l lined in the recent Appeal Board decisions in Consumers Power Company (Midland) (ALAD-10 G ) and Vermont Yankec (ALAB-12 4 ).

We urge you to require the Applicant to prepare a thorough l

written report disclosing what deficiencies in the quality assurance program allowed the defective valve to be installed and operated gt Indian Point No. 2 and allowed several key personnel to make a serious and erroneous assumption without actual verification.

Applicant should also propose specific corrective steps to eliminate the quality assurance defect and to recheck all other equipment which could have been insufficiently examined as a result of the same underlying quality assurance defect.

Until this matter has been resolved no further operation of Indian Point No. 2 should be al] owed.

The 50"4 testing license should be suspended pursuant to 10 CFR Part 2, Section 2.202.

We hereby specifically request such a suspension on an emergency basis without prior hearing.

The fact that " abnormal occurrences" were at a time and place where no serious safety consequences resulted is fortuitous at best.

They are clearly danger signals that there are significant defects in Applicant's quality assurance program and implementation of the progr.,m.

It u,uld be irresponsible to allow any operation of Indian Point No. 2 with the reactor critical until the problems are resolved.

In ALAB-124 (Vermont Yankee) the Board stated (p. 15):

if it... appeared that an adequate program were lacking, we would likely be conpelled now to reverse the decision authorizing issuance of the permanent operating license and thus to require immediate cessation of plant operation until the quality assurance matter was resolved.

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1 Mr. James P.

O'Reilly May 25, 1973 Page three In this case the two recently reported abnormal occurrences are abundant evidence that the quality assurance program is in-adequate.

There is no alternative but to suspend the license immediately, prior to criticality.

Sincerely,

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Anthony Z.

Roisman Counsel for Citizens Committee s

for Protection of the Environment V'

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All parties of record.

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m-2' f'.ny 21, 1973 02 Re Indian Point Unit I!o. 2 AEC Dochet I!o. 50-2h7 Facility Operating License DPR-26 I'r. John F. O ' Leary, Di rector Directorate of Licencing U. 3. Atc~.ic Energy Com aiccion

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O ' Leary In accordance with the require.nents of Technical Specification 6.6.1.E.

we wich to inform you of an abnormal occurrence which was identified on '*.ay 11,1973 at 2230 hours0.0258 days <br />0.619 hours <br />0.00369 weeks <br />8.48515e-4 months <br />.

During preccurization of the reactor coolant cycte~ preparatory to starting reactor coolant pumps for the performance of a hydroctatic leak test of the Reactor Ccolant System, prior to initial criticality, a leak was observed in valve number 2Cl;B which ic located in the charging line to Loop 21.

Subsequent investigation in:ilcated that the leakage var apparently due to a defect in the area of the ctu! holes permitting reactor ecolant makeup to coep into tuo of the ctud holes ani from there into the containment atmosphere.

Valve !!o. 20hD has been replaced.

The replacement valve meets the require-menta of codes and standards applicable to the desi6n and procurenent of equipment ac outlined in the Indian Point Unit I!o. 2 FSAR.

A hydrostatic tect of the reactor coolant cyr. tem was performed to insure the integrity of the new valve and accociated welds.

I'r, A. Facano of the Region I Regulatory Operations office of the U.

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Atemic Energy Conmission was notified by telephone on May 12, 1973 cf the occurrence.

In addition, a letter was telecopied to the Director of the He,; ion I Office, I'r. J. P. O'Reilly, on :ay ll, 1973 i

The valve that experienced the leakage will be subjected to analycis at the h'octin.; house Reccarch Lab. to identify the specific cause and nature of the defect.

This invectication will include:

(a) Compilation of a hictory of the valve after its installation in Unit !!c. 2.

(b) Photographs and physical neacurements of the valve.

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(c) Radiographa of the valve body.

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n Mr. John F. O'lcary l'ay 21,1973 He Indian Point Unit Ilo. 2 AEC Docket !io. 50-2h7 Facility Operating Licence DPR-2fs (d)

IFye pen"trant incpection.

(e) l'racto :raphy on specimenc in the area where leaks.3e occured.

(f) A chenical analycic of the valve body material.

Fol.lowin3 the completing of thic program, resultc of the investigation will be made available at the cite for revieu by the Regulatory Operations incpector.

For a namber of reaconc, the cafety implications of the occurrence are con ni.iored clL;ht.

The firct of these conciderations in that the leak was of a very minor rate and wac well within the take-up capability of the Chemical and Volume Control Cyctem.

SeconJ1y, a check valve is located downcteeam of valve 20hD and thic would prevent leaka;e directly out of the Reactor Coolant Cycten had the valve leakage in come way be-come exceccive.

A further concideration with regard to the safety im-p1icatienc ic that the leaWe, had it been radioactive, which it was nat, vac into the containment atmosphere and therefore would not have recultel in any dan:er to the health and cafety of the public.

Further-more, the 1eaha.;e would have been detected and identified by one of the four neth11: for monitoring leakage in containment ac specified in Technical Specification 3 1.F had the plant been in operation.

Finally, the plant was in a cold chutdown condition with the cystem preccure belo;. 500 pcic at the time of the occurrence.

Consequently, the occurr-ence does not reprecent a cignificant hacards concideration.

Our I ualear Facilities Safety Committee has reviewed the circumstances of thic cecurrence and coneurs that it does not reprecent a cignificant hacards concideration.

l Very truly yours e'-

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, o ' William E. Caldwell, Jr.

du Vice President Copy to Janec p. O'Reilly (AEC)