ML20106D980
| ML20106D980 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 02/04/1985 |
| From: | Otoole J CONSOLIDATED EDISON CO. OF NEW YORK, INC. |
| To: | Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8502130190 | |
| Download: ML20106D980 (6) | |
Text
7,.
John D o'Toob v.ce P<es;oert g
Consolecated Ed: son Company of New York. Inc.
((CE{YEC 1
4 trvtng Place. New York, NY 10003 E35 RB -g til 4: 30 Telephone (212) 460-2533 February 4, 1985 Re Indian Point Unit No. 2 Docket No. 50-247 Mr. Samuel J. Collins, Chief Division of Project and Resident Programs U.
S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, Pa.
19406
Dear Mr. Collins:
This refers to I.E.
Insection 50-247/84-32 conducted by Mr.
T.
Kenny of your office on November 1-30, 1984 of activities authorized by NRC License No. DPR-26 at Indian Point Unit No.
2.
Your January 4,
1985 letter stated that it appeared that certain of our activities were 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 items of non-compliance is presented in Attachment A to this letter.
Should you or your staff have any questions, please contact us.
Very!trulyyours, f',,j w
}'Y cca Senior Resident Inspector U. S. Nuclear Regulatory Commission P. O. Box 38 Buchanan New York 10511 0
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ATTACHMENT A RESPONSE TO NOTICE OF VIOLATION APPENDIX A VIOLATION 1
~ Technical Specification 6.8.1 requires that written procedures and administrative policies be established, implemented and maintained that meet or exceed the requirements and recommendations of Sections 5.1 and '5.3 of ANSI N18.7-1972 and Appendix A of Regulatory Guide 1 33.
Section 1.h of Appendix A to Regulatory Guide 1.33 includes procedures addressing log entries, record retention and review. Administrative Directive OAD-3, Revision 6,
" Plant Surveillance and fog Keeping" requires specific licensee log keeping technique, and actions to be taken when measured parameters exceed normal or maximum /hinimum values.
OAD-3 also requires proper administrative review of completed logs.
Contrary to the above, on November, 1984, the inspector identified that measured parameters of control room logs and conventional area logs for the period of October 31 to November 6, 1984 are not being logged in accordance with OAD-3, Revision 6,
in three separate areas.
a.
itchnical specification parameters, which had been logged out of normal operating bands were not addressed as required by OAD-3, Revision 6.
b.
Out of specification readings were not circled in red as required, nor were they delineated in the remarks section as required by OAD-3, Revision 6.
H c.
Administrative reviews of.the logs were inadequate because the reviewers failed to identify the examples delineated in 1 and 2 above.
Collectively, this is a severity IV Violation (supplement-1)
RESPONSE
' Administrative Directive (OAD-3),
Revision 6,
entitled " Plant Surveillance and Log Keeping", has been revised as of January 25, e
-1985 to further clarify log keeping requirements.
Those i
_=
P4/
individuals involved in the inadequate log keeping identified by this violation have been reinstructed in their responsibilities.
In addition, they have been informed that disciplinary action may be imposed if additional discrepancies persist.
Supervisory and staff personnel involved in the administrative review of the logs have been directed to be more thorough in their review of completed logs.
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a VIOLATION 2 2.
VI,
" Document Control" states, in
- part,
" Measures shall be established to control the issuance of documents...which prescribe all activities affecting quality."
Station Administrative Order SAO-120,
" Nuclear Plant Operating and Safety Information Handling System," Part "C",
Technical Specifications states that, " Reviewers of the amendment changes should assure the status of the
- plant, drawings and procedures, and
- training, are consistent with, and comply with amendment requirements in their area of responsibility."
contrary to the above, the licensee made the necessary changes, for Technical Specifcation Amendment #74 in the appropriate procedures, but failed to change the status of the plant in that setpoints of certain 480 volt relays as delineated in the amendment, were not reset to the new value.
This is a Severity IV v.'.olation.
(Supplement 1)
RESPON3E On December 10, 1981, when Technical Specification Amendment No.
74 was issued, the setpoints of certain 480 volt relays were not reset to the specified values.
We responsibility for revising plant parameters to be in accordance with changes to the hchnical Specification was implied in various Station Administrative Orders (SAO's) such as SAO 102 " Procedure / Procedure Change Approval Policy" but not explicitly set forth in any one SAO, such as SAO 120 " Nuclear Plant Operating and Safety Information Handling System."
This weakness, acknowledged by Con Edison, was among the bases for Revision 2 to SAO 120, issued August 4,
1983.
This revision explicity addresses the responsibility of reviewing parties concerning Technical Specification Amendments and e
reasonably assures that the above violation will not recur.
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..1 VIOLATION 3 10 CFR 50 73(a) requires a Licensee Event Report be submitted for any event described in the paragraph within 30 days after the discovery of the event.
Contrary to the above, on September 1,
- 1984, the licensee identified a plant condition that was contrary to prescribed parameters, but failed to report it in the form of Licensee Event Report 84-14 until November 7, 1984.
This is a Severity Level V Violation (supplement 1)
RESPONSE-The Station has established procedures for the internal review of significant occurrences for reportability per the requirements of 10 CFR 50.73.
These procedures call for the review of Significant Occurrence Reports and Test Reports for the purpose of determining reportability by-personnel other than those directly involved in the ' work itself.
His permits review by staff knowledgeable in the background-required for reportability decisions.
This reportability process recognises a 30 day period for the submittal of LER's after an event is discovered to be reportable.
In this
- instance, plant personnel had identified data from 'which reportability could be assessed, howe.ver staff responsible for-making reportability determinations were not apprised of this information until October 7, 1984, at which time the period for submittal of the LER was promptly commenced.
The failure to make a timely report was therefore inadvertent.
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i-
~:4 e.
To reduce the time between recognition of an event and the date it is discovered reportable and to reasonably insure LER's are subailtted within 30 days of the reportability date, the process for determining - reportability has been better defined and the report preparation process has been streamlined.
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