ML20115E879
| ML20115E879 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 04/03/1985 |
| From: | Otoole J CONSOLIDATED EDISON CO. OF NEW YORK, INC. |
| To: | Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8504190315 | |
| Download: ML20115E879 (4) | |
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John D. O'Toole vice prescent
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E Consohdated Edson Company of New York, Inc 3
4 trying Place, New York, NY 10003 Telephone (212) 460-2533
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April 3, 1985 Ret Indian Point Unit No. 2 j
Docket No. 50-247 M
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Mr. Samuel J. Collins, Chief Projects Branch No. 2 J
Division of Project and Resident Programs Region 1 U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pa.
19406
Dear Mr. Collins:
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This refers to I.E.
Inspection 50-247/84-33 conducted by Mr. T. Kenny of your office on December 1-31, 1984 of activities authorized by NRC License No. DPR-26 at Indian Point Unit No.
2.
Your February 14, 1985 letter set forth certain areas of concern as a result of this inspection.
Provided herewith as Attachment A is our response to these conce rns.
Should you cr your staff have any questions, please contact us.
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Ver truly youps,
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cc Senior Resident Inspector U. S. Nuclear Regulatory Commission P. O. Box 38 Buchanan, New York 10511 L
8504190315 85040'
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Attachment A Response to Items of Concern Item 1.
Reaffirm and upgrade-commitments made in your letter dated November. 16, 1983 (O'Toole to Martin) dealing with design modifications and drawing control.
i Response-The following is a status of the commitments dealing with design modifications and drawing control made in the above mentioned letters 1.
As a result of the commitment review program, a substantially greater number of commitments were identified than anticipated.
Because of the enlarged j
scope of our effort, the commitment review and corrective action process was ' revised and is being computerized.
Staffing was increased to support this effort.
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Presently, we have - loaded approximately 1000 out of approximately 4000 previously identified commitments into the computerized coseitsent tracking system.
As new commitments are made they are routinely -loaded i
and tracked by this system.
As commitments are l
loaded into the-computerized tracking system corrective actions are identified and assigned.
2.
The issuance of Control Room drawings revised as the result of walkdowns in. accessible plant areas has j
been completed.
The verification of Control Room drawings in areas that. remained iraccessible has been i
completed in all but a few areas due to ALARA considerations.
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Nuclear Power procedures to implement improvements to the processing of modification packages were revised y
by. June 2, 1984.
We will. continue to upgrade these pro::coures as appropriate.
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The long term program to schedule drawing restoration and fia,ld verification for canceled modifications has k.
been completed.
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- A systematic approach to ensure the quality ' of the drawing record has been developed ias part of the
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, Design Modification ' Drawing procedure issued January 9
22, 1985.
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Revision '2 to. the Indian Point; ttnit 2 updated. FSAR, 1-submitted in July 1984, included the' latest available
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company drawings for fire protection.
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~ Station Administ.rative Order 122 " Drawing Controls" i
was re'.cised and ' implemented June 2,.1984 to better
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- define the process for Control Room Drawing updates.
'i-The. appropriate department procedure, Operations h
Administrative Directive 20, was determined to be
[1 compatible with this.
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Item 2.
Delineate the. concerns your. management representatives expressed
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' at ' the exit meeting with regard to the safety Injection - Boric j
Acid event of. December 28, 1984.
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' Response
- j Our concerne,, as expressed at the exit meeting, dealt with the effect of blockages on Safety Injection pump performance and what' J
could be done to reduce boric acid injection related problems.
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- a.. result of.
these
- concerns, the following has been
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L initiated. --
Lehigh. University has been requested to perform J
scale. testing of the safety Injection pumps - to determine the y
effect ' that varying blockages,-in the suction line have upon the j
pump performance curve.
A preliminary report of ' the testing is estimated to be available by April ' 30, 1985.
Westinghouse is under contract. to perform an analysis-which will support elimination of the Boron Injection Tank. 'This study is estimated.
to be completed by June 30, 1985.
If the results of this ; study
'1 warrant a Technical specification. amendment, it could be ready by
[j 8eptember 1, 1985 for submittal to the NRC.
Item 3.
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Forward a safety analysis for the auxiliary feed ptsap steam isolation valves addressing the inspectors concern delineated in e
f section 7 of this report.
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n nesponse These valves were installed just prior to initial Indian Point 2 4
operation, to preclude disabling the = two motor driven pumps by.
l reason of a steam line rupture in the Auxiliary Feed Water (AFW) i a
pump room.- This was one of a number of modifications made to l
Indian. Point ' 2 which resulted. from a high energy line break
. analysis: that was requested of all utilities by the NRC in 1972.
1 Con Edison's responses for Indian point 2 were provided on April jj 9, 1973 and June 8, 1973, and for Indian Point 3 on May 14, 1973 j
'and June 8, 1973.
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. g The NRCI(then AEC) staff did address the addition of those valves at Indian -Point 3 in the Staff Safety Evaluation (SSE) supporting the issuance of the Indian Point 3 operating license.
To - our i
knowledge,.the NRC never issued. an SER on Indian Point
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However, there is no safety concern : with valves 1310 A& B for E
IP2 :since the NRC has -issued a formal SSE on the Indian Point 3 1.
Installation, 'which is essentially the same from a safety 1:
standpoint as Indian Point 2.
.he ' ; inspection report notes that-the inadvertent-closure. of s
valves 1310 A.and B appears not to have been addressed.
The
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effect of such an. inadvertent closure would be the loss of one of
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the.three AFW pumps.. Only one of the two remaining motor driven
[I AFW ' pumps-is required to satisfy minimum safeguards
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requirements.
Further,.open position every tire a surveillance valves.1310 A &
B' are indirectly j
confirmed to. be in the
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-test is performed on AFW Pump #22.
In addition, the Indian Point
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.Probabilistic Safety.- Study (IPPSS) analyses the AFW system failure modes and demonstrates : that the inadvertent closure of these. valves
'does' not' significantly contribute to AFW l
unavailability.'
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