ML20137A830

Forwards Response to NRC Ltr Re Violations Noted in Insp Rept 50-286/96-80 on 961213.Corrective Actions:Expert Panel Has Agreed to Include Turbine Bldg & Power Conversion Equipment Bldg in Scope of IP3 Maint Rule Program

ML20137A830
Person / Time
Site:	Indian Point
Issue date:	03/13/1997
From:	Barrett R POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
IPN-97-039, IPN-97-39, NUDOCS 9703210091
Download: ML20137A830 (7)

Text

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Indiin Point 3 Nuclur Power Pimt

. PO 8cx 2i5

, Bucharan. New York 10511

' d14 736 8001

1. > NewYorkPower ";;;"if*1

& Authority l

l March 13,1997 i IPN 97- 039 i 1

U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 t

Subject:

Indian Point 3 Nuclear Power Plant

' Docket No. 50-286 License No. DPR-64 Reolv to Notice of Violation 50-286/96-80  !

l Dear Sir.

This letter provides,in Attachment I, the New York Power Authority's response to the

. subject Notice of Violation. The Authority agrees with the Notice of Violation contained !

in NRC Region l Inspection Report 50-286/96-80.

l The commitments made by the Authority with this letter are contained in Attachment II.

If you have any questions, please contact Mr. K. Peters at (914) 736-8029.

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Very truly yours, I obert J. Barrett

, ite Executive Officer

Indian Point 3 Nuclear Power Plant O' (

Attachments cc: See next page s\

9703210091 DR 970313 ADOCK 05000286 PDR h .

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Docket No. 50-286

, IPN-97-039 Page 2 of 2 cc: Mr. Hubert J. Miller Regional Administrator l Region i U.S. Nuclear Regulatory Commission l 475 Allendale Road l King of Prussia, Pennsylvania 19406-1415 Mr. Curtis J. Cowgill 111, Chief l Projects Branch No.1 Division of Reactor Projects U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, Pennsylvania 19406-1415 j U.S. Nuclear Regulatory Commission i Resident inspectors' Office l Indian Point 3 Nuclear Power Plant 1

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i l Docket NO. 50-286 l

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. IPN-97-039

. Attachment i ,

Page 1 of 4 l Reply to Notice of Violation 50-286/96-80 i

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i VIOLATION l

I During an NRC inspection completed on December 13,1996, two violations of NRC requirements were

identified. These violations are as follows- i i

I Violation (50-286/96-80-01) l I

l A. "10 CFR 50.65(b)(2)(iii), part of the maintenance rule, requires that the scope of the monitoring l

program include nonsafety-related structures, systems, and components (SSCs) whose failure 1 4

could cause a reactor scram.

4 Contrary to the above, on December 13,1996, the following nonsafety-related structures whose j failure could cause a reactor scram were not included in the monitoring program scope: i i

Turbine Building i Power Conversion Equipment Building I i  :

This is a Severity Level IV violation." l i l l

Violation (50-286/96-80-03) l l B. "10 CFR 50.65(a)(1) and (a)(2) require that the performance or condition of SSCs shall be ,

monitored against licensee established goals unless it has been demonstrated that the l l performance or condition of a structure, system, or component is being effectively controlled 4

through the performance of appropriate preventive maintenance..'  ;

1 Contrary to the above, on December 16,1996, NYPA was not monitoring the performance or condition of numerous systems and components against established licensee-established goals, j j nor had NYPA demonstrated the effectiveness of preventive maintenance on these systems and l components.. i

. l This is a Severity Level IV violation."

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l' Docket NO. 50-286 IPN-97-039 Attachment I

Page 2 of 4 Reply to Notice of Violation 50-286/96-80

! A. Resoonse to Violation 96-80-01 i 1

! 1 The New York Power Authority agrees with this violation. The Turbine Building and the Power l Conversion Equipment Building were not included in the Maintenance Rule Program. l l

Reason for Violation The reason for this violation was a misinterpretation of how industry guidance should be applied in I

developing the Maintenance Rule Program. The Maintenance Rule Program is a new program at Indian '

Point 3, required by 10 CFR 50.65 as of July 10,1996. The program was developed following the i guidance of NUMARC 93-01 as endorsed by Regulatory Guide 1.160. Adjustments will be made to the l

program as appropriate. The Turbine Building and the Power Conversion Equipment Building should l

} have been included in the scope of the Maintenance Rule Program.

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i Corrective Actions Taken l The Expert Panel has agreed to include the Turbine Building and the Power Conversion Equipment i

, Building in the scope of the IP3 Maintenance Rule Program, by memo dated March 11,1997. I i

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Corrective Actions to be Taken to Avoid Further Violations 1 i l

< 1 l Applicable Maintenance Rule Program procedures and documents will be revised to reflect the inclusion  !

! of the Turbine Building and the Power Equipment Conversion Building in the Maintenance Rule Program. To be completed April 28,1997.

1 Date When Full Comoliance Will Be Achieved l

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Compliance will be achieved by April 28,1997 when applicable Maintenance Rule Program procedures and documents have been revised to include the Turbine Building and Power Conversion Equipment Building.

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Docket NO. 50-286 j

IPN-97-039 Attachment l Page 3 of 4 3

i Reply to Notice of Violation 50-286/96-80 j

I B. Resoonse to Violation 96-80-03 )

l I i The New York Power Authority agrees with this violation. Unavailability performance criteria had not

been established for all risk significant and standby SSCs; reliability performance criteria were not

] commensurate with safety; and the plant level performance criteria would not adequately monitor the effectiveness of maintenance for SSCs monitored at the plant level.

Reason for Violation l

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! The reason for this violation was a misinterpretation of how industry guidance should be applied in l

developing the Maintenance Rule program. The Maintenance Rule Program is a new program at Indian j Point 3, required by 10 CFR 50.65 as of July 10,1996. The program was developed following the guidance of NUMARC 93-01 as endorsed by Regulatory Guide 1.160. Adjustments will be made to the program as appropriate. Several risk significant systems should have had unavailability criteria '

4 established; the performance criteria were not objectively based in safety; and the plant level performance criteria for unplanned scrams should have included manual as well as automatic scrams.

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l Corrective Actions Taken Unavailability criteria have been defined, as documented by memo dated March 11,1997, for the

subject systems, with the exception of the 120 VAC system which is monitored as a part of the Auxiliary

Boiler Feedwater Building Ventilation System.

An analysis was performed on the reliability performance criteria (Maintenance Preventable Functional Failure [MPFF]) for risk significant systems. This analysis concluded, as documented by memo dated March 11,1997, that the acceptable reliability criteria for the Reactor Protection System is no MPFF.

The plant level criteria for scrams has been defined, as documented by memo dated March 11,1997, to be " unplanned scrams", to include automatic and manual, instead of " unplanned automatic scrams".

Corrective Actions to be Taken to Avoid Further Violations Applicable Maintenance Rule Program procedures and documents will be revised to incorporate newly established unavailability performance criteria. To be completed April 28,1997.

Applicable Maintenance Rule Program procedures and documents will be revised to incorporate re-estai>iished reliability criteria. To be completed April 28,1997.

Applicable Maintenance Rule P'rogram procedures and documents will be issued or revised to reflect the revised plant level performance criteria. To be completed April 28,1997.

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I Docket NO. 50-286

, IPN-97-039 2 ,

Attachment I j Page 4 of 4 1

i i Reply to Notice of Violation 50-286/96-80 i I l l

4 Date When Full Comoliance Will Be Achieved 1  :

j Compliance will be achieved by April 28,1997, when applicable Maintenance Rule Program procedures i and documents have been revised to include the availability criteria, reliability criteria commensurate

with safety and effective plant level performance criteria.

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Docket NO. 50-286

, IPN-97-039

, Attachment 11 Page 1 of 1 List of Commitments l

Number Commitment Due IPN-97-039-01 Applicable Maintenance 4/28/97 Rule Program procedures and documents will be revised to reflect the inclusion of the Turbine Building and the Powo Equipment Conversion Building in the Maintenance Rule Program.

IPN-97-039-02 Applicable Maintenance 4/28/97 Rule Program procedures and documents will be revised to incorporate newly established unavailability performance criteria.

IPN-97-039-03 Applicable Maintenance 4/28/97 Rule Program procedures and documents will be revised to incorporate re-established reliability criteria IPN-97-039-04 Applicable Maintenance 4/28/97 Rule Program procedures and cocuments will be issued or revised to reflect the revised plant level performance criteria.