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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217B3331999-10-0707 October 1999 Responds to 990825 Telephone Call Re Presense of Polychlorinated Biphenyl Wastes at Plant,Unit 1 ML20212F4481999-09-17017 September 1999 Forwards NRC Form 536 Containing Currently Proposed Site Specific Operator Licensing Exam Schedule & Estimates of Number of Applicants for Generic Fundamentals Exams Through Cy 2003 ML20212F7051999-09-14014 September 1999 Forwards Rev 19 to Ipn,Units 1 & 2 Physical Security Plan. Plan Withheld,Per 10CFR2.790(d) & 73.21 ML20211N0681999-09-0202 September 1999 Informs That Commission Requested Publication of Notice of Consideration of Issuance of Amend to Fol,Proposed NSHC Determination & Opportunity for Hearing. Amend Changes Senior Reactor License Requirement for Operations Manager ML20211H6291999-08-26026 August 1999 Forwards NPDES Discharge Monitoring Rept for July 1999 for Indian Point,Units 1,2 & 3. Rept of Noncompliance Is Attached for Noncompliance Which Occurred at Unit 3 ML20211E1531999-08-18018 August 1999 Forwards Semi Annual fitness-for-duty Program Performance Data for 990101-990630,IAW 10CFR26.71(d) ML20211H6051999-08-18018 August 1999 Forwards Rev 8 to Security Force Training & Qualification Plan, for Indian Point 3 Nuclear Power Plant.Rev Facilitates Transition of Duty Weapons Carried by Security Force Members from Revolvers to Semiautomatic Pistols ML20211A9241999-08-11011 August 1999 Informs That IPS Currently Estimates,That Approx Two Licensing Actions Will Be Submitted to NRC During Remainder of 1999 NRC Fiscal Yr & Approx Ten Will Be Submitted During 2000 NRC Fiscal Yr ML20210M7251999-07-26026 July 1999 Forwards Projection of Ability to Pay Retrospective Premium Adjustment for Period of Aug 1999 to 000731, Which Demonstrates That Ceny Will Have Sufficient Cash Flow &/Or Cash Reserve Available Throughout Period to Pay Premium ML20210G8911999-07-20020 July 1999 Forwards Application for Amend to License DPR-5 for Proposed New TS 3.2.1.i,revising Senior Reactor License Requirement for Operations Manager ML20209B6611999-06-29029 June 1999 Returns Recently Submitted Renewal Applications,Nrc Form 398,for Three Reactor Operators,As They Are Not Completed Properly.List of Docket Numbers & Block Numbers That Contain Incorrect Info & Block Numbers Not Completed.Without Encls ML20196A6371999-06-15015 June 1999 Forwards Rev 19 to Physical Security Plan.Rev Withheld,Per 10CFR2.790(d) & 73.21 ML20207D1861999-05-27027 May 1999 Informs That Effective 990328,NRC Office of NRR Underwent Reorganization.Mt Masnik Section Chief for Indian Point Station,Unit 1.JL Minns Remains Primary Contact for All Routine Licensing & Administrative Matters.Chart Encl ML20205R1981999-04-15015 April 1999 Requests That Dept of Environ Conservation Modify SPDES Permit for IPS IAW Proposed Rev Attached & Described as Listed ML20205R2961999-04-15015 April 1999 Forwards Copy of Proposed Change to Indian Point SPDES Permit NY0004472.Proposed Change Requests Permission to Add Permitted Outfall to Plant as Well as Change Character of Existing Outfall.Without Encl ML20196K8111999-03-31031 March 1999 Forwards Decommissioning Funding Status Rept for Indian Point,Units 1 & 2 Through 981231 ML20205F9711999-03-25025 March 1999 Informs That Under Separate Cover,Licensee Transmitted to Ofc of Nuclear Regulatory Research Annual Rept of Results of Individual Monitoring at Indian Point,Units 1 & 2,for CY98 ML20204F7931999-03-17017 March 1999 Forwards Table Outlining Nuclear Property Insurance Which Has Been Placed on Behalf of Consolidated Edison Co of Ny, Inc.Insurance Covers Indian Point,Units 1 & 2 ML20204J9971999-03-0909 March 1999 Forwards Insp Rept 50-003/98-19 on 981130-990222.No Violations Noted ML20203B9001999-02-0808 February 1999 First Partial Response to FOIA Request for Documents. Forwards Documents Listed in App a Already Available in PDR, Documents in App B Released in Entirety & Documents in App C Being Withheld in Part (Ref Exemption 6) ML20202J6171999-02-0505 February 1999 Forwards Transcript from 990120 Public Meeting Held in Peekskill,Ny Re Decommissioning ML20199H3731999-01-11011 January 1999 Informs That T Schmeiser,Con Ed Plant Manager for Plant Is Retiring,Effective 990111.AA Blind Will Assume Duties & Responsibilities of Plant Manager Until Replacement Named ML20198E9561998-12-21021 December 1998 Forwards Order Prohibiting Involvement in NRC Licensed Activities Re Deliberate Misconduct in Violation of Regulation When False Info Was Provided to Two NRC Licensees ML20198C2371998-12-15015 December 1998 Ltr Contract:Task Order 237, Review & Evaluation of Indian Point 3 Nuclear Power Plant Application for Conversion to Improved TS, Under Contract NRC-03-95-026 ML20198C4911998-12-11011 December 1998 Forwards Rev 18 to Physical Security Plan,Reflecting Organizational Changes & Incorporating Administrative Corrections & Clarifications.Encl Withheld ML20198C3251998-12-11011 December 1998 Responds to ,Responding to NRC Ltr Re Concerns Raised About Potential Chilling Effect from Temp Denial of Site Access to Employee Raising Safety Issues to Util Senior Mgt ML20155H2901998-11-0303 November 1998 Responds to to Lj Callan Expressing Concern About Continued Operation of Indian Point Nuclear Generating Station.Explanation Why NRC Do Not Think Revoking OLs for Indian Point Units 2 & 3 Justified,Provided ML20155F9181998-10-28028 October 1998 Forwards Changes to SPDES Permit,Removing Requirement to Monitor Svc Boiler Blowdown for Phosphates,Eliminate Redundant Sampling of Oil or Grease Entering Flow Tributary to Floor Drains,Per Ts,App B,Section 3.2 ML20155D2791998-10-23023 October 1998 Forwards Corrected Pages for Indian Point Annual Radiological Environ Operating Rept for 1997 ML20154Q1761998-10-21021 October 1998 Second Final Response to FOIA Request for Documents. Documents Listed in App C Being Withheld in Part (Ref FOIA Exemption 7) ML20154L8031998-10-16016 October 1998 Ack Receipt of & Payment in Amount of $55,000 in Electronic Funds for Civil Penalty Proposed by NRC in .Corrective Actions Will Be Examined During Future Insp ML20155H3021998-09-24024 September 1998 Urges NRC to Revoke Operating Licenses for Indian Point Nuclear Generating Station,Units 2 & 3 & Not Renew OL for Unit 1 ML20154A1391998-09-22022 September 1998 Informs That Effective 980724,AA Blind Assumed Position of Vice President,Nuclear Power & Ja Baumstark Assumed Position of Vice President,Nuclear Power Engineering,Effective 980813 ML20153F0661998-09-18018 September 1998 Provides Response to Violations Noted in Insp Rept 50-286/98-05 & Proposed Imposition of Civil Penalty Dtd 980819.Corrective Actions:Existing Drawings for Spare Switchgear Cubicles Have Been Revised ML20151W4871998-09-10010 September 1998 Informs That as Part of NRC Probabilistic Risk Assessment Implementation Plan,Commission Assigned Two Senior Reactor Analysts (Sras) to Each Regional Ofc.T Shedlosky & J Trapp Has Been Assigned as SRAs for Region I ML20151W9511998-09-10010 September 1998 Informs That as Part of NRC PRA Implementation Plan, Commission Has Assigned Two Senior Reactor Analysts (Sras) to Regional Ofc.T Shedlosky & J Trapp Has Been Assigned SRAs Duties for Region I ML20155F4391998-08-26026 August 1998 Forwards Demand for Info,Being Issued to Enable NRC to Fully Understand Recipient Views on Facts & Circumstances Surrounding Allegedly False Info Provided to Two NRC-licensed Activities ML20238F5151998-08-26026 August 1998 First Partial Response to FOIA Request for Documents. Documents Listed in App a Being Released in Entirety. Documents Listed in App B Being Withheld in Part (Ref FOIA Exemption 6) IR 05000286/19980051998-08-19019 August 1998 Discusses Insp Rept 50-286/98-05 on 980528-0612 & Forwards NOV & Proposed Imposition of Civil Penalty in Amount of $55,000.Most Significant Violation Involved Failure, Following Design Mod in Oct 1997 ML20237B1001998-08-0505 August 1998 Responds to NRC Re Violations Noted in Insp Repts 50-247/97-13,50-247/97-15,50-247/98-02 & Investigation Rept 1-97-038,respectively.Corrective Actions:Acted Promptly to Assure Conforming to Testing Requirements ML20236X8511998-07-31031 July 1998 Forwards Rept Re Projection of Ability to Pay Retrospective Premium Adjustment for Period 980801-990731,per 10CFR140.21 ML20236V4211998-07-13013 July 1998 Forwards SER Approving Topical Repts WCAP-14333P & WCAP-14334NP (Proprietary & non-propiretary, PRA of RPS & ESFAS Test Times & Completion Times ML20236Q1431998-07-0808 July 1998 Responds to Administrative Ltr 98-03 Re Operating Reactor Licensing Action Estimates IR 05000247/19970131998-07-0606 July 1998 Discusses Insp Repts 50-247/97-13,50-247/97-15 & 50-247/98-02 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $110,000 ML20238F5231998-06-29029 June 1998 FOIA Request for Documents Re NRC Office of Investigation Rept 1-97-038,meeting Minutes of Summary of Enforcement Conference on 980506 & Meeting Minutes or Summary of 980520 Predecisional Enforcement Conference ML20154Q1831998-06-29029 June 1998 FOIA Request for Documents Re NRC OI Rept 1-97-038,meeting Minutes of Summary of Enforcement Conference on 980506 & Meeting Minutes or Summary of 980520 Predecisional Enforcement Conference ML20236J9871998-06-24024 June 1998 First Final Response to FOIA Request for Documents.Documents Listed in App a Already Available in Pdr.Documents Listed in App B Being Released in Entirety ML20248F2891998-05-26026 May 1998 Ltr Contract:Task Order 8, Indian Point 2,A/E Follow-up Insp, Under Contract NRC-03-98-021 ML20248L9861998-05-21021 May 1998 Forwards Rev 7 to Security Force Training & Qualification Plan.Review to Verify Receipt of Revised Plan & Sign & Return Receipt Ack Form Provided ML20247M6951998-05-20020 May 1998 Forwards RAI Re GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design-Basis Accident Conditions, for Plant,Unit 2 1999-09-02
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20212F4481999-09-17017 September 1999 Forwards NRC Form 536 Containing Currently Proposed Site Specific Operator Licensing Exam Schedule & Estimates of Number of Applicants for Generic Fundamentals Exams Through Cy 2003 ML20212F7051999-09-14014 September 1999 Forwards Rev 19 to Ipn,Units 1 & 2 Physical Security Plan. Plan Withheld,Per 10CFR2.790(d) & 73.21 ML20211H6051999-08-18018 August 1999 Forwards Rev 8 to Security Force Training & Qualification Plan, for Indian Point 3 Nuclear Power Plant.Rev Facilitates Transition of Duty Weapons Carried by Security Force Members from Revolvers to Semiautomatic Pistols ML20211E1531999-08-18018 August 1999 Forwards Semi Annual fitness-for-duty Program Performance Data for 990101-990630,IAW 10CFR26.71(d) ML20211A9241999-08-11011 August 1999 Informs That IPS Currently Estimates,That Approx Two Licensing Actions Will Be Submitted to NRC During Remainder of 1999 NRC Fiscal Yr & Approx Ten Will Be Submitted During 2000 NRC Fiscal Yr ML20210M7251999-07-26026 July 1999 Forwards Projection of Ability to Pay Retrospective Premium Adjustment for Period of Aug 1999 to 000731, Which Demonstrates That Ceny Will Have Sufficient Cash Flow &/Or Cash Reserve Available Throughout Period to Pay Premium ML20210G8911999-07-20020 July 1999 Forwards Application for Amend to License DPR-5 for Proposed New TS 3.2.1.i,revising Senior Reactor License Requirement for Operations Manager ML20196A6371999-06-15015 June 1999 Forwards Rev 19 to Physical Security Plan.Rev Withheld,Per 10CFR2.790(d) & 73.21 ML20205R2961999-04-15015 April 1999 Forwards Copy of Proposed Change to Indian Point SPDES Permit NY0004472.Proposed Change Requests Permission to Add Permitted Outfall to Plant as Well as Change Character of Existing Outfall.Without Encl ML20196K8111999-03-31031 March 1999 Forwards Decommissioning Funding Status Rept for Indian Point,Units 1 & 2 Through 981231 ML20205F9711999-03-25025 March 1999 Informs That Under Separate Cover,Licensee Transmitted to Ofc of Nuclear Regulatory Research Annual Rept of Results of Individual Monitoring at Indian Point,Units 1 & 2,for CY98 ML20204F7931999-03-17017 March 1999 Forwards Table Outlining Nuclear Property Insurance Which Has Been Placed on Behalf of Consolidated Edison Co of Ny, Inc.Insurance Covers Indian Point,Units 1 & 2 ML20199H3731999-01-11011 January 1999 Informs That T Schmeiser,Con Ed Plant Manager for Plant Is Retiring,Effective 990111.AA Blind Will Assume Duties & Responsibilities of Plant Manager Until Replacement Named ML20198C4911998-12-11011 December 1998 Forwards Rev 18 to Physical Security Plan,Reflecting Organizational Changes & Incorporating Administrative Corrections & Clarifications.Encl Withheld ML20155F9181998-10-28028 October 1998 Forwards Changes to SPDES Permit,Removing Requirement to Monitor Svc Boiler Blowdown for Phosphates,Eliminate Redundant Sampling of Oil or Grease Entering Flow Tributary to Floor Drains,Per Ts,App B,Section 3.2 ML20155D2791998-10-23023 October 1998 Forwards Corrected Pages for Indian Point Annual Radiological Environ Operating Rept for 1997 ML20155H3021998-09-24024 September 1998 Urges NRC to Revoke Operating Licenses for Indian Point Nuclear Generating Station,Units 2 & 3 & Not Renew OL for Unit 1 ML20154A1391998-09-22022 September 1998 Informs That Effective 980724,AA Blind Assumed Position of Vice President,Nuclear Power & Ja Baumstark Assumed Position of Vice President,Nuclear Power Engineering,Effective 980813 ML20153F0661998-09-18018 September 1998 Provides Response to Violations Noted in Insp Rept 50-286/98-05 & Proposed Imposition of Civil Penalty Dtd 980819.Corrective Actions:Existing Drawings for Spare Switchgear Cubicles Have Been Revised ML20237B1001998-08-0505 August 1998 Responds to NRC Re Violations Noted in Insp Repts 50-247/97-13,50-247/97-15,50-247/98-02 & Investigation Rept 1-97-038,respectively.Corrective Actions:Acted Promptly to Assure Conforming to Testing Requirements ML20236X8511998-07-31031 July 1998 Forwards Rept Re Projection of Ability to Pay Retrospective Premium Adjustment for Period 980801-990731,per 10CFR140.21 ML20236Q1431998-07-0808 July 1998 Responds to Administrative Ltr 98-03 Re Operating Reactor Licensing Action Estimates ML20238F5231998-06-29029 June 1998 FOIA Request for Documents Re NRC Office of Investigation Rept 1-97-038,meeting Minutes of Summary of Enforcement Conference on 980506 & Meeting Minutes or Summary of 980520 Predecisional Enforcement Conference ML20154Q1831998-06-29029 June 1998 FOIA Request for Documents Re NRC OI Rept 1-97-038,meeting Minutes of Summary of Enforcement Conference on 980506 & Meeting Minutes or Summary of 980520 Predecisional Enforcement Conference ML20248L9861998-05-21021 May 1998 Forwards Rev 7 to Security Force Training & Qualification Plan.Review to Verify Receipt of Revised Plan & Sign & Return Receipt Ack Form Provided ML20217F8501998-03-20020 March 1998 Forwards Table Which Outlines Nuclear Property Insurance That Has Been Placed on Behalf of Util,Per 10CFR50.54(w)(3) ML20199L9531998-01-26026 January 1998 Forwards Addl Info on Rev 6 to Security Force Training & Qualification Plan,Per 980113 Telcon Request of G Smith.Encl Withheld ML20199F7541998-01-21021 January 1998 Forwards Rev 17 to Physical Security Plan,Per Requirements of 10CFR50.54(p).Rev 17 Contains Summary of Changes, Detailing Changes Incorporated.Encl Withheld ML20198N1151998-01-20020 January 1998 Submits Status of Response to NRC Request for Addl Info, for Licenses TR-3 & R-93.Request for Commitment to Complete Decommissioning Activities by 2007 Has Been Persued Up Through Nasa Mgt ML20202F8281997-11-26026 November 1997 Reports Mod to Indian Point SPDES Permit as Required in Ts. Copy of New York State Dept of Environ Conservation Ltr That Modifies Permit Is Encl ML20198P7901997-10-31031 October 1997 Forwards Rev 6 to Physical Security Plan,Per 10CFR50.4(b)(4) to Meet Requirements of 10CFR50.54(p).Rev 16 Contains Summary of Changes, Detailing Changes Incorporated. Encl Withheld ML20198P3181997-10-30030 October 1997 Forwards Corrected Pages to Annual Radiological Environ Operating Rept for 1996 ML20211H7771997-10-0202 October 1997 Forwards Responses to RAIs 650.1 Through 650.8 Re Generic Issues & Generic Communications on Valve Testing & Valve Qualification.Westinghouse Status for Subject Issues Will Be Confirm W Pending Rev to Ssar & WCAP-13559 ML20211B4241997-09-19019 September 1997 Requests Withdrawal of Revs 16 & 18 to Physical Security Plan.Rev 16 re-submitted Per Provisions of 10CFR50.54(p)(2) & Deals W/Specific Operational Criteria of New Sys.Plan Withheld ML20211A9411997-09-18018 September 1997 Responds to NRC Re Violations Noted in Insp Rept 50-286/97-80.Corrective Actions:Revised Administrative Procedure AP-3 to Establish Responsibility for Engineering Review & Revised EOP ES-1.3 ML20149J2491997-07-16016 July 1997 Forwards Environ Ts/Nonroutine Event Rept for Units 1 & 2. Appropriate Ny State Agency Notified ML20148S5731997-06-26026 June 1997 Forwards Response to NRC Re Violations Noted in Insp Repts 50-247/96-80;96-07;96-08;97-03 & Imposition of Civil Penalties on 961027-970405.Corrective Actions:Unique Tag Numbers for Louvers Were Generated ML20148J1431997-06-0404 June 1997 Forwards Rev 15A to Ipn Units 1 & 2 Physical Security Plan, Per 10CFR50.54(p)(2).Plan Withheld ML20137M8371997-04-0101 April 1997 Provides Supplemental Response to RAI Re TS Change Request 96-01 on Conversion to Framatome Cogema Fuel.Tech Specs, Encl ML20137A8301997-03-13013 March 1997 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 JPN-97-008, Forwards Comments on Draft NUREG-1560, IPE Program: Persprctives on Reactor Safety & Plant Performance1997-03-0404 March 1997 Forwards Comments on Draft NUREG-1560, IPE Program: Persprctives on Reactor Safety & Plant Performance ML1004713451997-02-26026 February 1997 Forwards Proprietary & non-proprietary Versions of W Rept Entitled, Conditional Extension of Rod Misalignment TS for Indian Point 3. Authorization Ltr & Affidavit,Encl. Proprietary Encl Withheld Per 10CFR2.790 ML20135C7121997-02-21021 February 1997 Forwards Table That Outlines Nuclear Property Insurance on Behalf of Util Covering Units 1 & 2 ML1004713471997-02-18018 February 1997 Authorizes Utilization of Encl Affidavit by Util Re WCAP-14669,Rev 1, Conditional Extension of Rod Misalignment TS for Indian Point 3. Rept Should Be Withheld Per 10CFR2.790(b)(4) ML20134N6481996-12-24024 December 1996 Provides Further Details Re Corporate Reorganization of Consolidated Edison Co of Ny for Indian Point Units 1 & 2 ML20132C8071996-12-12012 December 1996 Forwards Check for $100 for Payment of NRC Invoice 7I0053 for Indemnity Fee on License DPR-5 for One Year Period 961204-971203.W/o Check ML20129D9611996-10-11011 October 1996 Forwards Controlled Copy of Plant Physical Security Plan,Rev 18,re Access Control Upgrade Which Adopts Biometric Hand Geometry.W/O Encl ML20117P6151996-09-11011 September 1996 Forwards Rev 9 to Security Training & Qualification Plan.W/O Encl ML20117E3891996-08-21021 August 1996 Forwards Four Copies of IP3 Security Contingency Plan,Rev 4. W/O Encl JPN-96-035, Informs NRC That Boraflex Not Used as Neutron Absorber in Either Util or Plant Spent Fuel Pool Storage Racks,Per GL 96-041996-08-0606 August 1996 Informs NRC That Boraflex Not Used as Neutron Absorber in Either Util or Plant Spent Fuel Pool Storage Racks,Per GL 96-04 1999-09-17
[Table view] |
Text
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g Itdan Point 3
. Nuclear Power Plant PO. Box 215 Buchanan. New York 10511 914 736 8001
- b NeWYorkPbwer a~u s-a g Site E ecutive offcer September 18,1998 IPN-98100 1
Director, Office of Enforcement l U. S. Nuclear Regulatory Commission ,
ATTN: Document Control Desk {
Washington, DC 20555
SUBJECT:
Indian Point 3 Nuclear Power Plant
! Docket No. 50-286 ,
Reply to Notice of Violation and Proposed Civil Penaltv. 50-286 / 98d5 l
l l
REFEdENCE: 1. NRC Letter, H. J. Miller to R. J. Barrett, " Notice of Violation and Proposed imposition of Civil Penalty," dated August 19,1998.
Dear Si..
This letter provides the Authority's response to two violations documented in Reference 1. The Authority agrees with these violations and has taken appropriate corrective actions as described in Attachment 1. Payment of the $55,000 civil penalty imposed for one of the violations has been made by electronic transfer of funds from the New York Power Authority to the Treasurer of the United States (Federal Reference Number 0749 on September 18,1998).
l There are no new commitments made by the Authority with this letter. If you have any l _ questions, please contact Mr. Ken Peters at (914) 736-8029.
tr ours, i /
%r obert J. Barre Executive Officer
/
Indian Point 3 Nuclear Power Plant cc: next page 1 /Y 9809280352 980918 PDR ADOCK 05000286 G PDR
Docket No. 50-286 IPN-98-100 '
Page 2 of 3 cc: , Regional Administrator U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 )
Resident inspectcr's Office I indian Point Unit 3 U.S. Nuclear Regulatory Commission !
P.O. Box 337 l Buchanan, NY 10511 Mr. George F. Wunder, Project Manager l
Project Directorate I 1 i j' Division of Reactor Projects I/II l U.S. Nuclear Regulatory Commission i Mail Stop 14 B2 Washington, DC 20555 l
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4 Docket No. 50-286 IPN-98-100 Page 3 of 3 l
State of New York County of Westchester James Comiotcs, being duly sworn, deposes and says ,
1 I am the acting Site Executive Officer of the Indian Point 3 Nuclear Power Plant of which I the Pe~ .r Authority of the State of New York is the owner and operator under Facility l Operating License DPR-64. I have read the enclosed Reply to Notice of Violation and i know the contents thereof; and that the statements and matters set forth therein are true and correct to the best of my knowledge, information and belief. j
~
imes'Comiotes Subscribed and sworn to before me this /A Nay of September 1998.
CHRISTINA LEITMANN ,
Notary Public, State of New York l No.01LE5070946 Que%ed in Putnam County Comtmssion Empires January 6, tw_ ff a
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' Docket No.50286 o
IPN-98-10'1 Attachment i Page 1 of 5 Reply to Notice of Violation 50-286 / 98005
- 1. ylglation Assessed a Civil Pena 4y 10 CFR Part 50, Appendix B, Criterion Ill, Design Control, requires, in part, that measures be established to assure that the design basis is correctly translated into specifications. drawings, and instructions. The design control measures shall provide for veiifying or checking the adequacy of design, such as performance of design reviews, or by the performance of a suitable testing program.
Design changes shall be subject to design control measures commensurate with those applied to the original design.
Contrary to the above, between October 24,1997 and May 28,1998, the licensee failed to assure that a design change in October 1997 was subject to design control measures commensurate with those applied to the original design. Specifically, during the design change made to the 32 and 33 EDGs that realigned the essential power supplies to the EDG auxiliary support systems (which include EDG room ventilation; the fuel oil transfer pump; and the crankcase exhaust blower), an undervoltage trip function was installed on the supply breakers to the EDG auxiliaries. With the undervoltage trip relay installed, the EDG auxiliary support systems would be deenergized following a loss of normal power and operator action would be required to restore power to the auxiliaries.
This was contrary to the design basis for the EDGs. Without the auxiliary support systems, the EDGs could not be relied upon to operate for the required period of time without operator action. The design error was not identified during design reviews. (01013)
This is a Severity Level 111 violation (Supplement I). Civil Penalty - $55,000 Resoonse to Violation The New York Power Authority agrees with this violation.
Reason for Violation The violation occurred during the development of a modification because a design engineer did not identify a plant drawing that showed relevant existing wiring. The modification involved installation of two new feeder breakers in spare switchgear cubicles for two new motor control conters (MCC 36D and 36E). The spare switchgear cubicles were prewired with a Safety i Injection / Undervoltage (S!/UV) trip signal that was not intended to be a design feature for the modification.
l The Authority's evaluation of this event identified the following cause and contributing factors:
t
- Design inputs were not thoroughly documented for this modification. An engineering
} procedure, DCM-13 (Conduct of Engineering) provides a prccess and instructions for the preparation of a Design input Summary Checklist. Although a checklist was prepared for
- this modification, it was not completed with the attention to detail intended by the procedure. The drawing which showed the presence of the SI/UV trip was not listed on
- the checklist.
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Docket No.50-286 IPN-98-100 Attachment l Page 2 of 5
'A contributing factor was that the number and title of the subject drawing were such that the engineer did not recognize that the drawing was relevant to the modification.
1 Another contributing factor was that insufficient time may have been allocated for the assigned personnel to meet established deadlines.
In addition, several opportunities to identify the error were missed:
Reviewers and approvers of the modification package did not question the level of detail recorded on the Design Input Summary Checklist and did not recognize that a relevant reference drawing was not identified for this project.
A complete cross-check between the schematic and wiring diagrams was not performed.
A cross-check did verify that all circuits on the schematic were also on the wiring diagram. However, a reverse cross-check to verify that relevant information on the wiring diagram was shown on the schematic was not performed.
A modification acceptance test (MAT) did not identify the error because the test was not developed based on a review of design inputs using the approach described in the Authority's procedure for preparation of modification test requirements (MCM-11). The flawed schematic drawing that did not reflect the presence of the existing Sl/UV circuit was the primary reference used for development of the MAT.
The error was discovered on May 28,1998 during an unrelated event (Indian Point 3 Licensee Event Report 1998-003). Plant operators questioned the unexpected response of MCC 36D which deenergized during this event. The wirirg error was discovered during the investigation performed later that day.
Corrective Actions Taken immediate action was taken to address the as-installed configuration of this modification by stationing an operator at the feeder breakers for MCC 36D and 36E until the condition was I
corrected. An Engineering Change Notice was issued and the wiring error was corrected the following day, May 29,1998.
The Authoiity has completed the following corrective actions to prevent recurrence:
- This event was reviewed with design engineers at Indian Point 3 to emphasize the purpose and importance of using DCM-13 to thoroughly establish design inputs for plant modifications.
- Existing drawings for spare switchgear cubicles have been revised to facilitate future identification and use of this information.
- The Authority is implementing intermediate milestones to improve planning for refueling outages. Although this action was taken independently of the subject violation, the established milestones include preparation and review of modifications. The Authority believes that this approach willimprove the allocation of time for assigned personnel to develop modification packages.
=
- Docket No.50-286 IPN-98-100 Attachment l Page 3 of 5 in addnion, the Authority has completed the following actions regarding the failure to identify the error:
A new engineering procedure, DED AD-25, " Modification Quality Review Process" was issued in July 1997. This procedure was developed as a result of Authority self-assessment activities to improve overall quality of modification packages. The procedure includes instructions to reviewers regarding content of modification packages and verification that procedures and processes were appropriately followed in the preparation of the modification package. Although this action was taken independently of the subject violation, the Authority believes that the new procedure improves the modification review and approval process.
Design Guide & Drafting Standard DDS 0 05 04, " Guidelines for Checking for Electrical Design Drawings," was revised on July 30,1998 to include a specific statement for cross-checking schematic and wiring diagrams.
Training was conducted by the Design & Analysis Manager to reinforce the general testing philosophy and expectations regarding post modification tecting requirements and acceptance criteria as established in procedure MCM-11, " Preparation of Modification Test Requirements."
Corrective Actions that will be Taken The Authority believes that actions already taken will prevent recurrence.
Date When Full Comolir ;e was Achieved Compliance was achiev an May 29,1998 when the wiring error for MCC 36D and 36E was corrected.
l
~ Docket No.50-286 5 IPN-98-100 Attachment I i Page 4 of 5 II. Violation Not Assessed a Civil Penaltv l
10 CFR Part 50, Appendix B, Criterion XVI, requires, in part, that measures be established to assure l that conditions adverse to quality, such as deficiencies, deviations, and nonconformances are l promptly identified and corrected.
Contrary to the above, between September 1997 and May 28,1998, the licensee failed to promptly l correct a condition adverse to quality involving the inadvertent closure of the reactor coolant pump (RCP) thermal barrier flow control valve (FCV). Specifically, between S9ptember 1997 and March 1998, the licensee initiated four deviation event reports (DERs) to address the inadvertent closure of FCV-625, the thermal barrier FCV, when swapping component cooling water (CCW) pumps.
However, this condition had not been corrected as of May 28,1998. On May 28,1998, the inadvertent closure of FCV-625 in conjunction with loss of a charging pump resulted in a momentary loss of all RCP seal cooling. (02014)
This is a Severity Level IV violation (Supplement I)
Resoonse to Violation 1
The New York Power Authority agrees with this violation.
Reason for Violation l
The violation occurred because of a failure to clearly define and prioritize a problem reported by l plant operators. The issua was initially documented in a Deviation Event Report (DER 97-2412) l
! written by a plant operator in September 1997. The issue was reviewed by System Engineering l staff and the DER was closed based on a belief that the valve closure was not the result of a l system deficiency and was an expected system response for a specific set of test conditions.
l Therefore, the initial DER was closed based on a corrective action that revised the test procedure to include a warning of potential valve closure and direction to reopen the valve. This initial response created a mindset that influenced the disposition of subsequent problem reports written on this subject.
The Authority's evaluation determined that the failure to clearly define and prioritize the reported problem was the result of the following causes:
The Plant Identified Deficiency (PID 36171) for tnis issue was not classified by the Shift Manager as an Operator Work Around and was closed by the PID Review Committee based on the response to the DER. Issues identified as Operator Work Arounds are monitored separately from DERs and are assigned a specific priority for action. The Shift Managers' role in screening PIDs for possible Operator Work Around classification is desenbed in procedure SPO-SD-01, " Work Control Process."
Subsequent DERs that reported repeat occurrences were not highlighted and identified by the Operations Review Group (ORG) as an adverse trend, so that a higher level of attention could be directed on the prob!em.
Docket No.50286 a
IPN-98-100 Attachment i Page 5 of 5 Correcfive Actions Taken l
On May 26,1998 a new Plant Identified Deficiency (PID 61049) was opened and the issue was l classified as an Operator Work Around. Action to investigate and resolve the valve closure issue I was assigned to the Engineering Department with a work priority consistent with the Operator Work Around classification. Engineering issued an Action Plan (IDSE-APL-98-012) on July 20, 1998 to document the approach for resolution. A principle component of the action plan was the performance of a test to collect data regarding the valve response. The test procedure (ENG-622) was performed on July 21,1998. The data collected is being used to support development of a resolution.
The Authority has completed the following actions to prevent recurrence:
The Operations Department issued a shift order to emphasize the importance of the Shift Managers' role in reviewing PIDs for possible classification as an Operator Work Around.
- On August 17,1998 the Operations Review Group established a ' Recurring Issues List' to document DERs that may need a higher level of attention because of the repetitive nature of identified problems. Closure of FCV-625 is included on that list, pendin0 completion of i the action plan. The Authority is continuing to review alternative methods to ensure that l repeat problems are appropriately identified and prioritized.
Corrective Actions that will be Taken The Authority believes that actions already taken will prevent recurrence. The Authority is continuing to implement the steps ouitined in the Action Plan for FCV-625. The Authority will also review the current definition for Operator Work Around and if needed, provide additional criteria to assist the Shift Managers and PID Review Committee in classifying reported problems as Operator Work Arounds.
Date When Full Comoliance was Achieved Compliance was achieved on July 20,1998 when the Authority issued an Action Plan outlining the i steps to be taken to prevent the inadvertent closure of FCV 625. '
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