ML20153F066

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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
ML20153F066
Person / Time
Site: Indian Point Entergy icon.png
Issue date: 09/18/1998
From: Barrett R
POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:
NRC OFFICE OF ENFORCEMENT (OE), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-286-98-05, 50-286-98-5, IPN-98-100, NUDOCS 9809280352
Download: ML20153F066 (8)


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g Itdan Point 3

. Nuclear Power Plant PO. Box 215 Buchanan. New York 10511 914 736 8001

  1. 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

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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.

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%r obert J. Barre Executive Officer

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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

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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:

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  • 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.

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  • 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.

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~ 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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