ML20206R686
| ML20206R686 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 06/20/1986 |
| From: | Selman M CONSOLIDATED EDISON CO. OF NEW YORK, INC. |
| To: | Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8607070203 | |
| Download: ML20206R686 (4) | |
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krrey h Vca Precedent Consolidated Edison Company of New York, Inc.
Indian Point Station I
Broadway & Bleakley Awe.
Buchanan. NY 10511 Telephone (914) 737-8116 June 20, 1986 Re:
Indian Point Unit No.'2 Docket No. 50-247 l
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Mr. Samuel J. Collins, Chief Projects Branch No. 2 Division of Reactor Projects i
U.S. Nuclear Regulatory Commission Region I 631 Park Avenue
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King of Prussia, PA 19406
Dear Mr. Collins:
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This refers to inspection 50-247/86-10 conducted by Mr. L. Rossbach and P.
I Kelley of your office April 1-30, 1986.at Indian Point Nuclear Generating Station, Unit 2.
Your May 14, 1986 letter stated that it appeared that one of our activities was not conducted in full compliance with NRC requirements as set forth in the Notice of Violation' enclosed therewith as Appendix A.
Pursuant to the provisions of 10 CFR 2.201, our response to the notice is presented in Attachment A to this letter.
The schedule for this response was extended to June 23, 1986 in discussion between Mr. Rossbach and Mr. M. Blatt of my staff on June 11, 1986.
i In addition to the above referenced response Attachment B reviews our I
actions to improve the content of event notifications.
Should you or your staff have any questions, please contact us.
Very truly yours, i
i Attachment i
1 cc: Senior Resident Inspector j
j U.S. Nuclear Regulatory Commission P.O. Box 38 j
Buchanan, New York 10511 4
17.190.6.9.2 1
8607070203 8 M 20 f3 hDR ADOCK 05000247 p
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June 20, 1986 Re:
Indian Point Unit No. 2 Docket No. 50-247 ATTACHMENT A Response To Notice of Violation i
Violation A:
Technical Specification 6.9.1.3 requires that the Annual Radiation Exposure Report be submitted no later than March 1 of each year. Technical Speci-fication 3.13.A.3 requires that a telephone notification be made to Region j
I within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of identifying that the fire protection system is inoper-able.
l Contrary to the above, in April 1986, the inspector identified the follow-l ing:
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(a) The Annual Radiation Exposure Report was submitted on March 31, 1986.
(b) The fire protection system became inoperable on March 28, 1986, but the telephone notification to Region I was not made until March 31, 1986.
This is a Severity Level V Violation (Supplement 1).
Response
(a) The non-compliance occurred as stated in paragraph (a).
Consolidated Edison personnel discovered during the first week of March 1986 that the report was overdue and informed the resident inspector. On March 31, 1986, the report was sent to the Regional Office, Region I.
An additional copy was subsequently sent to the Of fice of Nuclear Regu-latory Research achieving full compliance with requirements.
The non-compliance occurred due to failure to follow the schedule for submittal of this report contained in Station Administrative Order l
125, " Station Written Report Requirements," and this schedule not being included in the Environmental Health and Fifety (EH&S) Records and Reports Procedure or in the new commitment tracking system.
The plant's commitment tracking system was modified to include the submit-tal of this report. The Environmental Health & Safety Department has modified Procedure EHS-SQ-2.001, (EH&S Records and Reports) to reflect the technical specification required submittal of March 1 for these exposure reports.
In addition, the procedure for written reports, which lists written report requirements, is being further reviewed for completeness and to verify that its requirements are included in the tracking system.
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June 20, 1986 Re:
Indian Point Unit No. 2 Docket No. 50-247 1
The immediate-(b) The non-compliance occurred as stated in paragraph (b).
3 corrective action associated with making the delayed notification on i
March 31 included review of the incident with the personnel involved.
Required notifications at Indian Point ' Unit,2 are identified and completed in accordance with a ' written. procedure (Station Administrative Order 124, " Oral Reporting of Significant Events and Items of Interest").
Procedure implementation for this event was initiated during the shift when the event occurred but. could not be completed prior to shift turnover on March 28, 1986. Miscommunication between the departing and arriving Senior Watch Supervisors (SWS) led the arriving. SWS to - believe the notification had not in fact been completed.
The SWS shift turnover procedure has not until now included a required review of the status of events and notifications initiated on the j.
departing shift.
To prevent ~ a recurrence of delayed reporting the~
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"SWS Shift Turnover Sheet," DCR-2, will be revised by July-15, 1986 to require inclusion of events occurring during the departing shift which' require or could require notifications, d
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k June 20, 1986 Re:
Indian Point Unit No. 2 Docket No. 50-247 ATTACHMENT B Notification Policy It has been and continues to be Con Edison policy "to develop and maintain open lines of communication for reporting any change in status or items of interest at our Indian Point facility in a timely and comprehensive manner."
(Station Administrative Order 124)
Actions taken or in progress to improve event notifications are summarized below.
This procedure is undergoing revision to provide additional guidance for personnel responsible for implementation of this policy.
In 1985 Regulatory Affairs personnel attended an Operations Manager's Senior Watch Supervisors meeting to review event notification requirements.
Consideration is being given to repeating this agenda with Regulatory Affairs at regular intervals.
In 1985 representatives from Emergency Planning and Operations made an orientation visit to NRC's Operations Center.
The value of additional visits for other Operations personnel is under review.
NRC IE Information Notice No. 85-78:
Event Notification dated September 23, 1985 was reviewed by Nuclear Power during the fourth quarter 1985.
Operations and Training concluded that a properly completed " Event Notification Worksheet" would reasonably assure complete event reporting.
In practice it has been difficult to use both the notification form in the station notification procedure and the new NRC form simultaneously.
Operations will develop a combined form for incorporation and use in the station procedure.
Event notification requirements have been reviewed with Training Section personnel.
The Training Section will incorporate NRC reporting into simulator emergency exerciscs.
The exercise will require operators to diagnose the events, document the conditions, and simulate communications with appropriate personnel and agencies.
Senior station managenent is conducting additional instructional meetings which emphasize event notification policy for personnel whose duties require or may require reportable event identification and reporting.
Managers at various other meetings are also reinforcing the importance of fully implementing Con Edison's event notification policy in their communications with NRC representatives.