ML20207N169

Notice of Violation from Insp on 861014-1121

ML20207N169
Person / Time
Site:	Indian Point
Issue date:	01/05/1987
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20207N157	List: IR 05000247/1986028 ML20207N155 ML20207N169
References
50-247-86-28, NUDOCS 8701140026
Download: ML20207N169 (2)

Text

O APPENDIX A NOTICE OF VIOLATION Consolidated Edison Company Docket No. 50-247 Indian Point Unit 2 License No. OPR-26 As a result of the inspection performed from October 14 to November 21, 1986, and in accordance with the General Statement of Policy and Procedure *or NRC Enforcement Actions, 10 CFR Part 2, Appendix C (Enforcement Policy 1986), the following violations were identified:

A. 10 CFR 50, Appendix B, Criterion XI requires, in part, that a test program be established to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents. Test results shall be documented and evaluated to assure that test requirements have been satisfied.

The Consolidated Edison Quality Assurance Program, 1985 Revision, commits to a program which complies with Regulatory Guide 1.33, Revision 2, February 1978, which adopts the requirements of ANSI N18.7-1976. ANSI N18.7-1976, Section 5.2.19.3 states that tests shall be performed following plant modifications or significant changes in operating procedures to confirm that the modification or changes reasonably produce expected results, and that the change does not reduce the safety of operations.

Contrary to the above, following the modification of valve PCV 1139 in March 1986, as described in Modification 85-30720 for the Auxiliary Feedwater System, the licensee failed to perform.a test confirming that the modification reasonably produced expected results and that the modification did not reduce the safety of operations. Also, following the repositioning of Auxiliary Feedwater Pump #22 speed changer to the 20% position, as described in Temporary Procedure Change 86-106, the licensee failed to provide a suitably documented test procedure to assure the required quality of work and to confirm that the procedure change produced expected results.

This is a Severity Level IV Violation (Supplement II).

B. Technical Specification Section 6.8 requires that written procedures and administrative policies be established and implemented covering the recommendations of Regulatory Guide 1.33, November 1972, Appendix A. Regulatory Guide 1.33 requires that administrative procedures be established. Station Administrative Order 405, Revision 2, "Modiff-cations to Indian Point Facilities," states in part that: "A report 0FFICIAL RECORD COPY IR IP2 86 0004.0.0 26 e70105 12/19/86 h124gCK05000247 O

PDR

Appendix A 2 of installation shall be generated by the PMA for each completed or partially completed modification. There may be times when plant operation will be feasible even though all items identified are not completed. In those cases, a Start-Up Authorization may be issued.

This authorization must be approved by the General Manager Nuclear Power Generation and the General Manager Technical Support, and their written approval indicated on the Modification Tracking Form."

, Contrary to the above, the Auxiliary Feedwater System was returned to service following the partial completion of modification 85-30720, replacement of valve PCV 1139, in March 1986, and modification 86-52652, replacement of pump suction pressure switches, in October 1986, without completing a report of partial installation and without a documented Start-Up Authorization.

This is a Severity Level IV Violation (Supplement I).

C. 10 CFR 55.31 (e) specifies that prior to resuming licensed duties after four months of non performance of those duties, a license holder will certify to the Commission that his understanding of the facility is satisfactory.

Contrary to the above, the facility failed to comply with the requirements to make proper and timely certification to the Commis-sion prior to a licensed operator resuming licensed duties in 1986 after four months of not performing the functions of. an operator or senior operator.

This is a Severity Level V Violation.

Pursuant to the provisions of 10 CFR 2.201, Consolidated Edison Company of New York, Inc., is hereby required to submit to this office within thirty days of the date of the letter which transmitted this Notice, a written statement or explanation in reply, including: (1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending the response time.

OFFICIAL RECORD COPY IR IP2 86 0005.0.0 12/19/86