ML20210E946
| ML20210E946 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 02/04/1987 |
| From: | Selman M CONSOLIDATED EDISON CO. OF NEW YORK, INC. |
| To: | Kane W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8702100404 | |
| Download: ML20210E946 (5) | |
Text
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Murrey Selmen
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Consolidated Edison Company of New York, Inc.
Indian Point Station Broadway & Bleakley Avenue Buchanan, NY 10511 Telephone (914) 737-8116 February 4, 1987 Mr. William F. Kane, Director Division of Reactor Projects U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 l
Re: Consolidated Edison Company of New York, Inc.
Indian Point Station Unit No. 2 Docket No. 50-247-
Subject:
Routine Inspection No. 50-247/86-28
Dear Mr. Kane:
.This is in response to your letter of January 5, 1987 concerning routine inspection No. 50-247/86-28 conducted by Mr. Lawrence W. Rossbach and Mr.
Peter W.
Kelley on October - 14, 1986. to November 21, 1986 at Indian Point Unit 2.
In general we acknowledge that the procedures and practices then in effect permitted the observations noted in your January 5,
1987 letter.
The circumstances related to each violation, together with our corrective action and date of implementation to preclude recurrence, are stated in Attachment A to this letter.
Should you or your staff have any questions, please contact us.
Very truly yours, 19.190.1.28.1
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v cc:
Dr. Thomas E. Murley Regional Administrator - Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 38 Buchanan, NY 10511 lN 8702100404 870204
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t' Re: Indian Point-Unit No. 2 Docket No. 50-247 Attachment A Response to Notice of Violation Violation A.
10 CFR 50, Appendix B, Criterion XI requires, in part, that a test program be established to assure that all testing required to demon-strate that structures, systems, and components will perform satisfac-torily is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable-design documents.
These results shall be documented and evaluated to assure that test requirements have been satisfied.
The Consolidated Edison Quclity 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 modification 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).
Response
We concur that the test procedure chosen did not adequately cover modification of PCV-1139.
A test, PT-Q13, which strokes the valve (without steam) was initially successfully performed.
A second test, PT-Q34, which would have adequately tested the function of PCV-ll39 with steam, with pump discharge in the recirculation mode, was not performed.
The test procedure (PT-Q34) had been modified to permit the substitution of a pump turbine overspeed test, PT-VE.
This test,
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which does require exercise of PCV-1139 in a steam environment, is regarded as being less satisfactory.than PT-Q34 for the modification performed.
The test ' group has reviewed this situation and has concluded that j
improvements in management control, test procedure development and establishment of acceptance criteria are required in order to preclude j
future occurrences. Accordingly, a new Post Maintenance Test Criteria sheet. is in the process of development.
This sheet will clearly identify the safety function to be confirmed with more clearly defined acceptance criteria.
In addition a generic component based checklist to catalog specific parameters for each component to be tested at Indian Point 2 is in the process of development.
It is believed that use of the Post Maintenance Criteria sheet together with the Component Checklist will enable a Post Maintenance Test to be devised which is functionally adequate for all situations. Administrative Directive TAD-11 will be revised by March 31, 1987 implementing these changes.
With respect to the change in Auxiliary Feedwater Pump #22 speed changer from 0 to 20%, our policy is as follows.
The Manager for Operations is responsible for the review of all changes in Operating Procedures.
He emphasizes in this review process via the Temporary Change Procedures the adequacy of the technical basis for the change j
and the need for a formal test of expected performance.
He also assesses the need for additional review for the potential of an unreviewed safety issue prior to implementation of the modified Operations Procedure. The General Manager of Nuclear Power Generation must also review and concur in the change which is ultimately subject to a safety review by the Station Nuclear Safety Committee.
The subject of Operating Procedure Revision and the need for documented confirmatory testing has been the subject of intensive discussion between the Vice President of Nuclear Power and senior management personnel. The above policy is currently in effect.
Violation 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 i
established. Station Administrative Order 405, Revision 2, "Modifica-tions to Indian Point Facilities," states in part that:
"A report 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
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J' 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).
Response
The current revision of SAO-405 includes the requirements for a Report of Installation for all Modifications and Start-up authorization upon the completion of a partial. modification.
We acknowledge that,'in some instances, reliance has been placed upon submittal of a completed Work Package and a Report of Installation in the instances of partial modifications in lieu of a Start-Up authorization.
Consequently, these two modifications were returned to service without performing these steps.,
SAO-405 is currently being revised to incorporate many changes in'our method of accomplishing modifications.
A revised SAO-405 will be issued by March 31, 1987.
Violation 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 require-ments to make proper and timely certification to the Commission prior to a licensed operator resuming licensed duties in 1986 after four months of not performing the functions of an operator or senior oper-ator.
This is a Severity Level V violation.
Response
A station policy covering licensed operator training and requalification has been written and will be implemented by February 15, 1987.
The policy covers the below discussed provisions relevant to watchstanding proficiency.
These provisions are being followed to prevent recurrence of the violation.
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. fyl Watchstanding Proficiency (1)
Proficiency watches are defined as watch assignments stood by licensed operators or senior operators in control of station for the purpose of maintaining knowledge and understanding of facility operation.
(2)
Licensed Operators and senior operators who are routinely scheduled for watch do.not need to stand proficiency watches.
(3)
Licensed Operators and senior operators not routinely scheduled for watch, licensed operator training instructors, and selected station management personnel must perform proficiency watches during normal plant operation, excluding outage periods (4) ' Persons who do not_ maintain watchstanding proficiency and who have not been scheduled for watch over a 4 consecutive month period will be required to completed a special requalification program, certi-fication, and NRC approval before assignment to the watch. Content of the special requalification program shall include:
o At least two 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> watches under instruction at a licensed watch station, o
Completion of all reading required by the. Operations Feed-back program. A written or oral examination may be adminis-tered to the licensee on the feedback program ' material at the judgment of the General Manager, Nuclear Power Gen-eration.
o A plant walk through by the Operations Manager or designated Senior Watch Supervisor.-
o The operator or senior operator must have a satisfactory status in the license operator requalifications program.
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