ML20211A941

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

ML20211A941
Person / Time
Site:	Indian Point
Issue date:	09/18/1997
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
50-286-97-80, IPN-97-125, NUDOCS 9709250025
Download: ML20211A941 (9)

Text

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4 Indkm Point 3

'Ims O tk n 2 b Burhnan, New Yuk 10011 r 914 736 0001

1. > NewYorkPower "*i'AP"E-tv Authority i

September 18,1997 lPN-97-125 l

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- Director, Office of Enforcement U.S. Nuclear Regulatory Commission Attn: Document Control Desk, Washington, D.C. 20555 l

SUBJECT:

Indian Point 3 Nuclear Power Plant Docket No. 50-286 License No. DPR-64 Reolv to Notice of Violation and Procosed imoosition of Civil Penalty (Insoection Reoort 50-286/97-80)

Refarence: Nuclear Regulatory Commission Letter from Hubert J. Miller to Robert J.

Barrett dated August 19,1997.

Dear Sir:

This letter provides, in Attachment I, the New York Power Authority's response to Violation 97-80 03, identified in the referenced correspondence. The Authority agrees with this violation. Enclosed is a check for the Civil Penalty of $55,000.

The commitments made by the Authority with this letter are contained in Attachment II. If you have any questions, please contact Mr. K. Peters at (914)736-8029.

Very truly yours, w -

fL R. J. Barrett Site Executive Officer Indian Point 3 Nuclear Power Plant i /

Attachments cc: See next page I

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.- IPN-97-125 Page 2 of 3.

- cc: Mr. Hubert J. Miller .

Regional Administrator-Region l U.S. Nuclear Regulatory Commission'-

475 Allendale Road King of Prussia, Pennsylvania 19406-1415' .

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Director, Special Projects '

_ U.S. Nuclear Regulatory Commission --

Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Resident inspectors' Office '

Indian Point 3 Nuclear Power Plant 4

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. e Docket No. 50-286

.- lPN-97125 Page 3 of 3 State of New York County of Westchester s

James Comiotes, being duly sworn, deposes and says:

I am the acting Site Executive Officer of the Indian on oint 3 Nuclear Power Plant of -

which the Power Authority of the State of New York is the owner and operator under~ ,

Facility Operating License DPR-64. I have read the foregoing " Reply to the NRC ,

Notice of Violation and Proposed Civil Penalty EA 97-294" and know the contents thereof; and that the statements and mattcrs set forth therein are true and correct to the best of my knowledge,!nformation and belief.

kC 1 Jfnes ComiotW 1

Subscribed and sworn to before me this I ? day of September 1997.

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. I Docket No. 50-286

. IPN-97-125 Attachment 1 Page 1 of 5 Reply to Notice of Violation 50-286/97 80-03/EA 97 294 RESPONSE TO NOTICE OF VIOLATION NYPA is responding to tne Notice of Violation contained in NRC Inspection Report 50-286/97-80 in accordance with the requirements of 10 CFR 2.201. The response addresses the three examples in the same sequence as presented by the Notice of Violation and provides the reason for each. The response provides the correctivenctions taken and -

results achieved, the corrective actions that will be taken to avoid repetition, and the date when full compliance will be acheved.

Violation 10 CFR Part 50, Appendix B, Criterion ill, requires that measures shall be established to assure that applicable regulatory requirements and the design basis, are correctly translated into specifications, drawings, procedures, and instructions.

Contrary to the above, prior to May 20,1997, measures were not established to assure that applicable regulatory requirements and the design basis, were correctly translated into Emergency Operating Procedures (EOPs), as evidenced by the following examples:

1. Design basis information for the component cooling water heat exchangers' service water outlet valvo position was not correctly translated into EOP ES-1.3, Revision 10, Transfer to Cold Leg Recirculation. The EOP did not provide instruction for operators to re-position these valves (from their normally throttled position) at the beginning of the recirculation phase of a postulated design basis accident. Under certain conditions, failure to re position the valves, may have caused the loss of function of the component cooling water and other supported systems. ,

2. Design basis information for protection of the recirculation pumps from runout was not correctly translated into EOP ES-1,3, Revision 10, Step 18(b). The EOP did not provide appropriate instructions to reduce flow to less than 3000 gpm to assure that net positive suction head requirements are satisfied when only one recirculation

- pump is operating.

3. Design basis information for isolating nonsafety-related equipment was not correctly translated into EOP ES-1.3, Revision 10, Step 60(a), which directed operators to isolate component cooling water flow to the non-regenerative heat exchanger using air operated temperature control valve AC-TCV-130. This procedure step was inadequate because valve AC-TCV-130 could fall open, due to a non safety-related source of supply air, and divert cooling water flow from other safety-related components.

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1 Docket No. 50-286

, IPN-97-125 Attachment i Page 2 of 5 Reply to Notice of Violation 50-286/97-80-03/EA 97-294 Response to Violation 97-80-03 NYPA agrees with this violation. The reasons for the violation are presented individually for the three cited examples.

Violation 97-80-03. Example npmber 1 NYPA agrees with this example.

Facts Related to Examole During normal operation service water valves SWN 351 and SWN-35-2, at the discharge of the CCW heat exchangers, are set to positions consistent with the existing Hudson River inlet temperature to control CCW temperatures supplied to equipment during normal plant operations. In the event of a postulated LOCA, EOP-ES-1.3, " Transfer to Cold Leg Recirculation', provides instructions to open these valves to a predetermined position of 27 degrees using protractors installed on the valves to protect the service water pumps from runout and to provide adequate post-LOCA service water flow. During normal operation there were no administrative controls to prevent adjusting those valves to positions more restrictive than the 27 degree valve opening required by EOP-ES-1.3.

A review of the sequence of EOP-ES-1.3, Revision 9, concluded that operators were not directed to throttle flow to the CCW heat exchangers until late in the procedure (step 40) when the headers were split. This delayed action could result in the throttle valves not being opened for up to an hour such that the service water flow may be insufficient for the post accident heat load. An analysis did not exist for the various service water temperatures and the corresponding valve position required during the initial transition to recirculation to assure that the CCW system would perform as designed.

Cause of Examole

1. Original instructions provided by the plant designers for operating the service water and CCW systems did not adequately address the provisions for transferring from power operations to post-LOCA heat loads during the recirculation phase.

Operating instructions do not establish SWN-35 valve position limits based upon river water temperature.

2. Communications between site, WPO project and design engineering, and operations utilized memos to initiate related EOP procedure changes. There was inadequate followup to ensure that the recommended changes were incorporated as intended to assure plant operation in accordance with the plant's design basis.

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. I Docket No. 50-286

, IPN-97-125 -  :

Attachment I )

Page 3 of 5

- Reply to Notice of Violation 50-286/97-80-03/EA 97-294 Example number 2 NYPA agrees with this example.

Facts Related to Examole When preparing Revision 10 to EOP ES 1,3, " Transfer to Cold Leg Recirculation," the writer addressed a comment by revising a procedural step to try to start a second recirculation pump if only one recirculation pump was running. When doing this, the writer eliminated the step for adjusting flow to less than 3000 gpm with a single recirculation pump in service. There was no other procedural guidance to reduce flow to satisfy recirculating pump NPSH requirements for the single operating pump until step 38. This results in the pump operating in a cavitational mode (with one recirculation pump supplying two RHR heat exchangers, pump flow wou!d exceed 3000 gpm) for an extended period of time. Recent analysis has shown that the pump was capable of this operation for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> with high sump temperatures. Procedure review and approval of EOP-ES 1,3 Revision 10, failed to detect the inappropriateness of the procedure revision.

Cause of Examole 4 1. The procedure writer focused on the feedback recommendation and failed to develop appropriate contingencies for subsequent procedural steps and to consider the prerequisite actions proviously established.

2. Technical, including Validation and Verification, and OSR reviews did not adequately review Revision 10 to this procedure.

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- l Docket No. 50-286

., IPN 97-125 Attachment 1 -

Page 4 of 5 Reply to Notice of Violation 50 286/97-80 03/EA 97 294 Example nurr.ber 3 NYPA agrees with this example.

Eacts Related to Examole EOP ES 1.3 contained the requirement for manual valve isolation of CCW flow to the Non-Regenerative Heat Exchanger (NRHX) prior to entering the post-LOCA recirculation phase in order to assure adequate CCW flow to safety related components at elevated rivar water temperatures. The requirement was added to address a vendor Ultimate Heat Sink analysis supporting a rise in the design basis river water temperature to 95'F. The vendor subsequently recommended manually isolating CCW flow to the NRHX by closing AC-TCV 130. The vendor recommendation was based on an incorrect understanding that the Ul^Jmate Heat Sink analysis credited closure of AC-TCV 130 as an appropriate action. This understanding was not correct since the source of air supplied to AC-TCV-130 is not safety-related, no credit could be taken for the availability, and AC-TCV-130 would fall to its open position following a loss of air.

The vendor recommendation was incorporated in Procedure EOP-ES-1.3, Revision 9. Step 60, directed the operator to isolate CCW flow to the non-regenerative heat exchanger by closing AC-TCV-130 if only one CCW pump was running. If AC-TCV-130 could not be closed, the procedure instructed the operators to isolate CCW to the non-regenerative heat exchanger

, by closing manualisolation valves in accordance with system operating procedure SOP EL-15.

Cause of Examole

1. Inattention to detail by vendor, the site, and WPO engineering organizations relative to the review of technicalinformation impacting the content of EOPs.

2. Acceptance of vendor recommendations without performing a rigorous technical review to independently validate the basis for the recommendation.

3. Ineffective process controls goveming the EOP revision process.

4. Failure to establish Engineering " partnership" with Operations for the technical content of EOPs.

l S. Inadequate training provided to Engineering regarding EOP methodology to enable effective review and oversight of the technical content of EOP procedures V

.  ; Docket No. 50-286 IPN-97-125 Attachment i Page 5 of 5 Reply to Notice of Violation 50-286/97-80-03/EA 97-294 Corrective Actions Taken and Results Achieved

1. Administrative Procedure AP-3, "lP3 Procedure Preparation. Review, and Approval" was revised on July 30,1997 to establish responsibility for Engineering review and concurrence of EOP revisions to assure technical content consistent with the J.lant's design basis.

~ 2. EOP ES-1.3 was revised on August 25,1997 to ensure the minimum closure limits based on river water temperature anct minimum flow requirements to support CCW during recirculation.

3. An extent of condition review was performed for EOPs to validate technical content prior to restart from RO9. There were a total of 520 comments reviewed resulting in twenty three Deviation Event Reports with only two identified as potentially. reportable. These are currently under review.

4. Revisions to the design control manual procedures were made on August 15,1997 to ensure that design basis issues are implemented into appropriate procedures.

5. A seview of the procedure revision process was performed and specific expectations were provided relative to the conduct of procedure review.

Correcilve Actions That Will Be Taken To Avoid Recetition

1. Training will be developed and only engineering personnel who are qualified to the training program will review EOPs after October 30,1997 as part of cross disciplinary review. The L qualification will be included as part of the engineering support personnel training program.

l 2. An effectiveness review of corrective actions will be perforraed by February 28,1998.

1 Date When Full Comoliance Will Be Achieved.

Compliance was achieved, as follows, when EOP ES 1.3 was revised to address each of the

[ examples:

l l Example 3. ES-1.3 Revision 11 effective on April 23,1997.

Example 2- ES-1.3 Revision 12 effective on May 1,1997.

i Example 1- ES-1.3 Revision 13 effective on August 25,1997.

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,., ,e-Docket No. 50-286 '

IPN 97-125 Attachment ll

, Page 1 of 1 List of Commitments .

.w Number Commitment Due IPN-97125 Training . vill be developed and only engineering personnel October 30,1997 who are qualified to the training program will review EOPs after October 30,1997 as part of cross disciplinary review.

The qualification will be included as part of the engineering support personnel training program IPN 97125-02 Conduct effectiveness review of corrective actions taken in February 28,1998 response to Notice of Violation 97-80-03.

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