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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217B3331999-10-0707 October 1999 Responds to 990825 Telephone Call Re Presense of Polychlorinated Biphenyl Wastes at Plant,Unit 1 ML20212F4481999-09-17017 September 1999 Forwards NRC Form 536 Containing Currently Proposed Site Specific Operator Licensing Exam Schedule & Estimates of Number of Applicants for Generic Fundamentals Exams Through Cy 2003 ML20212F7051999-09-14014 September 1999 Forwards Rev 19 to Ipn,Units 1 & 2 Physical Security Plan. Plan Withheld,Per 10CFR2.790(d) & 73.21 ML20211N0681999-09-0202 September 1999 Informs That Commission Requested Publication of Notice of Consideration of Issuance of Amend to Fol,Proposed NSHC Determination & Opportunity for Hearing. Amend Changes Senior Reactor License Requirement for Operations Manager ML20211H6291999-08-26026 August 1999 Forwards NPDES Discharge Monitoring Rept for July 1999 for Indian Point,Units 1,2 & 3. Rept of Noncompliance Is Attached for Noncompliance Which Occurred at Unit 3 ML20211E1531999-08-18018 August 1999 Forwards Semi Annual fitness-for-duty Program Performance Data for 990101-990630,IAW 10CFR26.71(d) ML20211H6051999-08-18018 August 1999 Forwards Rev 8 to Security Force Training & Qualification Plan, for Indian Point 3 Nuclear Power Plant.Rev Facilitates Transition of Duty Weapons Carried by Security Force Members from Revolvers to Semiautomatic Pistols ML20211A9241999-08-11011 August 1999 Informs That IPS Currently Estimates,That Approx Two Licensing Actions Will Be Submitted to NRC During Remainder of 1999 NRC Fiscal Yr & Approx Ten Will Be Submitted During 2000 NRC Fiscal Yr ML20210M7251999-07-26026 July 1999 Forwards Projection of Ability to Pay Retrospective Premium Adjustment for Period of Aug 1999 to 000731, Which Demonstrates That Ceny Will Have Sufficient Cash Flow &/Or Cash Reserve Available Throughout Period to Pay Premium ML20210G8911999-07-20020 July 1999 Forwards Application for Amend to License DPR-5 for Proposed New TS 3.2.1.i,revising Senior Reactor License Requirement for Operations Manager ML20209B6611999-06-29029 June 1999 Returns Recently Submitted Renewal Applications,Nrc Form 398,for Three Reactor Operators,As They Are Not Completed Properly.List of Docket Numbers & Block Numbers That Contain Incorrect Info & Block Numbers Not Completed.Without Encls ML20196A6371999-06-15015 June 1999 Forwards Rev 19 to Physical Security Plan.Rev Withheld,Per 10CFR2.790(d) & 73.21 ML20207D1861999-05-27027 May 1999 Informs That Effective 990328,NRC Office of NRR Underwent Reorganization.Mt Masnik Section Chief for Indian Point Station,Unit 1.JL Minns Remains Primary Contact for All Routine Licensing & Administrative Matters.Chart Encl ML20205R1981999-04-15015 April 1999 Requests That Dept of Environ Conservation Modify SPDES Permit for IPS IAW Proposed Rev Attached & Described as Listed ML20205R2961999-04-15015 April 1999 Forwards Copy of Proposed Change to Indian Point SPDES Permit NY0004472.Proposed Change Requests Permission to Add Permitted Outfall to Plant as Well as Change Character of Existing Outfall.Without Encl ML20196K8111999-03-31031 March 1999 Forwards Decommissioning Funding Status Rept for Indian Point,Units 1 & 2 Through 981231 ML20205F9711999-03-25025 March 1999 Informs That Under Separate Cover,Licensee Transmitted to Ofc of Nuclear Regulatory Research Annual Rept of Results of Individual Monitoring at Indian Point,Units 1 & 2,for CY98 ML20204F7931999-03-17017 March 1999 Forwards Table Outlining Nuclear Property Insurance Which Has Been Placed on Behalf of Consolidated Edison Co of Ny, Inc.Insurance Covers Indian Point,Units 1 & 2 ML20204J9971999-03-0909 March 1999 Forwards Insp Rept 50-003/98-19 on 981130-990222.No Violations Noted ML20203B9001999-02-0808 February 1999 First Partial Response to FOIA Request for Documents. Forwards Documents Listed in App a Already Available in PDR, Documents in App B Released in Entirety & Documents in App C Being Withheld in Part (Ref Exemption 6) ML20202J6171999-02-0505 February 1999 Forwards Transcript from 990120 Public Meeting Held in Peekskill,Ny Re Decommissioning ML20199H3731999-01-11011 January 1999 Informs That T Schmeiser,Con Ed Plant Manager for Plant Is Retiring,Effective 990111.AA Blind Will Assume Duties & Responsibilities of Plant Manager Until Replacement Named ML20198E9561998-12-21021 December 1998 Forwards Order Prohibiting Involvement in NRC Licensed Activities Re Deliberate Misconduct in Violation of Regulation When False Info Was Provided to Two NRC Licensees ML20198C2371998-12-15015 December 1998 Ltr Contract:Task Order 237, Review & Evaluation of Indian Point 3 Nuclear Power Plant Application for Conversion to Improved TS, Under Contract NRC-03-95-026 ML20198C4911998-12-11011 December 1998 Forwards Rev 18 to Physical Security Plan,Reflecting Organizational Changes & Incorporating Administrative Corrections & Clarifications.Encl Withheld ML20198C3251998-12-11011 December 1998 Responds to ,Responding to NRC Ltr Re Concerns Raised About Potential Chilling Effect from Temp Denial of Site Access to Employee Raising Safety Issues to Util Senior Mgt ML20155H2901998-11-0303 November 1998 Responds to to Lj Callan Expressing Concern About Continued Operation of Indian Point Nuclear Generating Station.Explanation Why NRC Do Not Think Revoking OLs for Indian Point Units 2 & 3 Justified,Provided ML20155F9181998-10-28028 October 1998 Forwards Changes to SPDES Permit,Removing Requirement to Monitor Svc Boiler Blowdown for Phosphates,Eliminate Redundant Sampling of Oil or Grease Entering Flow Tributary to Floor Drains,Per Ts,App B,Section 3.2 ML20155D2791998-10-23023 October 1998 Forwards Corrected Pages for Indian Point Annual Radiological Environ Operating Rept for 1997 ML20154Q1761998-10-21021 October 1998 Second Final Response to FOIA Request for Documents. Documents Listed in App C Being Withheld in Part (Ref FOIA Exemption 7) ML20154L8031998-10-16016 October 1998 Ack Receipt of & Payment in Amount of $55,000 in Electronic Funds for Civil Penalty Proposed by NRC in .Corrective Actions Will Be Examined During Future Insp ML20155H3021998-09-24024 September 1998 Urges NRC to Revoke Operating Licenses for Indian Point Nuclear Generating Station,Units 2 & 3 & Not Renew OL for Unit 1 ML20154A1391998-09-22022 September 1998 Informs That Effective 980724,AA Blind Assumed Position of Vice President,Nuclear Power & Ja Baumstark Assumed Position of Vice President,Nuclear Power Engineering,Effective 980813 ML20153F0661998-09-18018 September 1998 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 ML20151W4871998-09-10010 September 1998 Informs That as Part of NRC Probabilistic Risk Assessment Implementation Plan,Commission Assigned Two Senior Reactor Analysts (Sras) to Each Regional Ofc.T Shedlosky & J Trapp Has Been Assigned as SRAs for Region I ML20151W9511998-09-10010 September 1998 Informs That as Part of NRC PRA Implementation Plan, Commission Has Assigned Two Senior Reactor Analysts (Sras) to Regional Ofc.T Shedlosky & J Trapp Has Been Assigned SRAs Duties for Region I ML20155F4391998-08-26026 August 1998 Forwards Demand for Info,Being Issued to Enable NRC to Fully Understand Recipient Views on Facts & Circumstances Surrounding Allegedly False Info Provided to Two NRC-licensed Activities ML20238F5151998-08-26026 August 1998 First Partial Response to FOIA Request for Documents. Documents Listed in App a Being Released in Entirety. Documents Listed in App B Being Withheld in Part (Ref FOIA Exemption 6) IR 05000286/19980051998-08-19019 August 1998 Discusses Insp Rept 50-286/98-05 on 980528-0612 & Forwards NOV & Proposed Imposition of Civil Penalty in Amount of $55,000.Most Significant Violation Involved Failure, Following Design Mod in Oct 1997 ML20237B1001998-08-0505 August 1998 Responds to NRC Re Violations Noted in Insp Repts 50-247/97-13,50-247/97-15,50-247/98-02 & Investigation Rept 1-97-038,respectively.Corrective Actions:Acted Promptly to Assure Conforming to Testing Requirements ML20236X8511998-07-31031 July 1998 Forwards Rept Re Projection of Ability to Pay Retrospective Premium Adjustment for Period 980801-990731,per 10CFR140.21 ML20236V4211998-07-13013 July 1998 Forwards SER Approving Topical Repts WCAP-14333P & WCAP-14334NP (Proprietary & non-propiretary, PRA of RPS & ESFAS Test Times & Completion Times ML20236Q1431998-07-0808 July 1998 Responds to Administrative Ltr 98-03 Re Operating Reactor Licensing Action Estimates IR 05000247/19970131998-07-0606 July 1998 Discusses Insp Repts 50-247/97-13,50-247/97-15 & 50-247/98-02 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $110,000 ML20238F5231998-06-29029 June 1998 FOIA Request for Documents Re NRC Office of Investigation Rept 1-97-038,meeting Minutes of Summary of Enforcement Conference on 980506 & Meeting Minutes or Summary of 980520 Predecisional Enforcement Conference ML20154Q1831998-06-29029 June 1998 FOIA Request for Documents Re NRC OI Rept 1-97-038,meeting Minutes of Summary of Enforcement Conference on 980506 & Meeting Minutes or Summary of 980520 Predecisional Enforcement Conference ML20236J9871998-06-24024 June 1998 First Final Response to FOIA Request for Documents.Documents Listed in App a Already Available in Pdr.Documents Listed in App B Being Released in Entirety ML20248F2891998-05-26026 May 1998 Ltr Contract:Task Order 8, Indian Point 2,A/E Follow-up Insp, Under Contract NRC-03-98-021 ML20248L9861998-05-21021 May 1998 Forwards Rev 7 to Security Force Training & Qualification Plan.Review to Verify Receipt of Revised Plan & Sign & Return Receipt Ack Form Provided ML20247M6951998-05-20020 May 1998 Forwards RAI Re GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design-Basis Accident Conditions, for Plant,Unit 2 1999-09-02
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20212F4481999-09-17017 September 1999 Forwards NRC Form 536 Containing Currently Proposed Site Specific Operator Licensing Exam Schedule & Estimates of Number of Applicants for Generic Fundamentals Exams Through Cy 2003 ML20212F7051999-09-14014 September 1999 Forwards Rev 19 to Ipn,Units 1 & 2 Physical Security Plan. Plan Withheld,Per 10CFR2.790(d) & 73.21 ML20211H6051999-08-18018 August 1999 Forwards Rev 8 to Security Force Training & Qualification Plan, for Indian Point 3 Nuclear Power Plant.Rev Facilitates Transition of Duty Weapons Carried by Security Force Members from Revolvers to Semiautomatic Pistols ML20211E1531999-08-18018 August 1999 Forwards Semi Annual fitness-for-duty Program Performance Data for 990101-990630,IAW 10CFR26.71(d) ML20211A9241999-08-11011 August 1999 Informs That IPS Currently Estimates,That Approx Two Licensing Actions Will Be Submitted to NRC During Remainder of 1999 NRC Fiscal Yr & Approx Ten Will Be Submitted During 2000 NRC Fiscal Yr ML20210M7251999-07-26026 July 1999 Forwards Projection of Ability to Pay Retrospective Premium Adjustment for Period of Aug 1999 to 000731, Which Demonstrates That Ceny Will Have Sufficient Cash Flow &/Or Cash Reserve Available Throughout Period to Pay Premium ML20210G8911999-07-20020 July 1999 Forwards Application for Amend to License DPR-5 for Proposed New TS 3.2.1.i,revising Senior Reactor License Requirement for Operations Manager ML20196A6371999-06-15015 June 1999 Forwards Rev 19 to Physical Security Plan.Rev Withheld,Per 10CFR2.790(d) & 73.21 ML20205R2961999-04-15015 April 1999 Forwards Copy of Proposed Change to Indian Point SPDES Permit NY0004472.Proposed Change Requests Permission to Add Permitted Outfall to Plant as Well as Change Character of Existing Outfall.Without Encl ML20196K8111999-03-31031 March 1999 Forwards Decommissioning Funding Status Rept for Indian Point,Units 1 & 2 Through 981231 ML20205F9711999-03-25025 March 1999 Informs That Under Separate Cover,Licensee Transmitted to Ofc of Nuclear Regulatory Research Annual Rept of Results of Individual Monitoring at Indian Point,Units 1 & 2,for CY98 ML20204F7931999-03-17017 March 1999 Forwards Table Outlining Nuclear Property Insurance Which Has Been Placed on Behalf of Consolidated Edison Co of Ny, Inc.Insurance Covers Indian Point,Units 1 & 2 ML20199H3731999-01-11011 January 1999 Informs That T Schmeiser,Con Ed Plant Manager for Plant Is Retiring,Effective 990111.AA Blind Will Assume Duties & Responsibilities of Plant Manager Until Replacement Named ML20198C4911998-12-11011 December 1998 Forwards Rev 18 to Physical Security Plan,Reflecting Organizational Changes & Incorporating Administrative Corrections & Clarifications.Encl Withheld ML20155F9181998-10-28028 October 1998 Forwards Changes to SPDES Permit,Removing Requirement to Monitor Svc Boiler Blowdown for Phosphates,Eliminate Redundant Sampling of Oil or Grease Entering Flow Tributary to Floor Drains,Per Ts,App B,Section 3.2 ML20155D2791998-10-23023 October 1998 Forwards Corrected Pages for Indian Point Annual Radiological Environ Operating Rept for 1997 ML20155H3021998-09-24024 September 1998 Urges NRC to Revoke Operating Licenses for Indian Point Nuclear Generating Station,Units 2 & 3 & Not Renew OL for Unit 1 ML20154A1391998-09-22022 September 1998 Informs That Effective 980724,AA Blind Assumed Position of Vice President,Nuclear Power & Ja Baumstark Assumed Position of Vice President,Nuclear Power Engineering,Effective 980813 ML20153F0661998-09-18018 September 1998 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 ML20237B1001998-08-0505 August 1998 Responds to NRC Re Violations Noted in Insp Repts 50-247/97-13,50-247/97-15,50-247/98-02 & Investigation Rept 1-97-038,respectively.Corrective Actions:Acted Promptly to Assure Conforming to Testing Requirements ML20236X8511998-07-31031 July 1998 Forwards Rept Re Projection of Ability to Pay Retrospective Premium Adjustment for Period 980801-990731,per 10CFR140.21 ML20236Q1431998-07-0808 July 1998 Responds to Administrative Ltr 98-03 Re Operating Reactor Licensing Action Estimates ML20238F5231998-06-29029 June 1998 FOIA Request for Documents Re NRC Office of Investigation Rept 1-97-038,meeting Minutes of Summary of Enforcement Conference on 980506 & Meeting Minutes or Summary of 980520 Predecisional Enforcement Conference ML20154Q1831998-06-29029 June 1998 FOIA Request for Documents Re NRC OI Rept 1-97-038,meeting Minutes of Summary of Enforcement Conference on 980506 & Meeting Minutes or Summary of 980520 Predecisional Enforcement Conference ML20248L9861998-05-21021 May 1998 Forwards Rev 7 to Security Force Training & Qualification Plan.Review to Verify Receipt of Revised Plan & Sign & Return Receipt Ack Form Provided ML20217F8501998-03-20020 March 1998 Forwards Table Which Outlines Nuclear Property Insurance That Has Been Placed on Behalf of Util,Per 10CFR50.54(w)(3) ML20199L9531998-01-26026 January 1998 Forwards Addl Info on Rev 6 to Security Force Training & Qualification Plan,Per 980113 Telcon Request of G Smith.Encl Withheld ML20199F7541998-01-21021 January 1998 Forwards Rev 17 to Physical Security Plan,Per Requirements of 10CFR50.54(p).Rev 17 Contains Summary of Changes, Detailing Changes Incorporated.Encl Withheld ML20198N1151998-01-20020 January 1998 Submits Status of Response to NRC Request for Addl Info, for Licenses TR-3 & R-93.Request for Commitment to Complete Decommissioning Activities by 2007 Has Been Persued Up Through Nasa Mgt ML20202F8281997-11-26026 November 1997 Reports Mod to Indian Point SPDES Permit as Required in Ts. Copy of New York State Dept of Environ Conservation Ltr That Modifies Permit Is Encl ML20198P7901997-10-31031 October 1997 Forwards Rev 6 to Physical Security Plan,Per 10CFR50.4(b)(4) to Meet Requirements of 10CFR50.54(p).Rev 16 Contains Summary of Changes, Detailing Changes Incorporated. Encl Withheld ML20198P3181997-10-30030 October 1997 Forwards Corrected Pages to Annual Radiological Environ Operating Rept for 1996 ML20211H7771997-10-0202 October 1997 Forwards Responses to RAIs 650.1 Through 650.8 Re Generic Issues & Generic Communications on Valve Testing & Valve Qualification.Westinghouse Status for Subject Issues Will Be Confirm W Pending Rev to Ssar & WCAP-13559 ML20211B4241997-09-19019 September 1997 Requests Withdrawal of Revs 16 & 18 to Physical Security Plan.Rev 16 re-submitted Per Provisions of 10CFR50.54(p)(2) & Deals W/Specific Operational Criteria of New Sys.Plan Withheld ML20211A9411997-09-18018 September 1997 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 ML20149J2491997-07-16016 July 1997 Forwards Environ Ts/Nonroutine Event Rept for Units 1 & 2. Appropriate Ny State Agency Notified ML20148S5731997-06-26026 June 1997 Forwards Response to NRC Re Violations Noted in Insp Repts 50-247/96-80;96-07;96-08;97-03 & Imposition of Civil Penalties on 961027-970405.Corrective Actions:Unique Tag Numbers for Louvers Were Generated ML20148J1431997-06-0404 June 1997 Forwards Rev 15A to Ipn Units 1 & 2 Physical Security Plan, Per 10CFR50.54(p)(2).Plan Withheld ML20137M8371997-04-0101 April 1997 Provides Supplemental Response to RAI Re TS Change Request 96-01 on Conversion to Framatome Cogema Fuel.Tech Specs, Encl ML20137A8301997-03-13013 March 1997 Forwards Response to NRC Ltr Re Violations Noted in Insp Rept 50-286/96-80 on 961213.Corrective Actions:Expert Panel Has Agreed to Include Turbine Bldg & Power Conversion Equipment Bldg in Scope of IP3 Maint Rule Program JPN-97-008, Forwards Comments on Draft NUREG-1560, IPE Program: Persprctives on Reactor Safety & Plant Performance1997-03-0404 March 1997 Forwards Comments on Draft NUREG-1560, IPE Program: Persprctives on Reactor Safety & Plant Performance ML1004713451997-02-26026 February 1997 Forwards Proprietary & non-proprietary Versions of W Rept Entitled, Conditional Extension of Rod Misalignment TS for Indian Point 3. Authorization Ltr & Affidavit,Encl. Proprietary Encl Withheld Per 10CFR2.790 ML20135C7121997-02-21021 February 1997 Forwards Table That Outlines Nuclear Property Insurance on Behalf of Util Covering Units 1 & 2 ML1004713471997-02-18018 February 1997 Authorizes Utilization of Encl Affidavit by Util Re WCAP-14669,Rev 1, Conditional Extension of Rod Misalignment TS for Indian Point 3. Rept Should Be Withheld Per 10CFR2.790(b)(4) ML20134N6481996-12-24024 December 1996 Provides Further Details Re Corporate Reorganization of Consolidated Edison Co of Ny for Indian Point Units 1 & 2 ML20132C8071996-12-12012 December 1996 Forwards Check for $100 for Payment of NRC Invoice 7I0053 for Indemnity Fee on License DPR-5 for One Year Period 961204-971203.W/o Check ML20129D9611996-10-11011 October 1996 Forwards Controlled Copy of Plant Physical Security Plan,Rev 18,re Access Control Upgrade Which Adopts Biometric Hand Geometry.W/O Encl ML20117P6151996-09-11011 September 1996 Forwards Rev 9 to Security Training & Qualification Plan.W/O Encl ML20117E3891996-08-21021 August 1996 Forwards Four Copies of IP3 Security Contingency Plan,Rev 4. W/O Encl JPN-96-035, Informs NRC That Boraflex Not Used as Neutron Absorber in Either Util or Plant Spent Fuel Pool Storage Racks,Per GL 96-041996-08-0606 August 1996 Informs NRC That Boraflex Not Used as Neutron Absorber in Either Util or Plant Spent Fuel Pool Storage Racks,Per GL 96-04 1999-09-17
[Table view] |
Text
.
4 Indkm Point 3
'Ims O tk n 2 b Burhnan, New Yuk 10011 r 914 736 0001
- > NewYorkPower "*i'AP"E-tv Authority i
September 18,1997 lPN-97-125 l
i
- 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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.- rz Docket No. 50-286
.- 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' .
- ~
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.
I i
1
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.
.. .s .
i
. 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.
. - . . - - - . . ~. . . .
2*
,y i
- 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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