ML20237B100
| ML20237B100 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 08/05/1998 |
| From: | Blind A CONSOLIDATED EDISON CO. OF NEW YORK, INC. |
| To: | Satorius M NRC OFFICE OF ENFORCEMENT (OE) |
| References | |
| 50-247-97-13, 50-247-97-15, 50-247-98-02, 50-247-98-2, NUDOCS 9808180045 | |
| Download: ML20237B100 (11) | |
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. A. Alan Bilnd g , it:s Prudent
, onr. tated dison Cornpany of New York, Inc Broadway & Bleakley Avenue Beanan, NY 10511 Telephone (914) 734-$340 5
$a$'dcMs August 5,1998 Re: Indian Point Unit No. 2 Docket No. 50-247 Mark Satorius Deputy Director Office of Enforcement U.S. Nuclear Regulatory Commission One White Flint North, 11555 Rockville Pike Rockville, MD 20852-2738
SUBJECT:
Reply to Notice of Violation and imposition of Civil Penalties - $110,000 (NRC Inspection Reports 50-247/97-13; 97-15; and 98-02 and Investigation Report No. 1-97 038)
The attachment to this letter constitutes Con Edispn'$ reply to the Notice of Violations (NOV) and imposition of Civil Penalties included with)our July 6,1998 letter to Mr. Paul Kinkel co u.arning the three NRC inspections conducted between October 27,1997 and March 23, 1998 at Indian Point Unit No. 2. The undersigned has in the interim assumed duties as Vice President Nuclear Power. An electronic funds transfer in the amount of one hundred ten thousand dollars ($110,000)in payment of the proposed penalty has been made to the NRC account as of July 14,1998.
Should you have any questions regarding this matter, please contact either the undersigned or Mr. Charles W. Jackson, Manager, Nuclear Safety and Licensing.
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A. Alan Blind Vice President l I
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t l N L L ANCASTER j Notary Puolic, Sta*e c' New Yrrk l No 60-4043C59 '
Oualifmd in Wett County Term Expires q j 9908190045 990905 PDR ADOCK 05000247 G PDR
cc: Document Control Desk
, US Nuclear Regulatory Commission Mail Station P1-137 Washington, D.C. 20555 Mr. Hubert J. Miller Regional Administrator Region i US Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. Jefferey F. Harold, Project Manager Project Directorate I-1 Division of Reactor Projects 1/ll US Nuclear Regulatory Commission Mail Stop 14B-2 Washington, D.C. 20555 Senior Resident inspector US Nuclear Regulatory Commission PO Box 38 Buchanan, NY 10511 1
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.1 ATTACHMENT i
REPLY TO NOTICE OF VIOLATION INSPECTION REPORT fiOs. 50-247/97-13; 3
97-15; AND 98-02 AND INVESTIGATION REPORT NO.1-97-038 J
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!~ CONSOLID ATED ED1 SON COMPANY OF NEW YORK, INC.
INDIAN POINT UNIT NO. 2 DOCKET NO. 50-247 j AUGUST 1998
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NOTICES OF VIOLATION The Notices of Violation enclosed in Inspection Reports 97-13; 97-15; and 98-02 and Investigation Report No.1-97-038 contained five Notices of Violations listed as I through IV A and B stated as follows:
- 1. YlOLATIONS RELATED TO INACCURATE INFORMA_ TION 10 CFR 50.9 requires, in part, that information required by the Commission's regulations to be maintained by the licensee shall be complete and accurate in all material respects.
Technical Specification Section 6.8.1 requires written procedures be implemented covering activities referenced in Regulatory (Safety) Guide 1.33, November 1972.
Appendix A of Regulatory Guide 1.33, recommends, in part, written procedures for performance of surveillance tests and for record retention.
Station Administrative Order (SAO)-521, " Records Management Program," provides instructions for the identification and storage of completed records. Section 4.1 of SAO-521, requires, in part, that quality assurance records be maintained in accordance with ANSI N45.2.9-1994,
- Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants." Appendix A, Section A.6.1 of this document, specifies retention of records dealing with periodic checks, inspections, and calibrations performed to verify surveillance requirements are being met.
A. Consolidated Edison surveillance test PT-M498," Appendix R Emergency Lighting (Nuclear)," provides instructions for monthly checks of the emergency battery lighting required by the NRC-approved fire protection program required by License Condition 2.K. PT-M49B provides instructions for inspections of 33 emergency battery lights in the ' primary auxiliary building (PAB) and requires signatures for completion / performance of all procedure steps.
Contrary to the above, on August 6,1997, the emergency battery lights in the PAB were not tested in accordance with PT-M498, yet records were created that indicated that the fights had been tested. Specifically, a Nuclear Production Technician (NPT) signed that he had completed all of the checks required by PT-M49B. l ,owever, on August 8,1997, the NPT was only in the PAB for a period of 15 minute? and the other NPT assigned to assist with the checks was only in the PAB for a period of 17 minutes; it is not possible to complete all the checks of the 33 ernergency battery lights in a period of 32 minutes. These records were material because they indicate whether certain required safety activities had been completed.
(01013)
B. Consolidated Edison surveillance test PT.W1, " Emergency Diesel Generator,"
establishes a weekly surveillanen test of the emergency diesel generator auxiliaries.
1_ Steps 3.4.1 and 3.5.2 of PT-W1 require double verification that the steps have oeen performed and require that the double verhication be documented.
Contrary to the above, on August 8,1997, the double verifications of steps 3.4.1 and 3.5.2 of PT W1, which involved checkb of the diesel generator compressor, were not i performed, yet records were created that indicated that the second verifications had been performed. An NPT signed the data sheet indicating that he had performed i
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l the second verification of the steps; however, the NPT did not enter the emergency
. diesel generator building on August 8,1997. Therefore, he could not have performed the second verifications. These records were material because they indicate certain required safety activities had been completed when in fact they had not been completed. (01023)
These violations represent a Severity Level 111 problem. (Supplement Vil).
Civil Penalty - $55,000.
l Response to Violation I f
We acknowledge the circumstances addressed in this violation and agree that on the date ;
indicated in the violation, the tests specified and the required actions did not occur. Based on observations by an NRC resident inspector of low water level on three emergency lights ;
in the Primary Auxiliary t uilding, which had recently been surveillance tested, the Manager j of Test and Performance initiated an investigation to determine the cause of the deficiency. !
The Consolidated Edison Performance Test and Quality Assurance organizations independently conducted investigations of the failure by a performance test technician to i perform and properly document surveillance tests. In both investigations, Consolidated Edison self -identified the failure to properly conduct and document the surveillance tests, and thereafter acted promptly to assure conformance to testing requirements, j i
Thorough investigations were conducted to determine the extent of the failure to fully i perform and document the surveillance tests. The investigations consisted of a thorough review of Emergency Lighting tests and other surveillance tests that could be subject to improper completion. These investigations did not reveal any similar occurrences. During these investigations, and as part of the line organizations' continuing review of testing performance, a test supervisor identified an occurrence of an improperly documented Emergency Diesel Generator weekly inspection, PT-W1. The Nuclear Production technician who signed for these tests was suspended and later terminated from his position with Consolidated Edison. A second Nuclear production technician who was involved in the Emergency Light testing event was suspended for a month and is no longer qualified to conduct Technical Specification surveillance testing.
In addition to the initial investigations, the Quality Assurance organization was directed to conduct an audit of the entire surveillance test program. This audit reviewed a significant I sampling of surveillance tests from groupings that were establ!shed based on the ability to track the technicians' movements via plant condition changes, alarms and security monitoring. In the less intrusive tests, extensive effort was put into identifying corroborating
. information, including technician putterns. This extensive audit revealed no additional occurrences of improperly documented surveillance testing.
In this instance the ability of the performance technicians to deviate from accepted testing requirem*nts was facilitated by the absence of test supervisors in the field during the performance of the tests. As a result, proper oversight of the conduct of these tests was not maintained. In addition, the investigations revealed an insufficient understanding of the standards and expectations for the conduct of testing within the test and performance l organization.
l The events and their investigations did yield additional information that will continue to benefit the performance of the surveillance test program. First and foremost, the importance of the first line supervisor's presence in the field, closer oversight of test activities, and clear setting of standards and expectations was reinforced. The first line supervisor received a L_____________..____
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dir .:iplinary letter in his personnel file in addition, he was provided additior,al counseling
' renarding his responsibilities and training in the area of the supervisoy role in error reduction.
A, of the Nuclear Production technicians in the test group were personally counseled as to
- t. e importance of their surveillance activities and the significance of their signing for an
- ctivity. The technicians attended a training program which focused on the basis for surveillance testing and the importance of procedural compliance. In addition, a Standards and Expectations policy document was issued on July 7,1998 in response to the findings of the Independent Safety Assessment. This policy document, sets forth the operating philosophy and professional standards and expectations including being accountable for ones actions for all Indian Point personnel. This pc! icy will be aggressively monitored and continuously reinforced.
II. VIOLATION RELATED TO DB50 BREAKERS 10 CFR Part 50 Appendix B, Criterion XVI, " Corrective Action," requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, deficiencies, and deviations, defective material and equipment are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition. ,
Contrary to the above, between August 1993 and October 14,1997, the licensee failed to determine the cause and take corrective action to preclude repetition of a significant condition adverse to quality involving failures of safety-related electrical breakers. ;
Specifically, a root cause analysis performed in June 1997 to address multiple recurring failures of Westinghouse DB-50 breakers (that occurred between August 1993 and May i 1997) was inadequate in that the analysis did not address all credible failure modes that could have prevented the breakers from closing. For example, the analysis did not address inadequate weight on the trip bar as a credible failure mode, in addition, the identified causes (malfunctioning amptectors and binding of the operating mechanisms due to accumulated dust, dirt, and lubricant) were not supported by the facts (e.g., there was little evidence of dust and hardened lubricant), and it was later determined that these factors weie not significant contributors to the fails s. As a result, corrective actions taken in July 1997 failed to preclude repetition of failures of DB-50 circuit breakers on August 13 and October 14, 1997. The failure of these breakers is I considered a significant condition adverse to quality because it could prevent safety'-
related equipment from starting during an accident. (02013) l This violation is classified at Severity Level lli (Supplement 1).
Civil Penalty - $55,000.
Response to Violation 11 We acknowledge the concems rddressed in this violation and agree that the root cause
- analysis effort performed prior to October 1997 did not fully identify all of the original design deficiencies affecting
- westinghouse type D8-50 electrical breaker operation.
However, our original analysis was based on historical equipment problems experienced by Con Edison and the industry with these breakers. The Con Edison and industry experience did not suggest any consistent deficiency implicating the original breaker design, and as e result recommended eterhaul as the means for resolving varied operating problems. Subsequent reviews indicate that the original design deficiencies were not identified as a result of the following:
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'The root cause analysis effort completed in June 1997 focused on restoring the DB-50 breakers to thek original design basis condition. This was to be accomplished by pe forming systematic overhauls in accordance with the original equipment manufacturer (OEM) recommendations and industry practice. Three breakers had been overhauled when the Safety injection System (SIS) pump breaker failed to close in October 1997.
In March 1998, Con Edison and an outside independent firm supplemented by a member of the station staff completed an assessment of our earlier root cause effort. !
The key findings of the assessment were that the inadequacies in the June 1997 I analysis had been due to insufficient training of team members and the team leader in enhanced root cause analysis techniques. The enhanced root cause analysis training i had been initiated early in 1997 and approximately 30 personnel had attended by June !
1997 when this investigdion commenced. Although root cause analysis techniques had been utilized in June 1997, there was an over-reliance on the industry experts participating in the investigation. As a result, the work plan had uncritically accepted an !
emphasis on industry best practices which recommended overhauls to bring the breakers back to their original design condition and did not implicate original breaker ;
design as a potential root cause.
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An extensive root cause investigation of the cause of the breaker failures was conducted in October 1997 and the effort was discussed in detail with the Region I staff in November 1997. In addition, a root cause analysis was completed in March 1998, to determine the cause of the fciture of the root cause analysis associated with the failures ];
through June 1997. Corrective actions from the October 1997 analysis han been !
Implemented for all of the DB 50 breakers.
To prevent a recurrence of events of this type, the lessons learned from this experience have been incorporated in the standards for performing equipment root cause analysis for engineering personnel. To date the enhanced root cause training has been provided to over 90 personnel in our enhanced root cause process to provide a core of qualified j root cause team members. The Analysis of Station Events and Conditions procedure, SAO 132, has been changed to requhe that when a root cause team is formed, at least one member will be selected from the listing of personnel trained in the enhanced root cause methodology. In addition, the other recommendations from the root cause self- 4 assessment have been implemented into SAO-132. The SAO-132 changes are intended to direct root cause analysis towards technical processes which do not over rely on any one source or system expert for corrective actions. I Ill. VIOLATION RELATED TO TECHNICAL SPECIFICATION SURVEILLANCE I
TESTING 10 CFR Part 50, Appendix B, Criterion XI, " Test Control," requires, in part, that a test program be established to assure that all testing required to demonstrate that systems and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents.
Contrary to the above, prior to January 1998, the Technical Specification (TS) surveillance test program did not assure that all testing required to demonstrate that systems and components will perform satisfactorily in service as specified in the plant ,
technical specifications was incorporated into test procedures. Examples of l i
deficiencies in the surveillance test program included:
- 1) No surveillance test existed to assure that the requirements of TS 4.4.D.2.b, 9 governing service water in-leakage into containment in the ovent of a loss of fan i cooler unit integrity, were met;
- 2) No surveillance test existed to verify that the steam generator blowdown valves isolate during an automatic initiation of auxiliary feedwater as required by TS Table 4.1-1, Item 30;
- 3) No procedural requirements existed to calibrate the service water inlet temperature monitoring system prior to service water temperature exceeding 80 degrees F, as required by TS Table 4.1-1, Item 45; and
- 4) Surveillance procedure PT-V16 only required a differential pressure of greater than 100 psid while performing leak tosting across certain reactor coolcnt system pressure isolation valves, although TS 4.16.A.5, requires that a minimum differential pressure of 150 psid across the valves being tested. (03013)
This violation is classified at Severity Level lli (Supplement 1).
Response to Violation lil We acknowledge the concerns addressed in this violation and agree that the listed Technical Specification requirements were not being fully met. All deficiencies have been corrected and associated testing has been completed.
In 1997, a number of instances were identified by Consolidated Edison that were related to the adequacy of the Indian Point Unit No. 2 Surveillance Test program. As a result, an extensive assessment of the program's compliance with the Technical Specifications was initiated. The review focused on the breadth of the Technical Specifications surveillance requirements and an assurance that implementing documents existed to address those requirements. The review resulted in the identification of 170 items which ranged from typographical errors in procedures to non-compliance with Technical Specification requirements. Of the 170 items,41 were identified to be significant.
Significance was defined as Technical Specification non-compliances, Technical Specification editorial errors, inaccuracies with some aspects of test procedures which made them not fully consistent with Technical Specifications (althou;6 s 'e Technical Specification requirements were met), and lack of procedures or programs to meet requirements (although requirements were met). A supplement to Licensee Event Report ( LER) No. 98-01 will address the results in detail.
The review is complete and the identified items have been resolved. A root cause analysis of the surveillance test program inconsistencies referenced in this violation was conducted and a number of root causes were identified. The root causes included weaknesses in the quality of the pertinent Technical Specifications, informality of
( program implementation, insufficient internal processes for the review of procedures and modifications, some deficiencies in the surveillance test procedure quality, and insufficient basis for surveillance test program content.
l To preclude future recurrence, a number of corrective actions have been completed. A
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Station Administrative Order has been developed and issued which formally identifies
- and meintains current provisions for the maintenance of the Technical Specification Surveillance test program contents. An amendment to the current Technical Specifications was submitted to address editorial errors, and a renewed commitment to the conversion to improved Technical Specifications is in place.
IV VIOLATIONS RELATED TO CONTAINMENT ATMOSPHERE CONTROL A. 10 CFR Part 50 Appendix B, Criterion XVI, in part, requires that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment are promptly identified and corrected.
- 1. Contrary to the above, as of December 31,1997, measures were not established to assure that conditions adverse to quality identified in work orders on the Post Accident Containment Venting System (PACVS) were promptly corrected. Specifically, on October 19,1993, work order 93-67432 identified that a flow meter (FM-1249) indicated incorrectly, and on February 1,1995, work order 95-75719 identified that flow integrator (FZ-1249) was not responding to input signals. This equipment is needed to permit the proper operation of the system as directed in its associated system operating procedure (SOP). However, these deficiencies were not corrected as of December 31,1997. (04014)
This violation is classified at Severity Level IV. (Supplement 1)
- 2. Contrar/ to the above, as of December 31,1997, measures were not established to assure that conditions adverse to quality identified in work orders on the hydrogen recombiners were evaluated and either promptly correcteo or adequately compensated for until corrective actions could be effected. Specifically, a) On October 22,1994, work order 94-74545 identified that repair / replacement of the 21 hydrogen recombiner RC-1 A ratio control was needed, b) On October 23,1996, work order 96-86886 identified that the 22 hydrogen recombiner hydrogen pressure gauge (PI)-5B was pegged high.
c) On April 8,1997, work order b7-90343 identified that the 22 hydrogen recombiner low pressure alarm was not working as a result of its associated pressure switch being broken.
These deficiencies could have impacted the operability of sa cty-related equipment required to be operable in accordance with Technical Specifications However, these deficiencies were not corrected as of December 31,1997. (06014)
This violation is classified at Severity Level IV (Supplement !).
l Response to Violation IV.A We acknowledge the concems addressed in this violation and ., gree that our actions to l
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repair or modify the equipment identified in IV.A.1 and 2 were not sufficiently prompt and
'that fully adequate compensatory action was not taken The deficiency with the flow meter (FM-1249) was identified on October 19,1993 and a deficiency with its flow integrator (FZ 1249) was identified on February 1,1995. Con Edison acknowledges that the review of these deficiencies did not fully evaluate the impact on the operation of the !
Post Accident Containment (PAC) Vent system or on the procedures used in the system l operation. However, our evaluations have concluded that the system could have been j operated if called upon. l On October 22,1994, a deficiency with the 21 hydrogen recombiner RC-1 A ratio control was identified. On October 23,1996, a deficiency report identified that the 22 hydrogen recombiner hydrogen pressure gauge (PI)-5B was off scale high. On April 8,1997, the pressue switch associated with 22 hydrogen recombiner low pressure alarm was noted as not working.
The PAC Vent and Hydrogen Recombiner deficiencies were identified by our staff and entered into the station corrective action system. The review of these items focused primarily on system operability and not on the impact of operation nor on the procedures used to operate the system. The PAC Vent flow meter and flow integrator have been upgraded with the installation of a modification. The Hydrogen Recombiner ratio control and the low pressure alarm pressure switch were repaired and the pressure gauge was re-calibrated.
To prevent recurrence of these and similar events, the Station Work Order procedure SAO-204 has been revised to require a review of identified deficiencies for needed compensatory actions by the Watch Engineer at least once-per-shift. The System Engineering Standard SE-304 has been revised to include, periodic system health reviews, a review by system engineers of open deficiencies for their impact on operating procedures.
B. TS 6.8.1 requires that written procedures be established covering activities referenced in Regulatory (Safety) Guide 1.33, November 1972. Appendix A of Regulatory (Safety) Guide 1.33 recommends written procedures that govem operation of safety-related systems including containment cleanup systems. An example of a procedure to operate a containment cleanup system is System Operating Procedure (SOP) 10.9.2, " Post Accident Vent System Operation."
Contrary to the above, until corrected by revision on October 20,1997, SOP 10.9.2 was inadequate because it did not reflect the proper containment pressure for system operation. The technical specification basis for the post-accident containment vent system (PACVS) states that a minimum internal containment pressure of 2.14 psig is required for the system to operate properly. The Updated Final Safety Analysis Report, section 6.8.2.2, states that the PACVS requires a differential pressure between the containment and the outside etmosphere in order to permit venting and that this is based on a pressure of 2.14 psig in the containment. However, step 2.6 of SOP 10.9.2 stated that the minimum l containment pressure for proper operation of the PACVS was 0.5 psig. Also, i steps 4.1.9,4.2.1, and 4.2.2, referenced the incorrect pressure value of 0.5 psig.
j (06014)
This violation is classified Severity Level IV (Supplement 1).
,Hesponse to Violation IV.B The Post Accident Vent System Operation procedure SOP 10.9.2 designated a minimum containment pressure of 0.5 psig, which was contrary to the Technical Specification and ,
UFSAR requirement of 2.14 psig. The original procedure used 0.5 psig as a constant ecting system resistance. The 0.5 psig total pressure calculation remained in effect in
' # 10.9.2 through revision 3 which was initiated in 1982. The total pressure of I
containment necessary for venting was calculated based on assuring that the total i pressure would be greater than F 5 esig.
SOP 10.9.2 was updated in 1984 to replace the total pressure calculation with a precaution which changed the meaning of 0.5 psig to the minimum required for system operation rather than a calculation reflecting system resistance. This inadequacy was investigated under Condition Identification and Tracking System event 97-E03602.
- The procedure SOF 10.9.2 was changed to agree with the Technical Specification and l UFSAR requirement. As a result of the 50.54(f) reviews currently in progress, a detailed effort is being made to ensure that station procedures are in agreement with the i Technical Specification and UFSAR requirements.
On October 20,1997, full compliance was achieved with respect to the necessary ;
procedure change associated with the PAC Vent pressure. '
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