ML20212K319

Discusses Insp on 860811-0922 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty.Violation Noted: Reactor Heated Up Above Cold Shutdown Condition When Both Recirculation & Containment Spray Pumps Inoperable

ML20212K319
Person / Time
Site:	Indian Point
Issue date:	01/20/1987
From:	Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Brons J POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
Shared Package
ML20212K323	List: ML20212K319 ML20212K352
References
EA-86-197, NUDOCS 8701290048
Download: ML20212K319 (4)

Text

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.- 4 JAN 2 01987 Docket No. 50-286 License No. OPR-64 EA 86-197 Power Authority of the State of New York Indian Point 3 Nuclear Power Plant ATTN: Mr. John C. Brons Senior Vice President Nuclear Generation 123 Main Street White Plains, New York 10601 Gentlemen:

Subject:

NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY (NRC INSPECTION REPORT No. 50-286/86-21)

This refers to the routine NRC resident inspection conducted between August 11 and September 22, 1986 at the Indian Point Nuclear Power Plant, Unit 3, Buchanan, flew York. The inspection report was sent to you on October 20, 1986.

During the inspection, a violation of technical specification limiting con-ditions for operation was identified. On November 10, 1986, an enforcement conference was conducted with you and other members of your staff to discuss the violation, its causes and your corrective actions.

The violation, which is described in the enclosed Notice of Violation, involved heating up the reactor to above the cold shutdown condition (200 F) with both recirculation pumps and both containment spray pumps inoperable. The technical specifications require that at least one recirculation pump and two containment spray pumps be operable prior to entering that condition. The pumps were inoperable in that their control switches in the control room were improperly in the stop pullout position, thereby defeating the automatic start features of the containment spray pumps, as well as the normal sequence for manually start-ing the recirculation pumps. This condition existed for over five hours, in-cluding a shift turnover, until it was identified by the NRC Senior Resident Inspector.

The NRC acknowledges that the safety significance of this violation relative to plant status is minimal, considering that the plant was in the heatup phase at the time. Further, a common safeguards system alarm existed in the control room, which procedures required to be cleared when the safety injection pumps were made operable prior to exceeding 350*F, but would not have cleared because of the inoperable recirculation and containment spray pumps, and thereby, would have alerted the operators. Nonetheless, the violation is of significant con-cern to the NRC because several members of the operations staff had an oppor-tunity to detect the mispositioned switches. Specifically, a reactor operator, CERTIFIED MAIL RETURN RECEIPT REQUESTED OFFICIAL RECORD COPY CP PKG INDIAN POINT - 0001.0.0 01/13/87

[ 0048 870120 Dock 050 g 6 .

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Power Authority of the State of New York 2 in completing a system checkoff list prior to exceeding the cold shutdown condi-tion, apparently assumed the proper positioning of the switches without adequate verification. Further, this condition was not identified by the shift super-visor prior to the heatup, nor was it identified by the oncoming shift prior to accepting responsibility for plant status.

In addition to these deficiencies, the NRC is also concerned that similar conditions existed for the safety injection (SI) system. The system checkoff list indicated that all three SI pumps were also operable, when in fact, none of the SI pumps were operable since their control switches were also in the stop pullout position. The stop pullout position was an acceptable position for the SI control switches at the time, since the technical specifications permit only one SI pump to be operable when the reactor coolant temperature is below 326 F so as to protect against a low temperature /high pressure transient.

Further, it was apparently not recognized that if more than one SI pump was operable at that stage of the heatup, as indicated on the checkoff list, it would constitute a violation of the technical specifications, and action was not taken to resolve this apparent anomaly.

These deficiencies demonstrate the importance of meticulous attention to detail during the completion of system checkoff lists, diligent oversight of control room operations by shift supervision, and thorough review of control room status during shift turnover, to assure that the plant is operated safely and in accordance with the technical specifications. To emphasize these concerns, I have been authorized, after consultation with the Director, Office of Inspec-tion and Enforcement, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of Fifty Thousand Dollars ($50,000) for the violation described in the enclosed Notice. The violation has been classified at Severity Level III in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986) (Enforcement Policy). Although the escalation and mitigation factors in the Enforcement Policy were considered, mitigation of the civil penalty was deemed inappropriate because (1) the violation was identified by the NRC; (2) the corrective actions were not considered sufficiently comprehensive to assure that checkoff lists, in general, are properly completed and adequately reviewed, and shift turnover practices are sufficiently thorough to ensure operators are aware of actual plant conditions; and (3) the recent SALP history in the opera-tions area is average, as evidenced by a Category 2 rating during the most recent SALP evaluation.

You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. In your response you should document the specific actions taken and any additional actions you plan to prevent recurrence. After reviewing your response to this Notice, including your proposed corrective actions, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirements.

In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosures will be placed in the NRC Public Document Room.

OFFICIAL RECORD COPY CP PKG INDIAN POINT - 0004.1.0 01/13/87

Power Authority of the State of New York 3 The responses directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.

Sincerely, Original ~ signed by Thecaa E. Murley.

Thomas E. Murley Regional Administrator

Enclosure:

Notice of Violation and Proposed Imposition of Civil Penalty cc w/ encl:

L. W. Sinclair, President j J. P. Bayne, First Executive Vice President and Chief Operations Officer W. Josiger, Resident Manager Gerald C. Goldstein, Assistant General Counsel A. Klausmann, Vice President - Quality Assurance F. X. Pindar, Quality Assurance Superintendent G. M. Wilverding, Chairman, Safety Review Committee M. Blatt, Director, Regulatory Affairs (Con Ed)

NRC Licensing Project Manager Dept. of Public Service, State of New York Public Document Room (PDR) local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector State of New York 0FFICIAL RECORD COPY CP PKG INDIAN POINT - 0005.0.0 01/13/87

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Power Authority of the State of New York 4 bcc w/ encl:

Region I Docket Room (with concurrences)

Management Assistant, DRMA (w/o encl)

DRP Section Chief Robert J. Bores, DRSS SECY CA J. Taylor, IE A. Beach, IE T. Murley, RI H. Denton, NRR D. Holody, RI J. Lieberman, OGC J. Sniezek, DED/ROGR Enforcement Directors RII-III Enforcement Officers RIV-RV F. Ingram, PA '

J. Crooks, AE00 B. Hayes, 01 S. Connelly, OIA D. Nussbaumer, OSP IE/ES File IE/EA File ED0 Rdg File DCS Office of State Programs i y L /

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