IR 05000247/1986019

Ack Receipt of 861024 & s Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-247/86-19. Discussion During 861119 Site Visit Helpful in Evaluating Full Scope of Corrective Actions

ML20210U646
Person / Time
Site:	Indian Point
Issue date:	02/10/1987
From:	Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Selman M CONSOLIDATED EDISON CO. OF NEW YORK, INC.
References
NUDOCS 8702180538
Download: ML20210U646 (2)

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I FEB 101987 Docket No: 50-247

. Consolidated Edison Company of

'New York, Inc.

ATTN: Mr. Murray Selman ,

Vice President, Nuclear Power Indian Point Station Broadway and Bleakley Avenue Buchanan, New York 10511

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Gentlemen:

Subject: Inspection 50-247/86-19 This refers to your letters dated October 24, 1986, and January 2,1987, in response to our letter dated July 24, 1986.

Thank you for informing us of the corrective and preventive actions documented in your letters. The discussions between Mr. J. Johnson of the NRC and Mr. M.

Lee and others of your staff during a site visit on November 19, 1986, (Inspection No. 50-247/86-31) were helpful to us in evaluating the full scope of your corrective actions. Your supplemental response dated January 2,1987, documents this additional information. These actions will be examined during a future inspection of your licensed program.

Your cooperation with us is appreciated.

Sincerely, p Stewart D. Ebnet , Director i Division of Reactor Safety Enclosures: Licensee letters October 24, 1986, & January 2, 1987.

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Robert Spring, Manager, Regulatory Affairs P. Kokolakis, Director, Nuclear Licensing i Brent L. Brandenburg, Assistant General Counsel nj Walter Stein, Secretary - NFSC

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. Consohdated Edison Company of New York, Inc.

' Indian Point Station

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Broadway & B6eakley Avenue Buchanan, NY 10511 Telephone (914) 737-8116 October 24, 1986.

Ret Indian Point Unit No. 2 Docket No. 50-247

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Mr. Stewart D. Ebneter, Director Division of Reactor Safety

U. S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 j

Dear Mr. Ebneter:

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This refers to the special operational safety inspection conducted by a

! team of NRC personnel led by Mr. Jon Johnson of your office on July 21, 1986 through Augu st 1, 1986, at the Indian Point Nuclear Generating 4 '

Station Unit No. 2.

j Your September 24, 1986 letter, which transmitted Inspection Report No.

50-247/86-19, stated that it appeared that certain of our activities were i

not conducted in full compliance with NRC requirements, as set forth in

' the Notice of Violation, enclosed therewith as Appendix A. Pursuant to i the provisions of 10 CFR 2 201, our response to that Notice is presented

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in Attachment A to this letter.

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In addition, your letter reaue sted that we re spond to certain concerns

related to our attention to detail. We have recognized the need for attention to detail at Indian Point and have ongoing activities in place

.I that address your concerns in this area.

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. We have recently initiated a systems engineer approach aimed at enhancing operational and system detail awa reness. We a re addressing plant trips

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! and equipment malfunctions by performing root cause analysis and equipment failure and reliability analysis with the goal of enhancing the effectiveness of our maintenance activities. In addition, housekeeping ha s been stepped-up in an effort to facilitate modifications and maintenance. In order to assure followup to required actions and details

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that reau' > action, we a re tracking more closely those open items that are generated by the ongoing licensing and regulatory process, as well as those generated by in-house activities.- In our operational and system a sse ssment s, inconsistencies that are found are either promptly corrected

' We or scheduled for correction, depending on their level of importance.

l a re awa re that supporting sof tware such as drawings, procedures and the c f l -,

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, simulator need to accurately reflect "as-built" plant conditions, and are routinely assessing our existing programs in these important areas to see where the revision process can be streamlined to facilitate changes. To better implement plant configuration control activities, training of our staff is being conducted in selected areas, such as the NRC unresolved safety issues program, backfitting controls, plant failure analysis and root cause determination, team building as well as operator qualificaton and recualifications. These actions, to mention a few, are geared towards enhancing the level of attention to detail.

We are integrating the above-mentioned activities into our routine daily ope ration s. We are confident that since we have recognized the need for increased attention to detail, over time we will routinely be focu sing our attention and appropriately more sensitive to details.

Should you or your staff have any questions, please contact us.

Very truly yours, D W Attachments cca Senior Resident Inspector U. S. Nuclear Regulatory Commission Post Office Box 38 Buchanan, New York 10511

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, October 24, 1986 Re Indian Point Unit No. 2 Docket No. 50-247 ATTACHMENT A Response to Notice of Violation 1. Violation At Technical Specification 6.8.1 reouires that procedures be established and maintained to combat emergencies and other significant events such as loss of coolant and loss of electrical power (and/or degraded power sou rce s) .

Contrary to the above, on July 31, 1986, certain procedures combating a loss of coolant emergency and another significant event such as a degraded power source were not properly established or maintained in that:

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Emergency Operating Procedure (EOP) ES 1.3, Transfer to Cold Leg Recirculation, does not provide for opening valve MOV-744, RHR Pumps Discharge Valve, which is reouired to be open in order to establish alternate recirculation flow.

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EOP E-1, Loss of Reactor or Secondary Coolant, in the procedural step for resetting containment isolation phases A and B, fails to reouire ope ra tion of personnel and eauipment hatch solenoid switches located on Control Room panel SM which must be operated in order to reset containment isolation pha se A. This deficiency is also applicable to several other EOPs.

-- EOPs, E-0, Reactor Trip or Safety Injection, and ECA-0 2, Loss of All AC Power Recovery with SI Recui red, align the boron injection tank (BIT) to the auction of the sa fety in jection pumps although the BIT has been removed from service by electrical modifications and retired from u se as a sa fety injection component.

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An abnormal operating procedure had not been established for a degraded or loss of the 138KV off aite power feeder sources.

This is a Severity Level IV Violation (Supplement I).

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Octobe r 24, 1986 Ret Indian Point Unit No. 2 Docket No. 50-247 Reaponse A The Emergency Operating Procedu res (EOPa) referenced in this violation have been revised. . In addition, other EOP discrepancies addressed during the inspection, although not part of the violation, have also been corrected.

The concerns raised by the inspection team with regard to the procedures referenced in the violation have been promptly acted upon. Howeve r, we believe the discrepancies noted are mitigated for the following reasons:

In the case of MOV 744 (RHR Pumps Discharge Valve) and the phase A reset ouestions, the procedure s contain contingency actions which address the conditions created by the procedure discrepancie s.

Therefore, the operator would not he rendered incapable of completing the procedures in question.

In the case of the retirement of the Boron Injection Tank (BIT), the need to change the EOPs to reflect BIT retirement was recognized by plant staff and was in fact underway at the time of the inspection.

In addition, Operations personnel were fully aware of the retirement of the BIT and actions had been taken to effectively isolate the BIT and deenergise the associated motor operated valves.

A procedu re addre ssing the loss of 138 KV offsite power will be issued by Decembe r 15, 1986. Technical Specification 6 8.1 references Regulatory Guide 1 33 and ANSI 18.7. In the case of R.G.

1.33, Appendix A state s "The following are typical activities that should be covered by written procedures". In the case of ANSI N18 7-1976, Section 5.3 9.2 etates "The following categories of events may, depending upon the design of the plant, be conaldered as examples of gotential eme rgencie s for which procedures are written

..." "I,oss or degradation of vital power sources" is one of the examples. Therefore, we believe that the lack - of such a procedure is not in noncompliance with Technical specification 6 8.1.

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. Octobe r 24, 1986 Re: Indian Point Unit No. 2 Docket No. 50-247 2. Violation B:

10 CFR 50, Appendix B, criterion V requires that activities affecting quality to be prescribed by and accomplished in accordance with documented instructions, procedures, or drowings.

Contrary to the above, on July 23, 1986 the as-found configuration of the recirculation sump grating and floor plate was not in accordance .

with the Indian Point Unit 2 Final Safety Analysis Beport, ' Section 6.2, and the Containment Building General Arrangement Drawing No.

9321-F-2503, Rev. 15. This sump, in the as-found configuration, may not have been able . to pe rform one of its safety functions of preventing large size objects from entering the sump and blocking the suction path for the recirculation mode of core cooling.

Fu rthe r, several other examples of as-found : plant conditions which did not match design configurations were identified and are noted in Section 9.1 of this report.

This is a Severity Level IV Violation (Supplement I).

Response B:

At the time of discovery, operability of the recirculation pumps was deemed unaffected by the se conditions. Nonethele ss, as a conservative measure, a decision was subsequently made to repair the floor grating and correct the gap in the floor plating. The se -

efforts were completed on July 25, 1986.

A written anfety assessment, based on a previous Bechtel study, was provided to the inspection team on July 31, 1986. That a sse ssment concluded that the floor gaps discovered on July . 23, 1986 did not impact recirculation pump operability.

An additional independent analytical a ssessment by Bechtel wa s subsequently performed and that assessment concluded that the recirculation sump in the "as-found" condition would not have created adverse effects on the recirculation system.

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, Octobe r 24, 1986 Re: Indian Point Unit No. 2 Docket No. 50-247 3. Violation C:

10 CFR 50, Appendix B, Criterion V requires that activities affecting quality be prescribed by and accomplished in accordance with documented instructions or procedures. Station Administrative Order No. 218 require s that all work a rea s be cleaned, all recoverable items (i.e., tools, ..., ra gs, cleaning fluid, ...) be removed and properly dispositioned at the completion of work shift as practical, and that gas cylinders be marked as to type, capped and secured if left unattended.

Contra ry to the above, several examples of inadeouate restoration or securing of eculpment were found

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On July 29, 1986, twelve Nitrogen bottles for Steam Generator Blowdown and two unmarked gas bottles were observed unsecured.

On July 31, 1986, two Hydrogen bottles near the Volume Control Tank Hydrogen cover gas supply area were observed unsecured.

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On July 29, 1986, pla stic bags, ra gs, tools and debris we re observed inside the Fuel Handling Building and out side of the Fan House.

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On July 21, 1986 and on July 28, 1986, oil spills were observed on the floors of the cable spreading room and the eme rgency diesel generator room.

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On July 23, 1986, two large plastic bags and a cuantity of soft plastic tubing were left on the floor of the containment in the vicinity of the recirculation sump.

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A two-ton gantry c ra ne and in strument table s with wheels we re observed in the cable spreading room un secu red; and four instrument tables with wheels were also found unsecured in the 480 V switchgear room.

This is a Severity Level IV Violation (Supplement I).

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Octobe r 24, 1986 Ret Indian Point Unit No. 2 Docket No. 50-247 Response C:

Housekeeping has always been and will continue to be an Jmportant priority with station pe rsonnel . Notwithstanding the particula r conditions cited in this violation, the general appearance of the station has markedly improved. The inspectors noted in the in spection report that hou sekeeping conditions and plant cleanliness were gene rally satisfactory. The report stated, in pe rtinent pa rt, that "..the inspectors concluded that, de spite recent improvements in housekeeping conditions and plant cleanliness, additional attention in implementing the provision s of Station Administra tive Orde r No. 218, Rev. O,

' Housekeeping Policy' was wa rranted."

Station Administrative Order No. 218 is being revised to give more detailed and improved control of a rea s of re sponsibility by redistribution of a rea s within normal work discipline s. Area s of responsibility for housekeeping are being redefined so as to involve all four General Managers and the Resident Const ruction Manager. In addition, a booklet on hou sekeeping, explaining Indian Point's housekeeping philosophy, will be distributed to Station personnel.

Hou sekeeping will be empha sized as part of Indian Point's Genera l Employee Training (GET).

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Docket No. 50-247 ATTACHMENT B Response to Inspector Concerns 1. Labeling Con Edison is currently. in the process of upgrading the identification of plant equipment. The valve labeling portion of the upgrade is planned to be completed by August 30, 1987. Following completion of the valve labeling portion, Con Edison will continue with system component labeling. Central Control Room labeling adjustments, if reauired, will be done as pa rt of Con Edison's Detailed Control Room Design Review (DCRDR) implementation process.

2. Procedures As stated in our response to violation A, the EOPs referenced in that violation and other EOP discrepancies addressed during the inspection have been corrected. In addition, as a result of discussions with the in spection team, certain other procedures have been or will be revised to incorporate in spector sugge stions. We feel that these suggestions are positive contributions to the cuality of our procedures. Review of procedures by . support personnel and comments f rom operators as a result of procedure usage facilitate a continuing upgrade of plant procedures.

3. Containment Clomeout To ensure that containment closeout activities are performed in an acceptable manner, a containment closecut check-off list will be developed by January 30, 1987. This check-off list should ensure that the containment is left in an acceptable condition with respect to " housekeeping".

4. Gaa Turbine No. 2 Following the unsuccessful black-start attempt during the inspection, a Westinghou se ga s turbine engineer wa s contracted to review the condition of Ga s Turbine No. 2. A thorough inspection was performed. As a result of the inspection, the component which resulted in the computer fault was identified. This component is on orde r. A black-start te st will be performed after the component is replaced.

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5. Plant Configuration Management As stated in the our cover letter, the establishment of a systems engineer program will enhance operational and system detail awareness.

This program requires the system engineer to develop an intimate level of knowledge, understanding and awareness of the operation and design of a ssigned plant systems. This would provide' the system engineer with the nece ssa ry skills and involvement to a ssist in maintaining a high level of system performance. The system engineer will also provide a channel, where reliable and detailed information is readily accessible to a ssist support groups in perf62 ming their functions. The system engineer will enhance the communication and coordination of efforts between support groups within the station organization.

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Individuals designated as system engineers may perform the following functions, for example:

1. Ve rify accu racy of drawings 'and initiate a drawing change if nece ssa ry.

2. Recommend procedure revisions to the Generation Support Manager, , -

Maintenance Manager or I&C Engineer, as appropriate. -

3. Identify and evaluate potentialities for the enhancement of system and equipment performance.

4. Assist in the inve stigation of opera tional events in order to determine the cause of the event or to a ssu re that the system functioned properly during the event. -

5. Identify and recommend to the Training Department any changes to the system design or operating procedures which may affect, the required training of plant personnel. J

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>. s, Murray Selman v(e Presusent Consotidated Edison Company of New York, Inc.

Indian Point Station Broadway & Bleakley Avenue Buchanan, NY 10511 -

Telephone (914) 737 6116 January 2, 1987 Mr. Stewart D. Ebneter, Director Division of Reactor Safety U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, Pa. 19406 Ret Consolidated Edison Company of New York, Inc.

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Indian Point Unit No. 2 Docket No. 50-247 ,

Dear Mr. Ebneter:

This refers to the special operational safety inspection conducted by a team of NRC personnel led by Mr. Jon Johnson of your office on July 21, 1986 through August 1, 1986, at the Indian Point Nuclear Generating Station Unit No. 2, and the subsequent conversations between Mr. Johnson and Con Edison staff on November 19, 1986. Attachment A to this letter transmits additional information that Mr. Johnson requested.

If you or your staff have any questions, please contact us.

Very truly yours, M^ . n,,_ _

attachment cca Mr. Jon Johnson Division of Reactor Safety U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, Pa. 19406 Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 38 Buchanan, NY 10511 nr}\%< ...

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January 2, 1987 Ret Indian Point Unit No. 2 Docket No. 50-247-ATTACHMENT A 1. In our response to violation A, we stated that we believed that the e lack of a procedure on the loss of 138 KV offsite power was not in noncompliance with Technical Specification 6.8.1. Based on further

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review we concur with you that if no procedure existed on the loss of 138 KV offsite power that would . be in noncompliance with Technical Specification 6.8.1.

We stated that such a procedure, addressing the loss of 138 KV offsite power, would be issued by December 15, 1986. Procedure A27.1.1 Rev.

O, titled " Loss of 138KV" was issued with an effective date of December 12, 1986.

As stated in our earlier response to Violation A, the concerns raised by the inspection team with regard to the procedures referenced in Violation A have been promptly acted upon. Con Edison previously committed to submit to the NRC a revised EOP Procedures Generation Package by February 15, 1987. This revision better defines the EOP generation and maintenance process to facilitate changes on a more routine basis. In addition, Con Edison has purchased a computerized ECP maintenance program to better facilitate the processing of required changes to the EOPs. This will reduce the manual effort involved in maintaining many of the controlling documents. This program is scheduled to be implemented during the first half of 1987.

2. To ensure that containment closecut activities are performed in an acceptable manner, a containment closeout check-off list has been.

developed and is under final review. This check-off list will be issued by January 30, 1987. This check-off list till ensure that the

' containment is Icft in an acceptable condition. This check-off list requires, among other things, that the individual inspect .the recirculation sump grating and floor plate to assure that the as-left configuration is in accordance with the Indian Point Unit 2 Final Safety Analysis Report, Section 6.2, and the Containment Building General Arrangement Drawing No. 9321-F-2503, Rev. 15, 3. In our response to Violation C, we stated that Station-Administrative Order (SAO) No. 218, entitled " Housekeeping", is being revised to give more detailed and improved control of areas of responsibility by redistribution of areas within normal work disciplines. That SAO revision is in final review and will be issued this month. A !

housekeeping guide was published in November, 1986. This. guide has l been prepared to assist all Indian . Point personnel in maintaining Indian Point Unit 2 cleanliness standards at the highest levels. The i J

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January 2, 1987 Ret Indian Point Unit No. 2 Docket No. 50-247 guide has been issued to' maintenance personnel and subsequent distributions will be made to other personnel.

The station has been divided into separate cleanliness areas and personnel have been assigned responsibility for these areas. Signs have been posted in these areas with the name of the individual who has the responsibility to ensure that housekeeping standards are maintained. These areas are routinely inspected by management personnel. If any housekeeping deficiencies arise, that individual is contacted to correct the deficiency. Weekly housekeeping meetings are held with section representatives to discuss- the housekeeping condition of those areas assigned to them.

In addition, Maintenance supervisors inspect maintenance work areas to ensure that post-maintenance restoration of the area and or equipment is acceptable.

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