ML20245D924
| ML20245D924 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 09/30/1988 |
| From: | Bram S CONSOLIDATED EDISON CO. OF NEW YORK, INC. |
| To: | Kane W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8810070306 | |
| Download: ML20245D924 (12) | |
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' Stephen B. Bram VeJ Prisnient
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Consohdate@ son Company of N;w York, Inc.
Indian Point $(ation BroTdway & Elgakley Avenue Buhhanan NY 10511 Techone (9h 737 8116
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Re:
Indian Point Station Unit No. 2 co Docket No. 50-247 50 e
William F. Kane U.S. Nuclear Regulatory Commission Regi<
i 475 Auendale Road King of Prussia, PA 19406-1498
SUBJECT:
Response to Inspection Report No. 50-247/88-20 (IPAT)
I This is in response to the inspection conducted by an Integrated Performance Assessment Team (IPAT) from June 20, 1988 to July 1, 1988.
The IPAT made noteworthy observations relative to our performance in some areas.
Although a response was not requested, due to the extensiveness of the report and the number of observations, we have decided that a response i
is warranted to indicate our actions to address issues of concern. We are determined to address the concerns expressed to us and to preclude their occurrence by enhancing our responsiveness to issues and events which may have safety-significance and by enhancing our overall conduct of activity.
The IPAT concluded that Indian Point Unit No. 2 is being operated safely but questioned the sensitivity to safety-significant issues.
The examples provided were primarily two-fold.
First, the IPAT notes that we appear to be hesitant to question the safety significance of oce:ational occurrences in sufficient depth.
Second, our reliance on the outcome of many well-conceived long term initiatives appears r impair our effectiveness in s
implementing immediate or interim compensatory measures.
A specific instance was our responsiveness to the June 23 Main Steam Isolation Valve (MSIV) test failure with respect to the initial determination of safety significance, Station Nuclear Safety Committee cv! m, reperti :q of the event and analysis of the causes of the evet.
This has been discussed in several correspondences and at our meeting on August 4, 1988.
The subsequent notice of four Level IV violations was issued and our response has been provided under separate cover.
The adequacy of our corrective action decision making is the apparent cause of the concern on the team's part that we appear to hesitate to question in-depth the safety significance of operational occurrences.
Since the IPAT report, there have been two operational occurrences, each of which demonstrated that lessons learned from earlier events are being applied.
Our response to these events, the first involving the Condenstate System's LCV1158 and the second, the absence of the displacer on the level l
indication of the RWST, was consistent with our understanding of the NRC's expectations.
N 8810070306 880930 PDR ADOCK 05000247 G
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The second example of an apparent inadequacy was that our operating philosophy appears to rely on long term initiatives with interim compensatory measures not in place.
As discussed in the IPAT report, this again is an example of insufficient follovup on well-conceived initiatives.
Specifically, formalizing the process of documenting engineering judgements to support plant operation prior to implementation of modifications is of ten lacking.
No unsafe plant safety conditions were noted as resultant from this deficiency in formality since it was pointed cut in the IPAT report that we were able to reconstruct the bases of our judgements on specific questioned issues.
We do, however, agree that such an informal process is weak and that a more formal, documented process is warranted.
Attachment I to his letter addresses the examples pointed out in the IPAT cover letter as well as many of the specific concerns noted in the IPAT inspection report.
In addition, tr a IPAT report noted that several of our long term projects are viewed by NRC as necessary with regard to continued safe operation.
Further, you noted that expedited scheduling and completion of these programs should be performed and that periodic presentation of any progress to NRC Region I is recommended.
One such long term program was corrective action trending and root cause analyses.
Procedures for such trending and root cause analysis, including Quality assurance follovup, are now being prepared and are anticipated to be implemented prior to the end of 1988.
Another program was the selection, training and integration of systems engineers into operations.
There are twelve systems engineers and two supervisors on the job at this time.
The development of the training program is scheduled for completion in the final quarter of 1988 and formal j
training of the systems engineers will commence immediately thereafter.
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A third program was the implementation of the procedure for the safety
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evaluation process.
This procedure is being finalized and all
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administrative directives and training are scheduled to be completed by the j
end of 1988.
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Another program noted was the increased use of planners and pre-planned work packages in maintenance.
Action is now underway to add three additional planners to the group by the end of 1988 and additions are yL. mwd " m-1 t P,9.
A r, fr mrpornted in the r,hort outage in June, pre-planned work packages are to be used for future outages as well.
The final program cited was the prioritization scheme proposed for j
engineering design modifications.
This program has been finalized and l
implementation is underway.
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- j As ' a followup, to. our -letter of July L 21, 1988, meetings with Region I on
. various initiatives. and corrective actions-have begun and will continue.
These will also address many of the. issues raised.in the IPAT Inspection Report.
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E' Should you have anyu questions, please contact-Mr. Jude G.
Del-Percio,.
Manager, Regulatory Affairs.
g Very truly yours, i;
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A cc: Document Control Desk
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'U.S. Nuclear Regulatory Commission Mail Station F1-137 Washington, DC 20555
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.c Mr. William Russell Regional Administrator - Region I U.S. Nuclear Regulatory Commission 475 Allendale Road l
King of. Prussia, PA.19406-1498
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Ms. Marylee M. Slosson, Proj ect Manager Project Directorate I-1 Division of Reactor Projects I/II U.S. Nuclear Regulatory Commission Mail Stop 14B-2 Washington, DC 20555 Senior. Resident Inspector U.S. Nuclear Regulatory Commission J
P.O. Box 38 i
Buchanan, NY 10511 l
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c, Attachment I Specific Responses i
to IPAT Concerns i
i Consolidated Edison Company of New York, Inc.
Indian Point Unit No. 2 Docket No. 50-247 September, 1988 f
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Specific Responses:
1.
In Section 2.3, it ' was stated that. the QA Surveillance procedure
' (QA-713-4) is deficient since it does not provide clear guidance' on the scope and depth' of-the audit program in the area of operations.
RESPONSE: The Eurve111ance Procedure QA-713 will be revised by November 30, 1988 to' identify those attributes which should be evaluated for each surveillance conducted in the operations area.
2.
In Section 2.4, the team discussed the inadvertent opening of the Main Steamline Isolation Valves (MSIVs) and drew several conclusions in Section 2.4.4.
RESPONSE: This event has resulted in the generation of Inspect 1'on Report 50-247/88-24 on July 22, 1988 and, since that time, this item has been separated from'IPAT.
On July 28, 1988, con Edison submitted a status report of. that, event to the NRC.
On July 29, 1988, LER 88-07, relative to the incident-was submitted to NRC.
On August 4, 1988, an Enforcement-Conference on the issue was held at the Region I offices.
By letter dated August 19, 1988, the NRC issued four Level IV violations.
On September-14, 1988, a supplemented LER-88-07 was submitted to NRC.
In addition, 'a response to the August 19, 1988 Notice of Violation was submitted on September 19, 1988.
3.
In Section 4.3, the team noted several instances of lack of formality in documenting engineering judgements of interim acceptability pending l
long-term actions.
RESPONSE: The specific issues are addressed as.follows:
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Pending completion of the electrical dynamic load study, it was judged that the current static load analysis was conservative and that, in any event, loads were within diesel capability (albeit within unwarranted ratings).
At the request of-IPAT, it was do m strated that a more ren11stic estiwte of loads resuitcd 1a loading within guaranteed ratings.
It was stated that this was the reason for interim acceptability pending the dynamic load study.
The study, which had been delayed, is now scheduled for completion during the first quarter of 1989.
It was always our intent to affect any appropriate FSAR or Technical Specification revisions following completion of the dynamic load study.
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'With regard. to L the : RER. mini-flow recirculation. issue. Indian Point 2 was 'already in a refueling outage when the. issue ' was -
L, raised..
Immediate action. was ~ initiated to - resolve the issue prior to returning the unit to service.
Revision of emergency procedures was deemed to be an appropriate and adequate' solution.
It was intended that-a hardware modification to increase recirculation flow would be investigated as a followup action, but that.this' would require. LOCA. reanalysis.
It 'was also recognized that. available Peak Clad Temperature-margin may not=
exist. to permit. the desired increase.
Thus, the corrective action, if feasible, would not be a near-term fix.
Nonetheless, the. procedural revisions were deemed to be adequate for any interim period and permanently, if necessary.
The evaluation of the issue and: the. analysis' leading to the emergency procedure revisions were formally documented,' received a pre-implemention SNSC review and were implemented prior to unit return-to service..
We believe our response to this issue was timely, adequate and documented.
Implementation of the mid-loop drain-down instrumentation project o
had been delayed as a result of technical concerns relating to the piping modification that would be required.
It has now been determined that installation (transducer
- mounting, wiring, PROTEUS display software) will be completed, utilizing a different instrument package, prior to start up f rom the 1989 Refueling Outage.
4.
In Section 4 '. 3,
concerns were. raised relative to SAO-405, Modifications to Indian Point Facilities. The procedure was judged to be weak in several areas.
RESPONSE: Station Procedure SAO-40S is presently under revision.
This new revision should be easier to follow and is intended to address specific concerns about the modification process.
Specific comments highlighted in the IPAT Report are addressed below.
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The mechanism of. handling comaents within the station is covered by a
separate Technical Engineering Administrative Directive.
o C1:*iHcaden as to whether a ecdiffertion rec rhte is required, (including definition of when one may not be required) will be included in the revised SAO-405.
o The definition of the role of System Engineers will be included in the revised SA0.
o The design process required for minor modifications is part of Central Engineering's Minor Modification Procedure rather than SAO-405.
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o In conjunction with tha eccign.cnt of a modifiestion ccordin2 tor, tha reviccd SAO-405 will includa I
guidelines for determining the need for a modification tracking form.
o The revised SA0 405 will include a modification flow diagram.
o The modification t racking form will include such elements as post-installation testing, operability, and as-built drawing review.
5.
In Section 5.1, the team noted several administrative deficiencies stemming from an apparent lack of full familiarity by the Nuclear Training management and staff with the detailed provisions of certain regulatory requirements such as 10 CFR 55, " Operating Licenses".
l RESPONSE: A review is ongoing that will result in the implementation of improvements to enhance awareness and improve comprehension of recent revisions to 10 CFR 55 with special attention to:
o Content of biennial written exams.
o Training records retention.
o Written requests to NRC on the regional training program.
o Written request to extend the requalification program.
o Revisions to the training program description for the requalification program to assure compliance with SAO 502 and Training Section Administrative Directives (TRAD).
o Revisions to TRAD 7 and SAO 502 regarding remedial training.
This program is currently anticipated to be completed by the end of 1988.
6.
In Section 5.1, it was recommended that we perform an audit to develop a listing of all regulations and plant requirements applicable to licensed operator requalification training to further enhance this program and its performance.
RESPONSE: The Quality Assurance organization will independently develop a listing and perform the recommended audit prior to October, 1989.
7.
In Section 5.3, it was noted that the inspectors found that no procedural mechanisms were in place to ensure that, if the plant modification package were revised, the nuclear training and simulator modifications would be revised likewise.
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RESPONSE: This weakness had been self-identified by the Nuclear.
L Training organization who
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. revising / developing procedure (s) to ensure plant modifications are ' incorporated into the training program and simulator modifications where appropriate.
This effort will be completed by the end of 1988.
8.
In Section 5.4, it was noted that the team had reviewed both the independent Quality Assurance (QA). audits and: tne Ernlear Training Section's internal review programs - that are ~ conducted to evaluate training of licensed operators.
The inspectors-found that none of the programs, currently in place, evaluated the effectiveness of licensed i
~ operator training particularly with ~ reprd to ' operation of the plant..
l In addition, QA management was unable to ascertain which standard was used for.the audits.
RESPONSE: We are now conducting an evaluation of these training program (s) to fully determine ' their effectiveness.
This evaluation and corrective action is to be completed in the first quarter of 1989.
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In addition. QA has conducted a review to determine which standard was used for the audits in question.
This review has been completed and its findings have been documented.
9.
In Section 5.5, deficiencies in the operators' required reading program were noted.
RESPONSE: The following action has been taken:
o Generation Support now prepares a. change summary for i
each procedure change ' that is included in Required Reading.
This will aid the operators in understanding the procedure changes and make it easier for them to complete required reading expeditiously.
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Generation Support now forwards a copy of the index sheet and procedure change summary sheets for. each
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required reading package to Training.
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e increcr,ed management ' attention h=a been placed en completing required reading before the due date.
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assignment and tracking of required reading is now j
being done by watch section to improve accountability i
and provide a more expeditious implementation.
o 0AD 21 has been revised to provide more specific criteria for what goes into required reading and to l
formalize the corrective action that has already been i
initiated.
This revision was reviewed by Operations, Generation Support, and Training.
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10.
In Section 6.7, it was noted that the ALARA program is generally good but that some areas of the program need to be strengthened.
Several such areas were discussed in some detail in that section.
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RESPONSE
o In order to increase awareness of the ALARA Program, special notices were developed and posted throughout the Station to announce the August winner of the ALARA Suggestion Program parking spot.
Also, additional personnel in the Rad Support section have been assigned to work on the evaluation and reduction of the ALARA suggestion backlog.
o The concerns expressed by IPAT on the Rem Reduction Committee were discussed at the 47th meeting of the Rem Reduction Committee.
SA0 305 will be reviewed and reissued as necessary to clarify committee responsibilities.
In addition, the committee will re-institute the policy of identify!ng and tracking action items in the meeting minutes.
o The post job ALARA review concerns of IPAT have been addressed by revising SAO-303 to require the participation of a radiological engineer at all post-ALARA meetings, not only when the exposure is over 25 man-rem.
o It is recognized that retrieval of historical information in the ALARA Data Base is difficult with separate, independent data bases. Although there are no current plans to tie the data bases together, methods of reducing retrieval time and coordinating historical data are being reviewed.
o Information and training an ALARA is currently provided in a number of ways.
In the Operational ALARA course, speakers from the Radioactive k'aste and Radiological Support cections normally present information on current
- goals, accomplishments and improvements.
Examples of such topics include the coordinated chemist program and the R&D effort to develop a robotic method to sludgelance steam generators.
ALARA information is also presented to ernbyees attending the Radiation Self-Monitoring course.
This course qualifies workers to verify established exposure rates with survey meters when entering High Radiation Areas.
Currently there are 92 employees qualified to perform self-monitoring.
o Concerning Engineering ALARA training, plans are being made to I
present an ALARA Design Review course several times during the fourth quarter of 1988.
o The training and qualification of radiological engineers involves several phases.
Con Edison Position Guides identify the educational and experience guidelines for each position level.
Procedure EHS-8.401 lists the Rad Engineering Support section responsibilities while other EBS procedures (Series B) and the SA0s (300 Series) provide direction on performance of th-I L
various responsibilities.
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The use of ALARA scores provides a mechanism for feedback to the
- work groups on progress in achieving the ALARA goals. The use of j.,
Radiation Occurrence Reports (RORs),. thet do not involve ALARA issues in. determining a section's - score. 'will be re-evaluated..
If it is determined that therel1s not a; negative impact,.the GAO
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will. be revised.'to include only ALARA related RORs to adjust the -
scores.
o The Station will' continue to develop ' aggressive. goals for ' the reduction'of radiation exposure. -These goals will be t.ontinually-refined as-better data base information 'becomes available as a l
' result of work performance and' evaluations of past work.
During June and July, two: short outages ' occurred to repair ' leaking conoseals and steam generator tube. leaks..
Approximately 92 man-rem of exposure that was not included in the current' yearly goal was received during.these outages.. To achieve the Station's' 1990 INFO exposure goal, the 1989 Outage Exposure Goal will be '
reduced appropriately.
11.
In Section 7.8, no'tice is taken to weaknesses in root cause analysis and trending of'. problems as well as inadequate compensatory measures taken prior to implementation of final solutions.
RESPONSE: Quality Assurance Audits and Surveillance Reports are directly-affected by this comment.
The following vill occur:
o Audits.- Management Summary Reports on Audit Program results will continue to draw conclusions about trend / root cause/ generic.
implication analyses.
These reports vill also address compensatory actions and final solution implementation.
Auditors are now being directed to carefully evaluate audit issues to determine if a trend / root cause/ generic implication is evident.
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' Annual Surveillance Summary Reports will
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Surveillance F
continue to draw conclusions about timely performance
'j effectiveness.
Surveillors will be required to - address the adequacy of:
Cerrection of the srecific(s) ferrd.
Identification of trend / root cause/ generic implication analyses.
4 Implementation of compensatory measures.
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Implementation of final solutions.
l In addition, the Surveillance Program will have a follow-up program to assure issues are not overlooked.
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. Implementation of these changes,in the Audit. program is effective'
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immediatt:ly and in' the' Surveillance procedure by-' the end of 1988.
'. A' comprehensive. ef fort. is currently underway at Indian Point to develop a.- root ' cause program that mee ts. station ' and '. industry g needs 'as well: as a training. program.that! stresses importance' and procedure.
This' is aimed.at three. major ' points: -(a) immediate l
' action (s) to; ameliorate the - item;. (b): actions (s) to preclude-i recurrence;. and -(c) a program that tidentifies. programmatic solutions.:
In addition, a methodology is being' prepared whereby corrective actions will be analyzed on. a periodic basis ' to ensure - that-relevance, - priority, ~ and safety significance are 're-addressed.
During this analysis, maj or milestones will be' checked for adherence.
Action is in progress to implement the ' program.. by : the end of 1988.
12.,in Section 7.3, reference is made: to deficiencies in design basis L
documentation.
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RESPONSE: As stated'in our May 12, 1988 response.to the. April 4, 1988>
SALP report, a Design Basis Documentation program has been initiated'to improve the: completeness and retrievability of.
- design basis information for key. plant.' systems.
It is expected that this effort will provide' additional capability-to ensure that-potential safety issues. will be ' properly addressed.-
This multi-year.. program is-being pursued on a
system-by-system basis.
The pilot phase.
(Auxiliary Feedwater System and Service Water System) is expected to be complete by the end of '1988.-.This program has been discussed with Region I'on September 22, 1988.
13.
In Section 7.3, the role of Quality Assurance was questioned.
RESPONSE: Quality Assurance's approaches to the specific items of IPAT will further fulfill.the " traditional'QA philosophy" by
" emf rg nanagement 'attentien to requiring cenp?cte ord r!>
and action on issues that are found.
QA does not believe that any additional authority to resolve -
issues is required.
The line is responsible to resolve issum;.QA has the authority to comment on the adequacy of the corrective action process; they will escalate issues if they believe that corrective action is not effective.
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Toward the end of 1989,.QA will' assess and ' audit the p'
' condition of corrective action processes.
14.
In Section 8.3.3, it was noted thati there is an inconsistent-format in the = material. specification listing-which. caused the planner. to order the wrong material _ for a certain section _ of piping.
A question was raised as ' to why a QA audit was not' performed to determine if any e
other modifications contained, or were; susceptible to, this ' type of y
-human error.
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_ RESPONSE: The modification process and related procedures have been the subject 'of Quality Assurance audits and surveillance as well'as NRC inspections.
The format-' of materials listings was never identified as a concern and' we ebelieve that this instance of material substitution was an isolated case.
QA's policy continues to,be that, once a potential weakness is identified, the cognizant organizations take the steps:
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necessary to correct it.
Quality - Assurance is monitoring Engineering's self-assessment process in. response to the 1988 SALP: report and will determine if this issue is being fully addressed.
Additionauy, as ' individual audits and surveillance are conducted, QA vill sample modifications to address this issue.and other human factors items. QA is now, evaluating - the need for a late 1990 audit to. review the-
- effectiveness of Engineering in this area as well as ' the results of changes.in response to their self-assessment.
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