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I-97-11 January 31, 1997
NOTE TO EDITORS:
The attached confirmatory action letter was issued to Consolidated Edison by the Nuclear Reglatory Commission staff this afternoon (1/31).
enc: as stated
License No. DPR-26 CAL No. 1-97-002
Mr. S. E. Quinn Vice President - Nuclear Power Consolidated Edison Company of New York, Inc. Indian Point Unit 2 Broadway and Bleakley Avenues Buchanan, NY 10511
Dear Mr. Quinn:
SUBJECT: CONFIRMATORY ACTION LETTER 1-97-002
On January 26, 1997, Indian Point 2 was shutdown when it was determined that three of the four feedwater regulating valves would not close upon demand. Subsequent investigation of the internals of these valves found extensive scoring of the valve plugs and cages as well as a buildup of a predominately iron-based foreign material that prevented closure of these valves. We understand that your investigation to date has indicated that this foreign material, an abrasive grit used to prepare the inner surface of the high pressure turbine during the early 1995 outage, is the probable cause of the failure of the valves to close upon demand. Furthermore, this abrasive material was found in other areas of the feedwater system and also caused the failure of a heater drain pump in June 1995, as well as damage to another heater drain pump this past week.
The NRC is concerned with the potential safety implications of this apparent common mode failure of multiple feedwater regulating valves, which also serve a safety function in isolating the feedwater system during particular design basis events. Moreover, we are concerned that this foreign material intrusion occurred over 1-1/2 years ago and previously led to a significant equipment failure, but was apparently not adequately evaluated such that the full extent of condition and its impact on the plant was known and appropriately addressed at that time.
Pursuant to a telephone conversation between yourself and Richard Cooper of my staff on January 31, 1997, it is our understanding that you and members of your management and technical staff will meet with my staff in Region I prior to the restart of Indian Point Unit 2. During that meeting, you should be prepared to discuss:
1) the scope of your efforts to determine the root causes of the FRV failures, and subsequent observed damage to other balance of plant components;
2) the basis for your confidence that the identified root causes completely encompass the failure mechanisms and the physical damage observed in the failed components;
3) the scope of your corrective actions to ensure that you have identified all affected equipment and the safety impact on that equipment; and that you have identified the location of all foreign material, and have appropriately removed it. Should you not have confidence that all material has been removed, provide your basis for restart of the plant in recognition of this condition;
4) the safety significance of this event;
5) the root causes of your failure to more broadly evaluate the extent of condition of the foreign material intrusion during your evaluation and corrective action pursuant to the June 1995 heater drain pump failure. In this discussion, also include information about other indicators that may have previously existed that were additional precursors to this event.
Pursuant to Section 182 of the Atomic Energy Act, 42 U.S.C. 2232, and 10 CFR 2.204, you are required to:
1. Notify me immediately if your understanding differs from that set forth above.
2. Notify me if for any reason you cannot complete the actions within the specified schedule and advise me in writing of your modified schedule in advance of the change.
3. Notify me in writing when you have completed the actions addressed in this Confirmatory Action Letter.
Issuance of this Confirmatory Action Letter does not preclude issuance of an Order formalizing the above commitments or requiring other actions on the part of the licensee. Nor does it preclude the NRC from taking enforcement action for violations of NRC requirements that may have prompted the issuance of this letter. In addition, failure to take the actions addressed in this Confirmatory Action Letter may result in enforcement action.
The response directed by this letter are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Pub.L. 96-511.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its enclosures will be placed in the NRC Public Document Room.
Sincerely,
ORIGINAL SIGNED BY:
Hubert J. Miller Regional Administrator
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