IR 05000003/1973015
| ML20042B105 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 12/20/1973 |
| From: | Brunner E, Fasano A, Oberg C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20042B103 | List: |
| References | |
| 50-003-73-15, 50-247-73-19, 50-3-73-15, NUDOCS 8203240577 | |
| Download: ML20042B105 (11) | |
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U. S. ATOllIC ENERGY CO:CIISSION
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DIRECT 0lMTE OF RCGUL1 TORY OPERATIONS
REGION I
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RO Inspection Report No.:
50-247/73-19, 50-03/73-15 Docket No.:50-247/
50-03 Licensce:
Consolidated Edison Company License No. :DPR-26 DPR-3 4 Irving Place Priority:
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New York. New York Category: B/C
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Location: Indian Point -2, Buchanan, New York Indian Point -1, Buchanan, New York
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PWR873MWe(Westi$ghouse)
Type of Licensce:
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PWR 615 MWe Type of Inspection: Special, Announced Dates of Inspection: October 23-25, November 8-9, 15, 1973 Dates of Previous Inspection: Septenber 27, 1973 i
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Reporting Inspector:s:
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or Inspector Date C. R. Oberg, Rear 7 tor Inspector
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NONE A//9/' 7f Accompanying Inspectors:
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Date
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NONE Other Accompanying Personnel:
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Reviewed By:
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'Date gf E. J. Brunner, Chief, Reactor Operations Brarch
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B203240577 740103 PDR ACOCK 05000003 G
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SUSDfARY OF FINDINGS A.
Violations 1.
Quality Assurance related to the Instrument Air System i
Modification
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l-Section VI of Corporate Instruction CI-240-1 was
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violated in that an approved procedure for weld
identification has not been issued and therefore not in use. (Details, Paragraph 2)
b.
Section VI of Corporate Instruction CI-240-1 was l
violated in that isometric drawings were not provided
in the Quality Assurance package for the Instrument-Air System modification.
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Section VI of Corporate Instruction CI-240-1 was violated c.
in that a weld authorization form is required for each weld. One authorization form was issued for 9 separate
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welds. (Details, Paragraph 4)
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Containment Integrity
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Technical Specification 1.7 and paragraph 3.6 were violated when the personnel air lock doors were both in an open position
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for a short time inte'rval.
Records reviewed indicate that notation required to be documented in the Shif t Watch Foreman's
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log in accordance with procedure UO 2-10, Rev.1, October 3, 1973 was not documented for September 11, 1973. (Details, Paragraph 5)
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B.
Sa fe ty None Licensee Actions on Previousiv Identified Enforcement Actions Not Inspected Design Changes
Instrumen't Air System Modification The modification relating to the instrument Air System by-pass (around the refrigerant dryers) was started on October 20, 1973.
i The modification (Reference Fbintenance Work Request No. 2-C-5-01385, l
Project No. 3428, Engineering Service Memo No. 73-2-011) remains to be completed.
This item remains open pending final installation
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of the modification.
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-2-Unusual occurrences None Inspected Other Significant Findings
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A.
Current 1.
Quality Assurance Indoctrination To date (October 24, 1973) three indoctrination and training courses on Corporate Instruction CI-240-1 " Quality Assurance Program for Opera'ing Nuclear Plants" were given to Quality Assurance personnel. Memoranda issued March 20, 1973, May 29, 1973 and Septe6!er 6, 1973; Subject: Training Program CI-240-1 were reviewed.
The memoranda listed personnel attending and course outline. (Details, Paragraph 6)
The Indian Point site personnel were given the first session of a 3 day series of indoctrination on Corporate Instruction CI-240-1.
The sessions were begun on October 24, 1973.
2.
Quality Assurance Audit Program Discussions with the licensee indicate that an audit of the startup of Indian Point 2 is being formulated.
The licensee stated that an audit of this phase of operations
, vill be conducted during January 1974.
(Details, Paragraph 7)
Management Interview A management interview was held at Consolidated Edison Corporate Of fice, 4 Irving Place, New York, New York with Mr. Beer and staff on November 9,1973.
A second management meeting was held at the Indian Point site, Buchanan, New York with Mr. Makepeace on November 15, 1973.
Persons Present for the November 9 Management Interview Consolidated Edison G. Beer, Director, Quality Assurance R. Gordon, Director, Quality Standards and Reliability G. Wasilenko, Manager, Quality Assurance R. Ilayman, Manager, Quality Assurance Operations Regulatory Operations A. Fasano, Reactor Inspector L
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Persons Present for November 15 ManSpement Interview
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Consolidated Edison
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J. Makepeace, Chief Engineer, Unit 2
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Rgulatorv Operations
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,C. Ch' erg, Reactor Inspector-
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Score and Findings
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" Tile licensee representatives were informed that on review of the
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- Quality Assurance package for the Instrument Air System !!odification an apparent violation was found with respect to meeting requirement
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as statedQn CI-240-1, " Quality Assurance Jcogram for Operating Nuclear Plants".
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(Details, Paragraph 2,3,'4).' s A violation reported
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by the licensee,on containment integrity was reviewed., Associated
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with this apparbnt violation was a fdilure related to fulfillment
of procedural requirements in documenting personnel air. : Lock, checks
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in the Watch Fbreman's Log..(Details, Paragraph-5)
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Audit Program-
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The licensee plans to include an audit of 'the startup phase of operation.
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The licensee is also considering an audit of commuriication system and interf aces within the organizational s tructure. (Details 6 and -7)
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C.
Deficiency Report and Corrective Action
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The licensee stated that action to better define conditions fo r,
" Authorization for Emergency Repair" will be reviewed for better control. (Detailc, 8)
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D.
Procedure for Evaluating Vendor Facilities, QAE-2
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The licensee stated that procedure:: are being and will be controlled s by proper review and ~ approval documentation. (Details, Paragraph 8)
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DETAILS 1.
Persons Contacted W. R. Cobean, Manager, Nuclear Power Generation Department G. Beer, Director, Quality Assurance
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R. Cordon, Director, Quality Standards and Reliability R. Hayman, Manager, Quality Assurance Operations W. Hill, Quality Standards and Reliability J. Makepeace, Chief Engineer Unit 2 G. Wasilenko, Manager, Quality Assurance G. Case, Station quality Assurance Engineer
W. Ferriera, Quality Assurance L. Cass, Quality Assurance V. Coctz, quality Assurance Engineer 2.
Availability and Use of Approved Procedures Corporate Instruction CI-240-1,Section VI, Identification and marking, paragraph 3.2, states 'in part : "This identification
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(of weld joint) will be accomplished'in accordance with procedures approved by the Mechanical Engineering Department".
The inspector stated, th a t in reviewing the Quality Assurance package (Revision 1) of the Instrument Air Modification, approved procedures were not included for veld identification.
Two memos were reviewei, that relate to methods to be used for veld identification: a) Memorandum issued October 22, 1072, Subject:
" Weld Identification Index Class I Systems" b) Memorandum issued October.4, 1972, Subject: " Weld Specification Index".
The contents of these memoranda discuss and reflect the intent of an " identification" procedure.
A final approved procedure remains to be formulated.
Also, th= nrocadure for an acceptable method of traceability remains to be finalized.
3.
Weld Joint Isometric Drawings Corporate Instruction CI-240-1,Section VI, " Identification and Marking", paragraph 3.3 s tates, in' part, "The Mechanical Engineering Department is responsible for preparation of weld joint isometric drawings including a weld joint numbering system for all piping fabrication and installation required for Class A items.
All required welds shall be identified on the isometric drawings by a ur.ique weld joint identification number".
The inspector stated, that in reviewing the Quality Assurance package (Revision 1) of the Instrument Air Modification, isometric drawings were not provided.
A drawing marked by and used by maintenance personnel was not an isometric.
Further, the initial drawings used for weld identification were not the latest corrected drawings and required a revision to correctly identify the weld location ~
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Weld Author.
4 tion Forms
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The Corporate Instruction CI-240-1,Section VI, paragraph 3.3 states in part that, "A weld authorization form (WAF) (Exhibit M), including a unique weld joint identification nunber, shall be issued by the Mechanical Engineering Department for each weld on the isometric drawing.
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The inepector reviewed a memorandum from the acting Director Quality Assurance to the Station Mechanical Engineer, September 11, 1973, Subject: "CI-240-1 Weld Authorization Form".
The memorandum presents an interpretation of paragraph 3.3 allowing for the use of cae Weld Authorization Form (WAF) Part J may be used for all welda tihich reft rence the same weld procedure in a given modification.
The inspector stated that the memorandum was used to change CI-240-1 instructions and would require proper revieu, approval and control prior to implementation.
5.
Con tainmen t Integrity on September 13, 1973 both doors of the 80 foot level personnel air lock were in an open position for a short period.
The abnormal occurrence was reported by 'the licensee to the Commission (Reference Report to the Directorate of Licensing, September 27, 1973).
The inspector examined applicabic records and held discussions with cognizant personnel to verify the circumstances concerning the violation of containment integrity on September 13, 1973 as reported in the referenced letter.
It is noted that the cause of the violation is not stated in this letter.
The inspector determined that the violation was caused by (1) the failure of a roller nut on the cam assenbly of the outer door and (2) the opening of the inner door by a workman who failed to follow the directions of the Watch Foreman as announced over the ;eneral announcing system inside containment.
The outer door was open and being repaired.
The interlock had been defeated to facilitata repairs.
Technical Specifications, paragraph 3.6 requires containment integrity (Specification 1.7) to be maintained at all times except when the reactor is in the cold shutdown conditions.
(Tave d,140 F and shutdown by at least 1% ~k/k).
At the time of the occurrence, primary system pressure was 450 psig and temperature was 185 F.
This failure of the door mechanism is related to a similar occurrence as reported to the Commission by Con Ed letter of April 27, 1973.
The September 13 event was reviewed by the Station Nuclear Safety Committee on September 14, 1973.
They made three recommendations ;
Issue a general directive regarding defeating of interlocks.
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Expedite redesign of containment air locks Post additional signs on air locks prohibiting defeat of c.
interlocks without permission of Watch Foreman.
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Because of the April door failure Unit Order U.0. 2-10 was issued (Rev. I approved 10/3/73).
This order requires a daily operability check of the door interlocks. These inspections and checks were to be recorded in the Shift Watch Foreman's log.
This was not done on September 11, 1973 and other dates in violation of the Unit order.
It is noted that the entry yas made on September 13, 1973.
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This item remains open until the redesign is completed.
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6.
Quality Assurance Indoctrination
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Refer <. Tee is made to Corporate Instruction 240-1, page 5, paragraph
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2.11 which states, in part, " Quality Standards and Reliability shall provide indoctrination and training concerning the requirements
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of this Quality Assurance Program to Quality Standards and Reliability personnel, Station Quality Assurance Engineer, and i
appropriate personnel in other organizations.
The documentation
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reviewed indicates that indoctrinaticn of Con Edison personnel l
was being pursued at the New York office and is currently being
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j implemented at the Indian Point Site'.
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Quality Assurance Audit Program
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The audit summary for audits 1, 2 and 3 were reviewed.
CI-240-1,
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page 67 states, in part, "It is the responsibility of the activity audited to review the list of discrepancien and reply
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within two vecks to the Vice President, Quality Standards and Reliability conceri.ing the actions that shall be taken to
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resolve each discrepancy.
The records reviewed indicated that response: were. received on all audits".
i The implementing procedures, " Consolidated. Edison Audit Program for Operational Nuclear Facilities" was reviewed.
All activitics and organizations responsible for the operation, maintenance, control,
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j administration or quality assurance of nuclear plants or facilities are subject to audit under the Con Edison program not less than once every two years. The checklists and program do not address an j
audit of the startup phase of operation.
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The licensee stated that the program was being augmented to include an audit of the startup phase of operation. He stated that the audit of this phase would be conducted during the month of January 1974.
This iten remains open for review by the RO inspector during subsequent i
inspections.
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Deficiency Reports and Corrective Action The deficiency reports, in accordance with CI-240-1,Section XIII, were reviewed and discussed with the licensee.
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Deficiency report DR No. 73-NPG-2-5, March 30,1973, Unit.2, " Steam
packing for valves 894C and 894B" was reviewed.
This DR. included "Aut'.:orization for Emergency Repair" (Reference
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procedure IX of CI-240-1) which states,in part, " Power Supply may
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authorize emergency repairs which due to their urgent nature cannot j
follow the above review and control requirements".
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j The RO inspector noted that the reason given for use.of the
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emergency authorization cla ne was to avoid delaying the startup i
program. He stated that paragraph 3.16 of Section IX, CI 240-1
required further clarification as to what constitutes a valid
use of " Authorization for Emergency Repair".
The reason given
in DR No. 73-NPG-2-6 appeared to be unacceptable.
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The licensee stated that further delineation on the use of the emergency authorization would be implemented. He referred to i
memorandum dated August 29, 19 73, File No. 4-121B, Subject
" Halting of Class 'A' Work to Clarify Conditions When Procedural Requirement Do Not Appear to Be Met" which addresses this same
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concern.
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This item remains open.
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QA Procedure for Evaluating Vendor Facilities DAE-2
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The implementinn procedure was reviewed.
The initial comment by the RO inspector was that a memorandum was being used as a
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mechanism for approval of use of the procedure. Procedures
should be controlled in accordance with Criterion II and l
Criterion VI, 10 CFR Appendix B.
The licensee stated that the procedere has been approved and that the policy is currently to implement properly approved procedures.
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The R0 Inspector stated that the implementation of CI-240-1 appears to require further guidance in the form of administrative procedures to carry o.ut the Quality Assurance organizational functions.
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10. Reactor Containment Fan Cooler Condensate Measurement Test *
The RO Inspector verified that this test was included, as a
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repeat test, in the schedule for testing at 75% power.
This item is considered resolved.
- Items 9 through 15, RO Inspection Report No. 50-247/73-17
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Details, Paragraphs 4,5,7; Also letter from Con Edison to USAEC Region
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-8-11. Hot Penetration Cooling System
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The Ro inspector reviewed and discussed current plans for final performance of this test.
It was stated that the test will be perforned during the 100% power operation to obtain additional data before final conclusions are made as to the adequacy.of performance of the penetration cooling system.
The RO inspector reviewed status documentation as stated in a letter from WEDCO, July 20, and a speed letter from IP-2 operations to Consolidated Edison Engineering, August 8,1973.
This item is considered resolved.
12. Fixed Incore Neutron Detector System This test is scheduled to be finalized at or close to 100% power operations.
This item is considered resolved.
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13. Rod Drive Mechanism Stepping Test The R0 inspector reviewed 1972 records which were made available by the licensee.
The records contained signatures and initials for documentation and trace;.bility.
A review of 1973 records contained test performance verification sheets signed by the person performing and observing the test.
This item is considered resolved.
14. Incore Movable Detector Check a
This item is considered closed pending final review and acceptance of results by Con Edison Engineering.
This comment is the same for "In-core movable detector system checkout".
15. Thermal Expansion (Hangers. Restraints, etc)
The follow;ng documentation was made available and reviewed by the RO inspector:
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Correspondence from WEDC0 to Con Ed Construction July 17, 1972.
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Corresponder.cc from WEDCO, Mechanical Engineering to WEDC0 Construction June 15, 1971.
Acceptance of test results is noted.
This item is considered resolved.
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-9-16.
Internal Movement Test Part 5.2.3 The RO inspector reviewed correspondence between Consolidated Edison Engineering and Consolidated Edison Construction, September 21, 1971.
The correspondence includes acceptance of the test results and a vaiver for cor.tinued testing.
Correspondence to Con Edison from NEDCO, October 22, 1973 references acceptance of results as documented in NCAP-7879.
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This iten is considered resolved.
17. Reactor Control cluster Pseudo Election Test at Zero Power The RO inspector reviewed correspordence to IP-2 operation from Consolidated Edison Engineering June 12, 1973.
The correspondence refIcces acceptance by Consolidated Edison of the test results.
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Correspondence from WEDC0 to Consolidated Edison, July 9,1973 relates to WEDC0 acceptance of test results.
The documentation above also relates to acceptance of Design Checks IPP SU 7.3 and minimum shutdown verification IPP SU7.7.
These items are considered resolved.
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MEMO ROUTE SLIP 5" me a bout ""$-
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im r.au RtMARas RO Chief, FS&EB RO:HQ (5)
CONSOLIDATED EDISON COMPANY RO Files cars Central Mail & Files INDIAN POINT 1 & 2 Regulatory Standards (3)
RO INSPECTION REPORT NOS. 50-247/73-19, TO Udem..nd uc rt)
lN)fl ALS alManns Directorate of Licensing (13)
50-03/73-15 Regional Directors, (R0 II, III, IV)
The above inspection report is forwarded for oars OGC
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in fortaation.
T O (s.m..,o unto Distribution will be made by this mmAO REMARK 5 office to the PDR, Local PDR, NSIC, DTIE, and onts State Representatives after review by the F ROM (N.m..nd unit)
licensee for proprietary information.
p[MARas E. J. Brunner Region I l
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PHONE NO.
DATE 8-337-1240 1/3/75 US$ OTHER SIDE PON AD0tTIONAL REM 9K5
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