IR 05000003/1974016
| ML20042B192 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 12/16/1974 |
| From: | Fasano A, Glasscock R, Napuda G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20042B187 | List: |
| References | |
| 50-003-74-16, 50-247-74-16, 50-286-74-23, 50-3-74-16, NUDOCS 8203250069 | |
| Download: ML20042B192 (55) | |
Text
{{#Wiki_filter:.. ... . . RO:1 1*orn 12 (Ocl'.*lli) (i.ev) . U.S. ATO::IC E::EUGY CO:'.*iSS10N i i DIRECT 01\\TE OF R!:GULiTORY OPERATIONS REGION 1 - 50-03/74-16 50-03 50-247/74-16; 50-286/74-23 Docket No: 50-247; 50-206 , R0 Inspectica Ecpert No: ~DPk-3- ~
Liconsce: Consolidated Edispn Company of New York, Inc.
License No: DPR-26; DPR-62 , 4 Irving Place Priority: __ New York, New York 10003 Category: C; C; B1 , Indian Point Units.1, 2 & 3; Buchanan, New York Safeguards Location: _ ' 1-PWR (BE.W) 615 Wt; 2 & 3 Pt.'R (W) 2758 Wt Type of Licencca: _ Routine, Announced Type of Inspection: November 18 - 22, 1974 I Dates of innpcetion: 1 - November 7-8, 1974 Daten of Prevfoes Inspectien: 2 - Ontch.ex. 30.-31,_197/o_.3:Fovember 11-13, 1974 ' i !/ d:,t,.1,_ r __ / 2y! d ' / F Reporting In p:etor: - A. N. Fasano, 7,cactor Inspector Dat'e ' Acco"panying Innpectors.:,,/) ,f,d,uM,. _ _/[[[-7M _ R. B. Glasscock, Reactor Inspector Date d Ne!M- /."_ _T/ hi...k ~ g' G. Napuda, ik actor Inspector Date _ .. _ L b I* M /.M _ I s. _ Date' W. A. Ruhl::an, Reactor Inspector ihte Otimr Accompanying Personnel: NONE.___ =- Date Reviated By: - I I* k __/,2 ft '7 / _ A. B. Davis, Senior Reactor Inspector Da e PWR Section, Reactor Operations Branch . 8203250069 741219 PDR ADOCK 05000003 _,_ G PDR
' * . . . , . .. . SUMMARY _OF FINDINGS Enforcement Action The f ollowing violations are considered to be Severity Category II.
1.
Audit "A com-10 CFR 50, Appendix B, Criterion XVIII requires, in part: prehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program and to determine the ef fectiveness of the program", and ....Follevup action, including reaudit of deficient areas, shall " be taken where indicated".
" Measures 10 CFR 50, Appendix B, Criterion XVI requires, in part: shall be established to assure that conditions adverse to quality, - such as failures, malfunctions, deficiencies, deviations, defective and nonconformances are promptly identified material and equipment, and corrected".
QA-7320 Consolidated Edison Audit Program for Operational Nuclear . Facilities, Revision 0 dated October 24, 1973, states in Section Item C: "Impiccentation of procedures by the 5.3.2 Audit condu;t, station shall be audited in sufficient depth to determine compliance or delineate nonconformance" and in Section 5.5 Folinw-Uo, that: "Re-audits shall be scheduled as necessary to insure that corrective measures have been effected or remedial action initiated".
Contrary to the above, the following were noted: The nonconformance item identified as item A.c.4 of the a.
Operatienal Audit of Indian Point Unit Nos. 1 and 2 for the last quarter of 1973 vere found to be unresolved one year after identified.
No remedial action had been initiated.
b.
The reaudit failed to verify compliance with'an aspect of the quality assurance program in that several cards in the instrument history file failed to conform with the require-cents of attachment 2 of PE-AD-8, " Calibration and Control of ?hasuring and Test Equipcent".
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Procedure Anproval Technical Specification 6.8.1 states in part: " Detailed written , procedures covering the areas listed below,...., shall be pre-pared, approved as specified in Section 6.8.2. and adhered to: " Surveillance end Testing Requirements of the Nuclear Facility".
Technical Specification 3.8.2 states in part: "All written pro - , cedures required by 6.8.1, and any changes to them shall be reviewed and approved for implementation in accordance with written , administrative control procedures...." The administrative control procedure required by this specification shall, as a minimum, clearly establish the critoria which will govern when preimplementation review by the Station Nuclear Safety Committec and the Nuclear Facilities Safety Committee is required".
Station Administrative Order 102, thy 23, 1974, Procedure / Procedure
Chcnge Approval Policy" states in part: "If a procedure / procedure change does involve safety related coa.ponents and or operation of same, a preinplementation review by the SNSC is required...." Contrary to the above, 19 of a sample of 25 surveillance procedures required by Technical Specification to be periodically performed were not reviewed by.the SNSC.
, 3.
Failure to Follow Procedures 10 CFR 50, Appendix B, criterion V, requires in part: " Activities affecting quality shall be prescribed by documented instructions, , procedures, or drawings.... and shall be accomplished in accord-ance with the instructions, procedures or drawings."
Contrary to the above the following were noted: a.
Procedure SAO-ll7 " Calibration and Control of Measuring Tools, Gages, and Test Equipment for use on Class A Nuclear Systems" requires in part" "Uhenever an item is beyond the required calibration due date, a red tag will be affixed indicating that it cannot be used until it has been calibrated".
Red tags were not affixed to test gages, IC-47, IC-48, IC-49, IC-63, IC-120, IC-132, IC-150 and IC-157.
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SAO-117 requires in part: "Each Sub-Section is responsible for maintaining a list of equipment under their control.
The list will contain, as a cinimum, the following: (1) Identifi-cation number, unique Indian Point Station assignment (assigned by Subsection involved)".
Tbc_Chentstry Sub-Section list did not have the required identification number for any of the instruments.
QA-AD-11, " Calibration and Control of Measuring Tools, Cages e c.
and Test Equipment for use on Class "A" Cc=ponent" requires (under 2. 0, B.
Master List) in part: "QA is responsible for maintaining a, list of equipment under its control.
The list cust contain, as a mini =um, the following: ... 4. Calibra-tion frequency, activity, date calibrated and method".
The Paster List currently being maintained does not contain the required date calibrated.
The following violations are considered to be Severity Category III.
1.
Examination of Products ppon Delivery . 10 CFR 50, Appendix B, Criterion VII states in part: " Measures shall be established to assure that purchased material.... con-form to the procurement documents.
These measures shall include p rovisions, as appropriate.... examination of products upon . delivery".
Contrary to the above no activity exists to assure the accepta-bility of the delivered or stored number 2 fuel oil procured for j the Emergency Diesel Generators.
. 2.
Failure to Follow Procedure , ( 10 CPR 50, Appendix B, Criterion V, requires in part: " Activities - i ! af fecting quality shall be presc'ribed by documented instructions, procedures, or drawings of a type appropriate to the circunstances and shall be in accordance with these instructions, procedures ...." Contrary to the above the following were noted: . es* N e
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The required quarterly su==ary of abnormal occurrences, by Procedure SAO-124, " Reporting of Anomalous Conditions" was not,available and apparently had not been written.
b.
Procedure 2AD-9, " Conduct of Operation" states in part: , " Charts - all charts to be naintained as follows: 1. --, 2. --, 3.
Pens checked for proper inhing at 1 cast once per watch".
Two (2) different two (2) pcn recorders were not . inking on one pen each for periods beyond one watch period.
3.
Procedure Inadequacy 10 CFR 50, Appendix B, Criterion VI requires, in part: " Measures shall be established to control the issuance of docucents, such as instructions, procedures, and drawings, including changes thereto, , which prescribe all activities affecting quality.
These ceasures shall assure that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel and are distributed to and used at the location where the prescribed acti-vity is performed".
Contrary to the above the following was noted: a.
Procedure QA-AD-11, " Calibration and Control of Measuring Tools, Gages and Te.st Equip:ent for use on Class "A" Com-ponents" failed to include all of the minimum requirenents (accurney to which it can be used) of the controlling pro-cedure, SAO-117.
Licensees Actions on Previously Identified Enforcement Itecs Not Inspected Unusual Occurrences A.
Accuuulator Boron Concentration * The revicu of the Watch Forcean's Log, November 20, 1974, input indicated a continuing difficulty in maintaining boron concentra-tion at or above 2000 ppm as required by Technical Specifications.
- Reference letter from Licensee to Director of Regulatory Operations, Region I, November 21, 1974
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f The licensce's interpretation on reportability of this and refer-
enced* previous occurrences is that a Limiting Condition for opera-tion was not violated, therefore, these occurrences are not con-sidered.as reportable abnormal occurrences.
This item is considered to be unresolved.
(Details, Section III, Paragraph 3)
B.
AO 4-21-74 - Closure of Boric Acid Injection Tank (B1T) Valves ' The abnormal occurrence resulted in an engineered safety systea component failure which could have rendered the system incapable of ! performing its intended safety function.
Valves on the boron . injection tank rgquired to open started to open then went closed.
! The series valves that would remain open until the BIT would empty went closed.
' The valves were recycled open when the stripped light bus was re-instated.
The cause was due to an error in wiring one of the low level bistables to a lighting bus.
Corrective action was taken by the licensee to avert a re-occurrence of this and similar events.
(Details, Section III, Paragraph 4) This item is closed.
. - ' Other Significant Finding.s ? A.
Current Findings , l 1.
Non-Deficient Items The following nreas were inspected with no open, unresolved or nonconformance items identified.
a.
General Employee Training.
(Details, Section I, Para-graph 2) b.
k'clder Performance Qualification.
(Details, Section I, Paragraph 5) Replacement Training /ilot License Training for Licensed c.
Personnel.
(Details, Section I, Paragraph 6) l
- Reference letter from Licensee to Director of Regulatory Operations, Re'gion I, November 21, 1974
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Licensed Operator Requalification Training-Completed Pro-gram Items.
(Details, Section I, Paragraph 7a) e.
Personnel Qualifications.
(Details, Section II, Para-graph 3) f.
Review.
(Details, Section II, Paragraph 4) g.
Document Control.
(Details, Section II, Paragraph 7) . h.
Surveillance Testing and Inservice Inspection Program.
(Details, Section II, Paragraph 9) 1.
Management of Quality Assurance Program.
(Details, Section II, Paragraph 14) j.
Plant Malfunctions, Failures and Abnormal Occurrence Reporting.
(Details, Section II, Paragraph 13) k.
Tests.
(Details, Section II, Paragraph 16) 1.
Control of Special Processes.
(Details, Section II, , - Paragraph 15) . m.
Audits-Planning and Scheduling.
(Details, Section II, Paragraph 6) Test and Measurement Equipment - Calibration / Standards.
n.
(Details, Section II, Paragraph 17) 2.
Open Items The following items are open because, while action to be taken i was defined, progress was insuf ficient to be properly evaluated at this time.
a.
Maintenance Personnel Training.
(Details, Section I, Paragraph 3) ' Details, ( b.
Instrument and Control Personnel Training.
Section I, Paragraph 4) ! l , I - I en-e - e-
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,3 ,. . , - .. ~7- . Licensed Operator Requalification Training - Incomplete c.
Progree Items.
(Details, Section I, Paragraph 7b) d.
Inspections.
(Details, Section II, Paragraph 5) e.
Preventive Maintenance.
(Details, Section II, Para-graph 10) . f.
Procurement Control'- Vendor Approval.
(Details, Section II, Paragraph 11) 3.
Unresolved Items The following items are unresolved because proposed corrective action is not sufficiently defined.
a.
Design Changes and Modifications.
(Details, Section II, Paragraph 8) . b.
Maintenance.
(Details, Section II, Paragraph 10a) c.
Accumulator Boron Concentration.
(Details, Section III, Paragraph 3) B.
Status of Previously Identified Unresolved and Open Items The disposition / progress / current status of each of the twelve (12) open and f our (4) unresolved items resulting f rom the Quality Asrurance Manual review phase of the inspection documented in Report 50-286/74-20 is delineated in Details, Section II, Para-graphs 2a through 2p.
At the close of this inspection, six (6) itcas remained open and one (1) item remained unresolved.
Manar,enent Interview An exit management interview was conducted on-site at the completion of the inspection with the following licensee attendecs.
Mr. G. Beer, Director of Quality Assurance Mr. H. Bennett, Maintenance Superintendent Mr. R. Bo:ck, Instrument and Control Repair Engineer Mr. R. Burdge, Nuclear Training Director Mr. H. Cairns, Supervisor-Construction Inspection Mr. S. Cantone, Chief Engineer _ _ _ _.
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-8- , Dr. A. Cheifetz, Radiation Safety Director Dr. G. Coulbourn, Manager-IP3 Construction Mr. W. Ferreira, Stacion Quality Assurance Engineer Mr. J. Halpin, Reactor Engineer Mr. L. Kauula, Test Engineer Mr. J. 1:elley, Station Chemistry Director Mr. J. Mahepcace, Chief Engineer Mr. S. Salay, Station Manager Mr. M. Shathouski, Reactor Engineer Mr. U. Stein, Manager-Nuclear Power Generation Mr. R. VanWyck, Manager of Nuclear Services l Mr. G. Ussilenko, Manager-Quality Assurance Engineering Mr. J. White, Quality Assurance Project Engineer The following summarizes the items discussed: A.
General Employee Training.
(Details, Secticn I, Paragraph 2) B.
Maintenance Personnel Training.
(Details, Section I, Paragraph 3) C.
Instrument and Control Personnel Training.
(Details, Section I, i Paragraph 4)
D.
Welder Performance Qualification.
(Details, Section I, Pa.ragraph 5) E.
Replacement Training / Hot License Training for Licensed Operators.
(Detailc, Section I, Paragraph 6) F.
Licenced Operator Requalifichtion Training-Completed Progran Items.
(Details, Section I, Paragraph 7a) G.
Licensed Operator Requalification Training-Inco=plete Program Iteus.
(Details, Paragraph 7b) 11. Report 50-286/74-20.
(Details, Section II, Paragraph 2)
I.
Personnel Qualifications.
(Details, Section II, Paragraph 3) J.
Review.
(Details, Section II, Paragraph 4) K.
Inspections.
(Details, Section II, Paragraph 5) L.
Audits.
(Details, Section II, Paragraph 6) M.
Docu=cnt Control.
(Details,,Section II, Paragraph 7)
N.
Design Changes and Modifications.
(Details, Section II, Paragraph 8) O.
Surveillance Testing and Inservice Inspection Program.
(Details, Section II, Paragraph 9) P.
Maintenance / Preventive Maintenance.
(Details, Section II, Para-graph 10) Q.
Procurcuent Control.
(Details, Section II, Paragraph 11) R.
Receipt and Storage of Equipacnt and Materials.
(Details, Section II, Paragraph 12) _.
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. (Details, Plant }!alfunctions, Failurcs, and Abnormal Occurrences.
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Section II., Paragraph 13) , ) (Details, Section II, T.
llanage.cnt of Quality Assurance Program.
Paragr:ph 14) (Details, Section II, Paragraph . U.
Controls over Special Processes.
15) (Details, Section II, Paragraph 16)(Details, Section II, Paragraph'17 ! V.
Tests.
W.
Test and Measurement Equipment.
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Routinc Operations.
(Details, Section III) l i
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- .. , . . . ... . . DETAILS GENERAL SECTION . 1.
Persons Contacted The follouing list of persons were those contacted during the course of the inspection conducted and documented as Section I, Section 11 and Section III of this_ report.
Consolidated Edison Company of New York, Inc.
Mr. R. Altadonna,' Field Engineer Mr. N. Altocare, Reactor Operator Mr. M. Andersen, Senior Vacch Foreman Mr. E. Arecudo, Reactor Operator - Substitute Mr. E. Babudri, Senior Production Technician Mr. L. Baer, General Supervisor - Instrument and Control Mr..G. Beer, Director of Quality Assurance Mr.11. Bennett, Maintenance Superintendent Mr. W. Bennett, Secretary-Nuclear Facilities Safety Committee '- Mr. A. Bobih, General Vo tch Foreman Mr. C. Bockhold, Jr., Nuc1 car Siculator Director Mr. R. Bozch, Instrument and Control Repair Engineer l'r. R. Burdge, Nuclear Training Director ik. R. Burr, Corrective Maintenance Engineer Mr. M. Bush, Storekeeper Mr. H. Cairns, Superviser - Construction Inspection Mr. S. Cantone, Chief Engineer Mr. C. Caputo, Engineer - Test ik. W. Carson, Engineer - Test Dr. A. Cheif etz, Radiation Saf ety Director - 1x. J. Conuny, Chairman-Guclear Facilities Scfety Committee Dr. G. Coulbourn, Manager - IP3 Conctruction Mr. A. Decher, Preventative Maintenanco Engineer Mr. W. Dief f enbagh, Senior Engineering Technician Mr. P. Dziadik, Reactor Operator In Training l'r. K. Eccleston, Mcchanical Engineer ik. E. Eich, Acting Performance Supervisor Mr. W. Firreirra, Station Quality Assurance Engineer lir. S. Fiorito, Senior Electrical Technician Mr. J. Fischur, Reactor Operator
Ms. D. Fleisher, Secretary 11r. R. Gordon, Director of Quality Standards and Reliability lir. J. Grob, Jr., Chief Mcchanical and E= missions Control Engineer Mr. J. Italpin, Reactor Engineer lir. N, Harttnn, QASR Consultant i _..., ._ - . . . - - - - - _
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.. , 11- . - . tk. M. Hayes, Reactor Operator ik. G. Hoskey, Supervising Engineer Mr. M. Hughes, Senior Watch Foreman 12. E. Imbimbo, Health Physics Supervisor Mr. J. Kawula, Test Engineer Mr. J. Kelly, Station Chemistry Director Mr. T. Kline, Engineer . Mr. J. Kohnken, Chemistry Supervisor Mr. T. Law, Director of Technical Engineering Mr. P. Lawrence, Senior Reactor Operator Mr. W. Lettneden, Senior Reactor Operator !!r. R. Lobue, Senior Production Technician Mr. H. Longano. Engineer Assistant - Planning Mr. J. Lowney, Chief Design Engic.ecr ^ ik. J. Ibkepesca, Chief Enginc.; Mr. C. FEnnscian, General Supervising Engineer Mr. J. Mooney, Senior Staff Assistant - Instrument and Control lir. B. !!orovey, Unit Engineer , 15. J. Mullen, Assistant Supervisor Mr. A. Respoli, Operating. Enginnar Mr. J. Odendahl, Senior Electrical Tcchnician Mr. J. O'Neill, Senior Uatch Foreman Mr. V. Perry, Jr., Supervicor of Field Operations lir. A. Polcz, Manager '{cchnical Services and Developr.cnt Department , Mr. I. Polircr, General Supervisor - Instrument and Control , Mr. F. Poplees, Senior Production Technician Mr. S. Prof etn, Chemistry Supervir.or Mr. R. Redding, Senior Reactor Operator Mr. H. Reizenstein, QA&R Consultant 1k. S. Salay, Station Fhnager lir. R. Says, Division En3 ncer - T.lectrical Engineering Department i tir. J. Schechan, Engineer Mr. J. Schuartz, Technical Assistant - Receipt inspector Mr. 11. Shatkovski, Reactor Engineer ik. T. Silco, Supervisor , Station Administration l Mr. R. Sicac, Chief Engineer l lir. D. Snith, Chief Conecpt Engineer Mr. U. Smith, Unit Instructor Mr. C. Sofia, Quality Assurance Engineer Mr. W. Stein, Ibnager - Nuclear Power Generation 12. J. Sullivan, Maintenance Forecan ik. W. Thompson, QAER Consultant Mr. P. Upson, Chief Construction Inspector lir. F. Urbin, Chief Field Inspector Mr. R. VanUyck, lbnager - Nuclear. Supervisor Mr. R. Vogel, Mechanical Design Engineer Mr. P. Waldo, Central Files Coordinator - - - - ,- ,e -- - - - - -+ _
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-12-Mr. R. W::rren, Security Supervisor Mr. G. Warilenko, lUnaj:cr - Quality Assurance Engineering Mr. W. Watson, Senior Reactor Operator lir. W. Ueber, Sr., Mce.hanic "A" lir. V. l'culer, Incervice Inspection Coordinator Mr. J. White, Quality Assurance Project Tngineer Mr. S. Zulla, Acting Operating Engineer . . e l i one * -
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f3 - , . .. . DETAILS SECTION I - TRAINING . 1.
Persons Contacted See GENERAL SECTION 2.
General Enclovce Training
The inspector reviewed the training provided for regular employees with respect to the requirements of 10 CFR 19, ANSI N18.1 - 1971, and 10 CFR 50, Appendix B, Criteria II, V and XVII.
The following, baced upon discussions held with and documentation furnished by licensee personnel, sutaarizes the inspector's findings.
a.
Radiological Health and Safety Training The liccnace's progrco requires that personnel receive training and examination covering the following subject areas.
(1) Health protection probices associated with radiation.
(2) Methods / techniques to ifnit/ minimize exposure.
(3) Dosc/ exposure limits delineated in 10 CFR 20.
(4) Reports availabic pursuant to 10 CFR 19.13.
(5) Responsibility to report conditions which could cause violations of AEC requirements or which could cause unnecessary exposure to radiation.
(6) Requirements for and use of protectivo clothing.
b.
Facility Contingency Procedures Training Documentation indicated that training had been conducted in the following procedurcs.
(1) Radiation Emergency Procedures.
(2) Natural Disaster Procedures.
(3) Fire Procedures.
(4) Personnel Injury Procedures.
(5) Domb Threat Procedures, c.
Facility Access Control and Security Traininn Employces at the site are required to read and initial documents indicating the understanding of Station Administrative Order 128 - SECURITY PLAN IMPLD ENTATION.
This SAO describes the respon-sibilities of persons other'than guard force personnel.
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ouality Assurance Training Training had been documented for personnel assigned to the Operations and Maintenance Departments in accordance with the requirements of procedure TR-GAD-10 QUALITY ASSURANCE TRAINING PROGRAM FOR OPERATIONS /d:D MAINTENANCE PERSO::NEL.
Industrial Health and Safety Training e.
Documentaticn furnished indicated that a ststion-wide union / management Safety Meeting is conducted annually with attendance and subject matter recorded.
Sub-section supervisors meet on Sub-section a monthly bas,is to dir. cuss safety related matters.
supervisors also conduct monthly safety talks, usually from 5 to 15 minutes in length, with their sub-section personnel and submit documentation of attendance and subject matter to the Safety Director for retention.
(1) First Aid Training had been given to approximately 120 station personnel.
These persons had received instruction and certification based upon satisfactory completien of , the STl.::DARD >RILTI-MEDIA cource of the.*cerican National
Red Cross.
(2) Fire fighting training had also been conducted for station personnel assigned to the Fire Brigado by means of a one day Fire Fighting School.
to the General The inspector identified no deficiencies with respect Employee Training areas (a through e above) inspected and he had no further questions at this time.
3.
Maintenance Personnel Trainine, The training was reviewed with respect to ANSI N18.1 1971 and Summarized Criteria II, V, VI and XVII of Appendix B to 10 CFR 50.
below are the findings bcsed upon discussion held with and docu-mentation furnished by the licensee.
a.
Training Prouram Maintenance personnel training was not described by an approved and therefore there were no formal requirements in'this document,The licensec stated that a document was being drafted area.
which would formalize the current department training practices.
Until the referenced document has been approved, issued and and implecented, this item will remain open.
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-15- , . the following Even thcugh no formal requirements exist, training was scheduled and documented.
Quality Assurance / Quality Control-Job related.
(1) Training in the Technical Objectives of the job.
(2) (3) Indoctrination in applicabic procedures, including: , -(a) Preventative and Corrective Maintenance Procedures.
(b) Requirements for adherence to procedures and the - methods and reasons to change procedures.
(4) Job related Health Physics Training, including: (a) Contamination Control.
Exposure / dose Control.
(b) , Personnel monitoring equipment - requirements for and (c) . proper use of.
(d) Personnel and equipment decontamination methods.
On-the-Job training, including: (5) Demonstration of proficiency in the use of tools and (a) ; equipment used in the job ponition.
Related technical training, including vendor taught schools.
(b) (c) Experience or training in the tests and inspections that the individual performs.
and measurement Familiarity with inspection, test, (d) equipment normally used in the performance of assigned jobs.
, b.
Documentation and Records The Ideensee discussed the possibility of controlling and coordinating all training records in one place as the respon- ' sibility of one individual; however, no specific commitment was This item is not considered to be deficient in that made.
education, experience, qualification, training and retraining All the records were produced when requested by the inspector.
items listed under 3a above were documented with the exception of item 3a(3)(b) which was verified by direct questioning of two individuals selected by the inspector.
Until the licensee commitment to set down and formalize the program has been net, this item remains open.
Instrument and Control Personnel Training . 4.
This area of training was also reviewed against the requirements of . and Criteria II, V, VI and XVII of Appendix B to ANSI N18.1 - 1971 As in the Maintenance Training, no formal procedure had 10 CFR.50.
. yet been approved and issued; however, an ILC Training procedure has . pe**e'
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. been written and the document was under review at the time of this inspection.
The summarization of this area of training is the
same as for the Maintenance Personnel (see Detail 3a and 3b) with ' the following cdditions: a.
Training Procram (1) Indoctrination in applicable procedures included, in addition to those described in Detail 3a(3): (a) Tagging and switching procedures.
(Verified by direct questioning of three (3) individuals selected by the inspector) (b) Surveillance Testing procedures.
(2) On-the-job training, in addition to the items listed in Detail 3a(5), included provisions to rotate individuals " in the perforr.ance of the various routine tasks.
, The lack of an approved procedure describing and requiring the training in this departcent was the only identified open item.
5.
Welder Performance Oualification . The inspector revicued the' licensco's records with respect to the pertinent requirements delineated in Section IX of the ASME B&PV Code and Criteria II, V, IX and XVII of Appendix B to 10 CFR 50.
The Indian Point Station uses wolders qualified and supplied by the Power Generation Maintenance Department.
During this review, only the plant maintained records were reviewed.
In addition to the requirements listed above, the licensee's procedure, QA-GAD-4, Rev O, CL\\SS A WELDI;;G OPERATIO::S N?D CONTROLS was used as an inspection standard.
The results are summarized below.
- a.
Welder / Welding Procedure Records The following records were caintained at the site.
(1) A record of the procedures, including the essential variabics, under which welders are examined and certified.
' (2) A record of the qualified welding procedures, and a list of the welders qualified to perform cach procedure.
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(4) The identifying symbol used by each welder.
The inspector had no further questions in this area.
6.
Replacement Training / Hot License Training for Licensed Ouerators.
The inspector reviewed the training program to verify that: the curriculum covered the examination subjects listed in 10 CFR 55.21 and 55.22; the practical training records and other documents were available to support an application in accordance with 10 CFR 55.10 (a)(6); other aspects of the training program met the requirements set forth in ANSI N18.1 - 1971 and the licensee'c procedure, SAO -
108, Rev. O, TRAINING POLICY.
The following summarizes the results of that revieu, a.
Curriculug During the training program, all license candidates are trained at the SRO level.
The documented curriculum included: (1) Principles of reactor operation (2) Features of facility design (3) General operating characteristics (4) Inntruments and controls (5) Safety and emergency systems (6) Standards and emergency operating,rocedures (7) ' Radiation safety and control (8) neactor theory (9) Radioactive caterial handling, dicpocal and hazards (10) Specific operating characteristics (11) Fuel handling and core parameters (12) Administrative procedures, conditions, limitations.
b.
On-the-Job Training On-the-job training is obtained from an on-site sinulator.
The siculator is codeled after the characteristics obtained during the actual operation of Indian Point Unit 2.
This training consisted of both simulation of day-to-day operations as well ~ as startups, shutdowns and simulated abnorcal operations and transients.
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Evaluation The training program was evaluated by written examinations and quiz:cs, oral examinations and walk-throughs, and by practical operations demonstrations.
d.
Documentation The documentation revie'ved encompassed at least the following: (1) Details on course of instruction given; (2) Course attendanca records (number of hours and which courses); (3) Simulator training rcccived; and (4) Records of startup and shutdown experience.
c.
License Performance , The group of license trainees reviewed started initially uith twenty-one (21) persons.
Prior to the Commission examinations, . the licensee dropped five (5) persons so that sixtcon (16) individuals sat for licenses.
All sixteen persons were to roccive licenses, thirteen (13) Senior Reactor Operator licenses and three (3) Reactor Operator licenses.
The inspector had no further questions in this area.
7.
Licensed Operator Recualification Training i l The Directorate of Licensing stated in a letter to the licensee dated October 31, 1974 that the proposed Indian Point Units 1, 2 and ! 3 requalification pror, ram for licensed operators and senior operators submitted on December 17, 1973, and the additional information sub-uitted on August 15 and October 21, 1974 met the requirements of Section 50.54 (1-1) of 10 CFR 50 and Appendix A of,10 CTR 55.
The collection of documents, referenced above by Licensing, were the , bases used for the inspection of this area of training.
i a.
Completed Program Items (1) Personnel have been assigned to administer the progrca.
(2) Lecture schedules are promulgated and followed.
a
(3) Systems have been established by which management evaluates program participants.
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- . . . . . . . . . -19- - (4) A system has been established for accomplishing the required . on-the-job training of operators.
(5) Reactivity control manipulations are being cade as required by the program.
(6) Required course c::nminations and periedic examinations,are being evaluated to determine the need for additional training.
(Also see Detail 7b(2) below) (7) Corrective actions, defined in the progtem, are being initiated when grade criteria are not net.
(See' Detail 7b(2) below) (8) Changes to syste=s, procedures, and Technical Specifications are being reviewed.
In addition to the inspector's record revicu.of this area, two (2) licensed operators were questiened on the cont'ents of a Technical Specification change submitted Septe=ber 6, 1974.
No attempt was made . to evaluate the conpetency of the operators to stand a watch, but in esch case the inspector verified that the operators were familiar uith the essential elements and limitations of the change.
(9) E=ergency and abnornal procedures are being reviewed and , documented.
This iten was verified, in addition to record revicer, by the direct quest ioning of another inspcc or selected licenced operator.
The procedure reviewed with the operator was titled E-3 LOSS OF TT.ED'.'ATER, Revision 1, dated 1/18/74.
Again, no attempt was cade to evalute the competency of the operator uith respect to watch standing.
The celected operator was famil.iar with the operator action defined in the procedure.
, The inspector had no further question in this area.
. b.
Incomplete Pro?, ram Itens , The items listed below were not, nor were they required to be, completed at the time of this inspection.
(1) The first annual examination, consisting of'four (4) parts, had not yet been completed.
All licensed operators (34) had completed section one of the first annual exac-ination; three (3) operators failed to attain the required .... ,m ._
. - .. ,, . -20 - seventy (70%) percent.
Approximately r.ix (6) operators had cocpicted part two; all attained greater than 70%. The first annual examination is required to be completed by December 17, 1974 unicss an extension is granted by the Operator Licensing Branch of the Directorate of Licensing. This item is open.
(2) The licensee's program requires (Section 2a) that persons attaining less than 70% on an examination part will receive training in the areas of weakness and a written follow-up cxamination.
The three (3) individuals which fell into this' category had been handled as follows: (a) Two (2) individuals hcd been given the required re-training and had successfully passed the required written re-examinationu.
(b) The remaining individual was scheduled for vacation, but his re-examinatica had been scheduled for December 3, 1974. This item $s open.
(3) The specified s.imulator training for Unit 2 and 3 parsonnel required that, during a two year cycle, at least two simulator training days will be devoted to casualty and abnornal operatiens f or training and evaluatinn. This iten:, required prior to Deccaber 17, 1975, was not yet completed and remains open.
Items 7b(1), 7b(2)(b), and 7b(3) are opeu and will be reinspected.
. 9 M
. - . . . - _- . . .. . .. . ~ o .. . . DETAILS SECTION II - O/A PROGRA'4 IlfPLE}!ENTATION l.
Persons Contacted ' See GET!.RAL SECTION - , d 2.
Report 50-286/75-20 The Quality Assurance 1bnual review phase of tha Operational Quality Assurance Program inspection identified open and unresolved items which were documented in Report 50-286/74-20.
The Details from that report which described those items are listed below along with the status of the respcetive items following review during this
phase of the inspection.
a.
Detail 2
The liccunce's co mitment, documented in the reference Detail, has not yet been incorporated as a progran requirement.
This item remains open.
i . . b.
Detail 3a i Recently issued procedures and procedure revisions, rcviewed during this inspection, indicated improvccent in the area of l cross-referencing.
In addition, efforts to combine / eliminate procedures was currently undervsy (see 2e belou).
Personnel interviewed on-site indicated a working imouledge of the pro-gram heirarchy of procedures (Policy Docur.cnt - Station Ad-ministrative Order - Concral Administrative Directive - Depart-nent Administrativc Directive).
While this process of revising and codif ying procedures will continue as an ongoing policy, and while the procedure heirarchy has caused conflicts between procedures (sce Details, Section II, Paragraph 17.b), the concerns addressed in the original open ite::: are considered f to be satisfied since core specific concerns are addressed l elsewhere in this report.
This general item is closed; specific items are addressed in other Details.
. l , . es age e m 7es --47- -c- ,, - .-r; .-- g
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c.
Detail 3b The licensee's training program, including those items identi-ficd in the ref erenced Detail, was reviewed during this in-spection and the results arc documented as Section I of this As indicated in Section I, the specific concerns de-report.
lincated in the referenced Details were satisfied.
This general iten is closed; specific open items for training are covered in Details, Section I of this report, d.
Detail 3e . The licensees program has not yet been revised to include t.he specific program review requirements covered in the referenced Detail.
.
This item remains open.
. e.
Detnfl 4 The actual reference procedure, TR-G.*d)-9 L'UCLE.AR PUJ;T OPERATOR RETRAINING PROGRAM, had not yet been revised to include the requirc:.cnts to factor design changes into the program..The , licensee stated that a manual, combining all of the Training General Administrative Directives into one document, was current]y being reviewed f or approval or rejection.
2The licensec further stated that if the composite Training -}bnual is adopted, the }Snual would bc revised to include the refcronced requirement; if the }baual is rejected, TR-GAD-9 l would be reviced to include the referenced requirement.
f This item remains open.
f.
Detail 6 All of the procedures referenced in. the subject Detail were cither furnished prior to or during this inspection.
( This item is closed.
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': . '. ' ' > . . - .. . . ~23-Detail 7_ g.
Memoranda to several Depart =cnt Heads, containing instructions to include the Director of Quality Assurance on the distribu-tion lists of quality related procedures, were shown to the Houever, all departmental Administrative Directives which control the preparation and distribution of departmental inspector.
procedures and directives had not yet been revised to include the new distribution requirement.
i This item remains open.
h.
Detail 13b(1) The licensee stated that all permanently installed instrumenta-tion for thc Reactor Protective Systems and the Engineered Safeguards Actuation Systems was covered by the Technical Speci-The licensee additionally fication surveillance requirements.
in his opinion, the referenced surveillance actions stated that, satisfied the requirements of Criterion XII of Appendix B to 10 CFR 50 for permanently installed instrumentation.
" Measures shall be established Criterion XII requires that: tools, gages, instruments, and other measuring to assure that and testing devices used in activities affecting quality are properly controlled, calibrated, and adjusted at specified periods to maintain accuracy within necessary litics".
, l The licensce's position, stated above, nas made during the exit Therefore, an RO:I reviac to deternine l canagement interview.
if all instrumentation required by the Criterion vac included in the licensco's stated program was not completed during this This determination will be cado during a future inspection.
inspection.
This item remains unresolved.
1.
Detail 13b(2) The departmental Administrative Directives which control the preparation of maintenance and surveillance procedures, requir-had not yet been ing the use of censureccut/ test equipment, revised to include the requirements that only controlled and calibrated equipment be used and that the particular equipment used be identified.
This item retains open.
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Detail 13b(3) The subject Detail indicated that the departmental (5) procedures which implemented SAO-ll7 were not furnished to RO:I for review with the 1!anual.
During this inspec-tion four (4) departmental implementing administrative directives (PE-AD-8, TE-AD-3, QA-AD-ll and C-AD-6) were The results of the requested, furnished, and inspected.
actual inspection of each procedure is documented in Paragraph 17 of this Details Section.
Since availab'ility was the open item identified in the referenced Detail, this item is closed.
k.
Detafi 14 Procedure PE-AD-20, STORAGE AND HANDLIMG OF CLASS A MATERIALS, Revision 0, was approved and issued on Ncvember 15, 1974, satisfying the concern documented in the refer- < enced Detail.
. This item is resolved.
, 1.
Detail 15 The tagging and suitching procedures identified in the refercuced Detail, while not included as part of the Manuni submittal to RO:I, vare available at the site.
Since availability was the open item identified in Detail 15 of Report 50-286,/4-20, this item is closed.
l Detail 17b m.
The temporary pen and ink changes made during the meeting as documented in the referenced Detail had been translated into Revision 1 to Procedure QA-GAD-2 uhich was approved and issued on November 22, 1974.
' This 'ccm is closed.
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Detail.17c n.
The review of surveillance test results specifically for i identification of possible trends, identified as unresolved in the referenced Detail, had been included as a specific in Procedure TE-AD-5, SURVElLLANCE TEST PROCEDURE requirement
ISSUANCE ANP REVIE1 PROCESS, Revision 0, dated November 13, 1974.
. 9, This item is resolved.
s
i o.
Detail 18b t The licensee requested, and was furnished, acplifying inf orma-tion on the issue of filing s'.pplemental/ revised information The licensee reiterated identified in the refe'renced Detail.
to include appropriate filing instructions in his commitment the Quality Assurance Program; however, these items have not - yet been included.
This item remains open.
Detail 18e . p.
Based on his review of the item identified in the referenced Detail, the licensee stated, in his opinion, i.ppendix B to 1.0 CFR 50 does not specifically require that records received for storage must be checked to verify that they agree with any attendant transmittal documents.
FO:I revicu indicated that the specific action is Subsequent The required by ANSI N45. 2.9 - 1974 (Section 5. 3, Item 3). licensee is not committed to follow the requirements of ANSI N45.2.9 - 1974 at this time.
this The inspector had no further questions on this item at time.
3.
Persennel Quali fications Using the education, experience and background requirements deline-and SNT-TC-1A as ated in applicabic sections of ANSI N18.1 - 1971 the bases, the licensce's records were reviewed for individuals filling the following positions.
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Station ihnager b.
Chief Engineer c.
Plant Engineer d.
Director of Technical Engineering e.
Two (2) Senior k'atch Foremen f.
Teo (2) !bintenance Torenen g.
Supervisor of on-site Q/A Group-h.
Two (2) Senior Reactor Operators 1.
Three (3) Licensed Reactor Operators j.
Two (2) Machanics "A" k.
One (1) !;DT Technician - Level II 1.
One (1) Chemistry Technician m.
One (1) Reactor Engiucer One (1) Instfument and Control Supervisor n.
Documentation indicated that all personnel selected for this review met the applicable requirements.
No deficiencies ucre identified.
4.
Revicu Discuncions with the Station Ibnager indicated that he is cognizant of commitments set forth in the on-site revicu charter.
. Further discussions indicated that the Station Ihnager is cognizant of the controls cnd responcibilitics established to assure that the f ollouing is accomplished in a timely manner: i Review of Completed Surveillance Test Data ! Review of Completed Corrective 'bintenance Status of Inservice Inspection Contract ' Review of Operating Records and Logs Review of Chemistry Review of Preventative >bintenancc The Station Manager conducts a daily critique with the Chief Engi-neer, Operations Engineer to discuss areas of concern.
}bjor ' occurrences are reviewed immediately.
Interview with the Chairman of the Of f-Site Independent Review.
Committee indicated that he was knowledgeable of the review commit-monts required of his group.
No nonconforrnnces vert identified.
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Insocctions a.
Equirrent Inspections (1) Personnel responsible for equipment inspection, including those in operations, u.aintenance testing and QA, were questioned to determine that they were cognizant of their responsibilitics., The personnel questiened were all . fa=111ar with their recpensibilities.
(2) The following three maintenance activities were evaluated to determine that appropriate inspection had been per-formed: Restraints SR8A Maintenance Work Request 3141 Charging Pump Number 23 lbintenance Work Request 3231 Pressurizer Valvc 1hintenance Work Request 2758 lhintenance Ucrk Requect 3134 on Restraint SnSA contained the follouing statenent: "The Chief Field Inspector shall select a representative comple of the restraints recoved and replaced and arrange for inspection to verify that the restraint is properly installed with proper oil level.
All data shall be logged en a QCIR".
No inspection data had been recorded on QCIR's since iby 15,1974.
The Chief Field Inspector stated he had beat perforaing a sarpling inspection on the restraints cince Fby, however, had not recorded the results.
He stated that the amount of sampling to be used would be established and inspection data vould be recorded.
This is an open item.
b.
Personnci (1) The Receipt Inspector uns interviewed to ascertain if he l vas f amiliar uith the written receipt inspection proce- ' dures.
No nonconformances ucre identified.
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Receipt Inspection Records (1) A sample of receipt inspection records were reviewed to verify that: (a) Required inspections were accomplished (b) The components matched inspection records descriptions (c) The components can be positively traced to their respective records.
No nonconformances were identified.
The following items were selected as -the sample nentioned (2) in (1). ' (a) High Pressure Valve, S/N BFD78 (b) Shafr Seal Pump, S/N 9-618J711G03 No nonconformances were identified.
A revicw indicated no safety related raterial was being (3) stored off-site.
No noncenformances were identified.
, . 6.
Audi ts Planninc and Scheduling n.
< The implerentation of scheduled audits and cudit requirements were inspected.
The Quality Ansurance and Reliability (QSSR) Itnager was (1) interviewed to determine his understanding of his respon-sibilities in the areas of : l Approving Audit Procedures (a) Detercining the adequacy of the qualifications of (b) audit personnel Determining the need for special training of audit (c) personnel Determining the independence of audit personnel (d) (e) Assuring corrective actions are taken for deficien-cies identified during audits.
, I No nonconformances were identified.
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.- . . . .. -29- . . (2) The following documents were reviewed: -(a) QA-7330 (Independent Construction Audit Program) , (b) QA-7430 (Startup Testing Auditing) (c) INT-ADMIN-1.0 and Addendun 1 (Test Program Adminis-trative Guidelines) (d) IPR-3051 (Conduct of Indian Point 3 Inspection Activitics - Ccastruction Phase) . (e) G. Salay Memo' 1/5/72 (Preoperational Testing) (f) G. Salay Memo 6/25/73 (Test Supervisors -duties and responsibilities) (g) File Q4-A (Weekly plan of projected inspections for 10/29/74 and 11/3/74) No nonconformances were identified.
(3) The following QS5R scheduled audits of Unit 3 Startup and Testing activities were reviewed.
(a) First Quarter 1974 - Construction Phase (Control of veld rod, velding and NDE) (b) First Quarter 1974 - Preoperational Testing (c) Second Quarter 1974 - Construction Phase (d) Second Quarter 1974 - Precperational Tcsting (c) Third Quarter 1974 - Preoperational and Startup Testing No nonconfornances were identified.
(4) The f ollowing QSLR Audits of operations activitics were reviewed.
(a) Third Quarter 1973 - Audit of Indian Point Units 1 and 2 (Health Phycies and Radiation Centrol).
(b) First Quarter 1974 - Audit of Indian Point Operational Nuclear Power Facilities (preparation, review, cnd control of design docunents and the Environmental l Monitoring Progran) ! l (c) Second Quarter 1974 - Audit of Indian Point Operational Nuclear Facilitics (handling and storage requir.em?nts, inservice inspections, and onintenance-and modification controls) i l I No nonconforcances were identified.
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.. - , , , - .. -30- . . The following construction quality control inspection, (5) startup and testing surveillance reports were revicuedi (a) Termination and running of Unit 3 computer, 4/19/74 - PSV (b) Prcoperational checks on Unit 3 computer, 5/14/74 - PBV (c) CCR and Air Conditioning Testing, 6/20/74 - PBV (d) Resctor Coolant System Cold !!ydro, 9/29/74 - CAL 1 (e) Reactor Coolant System Cold Hydro, 9/30/74 - CAL 1 (f) Primary Auxiliary Building Charging Pump, 31 Test, 9/23/74 - EUE f uel racks friction load testing,10/2/74 (g) Spent , - CAL 1 ' (h) Functional testing of diesels 31, 32 and 33 - FJ 1 (i) Ucekly Activity Reports, 11/12/74,11/13/74, and 11/19/74 No nonconf ormances vere identified.
The audits performed on the following vendors /supplicrs (6) in order to qualify them for the " Approved Vendors List" (AVL) ucre reviewed.
. (a) GUYON ' (b) American Alloy (c) Chicago Dridge and Iren Limitations and restrictions as to what con be purchased from certain vendors and/or other required actions-is not preccatly appearing along with that corpany's name on , f A new format for the AVL, which will list all the AVL.
i such pertinent inf ormation, is under development.
This in an open item.
7.
Document Control Systen Evaluation a.
The document control synten was evaluated for implementation as defined by the program.
This included: _. _...
_.
. . __ _ - . o . , . ., e-31, - (1) Perscancl responsible for the review and approval of . procedures were questioned to determine that they were cogniaant of their responsibilities.
(2) Perscnnel and supervisors involved in the distribution and codtrol of documents were questioned to deter =ine that they were cognizant of their responsibilitics for.
the distribution centrol and removal of obsolete pro-cedures and drawings.
(3) Four Procedures, AP-GAD-5 Revisica 1, AP-GAD-7 Revision 0, 3AD-2 Revision 3 and 3AD-7 Revision 3 were verified as properly issued and filed in the control room.
(4) Ten on-site drawings were checked against the corporate j engineering files to deternino that they were the correct ! revdsion.
The drauings chached were: , C186678-2 A179471-1 141347-17 F10273-3 UESC A210000-1 A210007-1 A160589-1 A2100SS-0 A178277-1 A210034-1 . ( . No deficiencies were found.
! (5) Six procedures ucre verificd as containing acceptance criteria.
They were: 3PT-V1 Muclear Sourec Range . . 3PT-V2 Nucicar Inturr.adiate Range l 3PT-M8 Secom Generator Level 3?T-M2 OTAT and OPAT 3PT-M4 Pressurizer Level 3PT-M3 Reactor Coolant Level Tent
j (6) Tuo modifications were verified as containing all the current design changes.
They were: i L'aste Gas Centrol Medification , Order 73-1-01 dated 5/15/74 and Breech Block Assembly McJification, Modification ! Order 72-1-04 dated 4/26/74 .
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.. . . . .. -32- - . All personnel questioned uere cognizant of their responsibili-ties and all items verified were being accocplished in accord-ance with the applicabic procedurcs.
b.
Followun and corrective Actions The licensec's followup and corrective actions were reviewed for one area (Instru=cnt and Control Department) of one audic (last quarter of 1973) with the f ollowing results.
(1) 10 CFR 50, Appendix B, Criterion XVIII requires, in part: "A comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program".
QA-7320, CONSOLIDATED EDISON AUDIT PROGRI.M FOR OPERATIONAL NUCLE-\\R FACILITIES, Revision 0 dated October 24. 1973 statec, in Section 5.3.2 h d_f_t Conduct, Item c): "c) Im-plementation of procedures by the station shall be audited in sufficient depth to determine compliance or delineate nonconforr.ance".
. . (a) The Operational Audit of Indian Point Units Non. 1 and 2 for the last quarter of 1973 identified an Item A.c.4 which reads: " Instruments past due on the recall cycle chart ucre found to be in use.
Action responsibility: NPG".
The reaudit of the same item, conducted in September 1974, according to the licensee, states: "Ninctcon instruments past due on recall chart were noc avail-able for examination and not signed out.
Three were identified on the list as 'cannot be located'. It must be assumed that they are in-use out of calibra-tion".
SAO-ll7, CALIBRATION AND CONTROL OF MEASURISG TOOLS, GACES AND Ti'.ST EQUIPMENT FOR USE 0" CLASS "A" NUCLEAR SYSTEM, states on page 2 of 3 that: "Whenever an item is beyond the required calibration duc date, a red tag will be affixed indicatin-g it cannot be used until it has been calibrated".
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. In violation of the quoted sections of both Cri-terion XVIII and QA-7320, the initial audit cad the reaudit failed to verify compliance uith all espects ~ of the quality assurance program and failed to audit in sufficient d:pth to deterninc compliance or delincate nonconforcance in that they both failed to identify the quoted prevision of SAO-ll7 which'was also applier.ble in this area.
As a direct result,of these failures, a violation was writtcn during this inspection as documented in paragraph 6b(2)(a) ef this Details Section.
(b) The Operati'onal Audit of Indian Pofnt Unit Nos. 1 and 2 for the last quarter of 1973, identified another iten, A. c. S which recds : "An instrument history file suitable for trend analysis is not being maintained.
Actica responsibility: NPG".
The reaudit of the same ites, conducted in Septcr.ber 1974, accord *ng to the Id eensec, states: "The status of this item.is unchenged.
This finding is considered open".
PE-AD-8, CALIERATION AND CONTROL OF MEASURING AND - TEST EQUIPMr.NT. Revision 1, with an ef fective date of June 19, 1974 (between tha first audit and the renudit) requires in Sectica 4.3, R _ cords, in part:
".... Each record shall idcutify the iten to "hich it cpplies, the procedure or instruction folleued in performing the calibration if donc in-house, the identity of the one perforning the cal.ibration, and the calibrat ion date (Sce Attachacnt 2 and 2A).
In violation of the quoted (See' (1) above) sections t of both Criterion XVIII and QA-7320, the reaudit failed to verify complianec with an aspect of the quality assurance progrt.m to conf oru with the c:.:acple given in Attachment 2 of the quoted procedure.
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. (2) 10 CFR 50, Appendix B, Criterion XVIII requires, in part: ".... Follovup action, including reaudit of deficient areas, shall be taken where indicated".
10 CFR 50, Appendix B, Criterion XVI requires, in part: " Measures shall be established to assure that conditions ndverse to quali,, such us failurcs, malfunctions, deficiencien, deviatiens, defective caterini and equip-ment, and nonconformances are promptly identified and corrected".
QA-7320, CO::SOLIDATED EDISON AUDIT FROGRA51 FOR OPERA-TIO"AL NUCLEAR FACILITIES, Revision 0 dated October 24, 1974 states, in Sectica 5.5 Follow-t:p, that: "Reaudits shall be scheduled as necessary to insure that corrective censures have beun effected or rene3ial action initiated".
(a) The nonconfernance item identified as Iten A.c.4 in - the last quarter audit (see 6b(1)(a) above) was also observed by the inspector during this inspection, one year citer the 1:ca was originnily identified.
In addition, the iten was still unresolved and no remedial action had been initiated.
L'hile rec,ognizing the duality of the responsibility to provide follovup and corrective cetions; and while recognizing that two (2) different organizations are involved; the licensee controls both organizations and the failure of either or both organizations to produce the required results is in violation of both the quoted sections of Criteria XVIII and XVI as well as the quoted section of QA-7320.
8.
Design Channes and Modifications a.
Design Change Control Representative perr.onnel in all organizations responsible for activitics related to design change control, including Tech-nical Specificatien and 50,59 type chan;as, were questioned to determine that they were cognizant of their responsibilities.
All personnel questioned were familiar with their responsi-l bilitics.
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f b.
Desicn Verification 10 CPR 50, Appendix B, criterion III, states in part: "The design control neasures shall provide for verifying or check-ing the adequacy of design, such as by the perf ornance of design reviews, by the use of alternate or simplified calcula-tional rcthods, or by the perfor:suce of a suitable testing.. The verifying or checking process shall be performed program.
by individuals or grcups other than those who perforned the original design, but who may be f rom the same organization.
"As the Engineerin; Procedure EP-7, Paragraph 3.3.e states: drawings required f or the job are completed, they shall be subjected to a design review and check by an individual of the Design Engineering Section other than the originating designer to chech th:t the design is proper and functional".
This fails to deceribe neasures to implement the requirement.
This is an unresolved item.
9.
Surveillence Testing and In-Service Inr.necti<n Pm.rt.m The follouing twenty-five surveillance test procedures vere reviewed to verify that personnel engaged in the surveillance program at Indian Point are meeting their asrigned responsibilitics: Source Range, PT-V-la Diesel Genera tor, PT-M21 Turbine Electrical 0/crspeed, PT-M13 l Centrol nod Excrcise, PT-LU-l Axial Off-set Calibrction, PC-M1 Pouer Range, PT-M1 Primary Coolant Plou, PT-M3 Pressuriner Level, PT-M4 Pressuriser Pressure, PT.$ ' 6.9 Kv Under Voltage, PT-M6A 6.9 Kv Under Freq mney, PT-M6B Rod Position, PT-M7 Steam Generator, PT-MS Contain:.ent Pressure, PT-M9 Area Radiation Monitors, PT-M10n Steam Line Pressure, PT-Mll Turbine First Stage Pressure, PT-M12 ' Safety Injection Logic, PT-M14B - - - -
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' ' , x . . s , o . .. . -36- . . Saf ety Injection Pumps, PT-M17 Containment Spray Pumps, PT-M19 Station p,atteries, PT-M22 Ilydrogen Reccabiner, PT-TM1 Dattery Charger, PT-Q1 Cable Tunnel Vent, PT-M16 , Intermediate Range, PT-V2 The above tests were related to the Unit 2 Technical Specification surveillance test requiremants, in particular Section 4.0 and Table The revieu indicates that surveillance tests are addressed.
4.1-2.
The " Periodic Test' Report" which is a scheduling system for planned surveillance tests was also reviewed and compared to Technical Specification rcquirements.
The review resulta indicates that the master schedule (Periodic Test Report) is in accordance with require-ments of the Technical Specification.
The following observations reflect adninistrative control over sur-veillance test procedure approval currently in usa at Indian Point: The cover page contsins the titic, designation of a periedic secuence, frequently for performance and revision notation.
Instructions are included for the subsection to which the procedure is directed.
The procedure contains the designation of the author, space f or revicuer, signature and subsection approval, including date for each.
Designated space is provided f or the on-site review committee SNSC and off-site review committee approval and date.
The procedures contain a control sheet for designating equip-ment needed to run the test with space for equipment serial numbers, title, users initial and date.
A review of th master listing reficces a similar approach is being taken to address Indian Point Unit 3 surveillance test requirements.
It appears that the approach will be in accordance with the same control documentation of Unit 2.
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. - > l-37- \\ - ~ j . The following procedures reviewed validate the observations that i q the licensee is in accord with his established controls, except ' where noted'. Nuc1 car P.,uer Gencrption, NPG, Muclear Service a.
Re f eren e_e : Section fWninistrative Directiva No. TEAD 2, Rev. 2 approved October 16, 1974.
The intent of the above procedure is to define controls necessary to assure that the Test Procedures. .are properly developed, reviewed and approved prior to in-plcmentation.
Ref erence: Station Administrative Order No. 102, Rev. 3, b.
>by 23,1974. " Procedure / Procedure Chante Anproval Policy".
This procedure contains directions for procedure / procedure changes that clearly do not involve safety related components and/or operat.icns of sa=e, in the opinion of the appropriate subsection head, approval by hi:9. to be sufficient.
Further reference to Paragraph 2.1.2 of this procedure indicates If a procedurc/ procedure change does involve safety that... related components e.nd/or operation of sese a preicplcnentation review by the SSSC is required unless an c=ergency is dccced SNSC review to exist by the appropriate subsection hend.
should.be performed on the first following vorking day.
l The inrpcetor neted that SNSC had not reviewed 19 of the sample of 25 surveillance test procedures inspected.
It app' ears the surveillance test procedures required by the Technical that Specifications are safety related and therefore are required This is an apparent by SAO-1C2 to be rev Lewed by the SSSC.
, violation.
and Test Intervicus with the Test Engineer, Engineer-Test, Director indicate that these persons understand their respon-sibilities.
Three approved surveillance test procedures were reviewed to verify that system and equipment are returned to norcal following testing or inspection.
Verification that forcal require cats have been established for including in the test procedur.rs specific identification of temporary or permanently instal 3cd test measurement equipment to obtain perfor=ance data.
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f comm .,... - -. - __ ,m.., - -...... - - _ _, ._.
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- . ., - -38- . The thrce approved surveillance test procedures were also revicued to assure that they were included in a master testing and scheduled in accordance with Technical Specifi-cations.
They were also reviewed to assure that the pro-cedures were approved in accordance with the licensec's established controls.
The three procedures reviewed were: Reactor Coolcnt Flow Analog Channel Test PT-M3, Rev. 5, approved October 5, 1974 Pressurizer Level Analog Channel Functional Test PT-M4, Rev. 4, approved October 8, 1974 Pressurizer Pressure Ana3 cg Channel Functional-Test PT-MS,*Rev. 3, approved October 13, 1974 The Unit 3 surveillan'ce proc 2dures are being developed. The licencee has stated that a total of 129 surveillance test procedurcs will be written and ir.plemented.
Currently there are 116 written of the 129 total.
The 13 remaining procedures are in the refueling and three year cycle schedule category.
Five surveillance test precedures were reviewed for testing method to assure the meeting of requirements of the Technical Specifications.
.
The following surveillance test procedures were reviewed in detail to determine that provisions existed for assuring systems and equipment are returned to normal status and that the identity of utilized test and censurc=ent equiptent is recorded.
IPC-N-S-00S (The Primary Sampling System) IPC-S-036 Revision 1 (Sampling of Waste Distillate Storage Tanks) PT-M21 Revision 3 (Diesel Generator Functional Test) The Diesel Concrator Functional Test procedure lacks specific-clarity.
The Test Department intends to revise certain para-graphs and their sequence.
This is an open item.
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. -39- - . The following surveillance test procedures were reviewed in detail to assure the described testing methods were tech-nically valid.
"IPC-A-041 Revision 0 (hydrazine, Colorimetric Determina-tica by Dimethyl minobenzaldehyde) a PT-M19 Revision 2 (containing spray pucp test) PT-M2 Revision 9 (overtemperature AT and overpower AT). PT-M21 Revision 3 (Diesel Generator Functional Test) Nuclear Source Range Test PT-V1, Rev. 5, approved November 4, 1974 The voltage settings limit appear to be inconsistent with the (Ref. page PT-V1-1).
Also page PT-Vl-2 puts boundarie.s set.
a limit of 2,30GV c'.iich is inconcistent with page PT-Vl-2 in-structiens.
The licensee has ar,rced to change the instructions to cli=inate any possible confusion.
This is an open item.
Diescl Generator PT-M21 6. 9"V Undervoltage PT-M6A Turbine First Stage Pressure Analog Test, Rev. 5 PT-M12 : Para 3.23 appears to have one step lacking to ansure the proper removal of the DVM and insertion.
, The licensee has agreed to add the step into the procedure.
This in an open itcm.
10.
Maintenanec/ Preventive Maintenance a.
Maintenance The maintenance program implementation uas evaluated as follous: (1) Personnel responsibic for mainten:nce activitics including those in the cperations, maintenanec, quality assurance, and testing orr.anizations were questioned to determine that The they were cognizant of their responsibilitics.
twelve personnel questioned were all f amiliar with the procedures in their areas of responsibility.
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. .s-4 0- . . . (2) Five maintenance activitics including one emergency nain-tenance, and tuo requiring personnel.with special~ quali-fications were evaluated.
The evaluation included a determination that the =ainten-ance activity had been properly approved, the procedures to which the maintenance ucs performed were identified and available, and that all checkoffs, inspections and tests were properly defined and comp]cted.
Also the qualifications of personnel ucre verified as being current and correct.
Two deficiencies were identified.
One related to in-spection of licintenance Werk Request 3141, which is explaincd in Details, Paragraph 5.a.2, and one related to the overall control of the naintenance package which is explairged in Paragraph 3 below.
' The remaining items were being accomplished in accordance with the applicable procedures.
The five caintenance activitics cva]uated were: Charging Pump Numbar 23 - >hintenance Work Request 3138 Pressurizer Safety Valve - lbintenance Work Request 2758 Restraints SRSA - lbintenance Ucrk Regn.:ut 3141 . Charging Pump I-:unber 23 - Shintenance Work Request 3231 Charging Pump ::umbor 23 - -hintenance Work Request 3118 (3) SAO-104, thintenance Work Requests Procedure, Revision 4, " Paragraph B states in part: .... Enclosure (2) is a conveni<nce item cnd the blanks ara to be used as desired by the ucer...." Enclosure 2 is the second sheet of the thintenance WerT: Request and appears to identify items pertinent to tha maintenance work such as the requirement for precedurcs, chechlists, etc.
Since SAO-104 Joas not , require the enclosure 2 to be cc:pleted it cannot be deturnined, in all instances, that the maintenance pack-age is complete c*ther during performance of or following - the raintenance.
This is an unresolved item.
b.
Preventivo j:,intenance
The Preventive thintenance Program for Indian Point 3 was reviewed with the preventive }bintenance Engineer.
He cthted that the program was being established using the same system as is being used for Indian Point 2, and it uns expected to be scheduled and impl(mented within six months of the operating licensing date.
This is an open item.
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-41-11.
Procurerent Control a.
Personnel (1) Key persons from purchasing, planning, quality assurance, and operations ucre intervicued to determine ~that they understood their responsibilitics, basic methods of con- ' trol, and that they had ready access to proceduren, directives, etc.
No nonconformances were identified.
b.
Procured Items / Suppl-tes (3) The following itens were selected as samples for the revler described in (2).
(a) Shaf t seal pump, S/N 9-618J711G03 (P.O. 2-42900) (b) 3/6" Schedule 160 ASTM 376 piping, lleat Number 0G105 (P.O. 4-43713) (c) liinh Pressure Valve, S/N BFD 78 (P.O. 3-12360) (d) Power Supply, S/N 2818463 (P.O. 3-32168) (e) Reiny CV7. Style 1875524A (P.O. 3-10011) (f) Micro Limit Switch, Catalogue Number 51ML1 (P.O. 3-8719) (g) Flexbolt Joint, S/N BB-31020-66-ll (P.O. 4-43048)
(h) Casket, 3Q73 (P.O. 3-44466) (1) 903 Schedule 10 LR Ell, P. cat Number JAAD (P.O. 2-8485, Item 39) (j) Silicone Fluid SF1154 (P.O. 4-8773) (k) Sulfuric Acid (1) Numbcr Two Diesel Fuel ! The procurement of number two diesel fuel is discussed in (2). . (2) The procurement documents for items listed in (1) were reviewed to verify that the following requirements were met.
(a) Items were purchased froa " qualified" vendors / suppliers (b) Approvals were accomplished according to established controls (c) Appropriate vendor / supplier quality documentation was specified ... , _ .. .. -
.., . . , < , . -42- - . . (d ) Items could be positively identified and traced to respective documents Scoring inadequacies of the " Approved Vendors List" were noted and are discussed in 5.a. (6).
Criterion VII. of 10 CFR 50, Appendia: B. states in part: "lfeasures shall be established to assure that purchased material.... conform to the procurement documents.
These measures shall include provisions, as appropriate .... examination of products upon delivery".
Contrary to the above, no activity existe to assure the acceptability of the delivered or stored number'tuo fuel oil procured f or the Eccrgency Diesel Generators.
This is an apparent violation.
, 12.
Receip_t and Storace of Ecuipuent and threrials a.
Konconforuint Items . (1) Three ite:ec ucre selected to confirm that they had been: (a) 1:arhed and segregated (b) Physically located to ;.revent in:Jvertent use (c) Identified ca ncnconforming to Effected organiz tions (d) Documented as nonconferuing (2) The itcas selected for purposes of verification in (1) were: '
(a) Ca te Valve, S/N 351-1 (P.O. 2-4475) l (b) Power Supply, '!adel 610 AT-2 (P.O. 3-9143) l (c) Piping Sub-Assembly, Sh: 406-857-114 (P.O. 3-12544) t l l No nonconformances were identified.
[ b.
Storanc Environecnt (1) The f ollowing documents were reviewed: (a) PE-AD-20 (Storage and I!andling of Class A Materials)- (b) Kanager, QA l'xaninntion and Evaluation to Project }!anager :'eno, July 5, 1973.
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, - . , =. - .. ,.. - -43- _ - ' ? , (2) Th:re _wcre no items presently in storage that required ,special protective environment conditions.
(3) The items listcd in c. (2) were properly stored.
Test and Inspect _3_en Status Ef "sterial and Ecuipment c.
? < ' -(1) Sin items were colecic'd '.a verify that : (a) Receipt inspection and testing records were readily available (b) Records accurately reflected the items' status y ~ ~ (2)' The f ollowing items were eclected as camples for veri-fications performed in (1).
~ (a) Shhft Seal Pump', S/N 9-618J711G03 (P.O. 2-42900) ^
- (b)
Casket, 3Q73 (P.O. 3-44466) ' (c) liig;t "rcosure Valve,' S/N BFD 73 (P.O. 3-12360) (d) 3/L" Schcdele 160 ASTM 376 Piping, Heat Number ~ 00105 (P.O. 4-43713) (c) P69er Supply, S/N 23-18463 (P.O. 3-1216S) (f)' _ Relay CV 7, Style 'le75524A (P.O. 3-10811) . No nohtonfornar$ces were identified.
13.
P? ant Malfunction. Fa llerere and Ibn'ar al Occurrences The inspector interviewed persons responsibl e f or initial identifi- ,' catian, subsequent revicu,. evaluatien and reporting of abnormal ! - ocetirrences.
i ' Senior Reactor Ogggat or ' ' a.
The Senior Reactor Operator interviewed indicated that he re- , i ports any occurrence involvi::n the operation of the plant that appears to be out of what is normally expceted.
Ile will ' questien any event or observance that doca not relate to what has been normal practice.
An example would be tlye question-ing of the need to add' makeup water to the volume control ! tank twice per hour where once per hour was the norral l, frequency.
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. . . .... - , . -44-He reports anything out of the ordinary to the 1:atch Toren n.
Thf is normally done by direct conversation.
The Watch Fcreann usually notes dcun in the log.
He vill evaluat e an out of the ordinary conditien as it re-later to the corrent cendition of the plant and have the reactor operator take spccific chcehs.
b.
Watch Forent:n The Watch Torc =an intervicued indicated that a significant occurrence is brought to his attentica through centact with the operator.
Fuch rcports criginste in both the nucicar and convention:] side of the plant.
The occurrence is usually transmitted to the Untch Foreman frca the Senicr Reactor Operator.
The '.atch Tore:nn also ccn observe the occurrence.
- Ht! nico revicv., the surveillcnce tect results r.nd identifies significant occurrences.
The Watch Terem n notes the cecurccnce in the U:tch Fore.an's Log and designates a partini number.
He also writes the Signi-
ficant Occucrence Report, SOR.
The operations engineer vill cceplete the SCR nu.:ber and review the S0R.
The Uatch Fonr.:n does not evaluate el e SOR f or abnornal occurr-ence status.
He docs initiate innediate action to resolve the significant occurrence.
c.
Operation Engineer l The Operation Engineer intervicued indicated that the sources l of a significant occurreace are the following: l Periodic test l Senior Reactor Operator l Watch Porc :an
! The Operation Engineer investigates the SOR as it related to becoming significant to be considered an Abnortal Occurrence.
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-45- . . { He decides and notes his decision on the SOR form.
The Opera- ' . tion Engineer notes his cc:.ments on the report to substantiate his decisions.
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Chief Ennincer All SOR's go to the Chief Engineer.
The Chief Engineer either Concurs or doed not concur.
. . A final agreement is reached and all SOR's are sent to the Technical Director who assigns the l' nit Reactor Ergineer a review function with respect to concurring on SOR's that are < narhed as not being Abnormal Occurrences.
If the Reactor Engineer does not concur, then there is a j mceting with the Operaticms Engineer, Chief En;incer Tech-nical Director and Roc'ctor Engineer to evaluate conclusions ' along with dctorr:ining if indeed it is to be categorized as an Abn rmal occurrence.
. e.
Reactor Enc.i,ncer Once a SOR is categori::cd as an Ab:4creal Occurrcuce, the Tochaical Director or his designee, Reactor En;;incer, contacts Regulatory 0,'erations by phonc and written docu:acnt to trans-mit the inf or:.ation.
Tha initial contacts are followed by repart uithin 10 workin;:' days of the occurrence.
Contact is made with "0:1 only of ter the Technical Directer or his desig- + nee, the Reactor Engineer gets authorization f rcm the Depart-ment Manager to nake the report to R0:1.
All abnorcal occurrences go to the S:!SC for review.
If the significant occurrence report is not designated as an A0 the Reactor Engineer will file the report.
lic does review
the contents and make.rocommendations to Operaticas.
! SORS are primarily the responsibility of Operations to initi- ' ate corrective action.
There are no requirements that SOR's are reviewed by the SNSC.
A duplicate copy of S0ns are kept by the Operations Engineer.
It appears that the persons interviewed understand their responsibilitics as reficcted in their directives and procedures.
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, . -46- , Ref erence S'.0 124. "Reperting of Anonalous Cond!:f ons" Uhile reviewin; SAO-124 it was noted that the procedure requires a quarterly sunnary repar: en the ctatus of abnornal occurrentes.
The inspector noted that ene had been written uhare there should have been tuo with a third in preparation.
This is an apparent violation.
14.
G3ngpement of Quality Arturance Fronram a.
Quality Acr.urance _ P.asonnel Respensibilities Quality Assurance personnel at all organitational lercis were questicacd re;ardin;, their knuv cdge of a: d their r:frpensibi-litics to define and impicncat the quality assur:nce program.
All perscnnel quartioned were ec3nizant of their rc;ponsibi-liti es.
15.
CanLrol of Specin] Procc tes The following specific special procerses uere seiccted by the in-spector from tbc liccnsce's rpcords and were reviewed with respect to Criteria V and IX of 10 CFR 50, Appendix 3.
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Welding The volding completed on the C";S Charging Pump on October 10, 1974 had bacn pcrfu.med by a qualified velder usir.g e qualifi.d welding procedure,.?-7283, C/A '.s'cidinE and Austenetic S:ain-less Steci Pipe uiJi "0V preparation according to the licenscc furnished recordt.. No deficiencies were identified.
. b.
Ultraconic T:< amin tip_:5, The ultrasonic cra ination record selected for verification was perforced on June 1, 1973 by a qualified'(Level II) technician in accord.:nce with.i qualified procedure, QA-7301 - EXMll : ATIC: OF CInCU: TERE::TIAL PIPE WELOS, Revision 0, dated rebruary 8, 1973 No deficiencies were identified.
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Chenistre Analysic A ch$nistry sample of the Mu=ber 23 Accu =ulator on Unit 2 was observed from collectica through analysis.
The Senior Prod;:ction Technician proccccing the sanple cet the qualifi-cation requirecents for his position.
While the boren ] analysis was perf erraed in r.cacral accord with an existing .
procedure (the stcps not pcrferced ucre designed to eliminate l interference which snould not be prcrent in the sanple taken, ! and which if present and not recoved, uculd yield results i which vere in the core conservative direction), the existing procedure was not availabic in uriting in the P.adiochenistry Laboratory. - V. hen nanagement uas alerted to this fact, copics
of all procedures performed in this lab were cado availabic ' in the Radiochemistry Laboratory.
The actual sauple observed produced results which were out of Tcchnical Specification , i r equir ce ents'. The inspectica of this espect is documented under Unusual Occurrences in the Surer.ry of Findings with ref erence to the appropriate Details scetion and paragraph.
Sec Details, Section III, Paragraph 3.
With respect to th: perfort:nce of the analysis, the inspector ' l had no further c.vections.
. 16.
_T_e s t s , a.
Test ur snonsibili t.(e s . _ l l Personnel having responsibilitics for rcvicu, approval and l the conduct of tests ucre questioned to eleternine that they j were cognizant of their reopensibilitics.
All pert,onnel questicned ucre familiar uith their responsibilitics.
i 17.
Test and 'kuurement F3;,igent j_
This area was revicued with resp.ct to the requirements of Criteria II, V, VIII, XII and Xi'II of AppenJix B to 10 CPR 50 and the licen-cco's internal procedures with the following results.
Calligation/ Standards l a.
With few exceptions, the major portion of the portabic measuring and tent equipment used by the Instrument and l . - eesp * o- -e .:-, -
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rie--wr+- .-p-v-'--v- +,*-w ~w + - - - T-~'e= m ,
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-48-Control Departtent is calibrated at the licensec's Technical Services and Development Department located in Ncv York, New York.
An inspection of those facilitics indicated that: (1) Procedurer. are used to calibrate instrumentation.
The two (2) examplec reviewed were: (a) Procedure fot Testing Ind$cating Wattacters - TI.10.37 dated October 23, 1974 (b) Procedure for Calibration of Standard Phase Angle !!eter - TL.10.11 dated January 26, 1966 (2) The stcrdards used in the calibration facility were trace-abic to primary standards.
The tuo (2) cxareples revicued were: (a) Stardard Resistor - 100 olns - Scrial 5206935 - Certified traceable to the ::ational Eureau of Stan-dards and for accuracy cu July 16, 1974.
(b) Volt nox - Scrial #103452 - Certified traceabic to the ::ational Bureau of Standards and for accuracy on August 6, 1T74.
J ' (3) Each standard is controlled and recorded.
Records indi-cate when standards are due for recalibration/recertifi-cation.
The inspector identified no deficiencies with thic area of incpcetion.
b.
A&-Jnistrative Directive Inadecuacy The licensee bas established a procedural hierarchy.
For this particular area, the Policy Departcent, CI-240-1, establishes the controlling policies in Section \\'III - CC::TnCL OF ::EASUR15G AND TEST EQUIP::F.ST.
The general policies are anplified and specific requirements added in Station Administrative Order (SAO) 117 - CALIP.lt\\TIO:: AND C0:: TROL OF MEASURI::G TOOLS, CAGT.S.
AND TEST CQ'JIP::EST FOR USE ON C1.iSS A NUCLEAR SYSTD:S.
SA0-ll7 further requires (under Pesnonsib_i,1_i_t", en Page 1 of 3): "It is the responsibility of the Sub-Sections listed below to es-tablish and maintain calibration syctens within their groups: .. . ' ' ...
, . -40- . (1) Plant Engineer (2) D(rector, Radiation Safety (3) Dircetor, Technical !:ngineering (4) Quality Assurance Engineer (5) Chenical Director " The Quality accurance Administrative Directive (QA-AD) uritten to caticfy this requirement of SAO-117 was titled QA-AD-11,
CAtlimATIO:: A::D CONTROL Or :ZASURING TOOLS, GAGES, A"D TEST EQUIF:2::T FOR USE 05 CLASS "A" CC:!PO::ENTS.
SAO-117 further rcquires (updcr Cali_bratien Stichers_ on Page 3 of 3) that: "' henever neasuring or test equipae.nt is cali-brated a calibration stir.hcr will be af fi::cd to the equipnent.
. The enlibration cticker will include, as a mininua, the follow-ing information: Instrume nt/..iacsurement ec.uipment identification number , (.1) (2) Accuracy to uhich it can be used l (3) Calibration date i Duc date f or next calibration".
~ (4) QA-AD-11 is inadco,unte. in that the follouing requirements are "After acceptoble
listed in Section VII, Cali_bration S_ticher: completion of calibration, a calibration sticher shall be attnehed by the calibrcting agency to the equipmer.t or itsThe l its status ca', La deter::ined at all times.
case r,o that ' the follouing: sticher shall ecatain, as a ninimum, ! Tdentific: tion number (assigned by Con Ed - Indian Point) l (1) (2) Calibration date (3) Calibrating Technician (4) Calibration duc date".
i it does not include all This procedure is inadequate in that J of the minimum requirements (accurney to which it can be ' used) of the controlling procedura, SAO-ll7.
This inadequacy is a violation of Criterion VI, Appendix B I " ! cast,res'shall be l to 10 CFR 50 which requires, in part : cctabli.shed to control the issuance of documents, such as l
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,.. . ,. e ' -50- . . instructions, precedures, and drawings, including chenges thereto, which prescribe all netivitics af fecting quclity.
These reasures shall assure that docuconts, including changes, are reviuved for cdequacy and approved for release by autho-rized personnci cnd.are distributed to and used at the location where the prescribed activity is perf orned".. c.
Instrument Controls 10 CFR 50, Appendix B, criterien V requires, in part: "Acti-vitics affecting quality shall be prescribcd by doeutented in-structions, procedurcs or drawings.... and shall be accomplished in accordance with these instructions, procedures or drawings.
. In violation of the above, the followinc specific instructions and precedures ucro not folleted.
(1) S/.0-117, C/.I.!?ATION /2;D CO:: TROL 07 ::ZASURI :G TCOLS, GACES, Alm YEST EQUI:'4E::T FCT. L'$r. 0:1 CL/.S$ 4 :.UCLElJ. SYSIE::5, Revision 1, dated January 14, 1974, requires (under Apglication on P..ge 2 of 3): "Whencver an item is beyond the required calibratien due date, a red tag will be affixed indica:Ing ;het it cannot be used until it has been calibrated".
, Contrary to the above, Test Gages, IC-47, IC-48, IC-49 IC-0? IC-120, IC-132, 3 C-150, cnd IC-157 were at least one r.onth past their respsetive calibration due dates and, uhile they had been rc=oved from service, they did not have the required icd tag affixed.
-(2) SAO-117, Call!C/. TION 12:D CO::TRC'L CF 27./sSUR1r.G TOOLS, GAGES, /J:D TEST EQUJi':T.:*r FOR USC 0:; CLASS A NUCLEAR SYST ::S, Revision 1, dated Janucry 1, 1974, required under J5 ster List,en Page 1 of 3): "r.ach Sub-Section is responsible for twintaining a list of equipment under their. control.
The list will contain,.as a minicu.n, the foJ1owing: (a) Identification number, unique India'n Point Station a ssignmen t (assir,ned by Sub-Section involved)".
Contrary to the above, the Chemistry Sub-Section list did not have the required identification number for any of the instruments.
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i l ' . (3) QA-AD-11, CALIEPE N C:: /0:D CO:: TROL OF 11 EAST!RI::C TOOLS,
CAGES N D TEST EQUIP E:iT FOR USE 0:i CLASS "A" COMPO::E::T,
tevisica 0, dated October 31, 1973, requires (under 2.0, l B. Mar.tcr Lint), in part: "QA is responsible for main-taining a list of equipment under its control.
This list _ cust contaJn, as a minimum, the following: ... 4.
Cali-bration frequency, activity, date calibrated and cathod".
a - Contrary to the above, the 15cter List currently being maintained did not contain the required date calibrated.
(4) The requirements of recently implemented procedure CAD-6 are bain; accompliched.
A central calibrction file, Kardex File", hac bean established and as equip ant is "
recelibrated all required inforestion trill be recorded.
. Over a period of tic.c the sycton vill beccme fully docu-
cented.
, This is en open itc:a.
(5) The folle.cing itens ::ere selected as sa ples to verify impicnentation of calibration requirescats, ' i (a) Volt Potentienater, S/:! 157-2265 (TZ) (b) Conductivity Coll, S/:: 1295 (IPC 09) (c) Check Coil, tr.lon Regener.-tlon (Mcdel 115081) i l The chech coil did not possess the rcquired unique station identificacica (SAO-11*/). This is discussed i above in Details, Scction II, Paragraph 17.b.
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. . . , .. .. , . . DETAILS ' - SECTION III - RO'JTINE 0ER'.TIONS OF UNIT 2 1.
Persens Cent. acted See GENEltAL SECTION 2.
Watch Reifel ihree (3) inapectors ebserved routine shift operations and the 11:30 P.M. tratch relief conducted on Unit 2 on Tuesday night, Noven.be r 19, 1974.
One inspector observed the Senior '.'atch Fore-unn; one the Seniet "cactor Operator; and the other the Kcactor . Operator.
The actions of each of these individuals ear revicwed with respect to the licensee.'s requirements delineated in Admin-istrative Directive 2.0-9,, CONDUCT 0F OPEn?.TIONS, Revision 4, dated 7/10/74.
The follouing cu =ariv.es the reeults of the inspection.
a.
Loc,T:cohn Revieu The los'.>ooks mlutnined by the Senior n acter Oper.-tor and the . Senior Uatch Foret:tn ucre rcviewed for the forty-eight (40) h:>ur period proceding the inspection.
No deficiencies 1.cre identified by thr Innpoctors.
. , < . h.
Shift Turnover Pcvics: > Prior to the actval shift turnover, each of the individuals 8 noted under 2 aheve were quactioned to detomine t hat infor- ' matica..nd actions ucre required by 2AD-9 to be panned on to , the relieving eliift.
An ine pector tioni tored the cetual untch reltrf at cach of the three (3) positionr.. No deficiencies ucro identified by the inspectors.
, I i
c.
Charts
-- , During the period prior to uatch relief, the charts care ^in-
spoeted to deteruine if the requiret.ents listed in 2AD-9 were being carried out.
Section 3.1 of 2A')-9 states in part : " Charts - All charts are to be trtintained as follows: 1....... ' 2....... 3. Pens checked for proper inking at 1 cast once per watch."
.. _ _ ,
. -- - ~ _ . - --._ . . - - . . , , . - . .. ! .. , . - -53- . d .dcrs During the inspection, two (2) dif ferent two ( were feend to be not inking on ene pen for d*' rhs of time, but both grcater than one watch.
Specli (1) !;o. 1 Scal Return Hi Pur;;c for Renctor C.
, and 24 had not inked on the red pen for (90) hours.
I (2) 1;o. 1 Seal Return Hi Purge for Reactor C.
?1 and 22 had not inked on the red pen for c (15) hours.
The failure to comply with the specific requf AD-9 chnical i quoted above is a violation of both the Indi: Specification 6.8.1 and Criterien V of Appcr.d' TR 50,- Sectic.n 6.E.1 of the Indian Point 2 Technical ons requires in part: "6.8.1 Detailed uritten precedures ceve- .s listed below, including applicah' lists , and instructions, shc11 be prepar . as specified in Section 6.8.2, ami a
I 1;ormal startup, operation, and shu a.
reactor and of all systems and cor, ving nuclear nafety."
Criterion V stater. in part: , "Activitics af fecting quality shall be documented instructions, precedures, or .. and r.hnll be accompliched in accord::ic.
, instructicas, proredures, or drauirt,s.
' The problems with charts, while ucver befer.
violation, is a continuing problem.
This c:
- n previour.ly discussed and docunented in Inspc
. 50-247/73-25 and 50-003/73-20, Detail 4c oi.
, report.
Several licens:ca indicated that the psn in'c time relationship prc51tus identified here and di
- tg previous
rveillance inspections, were equipment problems and not deficicnetes. The inspector acknowledr.ed th state-ments. The inspector stated that, regard 3c .sc, the led.
procedural and eperational requirements had i ' , en-s e no. ..v-vv .- r,, . ,.e- - ,,, , ..% - ,- . -, - - - --,-. . ,
. , ,. , . -54- . 3.
Accumulator Borca Concentration The inspector reviewcd the Watch Foreman Log for Novceber 20, 1974 and the letter dated November 21, 1974 to the Directorate of Regu-intory Operations, Region I froa the licensec.
, . It appears that the licensee is having difficulty in naintaining ! 2000 ppa er g: cater in the accunulators.
The Technical Specification for Unit 2, Reference 3.3, Engineering Safety Features, 3.3. A. l.C, states that four accumulators are to be pressurized to at least 600 peig and each contain a specified ' volume of vnter with a boron concentration of at least 2000 ppm.
I The inspecter's po.Eltica uns that once the boron condition was found to be beloa 2000 ppm the licensee uns outside the Limiting Condition for Operation at that tirao and therefore required to send j EO:I an Abnornal Occurrence report.
The licensce's position was ' ! that cince power reduction was f uitinted af ter the value of less than 2000 : pr. vas ccnfir:ued, no report uss necessary.
This is an unresolved iten.
4.
/.0 4-2-21 Clenure of EIT Valves . , . The abnormal occurrence resulted in an engince rd safety system l componcnt failure which could render the nyctem incapab]e of per- ' forming its it; tended safety function.
Valves on the boren injector tank required to open ctarted te open then uJot closed.
The series i valvcS th.;L would remain open until the DIT was empty vent closed.
The valves operated correctly with respect to the signals received in the lot:ie circuit.
The malfunction was due to a hard wire error tihich apparently had existed sinec initial installation of the EIT level channels.
The as desir,ued systet require:. that these BIT valves open when there is a SI signal and close uhen the BIT is c ptied.
The closure is important to assure protection of the charging pump froa i l becoming air Jocked due to the over presnure en the BIT vhich forces the boric acid into the pump intake line.
The pumps re-inained in creration and had RWST water availabic for insertion at all ti=cs.
, l l
r _ - -,, - g y-m-w,- ,- - - g.._ - _ ~ _ - _ _ --m- - - - + -
, - . e . -
o a
v . . -55- . . The wiring was revised to provide power to the valves frcm an in-strument bus and the system was tested to be satisfactory.
The condition that precipitated this occurrence was due to the allowed use of a light bus as back up scurce of electrical power for an inctrument bus.
When an SI signal is received the design of the syrtc= requires that all lighting busses are stripped of power.
When this occurred 2 of the 3 level indicators on the LIT failed' low which required the closure of the BIT Series - parallel valves.
The licensee re-established the lighting bus and the valves cycled open to the correct position.
Re-establishing the lighting bus is normal practice after the strJpping action.
Ref SOR 74-2-77. 6/24/74 The Son indicated. that the reactor was at 100% pouer when a steca line t.P safety injection was received.
The reactor tripped.
The SCR indicates that the BIT valves went cloced for no apparent reason then went c;rn when the 1.ighting Pt.ncis ucre reset.
Upon resetir.n the SI the parallel valves closed as required.
ILC found the BIT tanh icvel transmitter B bistable wired to the lighting bus.
. Ref CM "0:corandom 22 Autust 1974 to Actin: Station Mr. nager fron Task Ypycp _Chntr;55n Subj ect : E port of Task Force Investigation Instrument Power Supplies. This meto indicates that investigations ucro conducted to deterr.ine that all instruments are being fed from their proper source (instrument bus).
The licensee has correctly wired the BIT, refer to 1."..'9.008691, tank level transmitter and has taken corrective action to avert a sinilar occurrence.
This iten is c~onaidered closed.
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