IR 05000003/1975005
| ML20050B630 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 06/12/1975 |
| From: | Mccabe E, Ruhlman W, James Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20050B628 | List: |
| References | |
| 50-003-75-05, 50-247-75-09, 50-247-75-9, 50-286-75-16, 50-3-75-5, NUDOCS 8204070006 | |
| Download: ML20050B630 (23) | |
Text
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IE I Form 12
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U. S. NUCLEAR REGULATORY COMMISSION
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OFFICE OF INSPECTION AND E!.TORCDIENT
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REGION I
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50-03
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50-247 IE Inspection Report No: 50-03/75-05,/ 0-247/75-09, 50-286/75-16 Docket No: 50-286 (
Consclidated Edison Company of New York, Inc.
License No: CPPR-62 4 Irving Place Priority:
C, C, B-1
Safeguards Group:
Location:
Buchanan, New York: Indian Point 1, 2 & 3 Unit 1, PWR, 615 MWt (B&W)
Type of Licensee:
Units 2 & 3, PWR, 2758 MWt (W)
Type of Inspection *
Routine',' Unannounced
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Dates of Inspection: June 2-5, 1975
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IP-1, May 19-22, 19 7 5 Dites of Previous Inspection:
IP-2, May 21-23, 1975 IP-3, May 2/-2o, 19/5 Rsporting Inspeetor:
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eden /
g-r e / 1 /9'f 5
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W. A. Ruhlman, Reactor Inspector
DATE Accotipanying Inspectors: [I 3k
,b /A ///5~
j J. T. Smith, Jr., Reactor Inspector DATE
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DATE
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Other Accompanying Personnel:
None DATE R viewed By:
$[/
7f E. C. !!cCabe, Jr., Senior Reactor Inspector DATE Nuc1 car Support Section
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e 8204070006 750612 PDR ADOCK 05000 Q
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SUmfARY OF FINDINGS
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Enforcement Action
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A.
Items of Noncompliance Infraction Contrary to the requirements of Unit 2, Technical Specification Section 6.5.1.6.e, the Station Nuclear Safety Committee had not investigated, evaluated, prepared and forwarded a report to the Chairman of the Nuclear Facilities Safety Committee for the four (4) violations of Technical Specifications identified in IE Inspec-tion Report 50-247/74-11 dated September 27, 1974.
(Detail 7.b(5))
B.
Deviations None identified Licensee Action on Previously Identified Enforcement Items A.
Report 50-247/73-19
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The licensee's actions on the items identified in Details 2, 3 and 4 were reviewed with the inspector having no further questions.
(Detail 7.a)
B.
Report 50-247/74-11 (50-003/74-09)
The licensee's actions on the items identified in Details 8, 11 and 12 were reviewed with respect to the letter to IE:I dated October 22, 1974 with the inspector having no further questions.
(Details 7.b(1)-7.b(4))
Unusual Occurrences A.
A0 3-2-15 The bulk of the licensee's corrective actions for this occurrence had been reviewed and documented in IE Report 50-247/73-22.
The documentation packages for the welding actions, the only remaining unreviewed. item, were reviewed with the inspector having no further questions.
(Detail 9)
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B.
Emplovee Injury
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The circumstances surrounding the non-nuclear-related injury of an employee on June 2,1975 and the licensee's actions to prevent
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recurrence were revieued with the inspector having no further questions.
Other Sienificant Findings A.
Current Findings 1.
Acceptable Areas (These are areas which were inspected on a sampling basis and findings did not involve an Item of Noncompliance, Deviation, nr an Unreralved Item.)
a.
Training.
(Detail 2)
b.
Procurement.
(Detail 3)
c.
Design Control.
(Detail 4)
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d.
Records.
(Detail 5)
e.
Quality Assurance Audits, 1974.
(Detail 6)
f.
Welding.
(Detail 8)
g.
Quality Assurance Progree Changcc.
(Detail 10)
2.
New Unresolved Item (This is an item for which more information is required in order to determine if the item is acceptable, a Deviation,
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or an Item of Noncompliance.)
a.
Follow-up for NRC identified Items of Noncompliance.
(Management Interview, Item j and Detail 11)
B.
Status of Previously Identified Unresolved (or Open) Items 1.
Report 50-247/73-19 Detail 9 - The licensee's practices / policies for evaluat-a.
ing vendor facilities and Quality Assurance Manuals have been documented in an approved procedure. This item is
, resolved.
(Detail 3.g(l))
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Report 50-286/74-20
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a.
Detail 2-CI-240-1 has been revised to include the re-quirement that the Quality Assurance and Reliability (QA&R) Department will review, in a timely manner, ad-ministrative documents which define and/or control the
implementation of the Quality Assurance Program.
This item is resolved.
(Detail 10.c(1))
b.
Detail 3.c - CI-240-1 has been revised to include the requirement for QA&R to regularly (at least every two years) review the status and adequacy of the Quality Assurance Program.
This item is resolved.
(Detail 10.c (1))
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c.
Detail 4 - The traf ing program for Nuclear Plant Operators has been modified to include the requirement for the review and inclusion of applicable design changes.
This item is resolved.
(Detail 2.a)
d.
Detail 7 - CI-240-1 has been modified to require the inclusion of the QA&R Department on distribution of procedures which implement the Quality Assurance Pro-gram.
(Detail 10.c(1))
e.
Detail 13.b(1) - The licensee has made a commitment to conduct a survey of permanently installed instruments and to dispose of the calibration requirements accord-ing to acceptable criteria.
However, the licensee's actions have not yet been completed. This item remains unresolved.
(Detail 7.c)
f.
Detail 13.b s2) - The required procedures have been appro-priately r;dified to require the use and recording of identification of calibrated instruments.
This item is resolved.
(Detail 10.c(2))
g.
Detail 18.b - The licensee's procedures have been modi-fied to include specific requirements for the meintenance of superseded documents and the licensee's system satis-
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factorily handled the filing of supplemental information
. for the items reviewed.
This item is resolved.
(Detail 10.c (3))
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-4-50-003/74-16; 50-247/74-16; and 50-286/74-23 3,
Combined Report Details,Section I, Paragraph 3.a - The Maintenance s.
Personnel Training Program has been set down and for-malized. This item is resolved.
(Detail 2.a)
Details,Section I, Paragraph 4.a - The Instrument and b.
Control Personnel Training Program has been set down and formalized. This item is resolved.
(Detail 2.a)
Details,Section I, Paragraph 7.b(1) - The First Annual c.
Requalification Examination had been administered to allerequired personnel. This item is resolved.
(Detail 2.b(3))
d.
Details,Section I, Paragraph 7.b(2)(b}
T? 2 remedial actions for the one remaining individual for whom actions were not completed prior to the end of the referenced inspections, had been completed in accordance with the approved program. This item is resolved.
(Detail 2.b(3))
Details,Section I, Paragraph 7.b(3) - The Simulator e.
training for Units 1, 2 and 3 personnel had either been completed or scheduled for conpletion prior to the December 17, 1975 deadline. This item is resolved.
(Detail 2.b(2))
f.
Details,Section II, Paragraphs 2.a, 2.d, 2.e, 2.g,
2.h, 2.1 and 2.o - These paragraphs are identical with the items previously identified in B.2.a through g above.
Paragraph 2.h, which corresponds to item B.2.e above, remains an Unresolved Item.
(See Details under B.2)
Details,Section II, Paragraph 5.a(2) - The requirements g.
with respect to snubber sampling following maintenance have been redefined and a program meeting the revised requirements was adhered to for the sample reviewed.
This item is resolved.
(Detail 7.d(l))
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h.
Details,Section II, Paragraph 6.a(6) - The Approved Vendor's List now specifies the limitations and restric-This item is resolved.
, tions applicable to each vendor.
(Detail 3.g(2))
1.
Details,Section II, Paragraph 17.c(4) - The required
"Kardex File" is now being maintained as required by CAD-6.
This item is resolved.
(Detail 7.d(2))
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Manacement Interview An Exit Ibnagement Interview was conducted at the site at the conclusion of the inspection on June 5,1975 with the following licensee attendees:
Consolidated Edison Connany of New York, Incorrorated Mr. H. Bennett, Maintenance Superintendent Mr. S. Cantone, Chief Operations Engineer Mr. W. Ferriera, Quality Assurance Engineer - Plant Mr. R. Hayman, Manager, Quality Assurance Monitoring and Review Mr. T. 1.aw, Quality Assurance Manager Mr. J. Makepeace, Technical Engineering Director Mr. S. Salay, Plant Manager Mr. W. Stein, Manager, Nuclear Power Generation Department Mr. R. VanWyck, Nuclear Services Manager i
The following summarizes the areas discussed.
a.
Training.
(Detail 2)
b.
Procurement.
(Detail 3)
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c.
Design Contrel.
(Detail 4)
d.
Records.
(Detail 5)
e.
Quality Assurance Audits, 1974.
(Detail 6)
f.
Follow-un of Previous 1v Identified Items.
(Detail 7)
g.
Welding.
(Detail 8)
h.
A0 3-2-15 Closcout.
(Detail 9)
1.
Quality Assurance Program Changes.
(Detail 10)
j.
Follow-up for NRC Identified Items of Monconnliance.
(Detail 11)
The inspector stated that the plant management controls for the follow-up of NRC Identified Items of Noncompliance, including. the assignacut of responsibility for completing corrective action and the documentation of corrective actions taken, appeared to be an area of weakness.
The licensee stated that this area could pos-sibly lead to problems in the future.
The licensee further stated
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that on or befor.e August 6,1975, a management control system for
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tracking and resolving NRC Identified Items of Noncompliance would i
be developed and implemented.
The inspector acknowledged the li -
censee's. commitment.
Until the licensee's commitment has been fulfilled,'this item is unresolved.
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DETAILS 1.
Persons Contacted
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Consolidated Edison Company of New York, Incorporated Mr. R. Astrad, Senior Reactor Operator Mr. H. Bahrenburg, Nuclear Engineer Mr. W. Bell, Planning Engineer Mr. H. Bennett, Maintenance Superintendent Mr. G. Bockhold, IMclear Simulator Director Mr. R. Bozek, Instrument and Control Repair Engineer Mr. M. Bush, Foreman, Storeroom Mr. M. Byster, Quality Assurance Engineer Mr. S. Cantone, Chief Operations Engineer Mr. L. Cass, Senior Quality Assurance Engineer Mr. E. Dadson, Manager, Contractor and Vendor Quality Assurance Mr. W. Ferreira, Quality Assurance Engineer, Plant Dr. A. Flynn, Chief Nuclear Engineer Mr. P. Gaudio, Health Physics General Supervisor Mr. C. Giarrizzo, Senior Quality Assurance Engineer Dr. R. Gordon, Manager,, Quality Assurance and Reliability Mr. J. Halpin, QualILy Assurance Engineer, Operations Mr. N. Hartmann, Consultant, Quality Assurance and Reliability Mr. R. Hayman, Manager, Quality Assurance Monitoring and Review Mr. W. Hill, Consultant, Quality Assurance and Reliability Mr. E. Imbimbo, Health Physics Supervisor Mr. L. Kawula, Test Engineer Mr. J. Kelly, Station Chemistry Director Mr. J. Kohmken, Chemistry Supervisor Mr. G.
Lake, Senior Electrical Technician Mr. M. Langham, Senior Quality Assurance Engineer Mr. T. Law, Quality Assurance Manager Mr. G. Liebler, Radiological Engineer-
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Mr. J. Lillis, Senior Electrical Technician Mr. J. Lomm, Assistant Quality Assurance Engineer Mr. J. Makepeace, Technical Engineering Director Mr. W. Monti, Plant Engineer (Contacted by telephone, not in person)
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Mr'. B. Moroney, Senior Engineer Mr. G. Morris, Inspector Mr. R. Ruck, Unit 1 Instructor Mr. P. Sadowski, Quality Assurance Examiner Mr. S. Salay, Plant Manager Mr. M. Shatkouski, Reactor Engineer Mr. R. Simms, Senior Technical Engineer
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Mr. W. Stein, Manager, Nuclear Power Cencration Department
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Persons Contacted - Consolidated Edison Coneanv of NY, Inc. (Cont ' d. )
Mr. W. Thompson, Consultant, Quality Assurance and Reliability Mr. F. Urbin, Chief Field Inspector, Quality Control Mr. R. VanWyck, Nuclear Services Manager Mr. P. Waldo, Central Files Controller Mr. G. Wasilenko, }bnager, Quality Assurance Technical Support Mr. W. Wedler, Inservice Coordinator Mr. R. Williams, Quality Control Inspector, Electrical and Instrumentation United States Testing Company, Incorporated Mr. C. Sheridan, Quality Assurance Engineer 2.
Training The results of the inspector's review of this area with respect to the requirements of 10 CFR 50, Appendix B, Criteria II, V and XVII; 10 CFR SC.54 (1-1) and the licensee's accepted Operator Requalifica-tion Program; and ANSI N18.1-1971 are summarized below.
a.
Progra-
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A full-time training staff and an onsite simulator are util-ized for training for NRC licensed personnel and for some training of non-licensed personnel. Most of the training in the areas of Safety, Security, Radiation Protection /
Controls, Instrument and Control Personnel, and Maintenance Personnel Training is accomplished by designated staff per-sonnel on a non-full-time basis. The entire training pro-gram is currently codified in a draft, unissued Training Manual.
Although the entire manual has not been approved, the Instrument and Control (I6C) Personnel and Maintenance Control Personnel (Plant Engineering Sub-Section) Education and Training Requirements / Practices had been approved and issued in May 1975.
The formalization of the Maintenance and I6C Training Program resolves two _(2) items previously identified as open in IE Report 50-247/74-16 as DetailsSection I, Paragraphs 3.a and 4.a.
In addition, the re-quirements of the Draf t Training Manual, Section 8.5.6, Item 25 and Section 8.5.7, Item 22, satisfy the licensee's commitment to include design change reviews in the Nuclear Plant Operator Training Program, thus resolving the Open Item identified in Report 50-286/74-20, Detail 4.
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Requalifiestion Program Particination A review of the licensee's overall program schedules, prac-tices and summary sheets indicated the following:
(1) Lecture schedules have been established for required lecture items.
(2) The approved program requires four (4) days of simulator training for Unit 1 personnel and ten (10) days for Unit 2 personnel prior to December 17, 1975.
Currently, nine (9) of fourteen (14) Unit 1 operators have received the required four (4) days and the other five (5) have received tvo (2) or more days and have been scheduled to complete the required training prior to December 17, 1975. Ten (10) of the fifteen (15) Unit 2 personnel had received four (4) or more days and all had received two (2) or more days of simulator training.
The sched-ules indicated that all Unit 2 personnel would receive the required ten (10) days of training prior to December 17, 1975. The completed training and sched-ules resolve the Open Item identified in Report 50-247/
74-16 as Deyaila,Section I, Paragraph 7.b(3).
(3) The four (4) sections of the First Annual Requalification Examination were completed for all required personnel on
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or before January 31, 1975.
The accepted Requalification Program deadline of December 17, 1974 had been extended, at the licensce's request, to January 31, 1975 by the Operator Licensing Branch in a letter to the licensee dated December 3, 1974.
One NRC license holder had been promoted to a position (Plant Engineer) which does not require an NRC license.
This individual had not met the Requalification Program requirements which
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is acceptable based on the licensee's stated intention of allowing the license to expire.
A summary of the examination results is summarized below.
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(a)
16 of 20 Unit 1 personnel scored less than 80% on
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one or more sections, no one scored less than 70%
overall, and the average grade was 86.8%.
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(b)
13 of 16 Unit 2 personnel scored less than 80% on
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l one or more sections, no one scored less than 70%
overall, and the average grade was 81.8%.
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(c)
3 Unit 2 licensed personnel met the Unit 2 requal-ification examination requirement by taking the Unit 3 Pre-Licensing Examination which consisted of all Unit 2 items plus the items unique to Unit 3.
None of these three (3) scored less than 80% in any section and the average grade was 89.7%.
(d) The records of the one individual for whom required remedial action (for scoring less than 70% on a section of the annual examination) had not been completed prior to issuance of Report 50-247/74-16 was reviewed.
This individual also scored less
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than 70% on the examination.
During the subsequent management u..luation (required upon toilure of the
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reexamination) the licensee decided to allow con-tinuation until the entire examination was complete.
When the four (4) sections were averaged, this in-dividual scored greater than 70% overall.
The completion of the annual examination resolves the Open Item identified in Report 50-247/74-16, Dctails, SecLion I, Paragrapn 7.b(1).
The licensee's actions with respect to evaluation of the individual referenced in Detail 2.b(3)(d) above resolves the Open Item identified in Report 50-247/74-16, Details,Section I, Paragraph 7.b(2)(b).
(c) The licensee's records indicate that procedural changes are distributed to and acknowledged by licensed personnel.
(4)
Three (3) licensed operators' records were selected for revfew by the inspector.
In each case, the record included:
(a) Complet'ed course and annual examinations and answers; (b)
Documentation of program required reactivity manipulations;
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(c)
Documentation of required simulation of emergencies; l
(d) Results of supervisory evaluations; and'
l (e) Documentation, where required, of additional l
training accomplished.
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c.
General Training Three (3) records for faciliqr employees were selected by
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the inspector for review.
In each case, the inspector was able to verify that the selected individuals had received:
(1)
Indoctrination in security practices; (2)
Indoctrination in health physics practices; and (3)
Indoctrination (drill participation) in the requirements of the emergency plan.
The inspec' tor had no further questions in the area of Training.
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3.
Procurement The inspector reviewed procurement operations with respect to 10 CFR 50, Appendix B, Criterion IV, Corporate Instruction No. CI-240-1,Section III, and associated implementing procedures.
a.
Components Selected The follouing "Ciass A" components were selected for. review in accordance with Section b below:
(1)
Butterfly Valve (P.O. No. 5-34009)
(2)
Sola Transformer (P.O. No. 5-22928)
(3)
Source Range Detector (P.O. No. 22688)
(4) Hydraulic 011 (P.O. No. 3-13592).
b.
Specifications The procurement specifications used in the purchase of the components in Section a above were checked to verify that they included the following:
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(1)
Proper approval;
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(2)
Quality control inspection requirements; and (3)
Quality record requirements.
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Documentation l
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The inspector verified that documentary evidence was available onsite for the components listed in Section a above to support equipment and material conformance to procurement requirements.
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d.
Spare Part Components The inspector verified that the following two (2) spare part components, used in safety related functions, were processed as shown in the next paragraph:
(1) Cable Assembly (P.O. 3-10955); and (2) Orifice Plate (P.O. 2-42172).
Component Processing e.
The above spare part components were processed as follows:
(1). Inspected upon delivery; and Properly handled in accordance with measures established for control and separation of conforming and nonconform-(2)
ing materials.
f.
Approved Vendors The irspector verified that the two (2) spare part components identified above,.were supplied by the following approved vendors.
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(1) llarnischfegger Corporation.
(2)
Bailey Meter Company.
Previous 1v Reported Items g.
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The inspector reviewed the following items which were pre-viously reported as Unresolved Items.
Report 50-247/73-19, Detail 9.
The inspector reviewed the procedure for evaluating vendor facilities and QA (1)
manuals, which was approved on January 7, 1974 and identified as QAE-200.
This item is resolved.
(2) Report 50-247/74-16, Detail 6.a(6).
The inspector re-for the Approved Vendors List viewed the new format
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(AVL) which clearly specifies limitations and restrie-This item is tions applicabic to the listed vendors.
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No inadequacies were identified in the Procurement area.
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4.
Desima Control The inspector reviewed the area of design control of " Class A" components with respect to 10 CFR 50, Appendix B, Criteria III and VI, Corporate Instruction No. CI-240-1,Section IX, and associated implementing procedures.
a.
System Desien Chances A review of selected " Class A" design changes and modifica-tions to the following systems was conducted with respect to 10 CFR 50.59 for the following.
(Installation of a Recirculation l
Line on Unit No. 2)
(2) Reactivity and Power Control.
(Boiler Feed Pump Trip Setpoint Modification)
(3) Core and Internals.
(Ex-core Neutron Detector Position-ing Device Obstructing Pin Removal)
(4)
Pet.'er Conve;cien System.
(Medification to Cause a Delay in Generator Trip on Reactor Trip to 30 Seconds)
(5) Auxiliary System.
(Modification of Internals of Auxiliary Boiler Feed Valve 406B)
(6)
Electrical System.
(Wiring Change to Isolati n Valves
on Air Ej ector Discharge Diversion Line)
(7)
Emergency Power.
(Primary Lubrication Oil Pump Modification No. MAF-74-201 for Diesel Generator)
(8) Containment System.
(Modification of the Containment Building Purge and the Primary Auxiliary Building Ventilation Systems)
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(9) Other Engineered Safety Feature - Containment Air Locks.
(Installation of Overpressure Relief Device Relieving
. from Air Lock Volume into Containment)
b.
Procedures The inspector verified that the design changes selected in a above were done in accordance with formal procedures which includcd:
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(1) A safity evaluation to determine that the modification does not involve an unreviewed safety question; (2)
Identification of specifications and codes governing the work; (3)
Identification of inspections required by codes or standards; and (4) Acceptance test procedures which included acceptance standards.
c.
Drawings
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The inspector verified that the as-built drauing:
r two
modifications were updated.
The two modifications were:
(1)
Ex-core Neutron Detector Positioning Device Obstructing Pin Removal; and (2)
Installation of Overpressure Relief Device Relieving from Air Lock Volume into Containment.
No inadequacies were $dentified in the Design Control area.
5.
Records
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The inspector requested the records listed below to verify that the licensee's program for control, storage, retention and re-trieval of records met the requirements of the licensee's commit-ment to Criterion XVII of 10 CFR 50, Appendix B 'and the Technical-Specifications.
The inspector did not review the areas of record-keeping to detect long term equipment degradation or the nainte-nance of as-built drawings.
These areas are to be reviewed in a future inspection.
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'a.
Records Selected (1) Reactor Coolant System.
!!ydrostatic Test)
(2) Reactivity and Power Control.
(Central Control Room Log Sheet for February 8,1975)
l (3)
Power Conversion System.
(Main Turbine Stop and Control Valve Exercising Test - PT-M15, Revision 1)
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(4) Auxiliary System.
(Auxiliary Boiler Feedwater Pumps -
Full Flow Tests PT-R7/PT-R22)
(5)
Electrical System.
(Station Battery Load Test PT-A4)
(6)
Emergency Power.
(Diesel Generator Functional Test PT-M21, Revision 4)
(7)
Emergency Core Cooling System.
(Safety Injection Pump Functional Test PT-M17)
(8)
Engineered Safety System.
(Nuclear Power Range Analog Channel Functional Test PT-M1, Revision 10)
In each case, the record requested by the inspector was made
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available by the licensee.
No inadequacies were identified in the Records area inspected under paragraph a above.
6.
Quality Assurance Audits, 1974 The inspector reviewed the records of all four audits conducted during 1974 with respect to the requirements of 10 CFR 50, Appen-
dix B, Criteria II, V, XVI, XVII and XVIII and with respect to the guidance furnished by ANSI N45.2.12 as endorsed by the " Green Book" and " Gray Book."
A summary of specific items audited is presented below.
a.
' Audit Records The records for audits 74-1 (conducted 3/27, 3/28, 4/2 through 4/4, 4/17 and 5/3/74); 74-2 (conducted 6/12, 6/13, 6/17 through 6/20, and 7/8/74); 74-3 (conducted 9/18 through 9/20, 9/27, 9/30 and 10/9/74); and 74-4 (conducted 10/21, 10/22, and 10/25/74) were reviewed.
In each case, the audit records indicated that:
(1)
they were conducted in accordance with written check lists and procedures; (2)' they were conducted by trained personnel not having direct responsibility in the area (s) being audited; (3)
audit results were documented and reviewed by management having responsibility in the area (s) of audit and by Corporate Management;
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(4)
follod-up action, including reaudit, was taken, being i
initiated or in progress; and (5)
the audit frequency was in conformance with the estab-lished audit schedules.
l The inspector identified no inadequacies in the sample reviewed.
7.
Follow-up of Previous 1v Identified Items Although the inspectors reviewed the follow-up actions on some items as part of this inspection in other areas (see Details 2, 3, 8, 9 and 10), the below listed items were reviewed for the primary purpose of determining the licensee's actions and, the current status of each item. The results of the tr- '2w is cap-
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sulized below.
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a.
Report 50-247/73-19 The review of the licensee's records indicated the following i
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(1) Final approved procedures, QAGAD-4 end GE-6, cover veld-ing requirements to satisfy the concern documented in
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Detail 2 of the subject report.
(2) The Quality Assurance package for the Instrument Air System Modification now contains isometric drawings identifying the required welds to satisfy the concern documented in Detail 3 of the subject report.
(3) CI-240-1 has now been modified (page 89, Section 3.4, dated April 25, 1975) to allow the use of one Weld Identification Form (WIF) when duplicate welds are
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involved thus satisfying the concern identified in Detail 4 of the referenced report.
-b.
Report 50-247/74-11 (50-003/74-09)
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The corrective actions for the enforcement items identified in the subject report were set forth by the licensee in a letter to IE:1 dated October 22, 1974.
The inspector re-viewed the licensee's commitments based on that letter with the following results.
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(1)
Item 1.a through 1.f - A letter had been placed in the file of one individual stressing the need to follow established procedures.
Discussion of test procedures in general had been incorporated into the current cycle of retraining lectures.
By direct question of an inspec-tor selected operator, the inspector verified that in-structions had been disseminated on the requirement to run a thermal calorimetric if not run on a previous shift.
The inspector also noted that the shift requirements are now delineated on a log record (sheet 4 of 4, Central Control Room Log).
The inspector had no further ques-tions on this item.
(2) Jhe inspector physically observed that two separate
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routing boxes had been supplied for Units 1 and 2 log
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sheets which were distinct and separate from the rout-ing boxes used for interoffice mail.
The inspector had no further questions on this item.
(3) The licensee had instructed the technicians running periodic tests to immediately inform the Watch Foreman when/if a Technical Specification reading was found to be out-of-specification. The licensee had no docuren-tary evidence of this indoctrination; however, by direct questioning of two (2) inspector selected technicians, the inspector verified that the subj ect instructions had been issued.
To meet the requirements of 10 CFR 50, Appendix B, Criterion XVII, the licensee reiterated those instructions in a memo which was posted on the technician's information bulletin board prior to the completion of the inspection.
The inspector had no further questions on this item.
(4) The heat balance calibration of the power range channels was now defined as a checkoff requirement on sheet 4 of 4 of the Central Control Room Logs and personnel were aware of the requirement to run the heat balance.
(See also Detail 7.b(1) above)
The inspector had no further ques-tions on this item.
(5), The licensee's Technical Specifications for Unit 2 re-quire in Section 6.5.1.6.e that the Station Nuclear Safety Committee (SNSC) shall be responsible for:
" Investigation of all violations of the Technical Specifications and preparation and forwarding of a
report covering evaluation and recommendations to l
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prevent recurrence via the Plant !!anager to the
!!anager, Nuclear Power Generation Department and to the Chairman of the Nuclear Facilities Safety Committ ee. " Although the quote above is from the current Technical Specifications, the same require-ments were incorporated in Section 6.5.1.f.6 of the previous issue of the Technical Specifications.
The inspector noted that items 7.b(1) through 7.b(4) above were violations of the Technical Specifications (Sec tions 6. 8.1, 6.5.1, 6.12. 2. a, and Table 4.1-1, respectively).
These Technical Specifications viola-tions had not been reviewed, evaluated and a report prepared and forwarded as required by Section 6.5.1.6.e
,(6.5.1.f.6).
This failure to meet Technical Specifica-tion 6.5.1.6.e is an Infraction level Item a' Noncompliance,
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c.
Report 50-286/74-2,0 Additional items from this report were reviewed and docu-mented in Details 2 and 10 of this report.
The licensee's actions with respect to the only remaining outstanding item from the subj ect report is documented below.
(1)
In Detail 15.b(1) of the subject report, the inspector documented the licensee's position, given at the Exit Ifanagement Interview, with respect to calibration of permanently installed instrumentation.
During the cur-rent inspection, the licensee stated that, upon further consideration of his previously stated position, a re-view of the permanently installed instrumentation, for Class A systems, would be conducted.
The licensee stated, that based on the results of that review, in-struments not covered by either current surveillance or calibration schedules, would be either included in appropriate calibration schedules or removed from the Class A designation.
This-item is Unresolved pending completion of the li-censee's actions.
d.
Combined Reports 50-003/74-16: 50-247/74-16 and 50-286/74-23
}bny of these items were closed / resolved based on review of items documented elsewhere (Details 2 and 3) in this report.
However, the following items from these reports were also reviewed as summarized below.
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(1) Details,Section II, Paragraph 5.a(2) noted that follow-ing maintenance on snubbers, a sample was required to be checked for proper oil level.
The inspector was shown documentation that changed the requirement from a per job to a per number of snubbers repaired requirement by making the sample selection either based on each job or based on the cumulative number of snubbers repaired.
A total of 18 snubbers had been inspected and properly re-ported on Quality Control Inspection reports dated January 15, 1975, and February 1, 1975.
This item is resolved.
(2) Details,Section II, Paragraph 17.c(4) indicated that
'the "Kardex File" required by the recently implemented I
procedure CAD-6 was not yet " fully operational." The licensee indicated that the file would be " built up" as items were calibrated.
The inspector reviewed the file during this inspection and verified that the file was progressing in accordance with the licensee's com-mitment. This item is resolved.
8.
Welding The licensee's weldin'g documentation was reviewed with respect to the requirements of 10 CFR 50, Appendix B, Criteria I.I, V, IX and XVII and the ASME Boiler and Pressure Vessel Code,Section IX as well as the licensee's internal procedural requirements.
The re-sults of the review arc summarized below.
a.
Welding Certification The inspector selected three (3) welders and verified that they were certified in accordance with Section QW-300 of the ASME Code.
In addition, the inspector selected the Mainte-nance Uork requests, listed below, and verified that the velders performing the job were qualified for the procedure used.
(1) MWR 3524 - performed 3/20/75 using procedure 7283-GTA on less than 3" OD Stainless;
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(2) FSH13156 performed 3/21/75 using procedure 7283 as in (1) above; and (3) MWR's 1590 and 1592 - performed on or c'uet 11/23/73 also using procedure 7283 identified in (1) above.
(See also Detail 9)
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b.
Welding Records The inspector also verified ths.t the selected welders met the requalification requirements and that the licensee has a sys-tem for correlating and deternining which welders are currently qualified to perform the various qualified welding procedures.
The inspector identified-no inadequacies in Welding.
9.
A0 3-2-15 The bulk of the licensee's corrective actions for this occurrence has previously been inspected as documented in Report 50-247/73-22.
However, the welding packages associated with the modification to
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the vents on the Residual Heat Removal System, designa.ad as S-47, S-48 and S-51 had not been previously reviewed.
The inspector re-viewed the welding packages associated with these modifications under MWR's 1590 and 1592 (see also Detail 8.a(3)).
The inspector identified no inadequacies with this item, and this item is resolved.
10.
Quality Assurance Procram Chances
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Sincethelicensee'sirogramwaslastreviewedbyIE:1inNovember
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1974, the licensee has made approximately sixty (60) changes to the. program control document, CI-240-1.
While some of the changes have been of an editorial nature, some of them involved more de-tailed and fundamental revisions. The changes were reviewed to insure continued conformance to the requirements of 10 CFR 50, Appendix B criteria.
No inadequacies were identified in the following.
a.
Summary of Changes The changes which resulted in a complete reissuance of CI-240-1 was summarized by the licensee in a memorandum dated thy 8,1975.
He stated that the revision:
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(1) authorizes the Vice President, QA'&R to approve alternate l
written procedures as exceptions to CI-240-1 when called j
for by unique situation;-
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(2) authorizes the Director, Quality Assurance to provide advice and counsel concerning CI-240-1;
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(3)
provided for specific quality control requirements for work on Class "A" nuclear equipment at licensee shops consistent with NRC requirements and to permit the extending of the ASME's nuclear code stamp ("N" Stamp)
to cover shop work; (4)
provides for initiation of requisitions by Engineering for procurement of design services concerning Class "A" items; and (5) updates various quality assurance program requirements to reflect current practices.
b.
Impicnenting Procedures
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The following implementing procedures have been revised either as a result of revisions to CI-240-1 or to reflect current licensee practices. These procedures were also reviewed for conformance to the requirements of 10 CFR 50, Appendix B.
(1)
Station Administrative Order Policy - SAO 100, Revision 3.,
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(2) Work Permita - SAO 105, Revision 3.
(3) Training Policy - SAO 108, Revision 1.
(4) Calibration and Control of Measuring Tools - SAO 117 Revision 2.
(5)
Reporting of Anomalous Conditions - SAO 124, Revision 1.
(6)
Security Plan Implementation - SAO 128, Revision 3.
(7)
Preparation of Procedures, Instructions, Graphs and Lists - 3 AD-14, Revision 2.
(8) Test Procedure Development and Approval Process -
TEAD-2, Revision 2.
(9)' Quality Assurance Record List - QAAD-19, Revision 1.
(10). Engineering Procedures 1 (Revision 2), 7 (Revision 4),
9 (Revision 2),10 (Revision 2) and 13 (Revision 1).
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c.
Items from Report 50-286/74-20
(1) Revisions to Section 2.0 of CI-240-1.on pages 8 and 9 satisfy the concerns identified in Details 2, 3.c and 7-of the subject report.
Based on these revisions, Details 2, 3.c and 7 are resolved.
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(2) Revision 2 of TEAD-2 includes the requirecents (item 1.a(9)) to use and identify calibrated instruments used for testing.
This revision resolved the unresolved (open)
item identified in Detail 13.b(2) of the' referenced report.
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(3) Revision 2 of Appendix A In AAAD-3 9 sdi rec.the in-l spector's concerns with respecc to handling of superseded info rmation.
During the inspection, the inspector noted that the same system designation is given to supplemen-tal information and, in all cases reviewed, supplemental information was properly filed.
Based on the inspector's review and the revision to QAAD-19, the item identified in Detail 18.b of the referenced report is resolved, 11.
Follow-up of NRC Identified Items of Monconpliance q
During the Exit Management Interview the inspector stated that the
plant management controls for the follow-up of NRC identified Items l
of Noncompliance, including the assignment of responsibility for completing corrective action and the documentation of corrective
actions taken, appeared to be an area.of weakness.
The licensee
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stated that this area could possibly lead to problems in the future. The licensee further stated that on or before August 6, 1975, a managenent control system for tracking and resolving ::RC identified Items of Noncompliance would be developed and imple-mented. The inspector acknowledged the licensee's commitment.
Until the licensee's commitment has been fulfilled, this item
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is unresolved.
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