IR 05000003/1977008
| ML20042B155 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 06/27/1977 |
| From: | Conte R, Dante Johnson, Ruhlman W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20042B150 | List: |
| References | |
| 50-003-77-08, 50-247-77-18, 50-286-77-18, 50-3-77-8, NUDOCS 8203250034 | |
| Download: ML20042B155 (13) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT 77-08 Region I 77-18 Report No. 77-18
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Unit 1:
D Docket No. 50-03:247:286 Unit 2:
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License No. DPR-5:26:64 Priority Category
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Licensee:
Consoiidated Edison Comoany of New York, Inc.
l 4 Irving Place l
ity Name:
Indian Point Units 1, 2 and 3
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Inspecticn at:
Buchanan, New York
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Inspection conducted: May 31 - June 3, 1977 50 YY0
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6A3/M Inspectors.
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R. J. Cofite, Reac or Inspector
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D. F. Johns 6n, Reactor Inspector-
'date (signed
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%/m W. A. Muhlman, ting Chief, Nuclear Support date signed
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Sec}io No.
6/3 7 only)
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Approved by:
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A. Huntman, Acting Cnlet, Nuclear Support
/date sfgned Section No. 2, RO&NS Branch
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- Inspection Summary:
Inspection on May 31-Jure 3,1977 (Report Nos. 50-03/77-08; 50-247/77-18; 50-206/77-18)
Areas Inspected:
Routine, unannounced inspection of administrative control of facility procedures; format and technical content of facility j
procedures; procedure revisions resulting from Technical Specification changes and plant modificatior.s; review of licensee action on previous I
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inspection findings and, review of implementation of selected Environ-mental Technical Specifications. The inspection involved 59.5 inspector-hours onsite by three NRC inspectort.
Results: Of the five areas inspected, no items of noncompliance were found in three areas; four apparent items of noncompliance were found in two areas; Units 1, 2 and 3 (infraction - failure to have various
monitoring equipment required by Environmental Technical Specifications installed by June 1,1977 as required - Paragraph 4); Unit 2 (deficiencies-failure to adhere to procedures - Paragraph 6.c(1) - failure of an Rdgion I Fom ]2
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8203250034 770628 PDR ADOCK 05000003
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assembled quorum of the Station Nuclear Safety Committee (SNSC) to re-view temporary changes to procedures - Paragraph 6.c(2)); Unit 3 (def-
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iciency - failure to adhere to procedures - Paragraph 6.b)
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DETAILS 1.
Persons Contacted
- M. Byster, Quality Assurance Engineer
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- S. Cantone, Superintendent of Power (PASNY)
W. Carson, Test Engineer A. Decker, Technical Engineer E. Kessig, Assistant Vice President - Power Generation Operations
- T. Law, Plant Manager
- J. Makepeace, Technical Engineering Director E. McGrath, Assistant Manager Nuclear Power Generation Department
- B. Moroney, Chief Operations Engineer
- A. Nespoli, Unit 2 Operations Engineer
- H. Searles, Senior Quality Assurance Engineer
- E. Tagliamonte, Unit 3 Operations Engineer J. Vignola, Assistant Maintenance Superintendent The inspector also interviewed other licensee employees which in-cluded members of the technical and engineering staff, maintenance staff, reactor operators and general office personnel.
denotes those attending the exit interview.
- 2.
Licensee Action on previous Insoection Findings (0 pen) Noncompliance (247/76-33-01):
Failure to properly review and approve temporary changes.
The inspector verified that unauthorized pen and ink changes to alarm response procedures have been removed and temporary changes issued where applicable in accordance with Technical Specifications and established administrative controls.
Alarm response procedures have been revised and are in final form awaiting review by the SNSC and will be implemented by August 1,1977.
This item remains open pending SNSC review and implementation of procedures.
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-(Closed) Noncompliance (247/76-33-02):
Failure to properly review and approve temporary procedures.
TFe inspector verified that temporary procedures S-4, Normal ab Emergency Operation of Air Lock and Unit Order 2-10, Personnel Air Locks - Door Interlocks, have been cancelled and incorporated into System Operating Pro-cedure 50,P 10.6.3,, Containment Air Locks Operation, Revision 0, March 1, 1977, which has been reviewed and approved in accordance with the requirements of the Technical Specifications and the licensee's administrative controls.
(0 pen) Noncompliance (247/76-33-03):
Failure to provide complete procedural coverage in accordance with Regulatory Guide 1.33, Ap-pendix "A".
The inspector verified that the licensee has written procedures to cover those areas identified in Inspection 50-247/
76-05, detail 3.a.
These procedures are in final form awaiting SNSC review and will be implemented by August 1,1977.
This item remains open pending SNSC review and implementation of these procedures.
(Closed) Noncompliance (247/76-33-04):
Failure to furnish evidence of adequate graphs and operating curves.
The inspector verified by review of the graph and operating curve book in the control room
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that the licensee has removed superseded curves and all graphs and curves have been reviewed and approved in accordance with the requirements of the Technical Specifications.
(Closed) Noncompliance (286/76-34-01):
Failure to properly imple-ment a temporary change to System Operating Procedure SOP-RPC-5 Quadrant Power Tilt Calculation.
The inspector verified that changes to SOP-RPC-5 have been documented and are in accordance with the requirements of the Technical Specifications.
(Closed) Noncompliance (247/76-31-03):
Failure to have adequate procedural controls appropriate to the circumstances.
The inspector verified that the licensee has revised System Operating Procedure 50P-1-2, Draining and Reactor Coolant System, Revision 2, May 6, 1977, to include provisions in the event of a known steam generator i
tube leakage, that is, the secondary side of the steam generator is to be drained prior to draining the reactor coolant system. In addition, test procedure PMT-2, Steam Generator Side Pressure Test, Revision 0, November 11, 1976, has been issued to include additional precautions to prevent reactor coolant boron dilution.
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3.
Station Nuclear Safety Committee's Review of Items of Noncompliance The inspector verified by interviews held with licensee management and examination of representative records, that reviews were per-formed for items of noncompliance identified in Inspection 50-247/76-33 and 50-286/76-34, paragraphs 2-7, and the evaluations and recommendations to prevent recurrence were addressed.
The inspector noted that the committee's review of corrective actions and recommendations to prevent recurrence were not docu-mented in a timely manner, in that the SNSC meeting minutes reflec-ting the review was six months after the items were identified.
The licensee concurred with the inspector's comment and stated ad-ministrative procedures would be reviewed and revised, by August 1, 1977, to include a specified time period for the SNSC's review of items of noncompliance.
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This is an unresolved item pending action by the licensee. (247/77-18-01) and 286/77-18-01)
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4.
. Review of Monitoring Equipment Required by Environmental Tech Specs The inspector reviewed the licensee's actions with respect to 3 systems for monitoring activities which were required to be in-stalled by June 1, 1977.
This review was initiated by the licen-see's report that these systems would not be installed by the June 1,1977 date. Results are summarized below.
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a.
Section 3.4.1.h l
l This Section of the Environmental Technical Specifications re-quired the installation of a continuous liquid effluent monitor with recorder, and an alarm and automatic discharge valve clo-sure circuits.
None of these' items were installed and operable by the June 1 deadline.
This installation was completed and checked for operability by June 5, 1977, based on a telephone call to NRC:I by the licensee on June 6,1977.
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This item is one of three examples of an item (03/77-08-01, 247/77-18-02,286/77-18-02) of noncompliance for failure to comply with Environmental Technical Specification require-ments.
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b.
Table 2.4-3 This Table requires that outdoor storage tanks which are potentially radioactive be provided with liquid high level alarms by June 1,1977.
One such tank, the Unit 2 Refueling Water Storage Tank (RWST), did not have an operable liquid high level alarm until June 2,1977.
This item is one of three examples of an item (03/77-08-01, 247/77-18-02,286/77-18-02) of noncompliance for failure to comply with Environmental Technical Specification require-ments.
c.
Table 2.4-4 This Table requires that the Unit 1 Waste Gas Storage Tanks be provided with a Radiation Alarm Auto Control to Isolation Valves, and a Continuous Monitor by June 1,1977.
These tanks do not currently contain any waste gas.
These tanks will be used as part of a systems for processing waste gases in the future. While the monitor which will eventually be used was installed, it was not piped into the discharge flowpath with an automatic control isolation vcive. Although not currently in use, this installation of equipment was also incomplete as of the June 1, 1977 deadline.
This item is one of three examples of an item (03/77-08-01, 247/77-18-02,286/77-18-02) of noncompliance for failure to comply with Environmental Technical Specification requirements.
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Administrative Controls for Facility Procedures a.
The inspector performed an audit of the licensee's administrative controls by conducting a sampling review of the following administrative procedures:
Station Administrative Order (SAO)-100, Station Admin-
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istrative Order Policy, Revision 4, July 1,1975; SAO-101, NPG Managment Policy, Revision 4, January 19, l
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SA0-102, Procedure / Procedure Change Approval Policy,
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Revision 4, February 24, 1976; l
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SAO-131, Station Nuclear Safety Committee, Revision 0,
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January 11, 1975; Operations Administrative Directive (OAD)-1, Adminis-
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trative Directive Policy, Revision 0, May 21,1975;
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0AD-5,.P'rocedure Adherence and Use, Revision 0, December 7,1975; 0AD-7, Procedure Control, Revision 0, February 8,1976;
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The inspector verified by review of the above procedures and interviews held with licensee personnel that the licensee has adequate administrative controls for changing, revising, re-viewing, approving, updating and controlling facility pro-cedures in accordance with the requirements of the Technical Specifications.
No discrepancies were identified.
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Review of Facility Procedures
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'The inspector reviewed facility procedures on a sampling basis to verify the following:
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Procedures, plus any changes, were reviewed and approved in
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accordance with the requirements of the Technical Specifications and the licensee's administrative controls.
The overall procedure format and content were in conformance
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with the requirements of the Technical Specifications and ANSI N18.7, " Administrative Controls for Nuclear Power Plants."
Checklists, where applicable, were compatible with the stepwise
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instructions in the procedures.
Applicable Technical Specification limitations had been included
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Temporary changes were made in conformance with Technical Speci-l
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fication requirements and the licensee's administrative controls.
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a.
Unit 3 - The following procedures were reviewed:
Plant Operating Procedures P0P-1.2, Reactor Startup, Revision 0, March 10, 1976;
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P0P-2.2, Power Operation with Three Loops, Revision 0,
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March 10,1976; System Operating Procedures SOP-CS-1, Containment Spray System Operation, Revision 0,
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May 20, 1975; SOP-NI-1, Excore Nuclear Instrumentation System Operation,
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Revision 0, September 25, 1974; SOP-FW-4, Auxiliary Feedwater System Operation, Revision
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2, March 4, 1976;
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Plant Emergency Procedures PEP-SG-1, Steam Generator Tube Leak, Revision 0, May 16,
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1975; PEP-RPC-3, Instrument Failures, Revision 0, January 31,
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PEP-NI-1, Nuclear Instrumentation Malfunction, Revision
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0, September 25, 1974; Alarm Procedures Alarm List (page 5-18), Panel SBF-2, Hi-Hi Containment
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Pressure (Spray) Channel Trip, Revision 1, September 3, 1976;
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Alarm List (page 6-12), Panel SCF Auxiliary BF Pump Low
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Flow, Revision 0, October 4,1976;
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Maintenance Procedures 3-CM-7.12, Replacement of SIS Pump Internals, Revision 0,
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March 28,1977;
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2/3-CM-NI-ND-10.3c, Removal and Replacement of Neutron
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Detectors, Revision 1, April 15,1976; 2-CM-13.1, Modification to 21 and 23 Auxiliary Recircu-
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lation Valve BFD 77 and 78, Revision 1, April 12,1976; Administrative Procedures SA0-102, Procedure / Procedure Change Approval Policy,
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Revision 4, February 24, 1976; 0AD-7, Procedure Control, Revision 0, February 8, 1976.
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b.
Unit 3 During the review of Temporary Change (TC) 76-2 issued June 2, 1976 to procedure PEP:RP; 1, Instrument Failure, Revision 0, June 2,1976, it was noted that non-shift supervisory approval was not documented as required for temporary changes involving a change of intent of the approved procedures.
TC 76-2 updated the Steam Genertor Water Level Failure Section of PEP-RPC-3 l
regarding a malfunctioning Low Water Level Coincident with Steam Flow Feed Flow Mismatch Bistable. Although the tech-nical content of the change did not violate Technical Speci-l fications, there was a change of intent to the procedure as so indicated en the temporary change form by the Watch Foreman.
The temporary change form 76-2 required that if a change of intent of the approved procedure was marked "yes" on the' form, l
the written concurrence of the Operations Engineer was to be obtained or if the Operations Engineer was not present, his i
verbal concurrence was to be documented by the Watch Foreman.
I Copies of TC 76-2 maintained in the master file, control room and Station Nuclear Safety Committee re:ords file did not have the required written or verbal concurrence documented.
This finding represents noncompliar;ce with administrative controls set forth by SAO-102 paragraph 2.4.5 to provide a mechanism for making and approving temporary changes to facility pro-cedures in accordance with Technical Specification 6.8.3 and ANSI 18.7-1972, Section 5.1.2.
(286/77-18-03)
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In addition, a Reactor Operator stated, when questioned by the
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inspector concerning TC 76-2, that the subject instrument was no longer malfunctioning and that the change appeared to be out-
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dated.
The inspector noted this to the licensee and the licensee concurred with the Reactor Operator's statement.
Sub'sequently,' the licensee cancelled TC 76-2 to PEP-RPC-3 on June 3, 1977.
The cancellation of 76-2 is considered corrective action for this item and therefore only actions to assure that future items of this nature da not recur should be addressed by the licensee.
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Unit 2 The inspector reviewed approximately 40 temporary change forms issued during January through May,1977, to determine that temporary changes to procedures were being accomplished in accordance with Technical Specification requirements and established admin-istrative controls.
(1)
During this review the inspector nrted that temporary change
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forms issued on March 11 and March 12, 1977, involving ex-tensive changes to-Plant Operating Procedures, POP 3.3,
" Plant Cooldown from Zero Power to Cald Shutdown" and POP 3.4, " Low Pressure Operation without a Steam Bubble," did not contain any evidence that these forms were forwarded to the SNSC for review as required by tie licensee's admin-istrative procedure SA0-102, "ProcecLre/ Procedure Change Approval Policy." As a result of interviews held with
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licensee personnel and further examitation of representa-tive records, it was established that the three temporary change forms issued on March 11 and D2,1977 had not been forwarded to the SNSC for evaluation. These changes to the procedures identified above were the result of Techni-cal Specification changes and plant modifications.
This finding represents noncompliance with Technical Speci-fication 6.8.1 and Station Administrttive Orders, SAO-102, in that licensee personnel failed to follow procedures. The inspector verified that this item wai subsequently reviewed by the licensee's established admini2trative mechanism for the SNSC's evaluation.
(247/77-18-01)
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In addition, during this review of temporary changes it was determined that the review and approval process established by the licensee to the Technical Specifi-cation requirements consisted of sub-committee review.
In most cases this sub-committee review consisted of re-view by the Plant Manager as Chairman of the SNSC.
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Plan't Manager discussed the changes as he deemed necessary with other members of the SNSC but in no cases were the results of sub-committee reviews reviewed in the presence of an assembled SNSC quorum.
This finding represents noncompliance with Technical Specification 6.5.1.6 and 6.8.3 in that the the above identified temporary changes were not reviewed as re-quired by the SNSC. (247/77-18-04)
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Unit 2
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This unit's facility procedures are presently undergoing up-grading as noted in Inspection 50-247/76-33, details 4 (Item 247/76-33-03 - facility procedural coverage) and detail 9 (Item 247/76-33-05 - review and approval of facility pro-cedures). The commitment date for completing this upgrading was extended to August 1,1977, in a letter from NRC:I to the licensee dated May 10, 1977.
Therefore, a complete review of Unit 2's facility procedures will be conducted shortly after the required cc;. letion date.
7.
Procedure Changes Resulting from Technical Specification Amendments The inspector reviewed Technical Specification changes made during the period from April,1976 through April,1977, and verified that applicable procedures were revised as necessary to reflect changes to the Technical Specificaticns.
No discrepancies were identified.
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8.
Procedure Chanoes and Documentation Pursuant to 10 CFR 50.59(a)
and 50.59(b) Requirements The inspector verified, by review of the Station Nuclear Safety Commit. tee meeting minutes and correspondence records for the period April,1976 through April,1977, that changes made to procedures were in conformance with 10 CFR 50.59(a) requirements and that records of changes in procedures were made pursuant to 10 CFR 50.59(b).
No discrepancies were identified.
9.
. Technical Content of Facility Procedures The inspector conducted a review of the below listed procedures using FSAR System Descriptions, P&ID's and lechnical Specifications to verify that procedures were sufficiently detailed to control the operation or evolution described within Tectnical Specification Limiting Conditions for Operation.
P0P-1.2, Reactor Starlup, Revision 0, Rarch 10,1976;
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SOP-CS-1, Containment Spray System Opetation, Revision 0, May
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20, 1975; PEP-SG-1, Steam Generator Tube Leak, Fhvision 0, May 16,1975;
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Alarm List (page 5-18), Panel SBF-2, Hf.-Hi Containment Pressure
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(Spray) Channel Trip, Revision 1, Septenber 3,1976; Alarm List (page 6-12), Panel SCF, Auxiliary BF Pump Low Flow,
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Revision 0, October 4,1976;
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3-CM-7.12, Replacement of SIS Pump Indmnals, Revision 0,
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l March 28,1977.
No discrepancies were identified.
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10.
Control Room Tour The inspector toured the control room and discussed operations with several operators.
During this tour, the iTspectors reviewed plant operations by observing control board switet positions, indicators, and annunciators.
In addition, the inspectu s questioned operators as to annunciator status and compared severzl plant conditions with various Technical Specification Limiting Comditions of Operations to verify compliance.
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No discrepancies were identified.
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11. Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items or items of noncompliance.
An unresolved item disclosed during the inspection is discussed in Paragr'aph 3.
12. Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1)
at the conclusion of the inspection on June 3, 1977.
The inspector summarized the scope and findings of the inspection.
Subsequent discussions of the inspection findings occurred on June 6, 1977 in a telephone call from the licensee to NRC:I and on June 8,1977 in a telephone call from NRC:I to the licensee.
In addition, the inspector noted that liquid effluent discharges we e continuing under the aegis of Environmental Technical Specification 3.4.1 which allows such actions for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> with inoperable effluent monitors.
Since these monitors were required to be installed by June 1, 1977, the inspector stated that, for purposes of calculating the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowed, the monitors were to be considered inoperable as of 2400 hours0.0278 days <br />0.667 hours <br />0.00397 weeks <br />9.132e-4 months <br /> on June 1, 1977.
The inspector further stated that discharges with inoperable monitors / valves / recorders after 2400 hours0.0278 days <br />0.667 hours <br />0.00397 weeks <br />9.132e-4 months <br /> on June 4,1977 would be contrary to Environmental Technical Speci-fication 3.4.1.d.
The Plant Manager acknowledged the inspector's statements.
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