IR 05000003/1977010
| ML20042A980 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 08/24/1977 |
| From: | Conte R, Dante Johnson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20042A969 | List: |
| References | |
| 50-003-77-10, 50-247-77-25, 50-286-77-25, 50-3-77-10, NUDOCS 8203240354 | |
| Download: ML20042A980 (11) | |
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l U.S. NUCLEAR REGULATORY COMMISSION
j OFFICE OF INSPECTION AND ENFORCEMENT I.
Region I guca
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gguon 1 HAS et estamtp8"RDANC
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Report No.
77-1n 77-m 77-25 as as i
I Docket No.
50-03: 50-247: 50-286
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Unit 1 - D Category Units 2 & 3 - C l
License No. OPR-5: 26: 64 Priority
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Licensee:
Consolidated Edison Company of New York, Inc.
l 4 Irvino P13ce Y New York. New York 10003 i
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j Facility Name:
Indian Point -1, 2 & 3 j
l Inspection at: Buchanan, New York t
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Inspection conducted:
August 2-5, 1977 Inspectors:
bSb d'L3 k O AW
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R. J. Sonte, Reactor Inspector date signed
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date signed
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i date sign
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'M/ ~7i Approved by:
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D. F. Jokiis5n, Acting Chief, Nuciear Support fiate signed l
Section #2, RO&NS Branch
I Inspection Surunary:
j Inspection on August 2-5,1977 (Report Nos. 50-03/77-10; 50-247/77-25; 50-286/77-25)
Areas Inspected:
Routine, unannounced inspection of licensee action on previous l
inspection findings; administrative controls of facility procedures; format and I
technical content of facility procedures; procedure revisions resulting from
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Technical Specification changes and plant modification; and control room operations.
l The inspection involved 29.5 inspector-hours onsite by one NRC inspector.
Results : Of the five areas inspected, no items of noncompliance were found in
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four areas; two apparent items of noncompliance were found in one area; Units 2
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and 3 (Deficiencies - failure to document periodic review of Administrative l
Procedures, paragraph 3.b(1) - failure to establish an index of procedures j
reflecting latest revision' and temporary change, paragraph 3.b(2)).
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i 8203240354 770825 PDR ADOCK 05000003
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DETAILS
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1.
Persons Contacted
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- Mr. Byster, Quality Assurance Engineer J. DeVita, Assistant Maintenance Engineer
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M. Gross, General Maintenance Foreman
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- T. Law, Plant Manager
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- J. Makepeace, Technical Engineering Director i
- E. McGrath, Manager Nuclear Power Generation Department
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- 8. Moroney, Chief Operations Engineer M. Shatkoski, Director of Nuclear Training i
The inspector also interviewed seven other licensee employees which
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included members of technical and engineering staff, maintenance staff and operations staff.
- denotes those attending exit interview.
2.
Licensee Action on Previous Insoection Findinos (Closed ) Noncompliance (286/76-31-01):
Establish a program to require the periodic checking of accessible locked safeguards valves with implementation by March 1,1977.
The inspector veri-
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fied this List (COL) program has been established through the use of Check-off 51 with the first cycle completed by March 1,1977 and.
has subsequently been completed since that date on a periodic
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basis.
.(Closed) Noncompliance (286/76-34-02):
Revise administrative pro-cedures to address operating staff responsibilities in identifying off-normal valve positions and establish equipment status boards to
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include identifying off-normal valve line-ups.
The inspector verified 0AD-6 Revision 1, August 1,1977, Equipment Status Identifi-cation includes provisions for the following:
Operating Staff identify off-normal valve positions $
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Operating Staff will document off-normal valve positions on
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Status Boards at various locations in the plant; and i
On-coming shift personnel will review applicable status boards.
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The inspector noted the use of various Equipment Status Boards during the conduct of the inspection.
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(Closed) Noncompliance (247/76-33-01):
Alarm Response Procedures; SNSC review and implementation required by August 1,1977 (re: NRC Inspection Report 50-247/77-18, detail 2).
The inspector verified by interview with selected personnel and review of SNSC records that these procedures have been reviewed and were implemented by l
August 1,1977.
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i (Closed) Noncompliance (247/76-33-03): :SNStirto review procedures d
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providing complete coverage in accordance with Regulatory Guide 1.33, Appendix A and these procedures to be implemented by August 1,1977,(re: NRC Inspection Report 50-247/77-18, detail 2).
The inspector verified by interview with selected personnel and review of SNSC records that these procedures have been reviewed and were implemented by August 1,1977.
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(Closed) Unresolved item (247/76-33-05):
Details 7.b and 3, NRC Inspections Reports 247/76-18 and 247/75-14, respectively: Es tablish-
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ment of procedure cover sheets indicating latest revision /date and review / approval signatures for control room procedures; and comple-tion of program for revising and upgrading these facility procedures which would include the periodic revies requirements of 0AD-7.
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inspector verified that the subject procedures have cover sheets indicating revision numbers and effective dates in addition to review and approval signatures.
Further the inspector noted that since all subject procedures had been upgraded as of August 1,
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1977, this constituted a periodic review.
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(Closed) Unresolved item (247/75-14-01):
Temporary changes to Alarm Response Procedure for SI Accumulator. 22 Level (panels LC-
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9348, 9358, 935F and 934F) setpoints were not properly reviewed.
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The inspector noted that this procedure has been revised as of August 1,1977 with no effective temporary changes, the SNSC has properly reviewed and approved this procedure and that the procedure reflects setpoints that are conservative with respect to Technical i
Specification requirements.
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(Closed) Unresolved item (247/76-33-07):
Adequacy of Administra-
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tive Controls for Procedure Review and Approval.
Based on NRC management review of TS 6.8.2, the inspector verified that admini-strative controls established by the licensee are adequate to
ensure that each procedure and administrative policy (as requirsd by TS. 6.8.1) and changes thereto are reviewed and approved by the Manager, Nuclear Power Generation Department, with the concurrence i
of the Station Nuclear Safety Committee (SNSC).
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(Closed) Unresolved Items (247/77-18-01 and 286/77-18-01): Admin-
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istrative Procedures to be revised to include a period for which SNSC will review violations of Technical Spe'cifications.
The inspector noted that the SNSC Administrative Procedures have been revised to reflect a 30 day limit, from the time the Chairman of SNSC becomes cognizant of the violation.
This review will be
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documented in the minutes of meeting.
(Closed) Noncompliances (03/77-18-01, 247/77-18-02 and 286/77-18.-
t 02): Installation kork complying with Environmental Technical Specifications 3.4.1.b and Table 2.4-3 and 2.4-4 was not completed as required by June 1, 1977.
Subject equipment has been installed '
and this item along with other items involving commitment dates
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have been incorporated into the licensee's computerized system'for tracking such items and is reflected in a periodic report entitled
" Licensing and Regulatory Status Report."
(Closed) Noncompliance (247/77-18-03):
Failure of SNSC to review
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and approve Temporary Changes (TC) dated March 11, 1977 and March l
12, 1977 to the then current issue of POP 3.3, Plant Cooldown from I
Zero Power to Cold Shutdown.
The inspector verified that the content of both TC's have been incorporated into the latest revision of POP 3.3 and that personnel responsible for assuring review of i
temporary procedure changes are aware of SNSC review requirements.
l (Closed) Noncompliance (286/77-18-03):
Failure to document Unit 3
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Operations Engineer approval for two Temporary Changes.
Based on personnel interview the inspector verified that personnel are aware of the requirement to document verbal concurrence of Operations Engineer on the Temporary Change Form.
(Closed) Noncompliance (247/77-18-04):
Temporary Procedure Change
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Forms for period January through March 1977 were not reviewed by an assembled quorum of SNSC.
The inspector verified that the SNSC administrative procedure has been revised to include a requirement
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that all SNSC reviews will be finalized in a formal SNSC meeting with a SNSC conference telephone call, complying with quorum require-ments, as an acceptable alternative.
3.
Administrative Controls for Facility Procedures a.
The inspector performed an audit of the licensee's admini-strative controls by conducting a sampling review of the following administrative procedures:
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SAO-100, Revision 4, July 1,1975, Station Administrative
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Order (SAO) Policy; SA0-101, Revision 4, January 19, 1976, NPG Management
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Policy; SAO-102, Revision 4, February 24, 1976, i:-
Approval Policy;
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Procedure Change
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SA0-104, Revision 6, May 1, 1977, Maintenance Work Requdst
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(MWR) Procedures;
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SAO-105, Revision 5, March 30, 1977, Work Permits;
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SAO-131, Revision 0, January 11, 1975, Station Nuclear
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Safety Committee; OAD-1, Revision 0, May 21,1975, Operations Administrative
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Directive (OAD) Policy;
0AD-7, Revision 0, December 8,1976, Procedure Control;
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PE-AD-1, Revision 3, October 5,1975, PE Administrative
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Directive; PE-AD-4, Revision 5, October 24, 1975, Procedure for -
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Performing Maintenance;
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PE-AD-5, Revision 4, December 31, 1975, Conduct of Maintenance.
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The inspector verified by review of the above procedures and
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interviews held with licensee personnel that the licensee has
adequate administrative controls for changing, revising, reviewing, approving, updating and controlling facility procedures.
The requirements of the Technical Specifications, Section 6,
" Administrative Controls," ANSI N18.7 " Administrative Controls
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for Nuclear Power Plants" and Regulatory Guide 1.33, " Quality
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Assurance Program Requirements" were used as a basis for this review.
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The following discrepancies were identified:
(1)
During this review the inspector noted that SAO 100 requir.es a biennial review of SA0's and the results are to be documented. In addition, SA0-101 requires that a biennial review of 0AD's with the results documented and that the first 0AD review report was due one year from l
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approval date of SAO-101 which made the due date January 19, 1977.
Based on revision approval dates for SA0's/0AD's and the first 0AD report due date of January 19, 1977, the following procedures were due for periodic review:
SA0-106, Revision 0, December 18, 1973
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SAO-ll7, Revision 2, February 17, 1975
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SAO-ll8, Revision 0, April 31,:1974ir
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SAO-122, Revision 0, DecembeF~ 20, T973 SAO-123, Revision 0, September 28, 1973
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SAO-125, Revision 1, December 23, 1974 SAO-126, Revision 2, January 17, 1975 SAO-128, Revision 3, February 28, 1975 SA0-131, Revision 0, July 11, 1975
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OAD-1, Revision 1, May 21, 1975 OAD-2, Revision 0, June 8,1975 0AD-3, Revision 0, July 13, 1975 OAD-4, Revision 0, July 21,1975 OAD-5, Revision 0, December 7, 1975 OAD-7, Revision 0, December 8, 1976 The licensee acknowledged this and subsequently pointed out that periodic review of procedures are an on-going process through usage which would generate changes as needed.
The inspector stated that sole reliance on procedure usage as a periodic review in all cases may not derive the same benefits of an auditor, with access to requirements / references reviewing a specific procedure; The licensee acknowledged this and stated that SA0 procedure upgrading program has been established.
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The inspector noted that this program for upgrading and, consequently, periodic review has been formalized and that it has been established since June 1977.
This item represents noncompliance with Technical Specifi-cation ('TS) 6.8.2 (247/77-25-01 and 286/77-25-J1).
(2)
During this review the inspector noted that 0AD-7, paragraph
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3.0.2 required that operations staff maintain an index of procedures covered by 0AD-7 identifying the latest revision t
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On August 2,1977, the licensee stated the index for facility procedures upgraded as of
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August 1,1977, had not been established yet and the index
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presented to the inspector on August 4,1977, contained only procedure numbers, titles, latest revision and dates.
The licensee further indicated intentions to change OAD-7 to eliminate the temporary change requirement on the index.
The inspector stated the 10 CFR 50 Appendix B, Criterion VI, requires measures be establi:hed to control the issuance of documents such as procedures including changes thereto,
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which prsscribe all activities affecting quality.
The licensee acknowledged this and stated that measures for the control of temporary change would be reviewed.
This item represents noncompliance with TS 6.8.1 (247/77,
25-02 and 286/77-25-02).
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Review of Facility Procedures The inspector reviewed facility procedures on a sampling basis a.
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."
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Checklists, where applicable, were compatible with the step-
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wise instructions in the procedures.
Appropriate Technical Specification limitations had been
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included in the procedures.
Temporary changes were made in conformance with Technical
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Specification requirements and the licensee's administrative l
controls.
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The following procedures were reviewed:
l Plant Operating Procedures POP-l.1, Rev'ision 3, August 1,1977, Plant Heatup from Cold Shutdown Condition; POP-1.2, Revision 1, May 1,1977, Reactor Startup.
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System Operating Procedures 50P-1.4, Revision 0, May 1,1977, Pressurizer Pressure Control; SOP-10.1.2, Revision 1, May 11,1977, SI System Operation; SOPG7.1.3, Revision 0, August 1,1977, On/Off Site Power
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Emergency Procedures E-7, Revision 1, August 1,1977, Reactor Control System Malfunction; E-9, Revision 2, August 1,1977, Rupture of a Charging or Letdown Line; E-26, Revision 2, August 1,1977, Loss of Containment Integrity.
Alann List Procedures 4/SBF-1, Revision 2, June 8,1977, Safeguards;
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i 5/5BF-2, Revision 2, June 8, 1977, Safeguards; f
ll/SHF, Revision 2, June 8,1977, Electrical; 3/SAF, Revision 2, June 8,1977, Reactor Coolant System;
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15/SMF, Revision 2, August 1, 1977, Safety Injection.
Maintenance Procedures Mainter,ance/QA Work Step List (WR #2N20255), May 11,1974, Removal of Clogged Baron From SIS Pump Suction; 2/3 CM-RCS-PRZ-1.1, Revision 2, May 3, 1977, Unit 2 Pressurizer Manway Cover; Maintenance /QA Work Step List (WR #2W203847), 23 DG Lube Oil AP Switch Replacement.
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l No discrepancies were identified in this. area.
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9 S.. Technical Content of Facility Procedures The inspector conducted a review of the below listed procedures using FSAR System Descriptions, P&ID's and Technical Specifications to verify that procedures were sufficiently detailed to control the operation or evolution described within Technical Specification Limiting Conditions for Operation.
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P0P-1.1, Revision 3, August 1,1977, Plant Heatup from Cold
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Shutdown Condition!
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SOP-10.1.2, Revision 1, May 11, 1977, SI System Operation.
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E-7, Revision 1, August 1,1977, Reactor Control System
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Mal function,.
ll/SHF, Revision 2, June 8,1977, Unit Auxiliary Transformer
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Sudden Pressure, AP 5.5 psig, Instrument #63.
ll/SHF, 6900 V Bus Transfer Block.
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ll/SNF, Pressurizer Heaters Circuit Ground, ICR.
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11/SNF, Station Service Transformer No. 2 Trouble, Hot Spot Indicator Relay, 175 F.
' Maintenance /QA Work Step List (WR #2N20255), May 11,1974,
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Removal of Clogged Baron From SIS Pump Suction.
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0AD-7, Revision 0, December 8, 1976, Procedural Control.
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PE-AD-4, Revision 5, October 24, 1975, Procedures for Performing
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Maintenance.
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No discrepancies were identified in this area.
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Procedure Chances and Documentatica Pursuant to 10 CFR 50.59(a)
and 50.59(b) Requirements The inspector verified, 'by review of the Station Nuclear Safety Comittee (SNSC) meeting minutes for one year from July 1977 and Maintenance Work Requests involving plant modifi:ations, that changes nade to procedures were in conformance with 10 CFR 50.59(a) require-ments and that records of changes in the facility and in procedures were nude pursuant to 10 CFR 50.59(b).
No discrepancies were identifie.
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7.
Procedure Changes Resulting from Technical Specification Amendments
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a.
The inspector reviewed Technical Specification changes made during the period from June 1976 through July 1977 to verify that applicable procedures were revised as necessary to reflect changes to the Technical Specifications.
During this review
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the inspector noted the following discrepancies.
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(1)
Amendment 25 dated June 30, 1976, to ticense DPR-26 (
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in reference to Environmental Technical Specification (ETS)
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4.0,Section VI, paragraph (ii) establishes 1 total station
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fish kill limits for Units 1, 2 and 3 with an exception
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in that the Unit 1 count would not be included in -the
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total fish kill count during the conduct of Weir Feas-ibility Study.
POP-2.1, Revision 1, August 1,1977,.
Operation at Power, paragraph 4.1.c reiterates the established ETS fish kill limits but the procedure parenthetically. denotes these limits applicable to Units 2 and 3.
The inspector determined from the licensee that the subject study is not in effect and that the ETS fish kill limits are applicable to all three units.
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(2)
Amendment 26, dated January 12, 1977, to license DPR-26 revised SNSG-membership with respect to. latest facility position title, quorum requirements and SNSC responsibilities stated in TS 6.5.1.6.e, g, h and i.
Corresponding para-graphs of SAO-131, Revision 0, January 11,1975, Appendix I,
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j SNSC Charter do not reflect these latest changes. 'The
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i accordance with TS 6.5 by review of SNSC meeting minutes.
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(3)
Amendment 30, dated May 13, 1977, to license DPR-26 added
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action statements to TS 3.1.F, Reactor Coolant System I
Leakage in reference to Steam Generator Tube Leakage in excess of 1 gpm.
SOP-1.8, Revision 0, May 4, 1977, Reactor
Coolant System Leakage Safety Evaluation, paragraph 4.4.3 states that if leakage (in reference to Steam Generator Tube Leakage) is less than 10 gpm and is evaluated as safe, operations may continue with close surveillance for any increase in leak rate.
This is contrary to TS 3.1.F.4 and 5 which requires in part a cold shutdown condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from first time 6f detection of excessive steam generator tube leakage.
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b.
The licensee acknowledged the inspector's comments with respect to the. above discrepancies and stated that the applicable pro-
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cedures would be revised to reflect current TS requirements.
In a subsequent telephone conversation the licensee stated ~
that the procedures listed in paragraph 7.a would be revised
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by September 1,1977.
The licensee also s.tatad_in the telephone conversation that to prevent recurrence the SNSC would review all amendments to a license and assign personnel to review the
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amendments and initiate any necessary procedure changes.
The licensee also stated that the SNSC charter would be revised to
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reflect this by September 1,1977..
This item is unresolved pending revision of subject procedures to accurately reflect TS amendment requirements and revision of SNSC charter to ensure procedures reflect latest TS amendments (247/77-25-03).
8.
Control Room Tour The inspector toured the control room and reviewed plant operations by observing control board switch positions, indicators, and annunciators.
In addition, the inspector discussed operations with operators and compared several plant conditions with various Technical Specification
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Limiting Conditions of Operations to verify compliance.
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No discrepancies were identified.
9.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations.
An unresolved item disclosed during the inspection is discussed in paragraphs 7.a and 7.b.
10.
Exit Interview The inspector met with licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on August 5, 1977.
The inspector summarized the purpose and the scope of the inspection and the findings. These findings were also discussed in a subsequent i
telephone conversation on August 9,1977.
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