IR 05000286/1986023

Onsite Regular & Backshift Insp Rept 50-286/86-23 on 861118- 870105.Violation Noted:Failure to Follow Administrative Procedures AP-6 & AP-25-3 Re Work Requests & Matl Substitutions,Respectively

ML20213A508
Person / Time
Site:	Indian Point
Issue date:	01/15/1987
From:	Linville J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20213A290	List: IR 05000286/1986023 ML20213A287 ML20213A482
References
50-286-86-23, NUDOCS 8702030317
Download: ML20213A508 (9)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No: 50-286/86-23 Docket N Licensee: Power Authority of the State of New York 10 Columbus Circle New York, New York 10019 Facility: Indian Point Nuclear Generating Station, Unit 3 Location: Buchanan, New York Dates: November 19, 1986 to January 5, 1986 Inspectors: P. S. Koltay, Senior Resident Inspector {

R. S. Barkley, Resident I spector Approved by: A A / 5 afes f C. Linville, Chief '

/ dat'e R'eactor Projects Section 2 DRP Inspection Summary:

Inspection on November 18, 1986 to January 5,1987 (Inspection Report 50-286/86-23)

Areas Inspected: Routine onsite regular and backshift inspection of plant operations including shift logs and records; licensee actions on previously identified inspection findings; facility operations; plant tours; system walkdowns, two of which used the guidance provided in NUREG-4565,

"Probabilistic Safety Study Application Program for Inspection of the Indian Point Unit 3 Nuclear Power Plant"; surveillance; maintenance; steam binding of auxiliary feedwater pumps (TI 2515-69); and review of security activities. The inspection involved 212 hours0.00245 days <br />0.0589 hours <br />3.505291e-4 weeks <br />8.0666e-5 months <br /> by the resident inspector Results: One violation, failure to follow administrative procedures, was identified. The inspectors evaluated immediate corrective action Long term corrective actions in the areas of training have been initiated and will be reviewed by the inspectors. (Paragraph 4)

3702030317 870122 PDR ADOCK 05000286 G PDR

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i DETAILS Persons Contacted Within this report period, discussions were conducted with members of the licensee management and staff to obtain the necessary information pertinent to the subjects being inspecte . Licensee Actions on Previously Identified Inspection Findings (Closed) Inspector Followup Item (286/85-23-01) NRC inspection report 85-23 detailed the review of the licensee's corrective actions in response to IE Bulletin 80-11. At the time of the inspection, a periodic test to assure continued maintenance of the subject masonary walls was not in plac The inspector verified that on November 11, 1986, the

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licensee issued surveillance test 3PT-A19, Revision 0, "Masonary Block Wall Inspection."

(Closed) Unresolved Item (286/86-02-01) Deterioration in plant housekeeping practices resulted in the accumulation of eouipment and materials in the primary auxiliary building. The inspector verified that improved maintenance practices and better communications among involved departments enabled the licensee to maintain good housekeeping controls throughout the midcycle and turbine repair outage *

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(Closed) IE Bulletin 84-02: Failures of General Electric Type HFA Relays in Use in Class IE Safety Systems. The licensee stated in their responses to the NRC dated July 17, 1984, October 15, 1984, and December 7, 1984,

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that a review of the applications of GE Type HFA relays at Indian Point 3 revealed no instances where they are used in safety-related application .

Therefore, no actions were required to be taken as a result of this

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bulletin. However, the licensee did conduct a review of the general concerns addressed in the bulletin (i.e. accelerated thermal aging of relay components). They concluded that these bulletin concerns were not applicable to IP-3 and that current preventative maintenance practices were sufficient to minimize the potential for relay failures. This bulletin is considered closed.

l (Closed) Inspector Followup Item (286/84-12-02) Date of effluent monitor i source check to be entered on log of calibration factor verification

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program. The inspector verified that the date of the quarterly effluent monitor source check performance test is recorded on the calibration factor verification log (Table 2 of RE-CS-030).

(Closed) Inspector Followup Item (286/86-09-04) Licensee should establish an additional chemistry engineer position to strengthen management controls in the chemistry department. The inspector verified that this new position has been approved and that the licensee is in the process of filling the position.

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(Closed) Inspector Followup Item (286/85-04-12) Installation of a GA Technologies Wide Range Gas Monito The inspectors confirmed that the licensee has installed a GA Technologies plant vent wide range gas monitor (R-27). They reviewed the concerns raised in NRC inspection report 85-04 concerning the calibration accuracy of the high range channel of this monitor. Discussions with the licensee revealed the channel has a fixed sample / detector geometry. Also, the stability of the detector response to solid versus gaseous calibration standards is goo Therefore, no reliability concerns appear to exist with the calibration for the channe (Closed) Inspector Followup Item (286/84-17-02) Initiation of a training program for nonradiological chemistry technicians. The licensee is beginning a formal classroom and laboratory training program for chemistry technicians in January,1987. The inspectors reviewed various elements of the training program including the course schedule and the training requirements for acceptance as a qualified watch chemist. The training program is presently being reviewed by INPO for accreditatio The inspectors noted that the licensee is participating in an

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- inter-laboratory standards program with other Northeast power plants. In i addition, the licensee established an intra-laboratory standards program in February,1986, where the chemistry technicians analyze standard solutions that are prepared by the Chemistry Supervisor and evaluated by the supervisor for accuracy.

l 3. Facility Operations The unit operated at 100% of rated power through November 26, 1986. On November 27, a scheduled load reduction to approximately 35% power was i performed to facilitate repair to charging valve 204- Full power operation resumed on November 2 The 1987 refueling and maintenance outage, scheduled for approximately 90 days, will commence during the first week of May. Major items to be completed during the outage include the 10 year ISI program, 100% eddy current testing of all steam generators, service water pump replacement, and upper internals split pin replacement.

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4. Plant Tours

The inspectors conducted routine entries into the Control Building, Turbine Building, Primary Auxiliary Building, Fuel Storage Building and

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the Intake Structur The inspectors observed Central Control Room activities, including shift turnovers, log entries and responses to alarm annunciators, as well as maintenance and surveillance activities in progres Particular note was

- taken of the presence of quality control inspectors, quality control evidence and housekeeping. The inspectors interviewed operators, technicians, mechanics, supervisors and plant management. The purpose of

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the inspection was to affirm the licensee's commitments to and compliance with 10CFR, Technical Specifications and licensee administrative procedure Findings The following concerns deal with the Weld Channel and Containment Penetration Pressurization System (WCCPPS). This engineered safety feature is designed to minimize containment leakage into the environment by maintaining a monitored minimum air pressure on the weld channels installed over the containment liner welds, and the containment penetrations. The primary air supply is the instrument air system. A backup nitrogen supply is provided to each of the four zones of the WCCPPS through pressure regulators. The entire system is designed to Category I, seismic Class I criteri On November 24, during a tour of the Primary Auxiliary Building, the inspectors noted that the four nitrogen pressure regulators associated with the nitrogen backup supply to the WCCPPS appeared to be improperly installed. The original equipment, which was secured to a seismic Class I rack, had been replaced. The new regulators were not attached to the support rack. The inspectors' concern regarding the failure of the installation to meet seismic criteria was brought to the licensee's attention. The licensee stated that the original equipment is no longer manufactured and the replacement regulators did not fit the original bracket The licensee subsequently issued Work Request No. 9410, on November 26, 1986 for the installation of seismic supports for the regulators. The installation was accomplished in accordance with the maintenance / quality assurance work step list on the same day. The licensee, through its contractor, also initiated a study to determine the impact of a seismic event on the unrestrained regulators. This item is unresolved pending review by the resident inspectors when the study is complete. (Unresolved Item 86-23-01).

Subsequently, the inspectors attempted to review documents associated with the installation of the replacement regulators; however, no such documents could be located. The licensee's administrative procedure, AP 9, Revision 6, Work Requests, requires that each Category I maintenance task be requested via an approved work request. As per section III of the procedure, the issuance of the work request will assure the review and approval of tasks detailed in the document by the Operations Superintendent, the Maintenance /I&C Superintendert, the Quality Control Supervisor, the Technical Services Superintendent, and the Outage Coordinator. The document also allows the Maintenance Superintendent to determine the need for Materials Substitution Evaluatio The licensee's administrative procedure, AP 25.3, Revision 0, Material Substitutions, states that substitute items will not be installed until the Material Substitution Evaluation is prepared and approve ,-

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It appears that on July 12, 1986, while the plant was in cold shutdown, the shift supervisor bypassed the requirements of the above procedures and directed the replacement of the original regulators to take place without the benefit of the necessary documentation. This constitutes a violation of the licensee's procedures. (86-23-02)

The inspectors determined that the pressure regulators were purchased as Non-Category I equipment, through Purchase Order PO 85IP1678, May 23, 1985 for installation on the house service boiler. On July 12, 1986, one of the four original pressure regulators failed, allowing for rapid depletion of the backup nitrogen supply to the WCCPP system. The shift supervisor on watch decided to replace all four regulators with the new equipment available from the warehouse. The required paperwork for a Work Request and a Material Substitution Evaluation was not initiated prior to or after the installation of the equipment. Upon completion of the job, it was noted that the new equipment did not fit the brackets of the support rack. At this time, the shift supervisor and the Superintendent of Operations agreed that an engineering design change is necessary in order to complete the jo However, the required forms, in accordance with Procedure AP 25.1, Revision 1, Request for Engineering Services, were never generated, leaving the installation incomplet Based on interviews with licensee management ard licensed operations personnel, the inspectors identified the following factors that contributed to the licensee's failure to follow existing procedural requirements:

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The repair was handled as an emergency, during the back shift, since a failed nitrogen regulator may allow nitrogen to seep into the personnel air lock. The air lock was in periodic use, during the ongoing outag The shift supervisor erroneously assumed that his verbal request, to the Superintendent of Operations, to initiate a formal engineering change request met all procedural requirements for this installation. Furthermore, such a request was not communicated to the Superintendent of Technical Services, as required by procedure AP 2 The inspectors reviewed applicable licensee procedures including:

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AP-9 Work Requests

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AP-2 Conduct of Operations

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AP 2 Request for Engineering Services

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AP 2 Material Substitutions The above procedures contained detailed directives to allow licensee personnel to complete maintenance activities properly, t

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i Through interviews of licensed operations personnel, including shift supervisors, the inspectors verified that personnel are generally cognizant of the requirements of the subject procedures, specifically, responsibilities of operations shift personnel, which do not include the replacement and/or maintenance of safety-related equipmen The inspectors, as part of their routine inspection program, which includes detailed walkdowns of safety-related equipment, have not identified previous recurrences of similar natur In conclusion, it appears that the subject violation is a result of an isolated series of events. The licensee has initiated the following corrective actions to correct the deficiency and prevent recurrence Material Substitution Evaluation (MSE 86-3-143 WCCPP) was completed and approved by the Plant Operating Review Committee on December 4, 198 The Evaluation concluded that the off-the-shelf replacement regulator is of equal or better quality than the original equipmen The regulators were seismically restrained in accordance with Work Request WR 941 All licensed operators were reinstructed in the context and applicability of procedure The training department will discuss the event as part of the licensed requalification progra . System Walkdowns Using the licensee's approved checkoff lists, the inspector performed a walkdown of the accessible portions of the Chemical and Volume Control System (CVCS) and the Liquid Radioactive Waste Processing System per COL-CVCS-1, Rev . 1 Probabilistic Risk Analysis Based Inspections In addition, using the Probabilistic Risk Analysis (PRA) inspection guidance provided by NUREG-4565, "Probabilistic Safety Study Applications Program for Inspection of the Indian Point Unit 3 Nuclear Power Plant,"

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the inspector performed modified walkdowns outlined in the NUREG for the accessible portions of the following systems:

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Component Cooling Water System

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Containment Spray System i

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Findings The inspectors questioned the licensee as to whether a Nuclear Safety Evaluation (NSE) has been performed for the temporary radioactive waste processing system the licensee installed in the Fuel Storage Building truck bay. The licensee stated that NSE 80-03-023 WDS-L, Rev. 2, dated August 12, 1980, was performed for the tie-in of a temporary radioactive waste processing system to the existing waste processing system. The inspectors reviewed the NSE, which concluded that the system presented no unreviewed safety question. However, the inspectors noted that the safety evaluation was conducted for a different waste processing system than the one presently in use. Subsequent discussions with the licensee revealed that a new safety evaluation was not conducted for the system presently installed because the physical layout of the system is identical to that of the previous waste processing system. No new potential for radiological exposure to personnel or the environment has been introduced by the change. Therefore, the existing NSE was, and still is, considered vali No violations were identifie : Surveillance The inspector reviewed and/or witnessed the following surveillance tests performed during this report period:

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3PT-M8, Rev. 7, Steam Generator Water Level Analog Channel i Functional Test

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3PT-M3, Rev. 6, Reactor Coolant Flow Analog Channel Functional Test

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3PT-Q19, Rev. 3, Component Cooling Valve Testing Findings:

During the performance of 3PT-M8, the licensee found the dial setting for c

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bistable LC-447F was set lower than the required Technical Specification setpoint. This bistable is one of three channels which generate a

, reactor trip on low-low water level in steam generator #34. The bistable dial setting was incorrect because it was apparently bumped by licensee personnel during use of an electrical outlet located in close proximity to the setpoint dial. The inspectors questioned the licensee concerning this event. The licensee agreed to initiate corrective actions to minimize the potential for a recurrence of this even During the performance of 3PT-M3, the licensee found the recctor coolant loop 3 flow indication of FT-435 to be above the acceptance limit. Thus, the bistable setpoints for the loop 3 low flow reactor coolant system trip for this channel were below the required Technical Specification limit. The licensee issued Temporary Procedure Change 86-198-SV to change the output criteria and bistable setpoints for FT-43 The inspector noted that the Technical Specification requirements for the bistable setpoints are based on indicated versus actual reactor coolant

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loop flo Therefore, increasing the bistable setpoints for the channel is not prohibited by the Technical Specifications. Subsequently, the licensee initiated Maintenance Work Request (MWR) 6325 to investigate the

.' cause of the increased flow indication on FT-435. The cause of the increased flow indication was identified and corrected. The flow indication and bistable setpoints were then recalibrate No violations were identifie , Maintenance The inspector observed or reviewed the following maintenance activities, listed below, while they were in progress, or upon their completion, to ascertain the following:

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Approved procedures, adequate to control the activity, were being used by qualified technicians

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Evidence of QC involvement in the activity

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Proper radiological controls were implemented (where needed)

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Overall internal condition of disassembled equipment, paying particular attention for signs of excessive wear and/or corrosion and,

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Adequate post-maintenance testing was conducted.

i FT-435 Trouble Shooting - MWR 6325 The licensee investigated the cause of a gradual increase in reactor

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coolant loop 3 flow as indicated by flow indicator FT-435. The cause of the increased flow indication was determined to be a leaking drain valve on the low pressure side of the instrument. The leakage was stopped and  !

the instrument readings and setpoints recalibrated.

#35 Service Water Pump Motor Shaft Fabrication and Replacement - MWR-7896 f

The licensee is in the process of machining a new shaft for the motor of the #35 service water pump due to the failure of the existing shaft and the unavailability of a replacement from the original manufacturer. The

inspector reviewed the work step list used to fabricate the shaft, as l well as the drawing outlining the dimensional specifications for the i

shaft. He reviewed certification number IP-1043, as well as the Report l' of Materials Received (RMR-53029) and verified that the rolling stock used to fabricate the shaft is traceable by heat number. Material Substitution Evaluation 86-3-148 SWS, Rev. 0 was also reviewed.

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No violations were identifie l l

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,! Licensee Actions to Prevent Steam Binding of Auxiliary Feedwater Pumps The inspector reviewed the licensee's methods for preventing steam

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binding of the Auxiliary Boiler Feedwater Pumps (ABFP), as directed by IE

, Temporary Instruction 2515/69, " Inspection of Response to IE Bulletin

85-01 - Steam Binding of Auxiliary Feedwater Pumps." He reviewed the System Operating Procedure (SOP-FW-4) detailing the operation of the ABFPs. The procedure provides detailed guidance for recognizing the onset of steam binding and restoring the ABFW system to operable status

should steam binding occur. The inspector also reviewed the conventional plant operator's log and verified that the ABFP discharge piping temperature is checked once per eight hour shift to detect any leakage of

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hot feedwater into the syste !

No violations were identifie . _ Review of the Applications of General Electric Type, HGA Relays in Safety-Related Applications at Indian Point Unit 3

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The inspector performed a review of the applications of GE Type HGA

relays at Indian Point 3 in accordance with Region I Temporary Inspection Instruction No. RI-86-0 Discussions with licensee personnel confirmed that GE Type HGA relays are not used at IP-3. This Region I Temporary It spection Instruction is close !

10. Review of Security Activities The inspectors reviewed t1e status of the licensee's security system and their compliance with the provisions of the Physical Security Pla Specifically, the inspectors conducted tours of the alarm stations and i the security backup electric power source. They verified proper manning

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of the security shift as well as the proper acknowledgement and response i to incoming security alarm i

No violations were identified.

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11. Exit Interview i

! At periodic intervals during the course of the inspection, meetings were

, held with senior facility management to discuss the inspection scope and findings. An exit interview was held on January 9,1987 to discuss this report period. During the discussion, the licensee did not identify any 10 CFR 2.790 material, i

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