ML20041G296
| ML20041G296 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 06/27/1977 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20041G294 | List: |
| References | |
| 50-003-77-08, 50-247-77-18, 50-286-77-18, 50-3-77-8, NUDOCS 8203220018 | |
| Download: ML20041G296 (13) | |
See also: IR 05000003/1977008
Text
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U.S. NUCLEAR REGULATORY COMMISSION
- YICE OF INSPECTION AND ENFORCEMENT
Region I
Unit 1:
D
c.
Unit 2:
C
Priority
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Category
_,
._idison Company of New York, Inc.
<0
.
., York 10003
.
oint Units 1, 2 and 3
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an, New York
.
- ay31-June 3,1977
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77
.
- a, Reac or Inspector
/ date' signed
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2. 3
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.54n, Reactor Inspector
'date (signed
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an, A ting Chief, Nuclear Support
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an, Acting Cnlet, Nuclear Support
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'o. 2, RO&NS Branch
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e 3, 1977 (Report Nos. 50-03/77-08 50-247/77-
a, unannounced inspection of administrative
'arfures; format and technical content of facility
riisions resulting from Technical Specification
'ations; review of licensee action on previous
'. review of implementation of selected Environ-
'ations.
The inspection involved 59.5 inspector-
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inspectors.
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as inspected, no items of noncompliance were
or apparent items of noncompliance were found in
l 3 (infraction - failure to have various
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elred by Environmental Technical Specifications
// as required - Paragraph 4); Unit 2 (deficiencies-
edures - Paragraph 6.c(1) - failure of an
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assembled quorum of the Station Nuclear Safety Comittee (SNSC) to re-
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view temporary changes to procedures - Paragraph 6.c(2)); Unit 3 (def-
iciency - failure to adhere to procedures - Paragraph 6.b)
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DETAILS
1.
Persons Contacted
- M. Byster, Quality Assurance Engineer
- 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
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J. Vignola, Assistant Maintenance Superintendent
The inspector also interviewed other licensee employees which in-
cluded mcmbers 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.
The inspector verified that
temporary procedures S-4, Normal and 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 S0P 10.6.3,, Containment Air Locks Operation, Revision 0,
March 1, 1977, which has been reviewed and approved in accordance
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with the requirements of the Technical Specifications and the licensee's
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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):
Failu.e 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
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 50P-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
SOP-1-2, Draining and Reactor Coolant System, Revision 2, May 6,
1977, to include provisions in the event of a known steam generator
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 baron 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 revie; 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
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.
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 levsl 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 valve.
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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5.
Administrative Controls for Facility Procedures
a.
The inspector performed an audit of the licensee's administrative
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controls by conducting a sampling review of the following
administrative procedures:
Station Administrative Order (SA0)-100, Station Admin-
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istrative Order Policy, Revision 4, July 1,1975;
SA0-101, NPG Managment Policy, Revision 4, January 19,
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1976;
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SA0-102, Procedure / Procedure Change Approval Policy,
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Revision 4, February 24, 1976;
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SA0-131, Station Nuclear Safety Committee, Revision 0,
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January 11, 1975;
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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.
6.
Review of Facility Procedures
' The inspector reviewed facility procedures on a sampling basis to
verify the following:
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
N18.7Property "ANSI code" (as page type) with input value "ANSI</br></br>N18.7" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., " 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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in the procedures.
Temporary changes were made in conformance with Technical Speci-
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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 Emercency 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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1975;
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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;
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 Proceduras
3-CM-7.12, Replacemant 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-RPC-3, 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
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-
fications, there was a change of intent to the procedure as so
indicated on 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,
the written concurrence of the Operations Engineer was to be
obtained or if the Operations Engineer was not present, his
verbal concurrence was to be documented by the Watch Foreman.
Copies of TC 76-2 maintained in the master file, control room
and Station Nuclear Safety Committee records file did not have
the required written or verbal concurrence documented.
This
finding represents noncompliance 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 tated, when questioned by the
inspector concerning TC.76-2, that the subject instrument was no
longer malfunctioning and that1the change appeared to be out-
dated.
The inspector noted this to the licensee and the licensee
concurred with the Reactor Operator's statement.s
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
futuFe items of this nature do not ' recur should be addressed by
the licensee.
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c.
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 contro's.
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(1)
During th'is review the inspector noted 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 Cold Shutdown" and POP
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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 the ITcensee's admin-
istrative procedure.SA0-102, "Procehure/ Procedure Change
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Approval Policy." As i result of interviews held with.
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licensee personnel and further examination of representa-
tive records, it was established that the three temporary
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change forms issued on ~ March 11 and 12,1977 had notieen
fon arded to the SNSC' for. evaluation. .These changes to
the procedures identified above were the result of Techni-
cal Specification changes and plant modifications.
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This finding rep'res'ents noncompliance with Technical Speci-
fication 6.8.1 and Station Administrative Orders, SA0-102,
in that licensee personnel failed to follow procedures. The
inspector verified that this'ltem was subsequently reviewed
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by the licensee's established administrative mechanism for
the SNSC's evaluation. -(247/77-18-03)ir y ~
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(2)
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.
The
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Plant 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
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of an assembled SNSC quorum.
This finding represents noncompliance with Technical
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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)
d.
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 completion date.
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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 Specifications.
No discrepancies were identified.
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8.
Procedure Chances and Documentation Pursuant to_10 CFR 50.59(a)
and 50.59(b) Reouirements
The inspector verified, by review of the Station Nuclear Safety
Committee 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.
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9.
Technical Content of Facility Procedures
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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.
P0P-1.2, Reactor Startup, Revision 0, March 10,1976;
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50P-CS-1, Containment Spray System Operation, Revision 0, May
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20, 1975;
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PEP-SG-1, Steam Generator Tube Leak, Revision 0, May 16,1975;
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Alarm List (page 5'-18), Panel SBF-2, Hi-Hi Containment Pressure
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(Spray) Channel Trip, Revision 1
September 3,1976;
Alarm List (page 6-12), Panel SCF, Auxiliary BF Pump Low Flow,
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Revision 0, October 4, 1976;
3-CM-7.12, Replacement of SIS Pump Internals, Revision 0,
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March 28,1977.
No discrepancies were identified.
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10.
Control Room Tour
The inspector toured tne control room and discussed operations with
several operators.
During this tour, the inspectors reviewed plant
operations by observing control board switch positions, indicators,
and annunciators.
In addition, the inspectors questioned operators
as to annunciator status and compared several plant conditions with
various Technical Specification Limiting Conditions of Operations
to verify compliance.
No discrepancies were identified.
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11. Unresolved Items
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Unresolved items are mhtters about which more infonnation 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 were
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-
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fication 3.4.1.d.
The Plant Manager acknowledged the inspector's
statements.
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