ML20042B153
| ML20042B153 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 06/28/1977 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20042B150 | List: |
| References | |
| 50-003-77-03, 50-247-77-18, 50-286-77-18, 50-3-77-3, NUDOCS 8203250031 | |
| Download: ML20042B153 (3) | |
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3 License Nos. DPR-5 DPR-26 DPR 64 APPENDIX A NOTICE OF VIOLATION i
Based on the results of an NRC inspection conducted on May 31 - April 3,1977, it appears that certain of your activities were not conducted in full compliance with the conditions of your license as indicated 4
below.
Item A is categorized as an Infraction and Items B through D ire categorized as Deficiencies.
A.
Environmental Technical Specifications Section 3.4.1.h and Table 2.4-3 and 2.4-4 require that certain equipment be installed by June 1, 1977.
Contrary to the above, the following items were not installed by June 1, 1977:
the Section 3.4.1.h requirement that Unit 1 shall be pro-
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vided with a continuous liquid effluent monitor including i
a recorder and an alarm and automatic closure of the liquid i
waste isolation valve; d
the Table 2.4-3 requirement that the Unit 2 Refueling Water Storage Tank (RWST), an Outdoor Storage Tank potentially i
radioactive, be provided with a liquid high level alarm; and, i
the Table 2.4-4 requirement that the Unit 1 Waste Gas Storage Tanks be provided with a radiation alarm, automatic control to the isolation valve,'and a continuous monitor.
Prior to the completion of the inspection on June 3,1977, the i
Table 2.4-3 required High Level Alarm on Unit 2 RWST had been i
installed and tested. The licensee reported by telephone to NRC:I that the Section 3.4.1.h required items on the Unit 1 liquid effluent discharge had been installed and tested as of June 5, 1977.
Only your actions to assure that future items of this nature are completed prior to the required operability dates need to be addressed for these two items.
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~ APPENDIX A 2
B.
Technical Specification 6.8.1 states in part:
" Written procedures and administrative policies shall be established, implemented and maintained...."
Station Administrative Order No.102, Section 2.4.5 states:
"Es ta-blish a form for making temporary changes wh!ch insures that they are only made.by approved lianagement personnei in accordance with the requirements of ANSI N18.7-1972 and further, that such changes are documented and reviewed by the SNSC within 7 days of impie-nenta tion."
Temporary Change Forms require that the completed forms, or copies thereof, be forwarded to SNSC within seven days of issuance.
Contrary to the above, Temporary Procedure Change Forms issued on March 11 and 12,1977, were not forwarded to the SNSC for review.
(Unit 2)
C.
Technical Specification 6.5.1.6 states in part:
"The Station Nuclear Safety Committee shall be responsible for:
Review of
- 1) all procedures required by Technical Specification 6.8 and changes thereto....".
Technical Specification 6.8.3 states:
"A techanism shall exist for making temporary changes, and they shall only be made by approved management personnel in accordance with the requirements of ANSI N18.7-1972.
The change shall be documented, and reviewed by the SNSC within 7 days of implementation."
Contrary to the above, none of the temporary changes initiated during the period January through May,1977, were reviewed by an assembled quorum of the Station Nuclear Safety Committee (SNSC).
(Unit 2)
D.
Technical Specification 6.8.3 states in par::
"A mechanism shall exist for making temporary changes, and they shali be made by ap-proved management personnel in accordance wsth the requirements of ANSI 18.7-1972."
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ANSI 18.7-1972, Section 5.1.2 states in part "For Temporary Changes that may involve a change in intent of the approved procedure, the person authorized to approve the change shall be, in most cases, at a higher level of plant management than the person whose designated function includes shift supervisory responsibility for the safe operation of the plant."
SAO-102, Procedure / Procedure Change Approval Policy, Revision 4, February 24, 1976, paragraph 2.4.5 states that each sub-section head shall:
" Establish a form for making Temporary Changes which insure that they are only made by approved Management personnel in accordance with requirements of ANSI N18.7-1972.... "
Temporary Change Forms require that if a change of intent to the approved procedure is involved, written or verbal con-currence of the Operations Engineer must be documented.
Centrary to the above, from June 2,1976 to June 3,1977, Temporary Change 76-2 to procedure PEP-RPC-3 was in effect with no evidence of documented written or oral approval of the Unit 3 Operations Engineer.
Temporary Change 76-2 was cancelled June 3, 1977.
Therefore, only your actions to prevent recur-rence need to be addressed in your response to th.is item.
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