ML20050N691

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IE Insp Rept 50-286/82-03 on 820216-0315.Noncompliance Noted:Failure to Maintain Controlled Documents Re Administrative Procedures & Health Physics
ML20050N691
Person / Time
Site: Indian Point 
Issue date: 03/19/1982
From: Baunack W, Kenny T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20050N685 List:
References
50-286-82-03, 50-286-82-3, IEB-80-06, IEB-80-08, IEB-80-18, IEB-80-19, IEB-80-20, IEB-80-21, IEB-80-23, IEB-80-6, IEB-80-8, NUDOCS 8204140419
Download: ML20050N691 (14)


See also: IR 05000286/1982003

Text

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U. S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 50-286/82-03

Docket No. 50-286

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License No. DPR-64

Priority

Category

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Licensee: Power Authority of the State of New York

10 Columbus Circle

New York, New York 10019

f

Facility Name:

Indian Point Nuclear Generating Station, Unit 3

Inspection at: Buchanan, New York

Inspection conduct

Fe ruary 16, 1982 to March 15, 1982

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Inspectors: [

4rer,

~

f

i

T.

enyy, jident Inspector

/ ddte

) , a DM

3Nh2-

'

W. Baunack, Acting Chief, Indian Point

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~date

Resident Section, Division of Project

and Resident Programs

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Inspection Sumary:

Inspections on February 16, 1982 to March 15, 1982 (Inspection Report 50-286/82-03)

Areas Inspected: Routine onsite regular and backshift inspections of plant

operations including shift logs and records; licensee action on previous in-

spection findings; plant tour; surveillance; maintenance; review of monthly

reports; and followup on IE circulars and IE bulletins. The inspection involved

87 inspector hours by the resident inspectors.

Results: Of the eight areas inspected, no violations were identified in seven

areas. One apparent violation was identified in one area, (failure to main-

tain controlled documents, details, paragraph 3.D(1).

8204140419 820329

PDR ADOCK 05000286

G

PDR

DETAILS

1.

Persons Contacted

M. Albright, Instrument and Control Superintendent

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J. Brons, Resident Manager

J. Dube, Security and Safety Supervisor

D. Halama, Q.A. Superintendent

W. Hamlin, Assistant to the Resident Manager

W. Josiger, Superintendent of Power

J. Perrotta, Radiological and Environmental Services Superintendent

S. Munoz, Technical Services Supervisor

E. Tagliamonti, Operations Superintendent

J. Vignola, Maintenance Superintendent

The inspector also interviewed and observed other licensee employees in-

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cluding members of the operations, health physics, technical services,

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maintenance, and security staffs.

2.

Licensee Actions on Previous Inspection Findings

(Closed) Inspector Follow Item (50-286/78-01-27): The inspector's concern

was the licensee's handling of the requests for data gathering received

from the NSSS. The method of requesting data from, and the handling of

data received from the NSSS is accomplished through the onsite service

manager for Westinghouse, who is onsite as a resident. The onsite ser-

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vice manager is kept infomed in all matters concerning Westinghouse

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cquipment, by the licensee.

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(Closed) Unresolved Item (50-286/78-05-01): Correct problems causing fre-

quent degradations of charging pump, seals, fluid heads, and piping. The

inspector reviewed and verified Modification 78-3-47 CVCS, which added a

bypass line around the charging pumps that acts as a recirculating line in

order to start the pumps, wam them up, and remove any air from the system

prior to putting them in service. This practice is followed whenever the

seals are replaced. The inspector also reviewed and verified Podification

79-3-021 CVCS which added suction pulsation dampers to all charging pumps

and a discharge pulsation damper to #33 charging pump. These modifications

have reduced the number of seal failures by a factor of four. The licensee

has scheduled the addition of discharge pulsation dampers to #31 and #32

charging pumps for the March outage.

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(Closed)UnresolvedItem(50-286/78-10-01): The inspector's concern was

that the inspection of Neutron transmission poison plates in the high density

fuel racks was not 100% complete. The inspector verified completion (100%

inspection) of the Neutron transmission poison plates by review of Quality

Control Inspection Report IP 78-40.

(Closed) Inspector Follow Item (50-286/78-19-02): Review of licensee's

evaluation and disposition of pressurizer weld number L-1 UT indications.

The inspector reviewed inservice inspection reports for 1978 and 1979 con-

ducted by Westinghouse with the following results:

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Weld L-1 in the 1978 report was assessed to be laminar and a fabri-

cation fault. This assessment resulted frcm the examination of

x-rays made during fabrication.

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After the indication was found, a re-examination was conducted

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using 00, 45 , and 600 contact angles. The indication was found

acceptable to ASME,Section XI,1974 Addition,1975 Addenda.

The 1979 inspection reinspected weld L-1 using the same contact

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angles and showed no change in the indication. The report de-

duced the indication to be within the above-mentioned code.

This weld will be re-examined during the March outage.

The inspector has no further questions concerning this item.

(Closed) Unresolved Item (50-286/78-24-01):

Incomplete cable qualifica-

tion test data and apparent use of rejected cable. The original concern

of the inspector pertained to the following seven Receiving Inspecting

(RI) reports:

(1) Report 77-RI-474: No qualification test data had been released

by Engineering. The inspector reviewed additional testing done

by the Astora Labs, which qualified the cable in question.

(2) Report 77-RI-475 had incomplete qualification test data, and was

conditionally released. The inspector reviewed certification

papers for this report.

(3) Report 77-RI-477 found four reels of defective cable, but only

three had been returned to the vendor. The inspector verified

shipment of four reals of cable by review of shipping reports

dated February 15, 1978.

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(4) Report 77-RI-479: No qualifying test data. The inspector reviewed

certification papers.

(5) Report 77-RI-522: No qualifying test data. The inspector reviewed

documentation of additional testing perfonned by the licensee.

(6) Report 77-RI-533: No qualifying test data. The inspector reviewed

certification papers.

(7) Report 77-RI-541:

Incomplete qualifying test data. The inspector

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reviewed documentation of additional testing.

All of the above RI's were on hold when inspection 78-24 was conducted.

The inspector reviewed the QCIR's (Quality Control Inspection Reports)

that released the cable for use and has no further questions at this

time.

(Closed) Unresolved Item (50-286/78-27-01): Tenninal blocks and splices

qualification. This is a repeat item, and will be closed when Circular

78-08 is closed.

(Closed) Noncompliance (50-286/78-33-02): Testing of containment isola-

tion valves on a greater than two year interval. The inspector reviewed

the licensee's letter of January 17, 1979 to the Region contesting the

item. The inspector also reviewed the letter from the Region dated

February 5,1979 dismissing the item based on further consideration of

Amendment #7 to Technical Specifications. The inspector has no further

questions on this item.

(Closed)

Inspector Follow Item (50-286/78-33-04): Containment Integrated

Leak Rate Test Instrumentation.

The inspector's concern was the failure

of several dew cells during testing. The inspector reviewed Purchase

Order 82-IP-0668 which ordered a new five-channel humidity monitor,12

PCRC-11-HPB probes (detectors) which are an improved humidity detector

and cabling to install these detectors.

Discussion with the licensee's

representative indicates the detectors will be available for the next

ILRT to be done during the next outage.

3.

Plant Tour

A.

Nonnal and backshift inspections were conducted during routine er,tries

into the protected area of the plant, including the control room PAB,

fuel building, and containment.

During the inspection activities,

discussions were held with operators, technicians (HP & I&C),

mechanics, foremen, supervisors, and plant management. The purpose

of the inspection was to affinn the licensee's commitments and

compliance with 10 CFR, Technical Specifications, and Administrative

Procedures. Particular attention was directed in the following areas:

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Alamed control room annunciators, assuring that the operators

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understood the reason and the importance for each, and that correc-

tive action was being taken for each.

Control room, shift supervisor, senior operator and watch per-

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sonnel logs, assuring that trends, out-of-specification read-

ings and anomolities, if any, were being challenged.

That panel board displays and system lineups were in compliance

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with the licensee's procedures for safe operation.

That pressure and temperature relationships in the containment,

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primary and secondary systems were in compliance with operating

procedures.

That protected area access controls were in conformance with

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the security plan, including sufficient guards to perform duties,

and that selected gates and doors were closed and locked.

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That selected ESF trains were operable in accordance with

Technical Specifications and plant procedures.

B.

The inspector conducted biweekly inspections in the areas mentioned

in paragraph "A" above, observing, where possible:

Surveillance being conducted on plant parameters and equipment

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involving safety. Surveillance results are documented in para-

graph 4 of this report;

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Ongoing ESF maintenance being conducted to assure compliance with

licensee's procedures. Maintenance results are documented in

paragraph 5 of this report;

Selected liquid and gaseous samples to verify confomance with

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regulatory requirements prior to release;

Boric acid samples to confirm proper boric acid level for plant

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operation;

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Visual observations of operating equipment and piping systems

to ascertain if any leakage paths, vibration, unlocked normally

locked valves, obstructions to valve operators, and loose sup-

ports existed;

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Shift turnovers including a review of shift turnover sheet; and,

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In general, observation of the following for compliance with

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regulatory requirements:

1) Proper completion and use of selected radiation work

permits;

2) Proper use of protective clothing and respirators;

3) Proper personnel monitoring practices (wearing of badges

and use of monitoring equipment);

4)

Ignition sources and flammable materials are being con-

trolled to assure that they are in accordance with li-

censee procedures;

5) Equipment tagouts for conformance with controls for re-

moval of equipment from service; and,

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6) Plant housekeeping cleanliness practices for conformance

with approved licensee programs.

C.

During the inspection, the inspector reviewed the following procedures,

documents, or tests:

Radioactive Waste Release Permit 692 for #31 MT (liquid)

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Various shift turnover checklists

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Security Station Logs and Radio Checks

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Jumper Log

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COL-CS-1 - Containment Spray

COL-RHR-1 - Residual Heat Removal System

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Administrative Procedures AP-3

Procedure Preparation

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AP-4

Procedure Adherence and Use

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AP-21

Conduct of Operations

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AP-23

Conduct of I&C

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AP-34 - Processing, Control and Filing

of Documents

Verification of Technical Specifications Limiting Conditions for

operation for:

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Leakage of Primary Coolant

Safety Injection and RHR Systems

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Control Rod and Power Distribution Limits

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D.

Findings:

1) The inspector conducted an audit of four sets of controlled

documents, (Adninistrative Procedures, Operations Procedures,

Surveillance Procedures and Health Physics Procedures). Over-

all, the findings were satisfactory with the following :. -

ceptions:

a) Adninistrative Procedures

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Eleven manuals were surveyed;

Three manuals were in order;

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Three manuals were not up to date; and,

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Incgeneral, the remaining manuals had only

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minor problems.

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b) Surveillance Procedures

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The Surveillance Department had not provided the Op-

erating Cocument Coordinator with an updated index

of their procedures as required by Administrative

Procedure 34, Processing, Control and Filing of

Documents.

c) Health Physics

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Minor problems with several manuals not being up

to date; and,

Latest index had not been issued.

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d) Operations

All controlled cperating procedures were audited

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in the Control Room, Shift Sjpervisor's Office,

Conventional Nuclear Plant Operator's Office

(CNP0), and the Nuclear Plant Operator's (NPO)

Office; and,

All procedures were up to date with the exception

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of those in the CNP0 office, which had four procedure

manuals (Station Operating Procedures, Plant Emergency

Procedures, Off Normal Operating Procedures, and Alann

Response Procedures) which contained out-of-date pro-

cedu res.

The inspector stated the failure to adhere to administrative re-

quirements relating to the control of procedures is considered to

be a violation. (50-286/82-03-01)

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The licensee's actions to date have been:

All documents found out of date have been updated;

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A memo has been issued emphasizing the importance of

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keeping controlled documents up to date;

Instructions for making controlled document changes

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(Administrative Procedures) have been revised to re-

quire that department heads sign acknowledgement trans-

mittal sheets after the documents have been updated.

2)

During the audit of Checkoff List (COL) RHR-11, Residual Heat

Removal System, it was noted that the COL was in error in that

it called for the breaker for the RHR pumps recirculation valve

to the RWST (883) to be energized while the Technical Specifica-

tions require the valve to be deenergized. The inspector found

the switch to be in the correct position in accordance with

Technical Specification requirements. The licensee has stated

that the COL will be changed to correct the error.

3) During the audit of COL-CS-1, Containment Spray System, the in-

spector found that two drain header valves were shut, but not

locked. The COL called for them to be shut and locked. The

licensee stated that since no requirements are in place to

lock these valves, he will delete the requirement from the COL.

4) During discussions relating to perfonnance of COL's, the licensee

stated that all safety system COL's will be perfonned for the

purpose of verifying system alignment and to find possible errors

in the COL's, and also, to aid in the updating of system prints

currently being conducted. The licensee has also initiated a

valve tagging update program.

5) Steam Generator Identified Leakage

Since the steam generator (SG) tube leak in the #31 SG that

forced a shutdown on September 23, 1981, the licensee has been

monitoring several small SG tube leaks. The magnitude of these

leaks in #33 and #34 SG's are approximately 2x10-3 gallons per

minute (GPM). The licensee has been keeping a daily record and

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plotting the results which trend a steadily decreasing leak.

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The licensee is utilizing several sampling methods and analy-

zing the results by employing a Gama Spectroscopy Analysis

utilizing a 15% Ge(Li) (Gemainfun Lithium Drifted Semi-

ConductorDetector). The methods are as follows:

1.

Air Ejector Condenser Discharge which, when analyzed,

measures the total primary to secondary leakage of all

the SG's.

The resu

approximately2x10-}tsofthismeasurementequatesto

gpm and is the total primary leakage

to all four SG's.

(Technical Specifications limits leak-

age to 0.3 gpm to any one SG or 1 gpm total to all SG's.)

The results are being plotted and compared to the Reactor

Coolant activity of two isotopes, Argon 41 and Xenon 135.

The plots follow the activity of the reactor coolant for

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Argon 41 and Xenon 135, but at a much lower magnitude.

This method does not pinpoint the particular SG that is

leaking, but does give a quantitive leakage rate.

2.

Steam Generator Blowdown which analyzes all SG's indivi-

dually.

The gross Gama Spectroscopy has revealed that

  1. 33 and #34 SG's have a small leak.

3.

Resin Sampling - The blowdown samples have been arranged

so a 340 gallon. sample can be directed through a resin

bed. The bed can then be counted to analyze for any

isotope in the concentrated sample. The total activities

from all isotopes are:

SG #31

2.7x10- uc/cc

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SG #32

1.5x10- uc/cc

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SG #33

7.5x10-4 uc/cc

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SG #34

8.6x10-4 uc/cc

Part of the activities are from the long-lived isotopes

that are in the SG's from previous leaks, and carried

over from the secondary system. The licensee has selected

Iodine 131 to equate the primary leakage and confim the

particular SG's that are leaking with the following results:

SG #31

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9.255x10-6 uc/cc - 3.3 times higher than the

standard

2.736x10-luc/cc - standard

SG #32

uc

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SG #33

4.588x10-

/cc

16.8 times higher than the

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standard

SG #34

4.532x10-5 uc/cc - 16.6 times higher than the

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standard

Iodine 131 was selected because of its 8-day half life and

  1. 32 SG was selected as the standard because it has never

exhibited any primary to secondary leakage.

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After discussions, the licensee stated he will address

the chemically analyzed leakage during the planned re-

fueling outage, beginning March 26, 1982, by performing

helium leak detection methods on SG's #33 and #34 to

identify the leaking tubes. The licensee also stated

that other, yet to be determined, testing will be per-

formed on all the steam generators.

4.

Surveillance

A.

The inspector observed portions of four surveillance activities being

conducted on safety-related equipment to ascertain the following:

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That test instrumentation was properly calibrated;

That the redundant system or component was operable;

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That properly approved procedures were used by qualified

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personnel; and,

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That the acceptance criteria was met.

Tests observed:

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3PTQ13

Iodine Monitor

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3PTM14A

S.I. Logic "A"

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3PTM12

Turbine Electrical 0.S. Analog

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3PTM40

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Emergency Locker Equipment

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No violations were identified.

B.

The inspector conducted an indepth review of surveillance activities

to ascertain the following:

That the conditions listed in "A" above were met;

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That the test data was accurate and complete;

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That proper reviews, by the licensee, had been conducted;

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That the results of the tests met Technical Specification

requirements; and,

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That the testing was done within the required surveillance

schedule.

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Tests reviewed:

Diesel Generator (past 10 completed procedures)

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3PT-W1

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3PT-BW1

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Control Rod Exercise (past 5 completed procedures)

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CO2 System Inspection (past 10 completed procedures)

3PT-W7

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3PT-W3

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Evacuation Alam Test (past 10 completed procedures)

Service Water Pumps (past 5 completed procedures)

3PTM35

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Findings:

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During the evaluation of 3PTM35, the inspector noted that three TPCN

(Temporary Procedure Change Notices) were in effect. The procedures

were perfomed correctly, but the fact the three TPCH's were incor-

porated appeared to confuse the person cor. ducting the test. The in-

spector noted some of the TPCN's were in effect for almost two years.

The duration of TPCN's and the number in effect were discussed with

the licensee. The licensee stated changes to the procedures for the

implementation of TPCN's would be considered.

The licensee has revised procedure 3PTM35 and is waiting for the ad-

diticn of flow devices (which will be added during the March outage)

to issue the procedure.

No violations were identified.

5.

Maintenance

A.

The inspector selected maintenance activities being conducted on ESF

equipment to ascertain that redundant trains were in service, and

that approved procedures and qualified personnel were conducting

the maintenance.

B.

The inspector observed portions of maintenance activities listed below

to ascertain the following:

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The activities did not violate a limiting condition for

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operation;

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That redundant components were operable;

That equipment was tagged out in accordance with licensee approved

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procedures;

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That approved procedures, adequate to control the activity, were

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being used by qualified technicians;

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That Q/C hold points were observed, and that materials were pro-

perly certified;

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That radiological controls were proper and in accordance with

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licensee approved radiation exposure authorization's; and,

That the equipment was properly tested prior to return to service.

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1) Removal of a valve in the Isolation Valve Seal Water System

Documents Reviewed:

Work Request 2676

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Work Step List

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Purchase Orders 81-IP-2689 (Tubing)

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81-IP-2292 (Reducing bushing)

Certification Papers for the above purchase orders.

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2) Nitrogen tie-in to the Isolation Valve Seal Water System

Documents Reviewed:

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Work Request 2677

Work Request 2678

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Modification Procedure 82-03-036 N2

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Work Step List

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Purchase Orders 81-IP-2725 (Hilti Bolts)

82-IP-0822 (Valve)

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Certification Papers for the above purchase orders.

3) Repair to Timing Mechanism of #31 Instrument Air Compressor

Documents Reviewed:

Work Request 2602

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Work Step List

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4) Repair of Dew Point Recorder

Documents Reviewed:

Procedure IC-AD-4

Trouble Shooting Dew Point Recorder

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Preventive Maintenance Procedure ICPMA 1102

No violations were identified.

6.

Review of Monthly Report

A.

Monthly Operating Report

The Monthly Operating Report for February,1982 was reviewed. The

review included an examination of selected maintenance work requests,

and an examination of significant occurrence reports to ascertain

that the sunnary of operating experience was properly documented.

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B.

Findings:

The inspector verified through record reviews and observations of

maintenance in progress that:

The corrective action was adequate for resolution of the

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identified items; and,

The Operating Report included the requirements of TS 6.9.1.6.

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The inspector has no further questions relating to the report.

7.

Followup on IE Circulars

The inspector reviewed the following IE Circulars.

For each circular

reviewed, the inspector ascertained that:

The circular was received by the licensee's managerent.

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The circular was reviewed for applicability.

For each circular, if it is applicable to the facility, the

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appropriate corrective actions have been taken or are scheduled

to be taken.

(Closed) 80-CI-12 - Valve Shaft-to-Actuator Key May Fall Out of Place

When Mounted Below Horizontal Axis: The inspector reviewed PORC

minutes and a memorandum to file by the maintenance superintendent

stating this problem does not exist at this facility. The memorandum

to file also stated that the maintenance superintendent would remain

cognizant of the recommended fix should it be necessary in the future.

fio violations were identified.

8.

Followup on IE Bulletins

The inspector reviewed the following IE Bulletins.

In addition to his

comments, he ascertained that:

The written response was within the time period stated in the

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Bulletin.

The written response included the information required to be

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reported.

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The written response includes adequate corrective action commitments

based on the information presented in the Bulletin and licensee's

response.

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The licensee's management forwarded copies of the written response

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to the appropriate onsite management representatives.

The information discussed in the licensee's written response was

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accurate.

The corrective action taken by the licensee was as described in the

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written response.

1) The inspector determined, by a review of Plant Operating Review

Committee Minutes and other licensee documentation that the

following IE Bulletins are not applicable to Indian Point Unit 3

and considers them closed.

(Closed)80-BU-08

Examination of Containment Liner Penetration Welds

(Closed) 80-BU-18

Maintenance of Adequate Minimum Flow through

Centrifugal Charging Pumps Following Secondary

Side High Energy Line Rupture

(Closed)80-BU-19

Failures of Mercury-Wetted Matrix Relays in

Reactor Protective Systens of Operating Nuclear

Power Plants Designed by Combustion Engineering

(Closed)80-BU-21

Valve Yokes Supplied by Malcolm Foundry Company Inc.

(Closed)80-BU-23

Failures of Solenoid Valves Manufactured by

Valcor Engineering Corporation

2)

(Closed) 80-BU-06 - Engineered Safety Features (ESF) Reset Controls:

The inspector reviewed test performed as requested by item 2.

The

inspector also reviewed correspondance to the commission dated June 17,

1980 and March 23, 1981.

In addition, the inspector reviewed Pro-

cedure PER-ES-1 which describes in detail the resulting action, by

the operator, for ESF system operation.

3)

(Closed) 80-BU-20 - Failures of Westinghouse Tupe W-2 Spring Return

to Neutral Control Switches: The inspector reviewed correspondance to

the commission dated September 9,1980, February 10, 1981, and March 3,

1981.

The inspector also reviewed the licensee's Periodic Test Pro-

cedure 3PT-V19 which, accomplishes a check of these switches whenever

an operation is performed, or monthly, to determine if the switch has

returned to its proper position for the next operation.

The inspector had no further questions relating to actions taken by the

licensee.

9.

Exit Interview

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

held with senior facility management to discuss the inspection scope and

findings.

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