IR 05000289/1973023
| ML19256D446 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/19/1973 |
| From: | Davis A, Ruhlman W, Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19256D442 | List: |
| References | |
| 50-289-73-23, NUDOCS 7910180782 | |
| Download: ML19256D446 (13) | |
Text
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.. . . , U. S. ATOMIC ENERGY COSD1ISSION
, l l DIRECTORATE'0F REGULATORY OPERATIONS
- - , h - O} OD ' . .. . Docket No.: 50-289- ~ 50-289/73-23.
. - RO Inspection Report No.:
CPPR-40
Licensce: Metropolitan Edison Cocipany License No.: ' , ' Three Mile Island - tInit 1 p Bil .. , l Category: - - ! , - ! ,, Location:.. Middletown, Pennsylvania I ~- B&W 871 MWe PWR ' . Type of Licensee: ! , . Routine - Announced I Type of Inspection: ' . November 26, 29 & 30, 1973 Dates of Inspection: November 14-16, 1973 Dates of Previous Inspection: . , /2/ff/74 ~ - Reporting Insp tor: . , ,f R. L. Spessard, Reactor Inspector DATE . .- . , . . DATE - - . . ([ h / z// f/y t - ctv --- Accompanying Inspectors: W. A. Ruhlman, Reactor Inspector ' DA'TE - . . . . - DATE . [[ Z / 2.,[ #7 ; Other Accompanying Personnel: A.B. Davis, Senior Reactor Inspector DATE . 1449 175 ' ' - '~~ Reviewed By: M /7////7.3 DATE A. B. Davis, S.enior Reactor Inspector - Reactor Operation Branch 0N , , q 91 _ _._ - _.
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SUMMARY OF FINDING.] . Enforcement Action A.
Violations . . None Identified B.
Safety Items None Identified ' Licensee Action on Previously Identified Enforcement Items ' i A.
None Required Relative to Test and Stdrtup Activities t Unusual Occurrences ! None .-l\\)' Other Significant Findings - - A.
Current . Met Ed has implemented a maintenance program; however, a large number of procedures require development and approval to ensure an effective program is implemented prior to the scheduled core load date of March 22, 1973.
(Details, Section 1, Paragraph 5) ,
B.
Status of Previously Reported Unresolved Items No Change Management Interview An exit interview was conducted on November 30, 1973 at the conclusion of the inspection-Items discussed and personnel in attendance were as follows: 1449 I76 .- . - - _.. -... - -. ..
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! Licensee Represen(atives J. Herbein, Assistant Station Superintendent, Met Ed W. Gunn, Site Project Manager, GPUSC G. Miller, Test Superintendent, GPUSC M. Stromberg, Site Auditor, GPUSC T. Sturgeon, QA Specialist, GPUSC S. Kakarla, Assistant Lead Test and Startup Engineer, UE&C ,' L. Firras, Test and Startup Engineer, UE&C RO:I Representatives L. Spessard ! W. Ruhlman , B. Davis ' , . A.
Preoperational Test Results Inspection findings relative to the review of tests recently completed and accepted by the licensee were discussed.
(Details, Section 1, Paragraph 2) l (<-) e B.
Hot Functional Testing Inspection findings relative to the review of the status of activities affecting commencement of Hot Functional Testing were discussed.
(Details, Section 1, Paragraph 3) C.
UE&C Instrument Shop Inspection findings relative to the review of UE&C's methods of segregating and storing test instruments were discussed.
(Details, Section 1, Paragraph 4) D.
Met Ed Maintenance Program Inspection findings relative to the status and implementation of Met Ed's preventive and corrective maintenance programs.were discussed.
Additionally, the commitments received from licensee representatives during the inspection were discussed and acknowledged. During these discussions the inspector stressed that a large amount of work in the area of procedure development and apprcval remained to be done in order to ensure that an effective maintenance program would be 1449 I77 7, . - - ._ - _ - - . _.
-.~ - -.... -. .- g: - .... _... -.. -.. w --- -. =.a ..... . . ' -}3 _3_ implemented prior to the scheduled core load date. The representatives acknowledged the inspector's concern and indicated their awareness of the work remaining to be done. During discussions of the future pre-ventive maintenance progran, the inspector stated that he would expect the surveillance of pipe hangers and restraints to be included in the The representatives indicated that methods to accomplish program.
hanger surveillance were already under review.
The licensee represen- - tatives were informed that Met Ed's maintenance program would be re-viewed during subsequent RO inspections.
(Details, Section 1, Paragraph 5) . E.
System Turnover Packages Inspection findings relative to the licensee's implementation of testing and documentation requirements concerning system turnover packages were
discussed. The inspector stated that all specific deficiencies noted ~ during the inspection had been resolved.
Additionally, the inspector discussed his understanding that TP250/2 would be revised to clarify the two (2) areas where generic deficiencies were noted. A licensee representative concurred with the inspector's statement.
(Details, Section II, Paragraphs 2 and 3) '3 . !( F.
10 CFR 19 The insp~ector stated that based on his observations of the bulletin board in the Office Building the. licensee was meeting the requirements of Section 19.11 of 10 CFR 19.
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Persons Contacted Metropolitan Edison Company . . J. Herhein, Assistant Station Superintendent D. Shoilan, Supervisor of Maintenance J. Floyd, Supervisor of Operations N. Buhlmer, Lead Mechanical Engineer H. Mitchell, Electrical Maintenance Supervisor , W. Pheifer, Electrical Maintenance Foreman E. Daniel, QC Assistant , General Public Util:.. ties Service Corpo' ration J. Barton, Startup and Test Manager G. Miller, Test Superintendent M. Nelson, Technical Engineer j ) S. Poje, Shift Test Engineer i \\ -' T. Faulkner, Senior Test Planner United Engineers and Constructors . G. Somdahl, Instrument Supervisor . I 2.
Preoperational Test Results The inspector reviewed the completed test package as accepted by the licensee and is satisfied with the documentation of performance and results of the following tests: TP 201/2 Core Flooding System Functional Test SP 75.4 Diesel Fuel Oil Flush 3.
Events Leading to Hot Functional Testing (HFT) The status of the items delineated on the Time-Gridded Schedule of Events to HFT, which was approved on November 16, 1973 La accordance with Test Instruction No. 6 Test Schedules, was discussed with cog-nizant licensee representatives.
According to the representatives, 1449 l79 . -- _ _ -
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-. _. _.. .. _. _ _ .. -.......... - _.. _ . . . .) -5-project status was on schedule relative to commencement of HFT on December 19, 1973. The inspectors toured the Reactor Building to observe activities in progress.
Particular attention was given to the installation of insulation on the Reactor Coolant, Makeup, Core Flood, Decay Heat, Emergency Feed Water, Main Steam and Feed Water Systems and to overall cleanliness and the presence of com-bustible material.
Based on the inspector's observations, the licensee's estimate for project status relative to commencement of HFT appeared. realistic.
I 4.
UE&C Instrument Shop i The inspector toured the UE&C Instrument Shop to observe methods of
l segregation and storage of test instruments.
No deficiencies relative to the requirements of Test Instruction 19, Control of Test Equipment, ' ! were observed.
The previous RO:I finding relative to this matter is j resolved.*
} 5.
Met Ed Maintenance Program l a.
Preventive Maintenance {} The preventive maintenance program being implemented by Met Ed station personnel was established by GPUSC Special Procedure No.
4, Freventive Maintenance TMI Unit 1.
This procedure covers systems and components within the QC scope, as defined by ! Gilbert Associates, Inc. Quality Acceptance Standard for TMI
Unit 1, SP-5550. The intent of the procedure is to properly l maintain QC controlled equipment from arrival or site through and including normal operations. An Equipment History Card, which specifies the required maintenance and maintenance Laterval, , is provided for each piece of equipment by Gilbert Associates, Inc.
The organization (UE&C Construction, UESC Startup, or Met Ed) hav--
ing jurisdiction over an individual system or component within the I QC scope is responsible for performing preventive maintenance in accordance with applicable Equipment History Card (~s).
As systems and components are turned over from one organization to another, the applicable Equipment History Cards are likewise turned over.
The inspector discussed the preventive maintenance program being implemented by Met Ed station personnel with cognizant Med Ed representatives and reviewed several Equipment History Cards for The components in various systems under Met Ed jurisdiction.
inspector's observations and the licensee representatives ces ents, where appropriate, were as follows:
- R0 Inspection Reports No. 50-289/73-15, Paragraph 6.a. (6) and
. 50-289/73-06, Paragraph 4.f. (31 . I449 I80 we-.- ...eh -. .m.mer - -ye- -
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. __..... _._. _ _ __. . . - i . -/ . (1) About 90% of the program is being performed by operations personnel, and the remaining 10% is being performed by maintenance personnel.
(2) Equipment History Cards maintained by the operations and maintenance organizations were filed in notebooks according - to system and according to required maintenance interval, i.e., weekly, monthly, quarterly, etc.
(3) Documentation contained on the Equipment History Cards reviewed by the inspector indicated that maintenance was being performed in accordance with the requirements of Special Procedure No. 4.
Maintenance performed by both operations and maintenance personnel was included in the inspector's review.
Additionally, surveillance test pro- , cedures w(.., referenced on the cards as.the procedure to be used when a Technical Specification surveillance test was to be performed.
, . I (4) A lubrication s.tedule covering each component within the QC scope has been developed to insure the proper grease and i ,'] d w/ oils are used during the performance of preventive r11ntenance.
l (5) Met Ed has depended on Gilbert Associates, Inc. to provide an Equipment History Card for each piece of equipment within the
QC scope; however, Met Ed ha_d not verified that all required cards for systems and components under their jurisdiction had been prepared and were included in their program. A licensee representative indicated that these cards are part of the system turnover package which Met Ed accepts and that as such all cards should be present.
The representative indicated that a review would be made to insure all required cards were prepared and included in the program.
(6) Special Procedure No. 4 sets forth general inspection require-ments for mechanical and electrical equipment and supplementary inspection requirements, inspection intervals and documentation requirements are provided on Equipment History Cards; however, more detailed inspection requirements / acceptance criteria are needed. For example, criteria for normal oil consumption, valve operating time, presence of contaminants like boric acid, , 1449 I81 ... .. _ ... . . .. _
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-. iQ-7-i i chlorides and others, normal operating ranges of instruments, ! and other similar inspections are not included in the program.
' A licensee representative indicated that the program would be reviewed and more detailed inspection requirements would i be included.
(7) The program established by Special Procedure No. 4 vill be ' used until the unit is declared ready for commercial operation, and at that' time a more detailed preventive maintenance program, This which is being developed by Met Ed, will be implemented.
program was only in the early stages of development and theDur-program scope and requirements have not yet been defined.
ing discussions with a licensee representative relative to ,' this program, the inspector was shown an approved preventive maintenance procedure for a non-safety rela.ted system which ' The was an example of a procedure to Laplement this program.
' inspector reviewed this procedure and observed that definitive guidance / acceptance criteria was lacking in the following areas: the type of packing and packing adjustments data, pump align-t ment data, and vibration data. The licensee representative acknowledged the inspector's findings and indicated these ,_qj findings would be considered on a generic basis in tie develop-ment of preventive maintenance procedures for this reogram.
' b.
Corr'ective Maintenance . The corrective maintenance program being implemented by Met Ed station personnel was discussed with cognizant Met Ed representa-tives.
The administrative procedure which controls this program including f acility changes is Administrative Procedure No.1016 Implementation and Control of Station Maintenance; however, this procedure is only in draft form. Maintenance, when required, is being performed using this procedure in order to determine its acceptability.
This procedure establishes the use of the Work Request Form which includes the following: (1) Description of work required (2) Determination of whether or not a facility design change is involved (3) Assignment of Cognizant Engineer for post maintenanca testing, when required (4) Management review and approval including QC and PORC, as necessary (5) Maintenance procedure to be used (6) Description of work performed i449 l82 . . _.. . .. - - -
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.. .... ........ -. - -.... . ...-.. . . . . ' -8-(7) Results of post maintenance test (8) Initiation of revisions to applicable drawings The inspector was shown the file of completed Work Request Forms, and the inspector selected two of these forms at random for review.
No deficiencies relative to documentation contained on these forms (including attached procedures) were observed.
- According to.the licensee representatives, the administrative pro-cedure with the Work Request Form ensures maintenance or facility design changes are performed in a controlled manner; hcvever, the timeliness of individual jobs is affected because of the complexity of the system.
The inspector was informed that further chaIges to the administrative procedure were under revi.ew and that the pro-cedure would be revised. The need to develop and approve numerous ' maintenance procedures to work on safety related systems prior to core loading was stressed by the inspector during his discussions with the licensee representatives. The representatives acknowledged the inspector's remarks.
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._ - , , . . ~ T, < i DETAILS SECTION II Prepared by: William A. Ruhlman 1.
Persons Contacted . ' Met Ed J. Herbein, Assistant Plant Superintendent J. Peters, Office Supervisor UE&C , J. McDevitt, Lead Test and Startup Engineer '
J. Fleming, Lead Electrical Engineer R. Carlson, Lecd Instrument and Control Engineer S. Kakarla, Assistant Lead Test and Startup Engineer GPUSC ' (~h , l s -J G. Miller, Test Superintendent
2.
System Turnover Packages The inspector made a detailed page-by-page review of four (4) system turnover packages.
The licensee approved documents listed below provide detailed requirements for testing and documenting systems from release by construction through startup testing to final accep-tance by the licensee.
These documents were the basis for package ' documentation review, Test Procedure 250/2-TCN-3 - 9/21/73 a.
Testing of Mechanical and Electrical Equipment (TP 250/2) b.
Test Instruction 5 - Rev 0 - 6/27/73 System Turnover (TI-5) Quality Control 6 - Rev 4 thru Field Change 9/29/73 c.
Final Acceptance Inspection (QC 16) . 1449 184 ' < \\_ ' .. .. - -. --. .- ._.
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. . . . ., -10-During the inspection some procedural deficiencies were noted.
How-ever, all system turnover packages reviewed were in substantial con-formance with the licensee's procedures. The packages reviewed and the inspector's findings are as follows: a.
Rod Control System (MTX-53) . This package contained fifteen (15) file folders of material - numbered and arranged in accordance with TI-5.
Six cables had been identified as being improperly terminated on the print used for the check.
A field questionnaire had been generated as required. However, neither the field questionnaire nor the individual cables were noted on the Incomplete Items List.
> . When notified by the inspector, the item was added to the list ' by a licensee representative.
b.
Makeup and Purification System (MTX-144) O' - This package was subdivided Lato two (1) parts due to its size.
- (2) parts together contained thirty (30). file folders The two . of material numbered and arranged in accordance with. TI-5.
j The Incomplete Items Lists (2) noted the deficiencies Di accordance } with the applicable procedures.
However, the ttne completion section of the list had not been completed.
i l Sixteen (16) copies of Form ME-1 had been completed as required, but a signature identifying the data taker was missing.
j Several electrical checkoff sheets indicated that test 05 0?T and CT Check) had been completed on systems where the test was not applicable.
Six (6) instrument sheets were included that stated the instrument checkout was not complete. These instruments also appear 2d on the Incomplete Items List. However, the sheets-erroneously iuuicated the instruments had been accepted.
These deficiencies, representing a very small (<0.1%) portion of the package documentation, were corrected by licensea representa-tives prior to the completion of the inspection.
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Batteries and Battery Charges (MTX-276) No This package contained six (6) file folders of documentation.
apparent discrepancies were found during the inspection of this
package.
I d.
Core Flood System (MTX-63) There were eight (8) folders of documentation in this package.
Part of the documentation in the folder for Valve CF-V-2A was a completed megger test sheet.
Other documentation indicated ,
the megger test was incomplete.
A licensee representative contacted the appropriate employee ' i and the contradiction was resolved.
i !
, RO:I has no further questions on these packages at this time.
3.
TP 250/2 l($) During the inspection the following generic deficiencies were found
in TP 250/2: '. a.
Procedure - Step 2 (Page 11) ' The statement in Step 2 of the procedure states requirements for signatures on UE&C Startup Turnover Agreement (TO-11. The state-ment is inconsistent with the practice of using a fascimile in.- stead of an original signature for the UE&C Construction. Department.
b.
Tab 2, Section V, (Page 28) . Paragraph "A" - General Requirements is in conflict with Section I, Paragraph Cll, regarding cables requiring a megger check.
In addition, Paragraph "A" refers to a paragraph "D" which is non-existant.
, A licensee representative stated that TP 25 3/2 would be revised to eliminate these conflicts. These items will be checRed during a future inspection.
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Form Arc-93 < aev.. sin i4.194?> Atc.st 024o IngT16 REMARK $ TO (Name and unat) METROPOLITAN EDISON COMPANY RO Chief, FS&EB I RO:HQ (5) RO Files oATE Central Mail & Files / INSPECTION REPORT #50-289/73-23 Regulatory Standards (3) The above inspection report is forwarded rimu.S REMAaKs To (N.m..no onits Directorate of ! Licensing (13) for information.
Distribution will be OGC OAT Regional Directors made by this office to the PDR, Local PDR, (II, III, IV)
wet 1ALS REMAAK5 NSIC, DTIE, and State Representatives TO (N9me and unit) ' ,' a:fter review by the licensee for or, proprietary infot:n ution.
' REM AAKS I -., FROM (Name and unst)
- E. /. Brunner J Region I . e PHOMC NG DATI 8-337-1246 12/20/73 GPO : 4,110 - 445-44) . i USE OTMER StCE FOR ADDtTIONAL REMARKS ' i ! .,-- ~ } 1.449 187
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