IR 05000289/1975014
| ML19256D600 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/18/1975 |
| From: | Fasano A, Mccabe E, James Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19256D594 | List: |
| References | |
| 50-289-75-14, NUDOCS 7910190564 | |
| Download: ML19256D600 (52) | |
Text
Tr:I Form 12
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.n 75) (Rev)
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCDIENT
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REGION I
IE Inspection Report No:
50-289/75-14 Docket No:
50-289 Licensee:
Metropolitan Edison Company License No:
DPR-50 P.O. Box 542 Prfority:
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C Reading, Pennsylvania 19603 Category:
Safeguards
' Location:
Middletown, Pennsylvania (Three Mile Island 1)
Type of Licensce:
PWR, 871, Mwe, (B&Q)
'aype of Inspection: Routine, Announced
E of Inspection:
July 21-25, 1975 and July 28, 1975
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June 18-20, 1975 and July 10, 1975 Dates of Previous Inspection:
Reporting Inspector:
2.
LITE J. T.
ith, Re, tor Inspector Acconpanying Inspectors:
/ 8.4%1.,tT7)
[0F
,.8 Y 7f
A N. 'Fas no, Reactor / I spector DATE k b Asm
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8//7 /W T.B.plas ock, Reactor Inspector
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W. A. Ruhlman Reactor Inspector DATE 4 '!
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Other Accom-nying Personnel:
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H. J. George, Reactor Engineer DATE Office of Nuclear Reactor Regulation
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Reviewed By:
O. O N M, h
?IIPf 7f E.
C. McCabe, Senior Reactor Inspector DATE React.or Operations Branch 1452 042-
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7910190
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SUMMARY OF FINDINGS
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Enforcement Action A.
Items of Noncompliance Deficiencies
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1.
Contrary to Tech'nical Specifications Section 6.2.3 and TMI
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Administrative Procedure AP-1012: an abnormal occurrence to Emergency Diesel Generator lA was not' recorded in the Control Room Log Book or the Shift Foreman's Log Book.
(Details,
Paragraph 3.a)
2.
Contrary to 1C CFR 50 Appendix B, Criterion XVII and TMI Administrative Procedure AP-1012:
review of the Control Room Log Book by the Supervisor of Operations for the period of July 13, 2300 through July 22, 2300, 1975 was not documented.
(Details. Paragraph 3.b)
3.
Contrary to 10 CFR 50, Appendix B, Criterion V, Technical
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Specifications Section 6.2.3, and TMI Administrative Procedure
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AP-1013:
three entries in the " Jumpers Lif ted-Leads -
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Mechanical' Modification Log Book 37", were not initialed by the Shift Foreman.
(Details, Paragraph 3.c)
4.
Contrary to 10 CFR 50, Appendix B, Criterion V, Section 10 of the Operational Quality Assurance Plan, and Section 5.3 of ANSI N45.2.9:
the licensee did not have a procedure for the storage / receipt / control of Quality Assurance Audit Records, and the required record custodian had not been designated.
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(Details, Paragraph 4.c)
5.
Contrary to 10 CFR 50, Appendix B, Criterion VI, to Section 11 of the Operational Quality Assurance Plan, and to TMI Pro-cedure GP-1015:
a lack of control was demonstrated for three of the twenty engineering drawings sampled during this inspection.
(Details, Paragraph 5.b)
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e.
Contrary to 10 CFR 50, Appendix B, Criterion XV and the opera-tional Quality Assurance Plan Section 20:
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a.
a nonconformance report was not written for out-of-spec-ification conditions described in OQA Surveillance Report
.75-133;
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b.
procedures do not define controls / methods required /used to obtain concurrence from the Manager-Generation Engin-
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eering for "use-as-is" dispositions; and c.
procedures do not define controls required for the identi-fication and/or segregation of nonconforming items to prevent their inadvertent use.
(Details, Paragraph 6.d)
7.
Contrary to 10 CFR 50, Appendix B, Criterion V, to Section 12 of the Operational Quality Assurance Plan, and to TMI Pro-
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cedure GP-1009:
two safety-related items were purchased from
"N vendors not on the licensee's approved vendor's list.
(De-
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tails, Paragraph 9.f)
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8.
Contrary to Technical Specification 6.1.B and the referenced Figure 15.6-1, to Operational Quality Assurance Plan Sections 1 and 6.7 and the referenced Figure 1A-1:
since June 16, 1975
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when the Station Superintendent wes promoted to Manager-Generation,0peratiors-Nuclear, the position of Station Super-
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intendent has not been filled.
(Details, Parmgraph 13.a)
Licensee Action on Previousiv Identified Enforcement Items _
A.
Report 50-289/75-01 The licensee's corrective actions with respect to Items of Noncom-pliance designated as items 3 and 4 in Enclosure 1 of the ab6've *
referenced report were reviewed with respect to the licensee's response documented in a letter to Region 1 dated March 3, 1975.
The inspector had no further questions on these two (2) items at this time.
(Details, Paragraph 4.d)
B.
Reports 50-289/75-01 and 50-289/75-04
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The licensee's action (licensee letters dated March 3 and April 9,
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1975) to resolve the 10 CFR 50.59 safety evaluation inadequacies,
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identified in the above referenced reports was reviewed on a sampling basis.
The inspector had no further questions on this item.
(Details, Paragraph 7.a)
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Unusual Occurrences
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The following Abnormal Occurrences happened and were reported to the onsite inspector during the period of this inspection.
1.
Abnormal Occurrence A0 75-25
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Diesel Generator frequency relay (one of three) was in the " dropped out" state while the other two were " picked up."
The frequency
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relays are connected in a 2/3 logic.
This was a condition report-able under TS 6.7.2.c.4 The licensee replaced the relay with another which tested satisfactorily.
This item will be reviewed-further.
2.
Abnormal Occurrence A0 75-26 The reactor coolant system pressure trip set points for two RPS channels were found to be less conservative taan the set points
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required by TS Table 2.3-1.
The cause was attributed to minor drift of the associated reactor coolant system pressure trans-mitters.
The transnitters were recalibrated and retested satis-factorily.
This item will be reviewed further.
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Other Significant Findines
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A.
Current Findings 1.
Acceptable Areas (These are areas which were inspected on a sampling basis and findings did not include an Item of Noncompliance, Deviation, or an Unresolved Item.)
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a.
Training.
(Details, Paragraph 2)
b.
Procedure. Control.
(Details, Paragraph 5.a)
Knowledge of Procedures for Plant >bintenange.
(De tails,
c.
Paragraph 6.a)
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d.
Processing of Work Requests.
(Details, Paragraph 6.b)
e.
Processing of Change / Modification Requests.
(Details,
Paragraph 7.a)
f.
Chemistry Contrcls.
(Details, Paragraph 11)
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2.
New Unresolved Items.
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(These are items for which more information is required in order to determine if the item is acceptable, L Deviation, or an Item of Noncompliance.)
There is no procedure which requires 10 CFR 50.59 evalu-
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a.
ations to be forwarded to the General Office Review Board in accordance with the Technical Specifications, Section 6.1.6.5.
(Details, Paragraph 7.c)
b.
There is no procedure which requires 10 CFR 50.59 safety evaluations on Tests and Experiments in accordance with
the Technical Specifications, Section 6.1.6.3.
(Details, Paragraph 7.d)
Documentation is lacking to verify that the DVM used in a c.
test procedure was both traceable to the surveillance test performed and calibrated.
(Details, Paragraph 8.a)
d.
The DVM used to check the function of thz incore neutron detectors is not specified as equipment required or need-ing traceability.
(Details, Paragraph 8.e)
Minor changes to the procedure for the Poker Range Amp-e.
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lifier Surveillance Testing are needed.
(Details, Para-graph 8.f)
f.
Verification of the use of a calibrated, traceable DVM
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for the Turbine Overspeec Surveillance Test is needed.
(Details, Paragraph 8 g)
g.
The Station Battery Surveillance Test Procedure does no't call for DVM calibration or traceability.
(Details, Paragraph 8.k)
h.
There is no traceability and calibration verification requirement for the Hewlett Packard 3460B DVM.
(Details,
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Paragraph'8.n)
1.
The Borated k'ater Storage Tank Procedure requires the
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validation of the boron concentration of 2,270 ppm, but
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does not address the borated water storage tank capacity requirement of 350,000 gallens nor the temperature re-quirecent of not less than 400F.
(Details, Paragraph 8.p)
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A0 75-18, Inndequate Control of Vendor Performed Work.
(Details, Paragraph 10.d (8))
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Although the required PORC quorum was documented as being present for meetings, revision of the Technical Specifica-tion Section 6.1.I, to indicate changes in titles of the PORC membership is Unresolved pcnding submittal / approval of a Technical Specification change.
(berails, Paragraph 13.b)
3.
Noncompliance Items Identified by the Licensee A0 75-16, out of Limit settings for the Reactor Ccolant a.
Pressure Trip Setting.
(Details, Paragraph 10.d(2))
b.
AO 75-20, Xenon Reactivity Stability Occurrence.
(De-tails, Paragraph 10.d(6))
c.
Audit 75-10, R,ecord Storage.
(Details, Paragraph 12.b)
d.
Audit 74-29, Design Change Control.
(Details, Paragraph 7.b)
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B.
Status of Previously Identified Unresolved (Open) Items
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Report 50-289/74-32 1.
The incomplete General Employee Quality Assurance Training identified in Detail 2.d of the subject report has been sat-isfactorily completed.
This item is resolved.
(Details, Paragraph 2.a(1))
2.
The incomplete Maintenance Department Personnel Quality Assur-ance Training identified in Detail 3.a of the subject report has been completed.
This item is resolved.
(Details, Para-graph 2.a(2))
3.
The incomplete program items in the Operator Requalification Training Program have now fallen due and have been completed.
This item is resolved.
(Details, Paragraphs 2.a(3) and 2.b)
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Mana gener.t Interview An exit nanagement interview was conducted at the site on July 25, 1975 with the following licensee attendees:
Metropolitan Edison Ccmpany (Met-Ed)
Mr. J. J. Colitz, Unit 1 Superintendent Mr. J. C. Herbein, Manager-Generation Operations-Nuclear Mr. G. A. Kunder, Engineer Mr. L. L. Lawyer, Manager-Operational Quality Assurance Ms. C. A. Nixdorf, Office Supervisor hr. W. E. Potts, Supervisor-Quality Control.
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The following summarizes the items discussed.
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A.
Training.
(Details, Paragraph 2)
B.
Review of Plant Operations.
(Details, Paragraph 3)
,3 C.
Audits.
(Details, Paragraph 4)
D.
Document Control.
(Details, Paragraph 5)
E.
Plant Maintenance.
(Details, Paragraph 6)
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F.
Design Changes, Modifications, Tests and Experiments.
(Details,
Paragraph 7)
G.
Surveillance Testing.
(Details, Paragraph 8)
H.
Procurement.
(Details, Paragraph 9)
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Abnormal Occurrences.
(Details, Paragraph 10)
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Chemistry Controls.
(Details, Paragraph 11)
K.
Records.
(Details, Paragraph 12)
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L.
Organization and Administration.
(Details, Paragraph 13)
M.
Annual Review.
(Details, Paragraph 14)
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DETAILS
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1.
Persons Contacted Discussions were held with the following persons either onsite or at Corporate Headquarters during the conduct of the inspection activities documented in this report.
Metropolitan Edison Company (Met-Ed)
Ms. S. H. Bonneville, Administrative Assistant - Quality Control-Mr. J. J. Colitz, Unit 1 Superintendent Mr. W. W. Cotter, Lead Mechanical Engineer Mr. J. H. DeMan, Radiochemistry Technician Mr. J. R. Floyd, Supervisor of Operations Mr. A. C. Fredlund, Shift Foreman Mr. J. Fritzen, Staff Engineer Nuclear Mr. D. N. Grace, Licensing Engineer Mr. F. H. Grice, Safety' Representative Mr. R. Harper, Supervisor I&C Maintenance Mr. C. E. Hartman, Lead Electrical Engineer Mr. J. G. Herbein, Manager - Generation Operations - Nuclear Mr. M. W. Johnson, Quality Control Assistant
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i Mr. R. Kokstein, Engineer II, Generation Mr. G. A. Kunder, Engineer Mr. L. L. Lawyer, Manager - Operational Quality Assurance Mr. C. Leonard, Mechanical Foreman Mr. B. C. McCutcheon, Quality Assurance Engineer Mr. J. ScGarry, Mechanical Supervisor Mr. D. J. McGettrick, Engineer - Junior Mr. G. P. Miller, Unit 2 Superintendent
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Mr. E. N. Moore, Engineer II, Generation Mr. R. E. Neidig, Jr., Quality Control Assistant Ms. C. A. Nixdorf, Office Supervisor - Nuclear Mr. V. Orlandi, Lead I&C Engineer Mr. J. F. Peters, Station Administrator Mr. W. E. Potts, Supervisor - Quality Control
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Mr. W. S. Poyck, Coordinator of Services Mr. J. G. Reed, Acting Chemistry Supervisor
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Mr. J. E. Romanski, Supervisor - Radiation Protection and Chemistry Mr. M. Ross, Shift Supervisor Mr..
C.
Seelinger, Engineer Senior - Nuclear (Training Coordinator)
Mr. F. Scheimann, Auxiliary Operator, Nuclear
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Mr. H. B. Shipman, Engineer, Jr.
Mr. D. M. Shorlin, Supervisor of Ibintenance Mr. R. L. Summers, Project Engineer - Mechanical Mrs. A. Troutman, Clerk Mr. J. Wallace, Shift Supervisor Mr. W. Zewc, Shift Foreman General Public Utilities Service Corporation (GPUSC)
Mr. J. R. Thorpe, Chairman of GORB (Telephone Contact Only)
2.-
Training The inspector reviewed training and retraining of selected plant personnel with respect to the applicable requirements of:
10 CFR 50, Appendix B, Criteria II, V and XVII; ANSI N18.1 - 1971; ANSI N45.2.6 - 1973; the licensee's NRR accepted Operator Requalifica-tion Program; and pertinent Training Department Administrative Memoranda (TDAM).
Three (3) previously identified (report 50-289/74-32) incomplete training items were also reviewed.
The results are summarized below.
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a.
Report 50-289/74-32
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The remaining uninspected training items prevfously identified
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in the referenced report were reviewed with the following results.
(1)
Detail 2.d of the referenced report indicated that, while scheduled at the time of the previous inspection, Quality Assurance Training had not been completed for the " General Employee".
TDAM #7, GENERAL EMPLOYEE TRANINING/ RET _ RAINING, dated November 22, 1974 now requires, in addition to the previously documented and campleted training (report 50-289/ 74-32, Details 2.a, 2.b and 2.c), both initial Quality Assurance indoctrination and annual Quality Assurance retraining.
The licensee's lesson plans and attendance sheets indicated employees had received in-doctrination in the Appendix B Criteria and* job related aspects of Quality Assurance workmanship.
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This item is resolved.
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(2)
Detail 3.a of the referenced report indicated that, while also scheduled for the future, Maintenance Department Quality Assurance Training was also not yet completed.
On April 29, 1975 the majority (greater than 80%) of Main-tenance Department personnel received, according to the licensee's lesson plans and attendance sheets, indoctrina-
. tion in the eighteen Appendix B Criteria and the job re-lated aspects of the licensee's Operational Quality Assurance Plan.
The remaining maintenance personnel are scheduled for this training.
This item is resolved.
(3)
Dctail 6.b of the reference report documented aspects of the licensee's NRR accepted Operator Requalification Program which were not yet required as of the dates (October 7-9, 1974) of the previous inspection.
These items have now been completed, as required, as documented in Detail 2.b below.
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This item is resolved, b.
Licensed Operator Requalification Program
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The completed program items from the Operatur Requalification
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Program were verified and documented in Detail 6.a of report 50-289/74-32.
The non-inspected aspects of the program con-sisted of the administration and grading of the first annual examination (required prior to July 13, 1975) and the supple-mental actions required by the prograr predicated on the grades resulting from that examination.
These items were inspected as well as a selective review of previously inspected program-requirements based on examination of thrae (3) inspector selected licensed operator's records with the fo13oving results.
(1)
All required personnel were given their first annual re-qualification examination prior to July 13,1975.
Of the thirty-one (31) licensed operators at the site at the time of the examination, two (2) were used in pre-paring the examination and three (3) additional operators
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had been licensed less than six months; these five (5)
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.s were exempted from taking the examination by the NRR accepted Program.
The remaining twenty-six (26) licen-
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sees participated with the following results: none scored less than 70% overall; thirteen (13) scored less than 80% in at least one section; and, seven (7) scored
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less than 80% in two or more sections.
The required s.e
, participation by all personnel scoring less than 80% in a given section in the lectures on the specific section
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will be verified at the completion of the lecture cycle (July 1976).
The evaluations required for persons scor-ing less than 80% in two or more sections were in prog-ress during this inspection.
The inspector identified no inadequacies in this area, and the two (2) unresolved (open) items previously docu-mented as Details 6.b(1) and (2) in report 50-289/74-32 are now resolved.
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(2) The records,of three (3) licensed operators were selected 9 -
by the inspector and reviewed to verify that they contain-ed the following:
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(a) Completed course and yearly examinations.
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(b). Documentation of required reactivity manipulations.
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(c)
Documentation of required simulation of emergencies.
(d)
Documentation of the review of procedure / license changes.
The inspector identified no inadequacies in this area._ The licensee's records also included the results of the comparison grading performed by NRR personnel on July 17, 1975.
c.
Fire Fighting Training Two-hundred and fourteen (214) Three Mile Island site per-sonnel have participated in Fire Brigade Training, consisting of approximately four (4) hours training in classroom and in actual fire fighting, according to the licensee's documenta-
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tion.
In addition, one-hundred and thirty-four (134) site
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personnel have participated in " smoke-house" respirator train-ing.
New supplied-air steam / fire suits arrived on site during i452 052
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the cour.e of the inspection which, along with cetual ex-tinguishment of Class A, B and C fires, is to be the subject of a more extensive fire-fighting trainit.g course to be com-pleted, according to the licensee, before the end of 1975.
d.
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All twenty-three (23) female employees at the Three Mile Island Unit 1 facility had read, according to the licensee's documentation, Regulatory Guide 8.13, INSTRUCTIONS CONCERNING
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PRENATAL RADIATION EXPOSURE.
Four (4) of these employees had received additional instruction from the Training Department, and the remaining nineteen (19) employees were scheduled for this additional training prior to the end of September 1975.
The inspector identified ne inadequacies in this area.
e.
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While reviewing the' participation of three (3) inspector selected maintenance personnel in annual retraining, the in-spector also verified the licensee's implementation of ANSI
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N45.2.6 - 1973 as set forth in TDAM #8, QUALIFICATION OF TER-I"-
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SONNEL PERFORMING INSPECTION, EXAMINATION AND TESTING, dated i
May 2, 1975.
The three (3) records selected by the inspe.ctor contained documentation that indicated the following:
(1)
Participation in calibration, testing and equipment acceptance programs.
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(2) Demonstrated proficiency in the use of tools and other equipment required for the particular job position _
(3)
Related technical training (seminars and vendor schools).
(4)
Experience or training in the tescs and/or inspections that the individual performs.
(5)
Familiarity with inspection and measuring equipment cali-T bration and control methods.
(6)
Capability of verifying that equipment used is in proper working condition.
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Indoctrination in security practices / procedures.
(8)
Indoctrination in health physics practices / procedures.
(9)
Indoctrination in the site's emergency plans / procedures.
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The inspector identified no inadequacies in this area, f.
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The inspector reviewed the records of all personnel (fourteen)
currently routinely involved in performing or training to
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perform' audits at the Three Mile Island Unit 1 facility with respect to the requirements contained in ANSI N45.2.12 and Appendix B to 10 CFR 50, specifically Criteria I, II, V, XVII and XVIII.
The licensee's prccedural description of require-g men's for auditor training are contained in TCN#1 to GP 4016, 0QA AUDIT PROGRAM, dated July 8, 1975.
The review indicated that, as of July 27 1975, eleven (11) persons were certified as Auditors, and th,e remaining personnel were in various stages of training for certification.
Of the eleven (11)
certified audito;s, four (4) were also certified as HDE in-spectors.
The licensee's training folder also records the training and written examination results on training materials described in Quality Assurance Training Courses (QATC's )., The
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licensee stated that thirty-five (35) QATC's are currently issued or in the approval network and that one-hundred and fifty such documents are planned before the end of 1975.
Based on the documentation reviewed and the inspector's direct interviews with selected auditors, the current train'ing meets the requirements of Sections 2. 3.1, 2. 3. 2 and 2. 3.3 of ANSI N45.2.12.
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The inspector had no further questions on this item.
3.
Revier of Plant Operation a.
Recording Information The inspector reviewed Control Room Log Book No. 5 for the period July 19 to July 27, 1975.
The Log did not contain information indicating the occurrence of A0 75-25 with respect
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to Emergency Diesel Generator lA.
Administrative Procedure, 1452 054
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AP-1012, " Shift Relief and Log Entries", paragraph 3.3.1.c requires entry of abncrmal conditions of operation.
A review of the Shift Foreman's Log for the same period did not reflect the occurrence.
The above was contrary to the requirements of Criterion V,
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Appendix B, 10 CFR 50, and to Technical Specification 6.2.3 which states, " Written procedures shall be strictly adhered to in all matters relating to nuclear safety."
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This Item of Noncompliance is a Deficiency.
b.
Log Book Review The inspector reviewed the Control Room Log for the period July 13, through July 22, 1975 for review verification by the Supervisor of Operations.
The licensee stated that the log book for.this period had been reviewed, but documentation was not available.
Procedure AP-1012 paragraph 2.2 requires a
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review of the Logs ty the Supervisor of Operations at a fre-quency of once per week as a minimum.
This failure to document review results is contrary to 10 CFR 50, Appendix B, Criterion XVII, which states.in part, " Sufficient records shall be maintained to furnish evidence of activi. ties
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affecting quality.
The records shall include at least the following: Operating logs and the results of reviews,..."
This Item of Noncompliance is a Deficiency.
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c.
Jumper Log Review The inspector reviewed the Jumper Lifted Leads - Mechanical
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Modification Log Book 37.
Procedure AP-1013, " Bypass of Safety Functions and Jumper Control" requires notation by the user and initialing by the Shift Foreman prior to placing jumpers, lifting leads or making temporary mechtnical modifi-cations.
There were three entries, Tag 32, for 2 out of 3 booster pumps dated 5/25/75 and for mechanical modifications, Tag 3 dated 3/10/75 and 3/11/75, Hold MOV 1D green and Hold MOV lE green, that were not initialed by the Shift Foreman.
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The above is contrcry to the requirements of Criterion V, Appendix B, 10 CFR 50, and to Technical Specification 6.2.J which states, " Written procedures shall be strictly adhered to in all matters relating to nuclear. safety".
This Item of Noncompliance is a Deficiency.
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d.
Audit Sheet It was noted by the inspector that the Jumper Lifted Lead -
Mechanical Modification Log Book 37 contains an audit sheet in the front of the Log.
Procedure AP-1013 does not address the audit cheet.
The licensee stated that this audit sheet is being evaluated.
The inspector had no further questions on this item, e.
Lift Tump Jumper
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The innpector also noted that Jumper No. 11, 10/31/74, Stop
"A" Lift Pump for "A" Rocctor Coolant Pump, was in effect for an extended time.
The licensee stated that this item would be reviewed.
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The inspector had no further questions on thfs item.
f.
Auxiliary Operators Log Sheet The Auxiliary Operator Log Sheet, Out-Building Tour, was reviewed for the period July 10-15, 1975.
The inspector stated that this log sheet would be easier to evaluate if maximum, minimum or expected values were included on the log sheet.
The licensee stated that thic is under current -eval-uation.
It was noted that one input, SWP 2,
"A" or "B" could be in operation.
Four of the sheets reviewed did not have an
"A" or a "B" circled.
The irnpector will review this area during a sebsequent inspcetion.
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Primarv_ Operators _ Log
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The Primary Auxiliary Operators Log - Tour Readings was re-viewed for the period July -10-14,1975.
Inclusion of maximum, minime.m or expected values would also facilitate review of this sheet.
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The inspector will review this area during a subsequent inspection.
h.
LWDS "anels The Primary Auxiliary Log - LWDS Panels was reviewed for the period July 10-14, 1975.
Inclusion of maximum, minimum or expected values or ranges of values would expedite review.
The inspector will review this area during a subsequent m.m inspection.
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Technical Specifica' tion Limits
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The Control Room Operators Log Sheet was reviewed for the period July 10-14, 1975.
The inspector discussed with the
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licensee the possible inclusion of Technical, Specification
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Limits such as tank minimum levels.
The lidensee stated that
he is continuously reviewing the log sheets for improvement.
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The inspector had no further questions on this item at this time.
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j.
Auxiliary Building Tour
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The inspector toured the Auxiliary Building and noted 'the following:
(1) The operating crew composition was consistent with Tech-nical Specifications.
The control room was manned to Technical Specification requirements and the operator always had visual access to the control boards during the tour.
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t
-
(2)
Based on the Plant tour and observations of posted notices it was evident that Radiation controls were in force.
(3) A number of main steam lines were examined visually.
Based on this there were no apparent signs of unusual
.
pipe vibration.
The inspector had no further questions on this item.
(4) Seismic Restraints were observed on the intermediate closed coolant lines.
No abnormalities were observed.
.
(5) The Control board indications showed 68.9 gpm for point 497 of the Letdown.
The computer read out showed 70 gpm.
The RMS Recorder RMG 5, Reactor Building Personnel Access Door indicated Smr.
The RMS indicator read Smr.
These were all within Technical Specification requirements.
The inspector had no further questions on these items.
(6)
Control board indications showed turbine bypass valves ~
closed, MSV-3A, B, C, D, E, and F, with A, D, E, and F armed in auto.
These are backed up by the atmospheric
'
)
decay heat values.
.
The inspector had no further questions on this item.
(7)
Equipment tags for lock out were placed on the Secondary Service Cooling - River Water Pump.
A red tag vcs attach-ed to the control room controls.
Procedure AP-1002,
" Rules for the Protection of Men Working on Electrical and Mechanical apparatus", was referenced for the' proper use of the red and blue tags.
The red tags were on SR-P-1A and numbered 7485 and 86.
Similiar tags were found in the Screen House on Bus 1R, and the breaker was tagged and'open to full out.
The Tag information was consistent.
Red tags restrict operation of the unit until work is completed and tags removed.
Red and white tags were attached to discharge valve SRV-1A, tagged closed, and the numbers matched the red tags.
-
1452 058
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-17-
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Blue tag 7502 on the 1B Heater Drain Pump ex:ernal con-trol HD-P-1B, 7/22/75, was noted and traced to equipment.
~
The breaker was in the full out position, Panel 1B 4160 Bus.
The tag information was consistent.
Blue tagged equipment may be operated under special controls.
.
The inspector had no further questions in this area.
(8)
Discussions with the Control Room Operator (Ch0) in-dicated that Heat Trace Trouble Alarm was lighted due to probleus with the BWST heat trace circuits.
The Con-densate '?scer Storage Tank was reading 0 for level when it should have indicated 11 feet.
The CRO indicated that, due to the sampling procedures used, they exper-
~
ienced this loss of indication.
The second tank in-dicated 11 feet as required.
E The. inspector had no futher questions in this area.
}
(9) The inspector ' verified that the Shif t Foreman and Shif t Supervisor made daily tours of the plant.
The inspector had no further questions in this areat
)
4.
Audits
-
Audits for the one year period ending July 22, 1975 were reviewed with respect to the requirements of 10 CFR 50, Appendix B, Criteria I, II, V, VI, XVI, XVII and XVIII, ANSI N45.2.12, Procedure GP 4016, OQA AUDIT PROGRAM, Revision 0, dated April 17, 1975, and, for audits conducted after March 10, 1975, Procedure GP 4015, AUDIT
'~
FINDING CLOSE0UT PROGRAM, Revision 0, dated March 10, 1975.
_
,
a.
Items Reviewed The audit reports listed in Detail 4.b below were specifically reviewed to determine the following:
(1) That audits were conducted in accordance with written and approved checklists.
(2)
That au ts were conducted by licensee trained, or pre-vious experience qualified, personnel not having direct responsibility in the area (s) being audited.
1452 059 i
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-18-
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J (3) That audit results were documented and reviewed by management having responsibility in the ares (s) of audit and by Corporate Management.
(4)
That where required, followup action (s), including reaudit, was (were) completed, initiated, or in progress.
,
(5) That unless waived by written authorization baced on justifiable cause, audits were conducted in accordance with established schedules.
(See also Details, Paragraph 4.d)
b.
Reports Reviewed The reports listed below were reviewed with respect to the requirements listed in 4.a above.
Items designated with an asterisk (*) were delayed due to a plant shutdown and were the subject of a memorandum dated May 22, 1975 requesting per-mission for the delay.
The Manager - Operational Quality Assurance approved this deviation from the published audit schedule.
(See also Details, Paragraph 4.d)
Number Audit Area Conducted 5-I (1)
74-19 Control of Procedures (GP-0001)
08/05/74-08/09/74
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-
(2)74-19A Technical Specifications-Water Chemistry 08/25/74-09/19/74 (3)
74-20 Station Organization-Chain of Command 09/04/74 (4)
74-21 Technical Specification Requirements 10/07/74-10/11/74 (5)
74-22 HP Coverage for Maintenance 07/22/74 (6)
74-2 3 GPUSC Construction Program 09/01/74 (7)
74-24 Technical Manual's Audit 09/30/74 (8)
74-25 Drawing Control 09/23/74 (9)
74 ^5 Maintenance Procedure 1402 11/25/74-f2/06/74 (10) 74-27 Cancelled (See Report 50-289/75-01, Detail, Paragraphs 4.d and 7.f(l)
(11) 74-28 Warehousing 12/30/74-12/31/74 (12) 74-?9 Modification Control 11/07/74-11/21/74 (13) 74 10 Environmental Technical Specifications 02/11/75-02/15/75 (14) 74-:4 Operator Requalification Program 01/02/75-01/18/75 (15) 74-32 S.P.C.C. Plan for TMI (40 CFR 112)
10/09/74-10/10/74
..
1452 060 s
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-19-D D
D O
!
aq m
S g- -)
\\ _.. /
- we e
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--
='
i N;
wr-Audit Area Conducted (16) ?! E,
Nc compliance Report Followup 12/09/74-12/13/74 (17) 74 _ -
At it Followup 12/19/74 (18) /; il Security Audit 05/03/75-05/05/75 (19) 73 Sp;cial Nuclear Material 04/26/75-04/30/75
'
(20)
M-~-
IMi Emergency Plan 05/02/75-05/05/75 (21) 7
Aidnistrative Procedure 1010 02/10/75-02/24/75 (22)
7.
';
T.oging Procedures-AP-1002 02/24/75-02/28/75
(23) 75
't c:.ification Control 02/05/75 ( 2'4 ) 7i-
'
'd.inistrative Activities 04/14/75-05/12/75
..
(25) )
res_2 ip t Inspections 04/07/75-04/11/75 ni (26) i
.;
- J:eorological Tower 07/14/75-07/18/75*
(27) ~
.0 racord Storage 04/21/75-05/01/75 (28) 7 11
.c.us NPDES Permit 05/01/75-05/02/75 (29)
1.
e ification Design control 05/12/75-05/16/75 a
(30)
L iment Control 06/23/75-inspection *
.
-
- udit; '4-32 and 75-07 were not issued in accordance with the
.icca::
's commitment (See Details, Paragraph 4.d below); how-
_ver,
- ese audits were not related to nuclear activities or i
safety-related operations.
Audit 75-13 was in progress dur'ing
-
,
he ai c 2ction and therefore could not be completely reviewed.
'n or.
to determine the dates of conduct of seven (7) o.f the
- hirt) (30) audits reviewed, documentation other than the sudit. alder was required.
The licensee stated that future
.udit 2 ports would contain the dates of audit conduct in the
~
cody c; the report.
.
'!ith raspect to the five (5) areas of review (Details, Para-graph 4.a), the inspector had no further questions on audits,
_
c.
7ecord leeping During the course of conducting the review of the audit re-ports, he inspector determined, by direct questioning, that
'o it.21:idual had been designated as file custodian.
ANSI
.45.2.: requires in Section 5.3 that:
" Prior to storage of records in a quality assurance record file, a written storage
procedure shall be prepared and a custodian shall be designated ith ti" responsibility to enforce the procedure.
This pro-edure chall include the following as a minimum:
1.
......
'....."
...
1452 061 s
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-20-
.
Section 10 of the Operational Quality Assurance Plan states in part:
"Each manager is responsible for developing, reviewing, approving, and implementing his group's procedures as required to.... cover activities such as document control,
.......re-sponsibilities and duties of personnel..."
~
10 CFR 50, Appendix B, Criterion V requires in part.
"Activ-ities affecting quality shall be prescribed by documented instructions, procedures, or drawings....and shall be accom-plished in accordance with these instructions, procedures, or drawings."
Contrar.y to the above requirements, no procedures were avail-able and no record custodian had been designated.
This is a Deficiency level Item of Noncompliance.
d.
Previous Items of Noncompliance In the letter dated February 7, 1975, which forwarded report 50-289/75-01, Enclosure 1 identified two Items of Noncom-pliance designated as item 3 and item 4, associated with the conduct of audits and the followup of audit findings.
The licensee's response to these Items, included in the letter to
.
Region 1 dated Fbrch 3,1975, were reviewed with the results
)
indicated below.
,
'
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(1)
Four (4) audits were involved in the citation, 74-13, 74-25, 74-27 and 74-29.
The licensee stated that audits 74-13 and 74-27 were no longer considered as areas to be audited and that these would be officially cancelled.
The audit folders for these two audits contained a memorandum, approved by the Manager - Operational Quality Assurance, indicating that the cancellation of these audits was sanctioned.
The remaining audits were to have their results published by February 3, 1975 for 74-25 and by }brch 14, 1975 for 74-29; both of these dates were met.
The response indicated that, to prevent future items of this nature, audits would only be cancelled with the written concurrence from the Manager-Operational Quality Assurance and that an audit tracking system would be
-
established to assure publication of audit results within thirty (30) days of the audit exit interview.
The inspector reviewed the tracking system (a handwritten chart on which'is recorded the date of the final exit interview, 1452 062
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the audit number, the auditor, the subject, and the date of audit results publication) maintained at the Corporate Offices.
Since the date of initiation (4/4/75) the inspector identified no safety-related or nuclear activ-icy related audits (See also Details, Paragraph 4.b(15)
and (24) which had not been published within the pre-
,
scribed time limit.
The inspector also verified that audits (See Details, Paragraph 4.b(26) and (30)) which were to be significantly delayed had been the subject of prior approval by the Manager-Operational Quality Assurance.
_
The inspector had no further questions on these items.
(2)
The failure to receive prompt correct actions involved three (3) specific audit findings:
74-13-4; 74-11-6; and 74-12-3.
The inspector's review of the licensee's do.umentation verified that each of these items had been closed on or before the date specified in the, licensee's March 3rd letter of response.
To prevent future items of this nature, the licensee stated that a system would be provided fer progressive escalation of OQA Department action based on milestones
_
(commitment dates) for accomplishing corrective actions.
';
The inspector reviewed the implementing' procedure, GP 4015, AUDIT FINDING CLOSE0UT PROGRAM, Revision 0, dated March 10, 1975 as it applied to audit findings conducted after the April 4, 1975 date referenced in the licensee's response.
The inspector had no further questions on these items.
~
5.
Document Control
-
The inspector reviewed the document control phase of the Quality Assurance Program with respect to the requirements of ANSI N18.7, 10 CFR 50, Appendix B, Criterion VI, the TMI Operational Quality Assurance Plan, Revision 6 and associated implementing procedures.
1452 063 s
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a.
Procedure Control
_
_
(1)
Personnel responsible for the review and approval of procedures were questioned and indicated that they were cognizant of their responsibilities.
(2)
By direct questioning of the Supervisor of Operations
-
the inspector verified that:
(a) The control room copy of the operations p'.ocedures manual is complete and current; (b)
Recalled procedures were, in fact, removed from
the control room copy of the operations procedures f-manuals; and
"
~(c)
Current standing and special orders were issued in accordance with the established controls identified in plant procedures.
.
(3)
The inspector reviewed the drawing summary li. sting to verify that it identified the current drawings in the.
files.
This listing was identified as follows:
,
-
)
"TMI Nuclear Station Unit #1 List of GAI Drawings
"
issued from start to 7-16-75."
The inspector had no further questions on this item.
b.
Engineering Drawing Control
,
(1)
Twenty onsite drawings were checked against the corporate engineering files to verify that as-built drawings-were being maintained in accordance with established procedures.
The results of the review were as follows:
Site Corp. Engineering Drawing No.
Rev. No.
Rev. No.
(1)
201-041
13 (2)
201-045
6 (3)
201-122
0*
(4)
208-110
7 (5)
208-207
2 (6)
208-421
6 (7)
209-187
3 1452 064 3 Discrepant _ items
,
.
.
-23-
)
Site Corp. Engineering
..,
Drawing No.
Rev. No.
Rev. No.
(8)
209-357
3 (9)
302-011
18 (10) 302-051
21 (11) 302-081
15 (12) 302-694
16 (13) 302-711
missing *
(14) 302-847
6 (15 304-086
14 (16) 304-131
6
.
(17) 304-201
5 (18) 304-711
13 (19) 307-382 0*
(20) 313-017
1
- Discrepant items
.
Drawing 302-711, Rev. 12, (item 13), was missing from the corporate engineering files and was not available to the inspector at this location.
.
==.
)
Drawing 201-122, Rev. 1, (item 3) and. Drawing 307-382,
=
Rev. O, (item 19), were found to have different drawing revision numbers than the corresponding site review numbers.
10 CFR, Appendix B, Criterion VI, states in part ".... Measures
}
shall be established to control the issuance of documents, such as instructions, procedures, and drawings, including changes thereto..."
-
-
Section 11 of the Operational Quality Assurance Plan states in
..
part, "....The Generation Division document control procedure requires that documents be controlled..."
Procedure GP-1015 states in part, "... drawings must at all
"
times correctly reflect the as-built system, components, and equipment..."
Contrary to the above, a lack of control existed for three engineering drawings out of the twenty drawin:;s sampled dur-ing this inspection.
This is a Deficiency.lerel Item of Noncompliance.
'T 1452 065
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fmg
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....
6.
Plant Maintenance
'
This area was reviewed with respect to the requirements of 10 CFR
[
50, Appendix B, Criteria II, V, VI, VIII, IX, X, XI, XVI and XVIII,
.
ANSI N18.7, and the licensee's Quality Assurance Plan.
"
The following summarizes the results of that review.
.),,
a.
Knowledge of Procedures Personnel responsible for maintenance activities were quest-ioned to determine if they were cognizant of their respon-sibilities.
This evaluation included whether each person g.
questioned was knowledgeable of the areas where he had direct responsibility, and familiar with the procedures and proced-ures system such that he could quickly determine the methods
.,
of control for related and interfacing activities.
No inadequacies were identified.
b.
Work Requests Seven maintenance activities, including one requiring per-sonnel with special qualifications, were evaluated.
The
!
evaluation was made to determine that the ma'intenance activity had been properly approved, that the procedures to which'the maintenance was performed were approved, identified and available, and that the qualification requirements were in accordance with procedures.
The material used could be identified as properly accepted and all checkoffs, inspections and tests were properly defined and completed.
-
One inadequacy was identified and is discussed following the list of Work Requests evaluated.
Work Work Request Finish Requests Date Date Work Performed (1)
9568 6-13-75 7-1-75 Remove motor and return to Westinghouse for key installation.
...
(2)
9657 6-18-75 6-24-75 Repair AH-E-178 Breaker that will not reset.
(3)
9781 6-25-75 7-8-75 RPS-Channel C, Hi Temperature Trip repair.
U 1452 066
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-25-
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=
. Work Work Request Finish Requests Date Dat Work Perf orr.ed
-
%
(4)
9782 6-25-75 7-17-75 CRD-Group 7 Shin and Secondary power supplies repair.
,
(5)
9791 6-25-75 7-1-75 RB snubbers outside D ring repair.
(6)
9930 7-5-75 7-15-75 NV-V-74 C "A" discharge value repair.
.
(7)
10049 7-10-75 7-18-75 Make-up system.
Repair recent line weld leaks.
c.
Data Sheet and Testing Procedur_e_
The testing of the, repair authorized by work request 9781 was performed using a portion of Reactor Protection SP 1303-4.1.
The following inadequacies were noted in the data ~heet used s
to record the results of the testing.
Procedure SP 1303-4.1, Section 6.8.5.3 states the voltage shall be n 09735 to
-
""
'x
.09865.
The data sheet contained 09735 to.
.9865 as the
)
voltage limits.
The actual results recorde'd were within the
""
procedure requirements.
The following inadequacies were noted in the SP 1303-4.1 pro-cedure and data sheets.
.
Two sections listed the voltage requirements to three decimal places and the tolerances to four decimal places as follows:
Sections 6.8.5.1 lists the voltage as -0.070!.0002.
Section 6.8.5.6 lists the voltage as
.0842.0002.
The actual voltage recorded on the data sheet for this section was.084.
It vcs confirmed that the voltage was actually measured to the fourth decimal place and was within tolerance.
Prior to completion of the inspection, a change was initiated to correct Section 6.8.5.3 on the data sheet to agree with the procedure and to correct sections 6.8.5.1 and 6.8.5.6 on the procedure and data sheets to define the requirement to four decimal places where the tolerance is in the fourth decimal place.
The inspector had no further questions on this item.
~
~
1452 067
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p V
d.
OC Surveillance of Maintenance
_
QC Surveillance Report Number 75-133 dated 7-3-75 documented
@
the vibration readings on pumps NP-P-lt and DR-P-1B as 5.4 mils. and 4.5 mils, respectively.
It further stated that vibration was greater than four mils. (Specification established
~
by Manager - Generation Operations Nuclear).
In addition, a letter to the Supervisor of Fbintenance, dated 7-1-75 approved by the >bnager - Generation Engineering and the Manager - Opera-tional Quality Assurance states in part: "For long term pump operation it is desirable to reduce the motor vibrations on subject pumps to less than 4 mils. (preferable to the 2-3 mil.
range).... "
The specification referred to in the surveillance report could not be located and was not reviewed by the inspector.
The evaluation of the above surve111ance report and the noncon-formance controls indicate the followin; deficiencies.
10 CFR 50, Appendix B, criterion XV, states:
' Measures shall be established to control materials, parts, or components which do not conform to requirements in order to prevent-their in-advertent use or installation.
These measures shall include, as apprcoriate, procedures for identification, documentation,
==
segregar.on, disposition, and notification to affected organiza-
~
i tions.
-I t:enconforming items shall be reviewe'd and accepted, re-jected or reworked in accordance with documented procedures."
The Operational Quality Assurance Plan, Revision 6, Section 20, states in part:
"Nonconformances, as discussed herein, include both hardware problems involving materials, parts, comporents, or systems which do not comply with licensing, codes, specifica-tion, or drawing requirements, and nonhardware problems such as failure to comply with the operating license, Technical Specifications, procedures, regulations, etc.
with respect to test, operations, etc.
The requirements for identification, reporting, segregation, disposition, and management review of noncompliances are in-cluded in the implementing procedures.
...It is the responsibility of anyone who detects a nonconformance to report it in accordance with the nonconformance procedure
-
that is applicable to his part of the organization.
Each Manager and the Station Super 5atendent is responsible for 1452 068
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.
-27-
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ensuring that nonconformance procedurcs (covering the type of nonconformances af fecting his staf f) are written, reviewed,
-
approved by themselves, and implemented by their staff.
Each procedure describes the specific methods for recording, identi-fying, and segregating nonconformances...In regard to non-conformances noted in connection with... work at the site, the
,
Manager-0perational Quality Assurance is responsible for approving procedures which control nonconforning materials, parts, or components prior to installation and system turnover to prevent their inadvertent use in station modification, maintenance, or repair.
These procedures require that non-conforming items found during the receipt inspections or checks of modification, maintenance, or repair work be clearly identified and documented.
...Any nonconformance which is dispositioned 'use as is' or ' repair' requires formal docu-mentation in accordance with appropriate procedures..."
Contrary. to the above :
(1) No nonconform3nce report was written for the out of specification requirement identified in surveillance report 75-133.
(2) There are no procedures approvec by the, Manager-Opera-
,
')
tional Quality Assurance which define the requirements for identification and segregating of nonconforming' items to prevent their inadvertent use or installation.
(3)
Engineering Procedure GP 1024 requires the Manager-Gen-eration Engineering concurrence on all Nonconformances which are dispositional "use as is" or " repair." The Nonconformance procedures do not include requirements for obtaining this concurrence by the Manager-Generation
~
Engineering.
These above three items taken together indicate a *ailure to define and control nonconformances and is a Deficiency level Item of Noncompliance.
1452 069
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(
7.
Design Changes, Modifications, Tests and Experiments
.
This area was reviewed with respect to 10 CFR 50, Appendix B, Criteria II, III, V,.VI to 10 CFR 50.59 and to the licensee's Quality Assurance Plan.
~
The following summarizes the results of that review.
a.
Design Chang,es and Modifications Ten design changes and modifications were evaluated to de-termine:
that they had been made in accordance with 10 CFR 50.59; that they specifically identified, in accordance with procedures, the proper codes governing the work, including inspections; and that the acceptance test procedures defined acceptance values.
The evaluation also verified that the modification conforued to Technical Specification requirements and that the appropriate procedures and prints were updated or scheduled for update.
.
The ten change / modifications evaluated were as follows:
C/M Request Date Modification
-
~'N)
(1)
230 1-21-75 RCS modtfy Control Circuit to
,
-
add limit switch.
(2)
235 1-27-75 1B ESMCC Increase lead size to breakers.
(3)
245 1-22-75 Loose parts monitoring.
Change pickup from subassembly "B" to
-
subassembly "C".
(4)
254 2-24-75 CA BAMT.
Reroute and modify lines.
(5)
260 2-26-75 Modify spent fuel pool storage racks (still in process).
(6)
300 4-8-75 CRD install spare stator cable assembly.
--
(7)
302 4-8-75 CRD install spare stator cable assemblies.
1452 070
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,
-29-
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C/M Request Date Modification
__
(8)
324 4-23-75 Emergency diesel generator governor replacement.
(9,)
378 5-30-75 DR-V 6A and B check valve nut weld.
(Change disapproved by engineering).
(10)
388 6-9-75 NR-V-16A, B and C and NR-V-18, 19 modify control circuit.
(Modification not complete).
The inspector had no further questions in this area.
b.
Engineering Control,of Design Changes The evaluation of this area was limited to the revi.ew of audit report 74-29 and changes to procedures GP 1003 and GP 1015.
Audit report 74-29,-issued 3-6-75, identified two findings where the engineering activities and/or procedures were not in compliance with the FSAR Commitments.
These are as follows:
(1)
Section 8 of the Operational Quality Assurance Plan Rev.
6 (Design, Modification, Maintenance, and Repair Control)
5d
"'
states, "The Manager-Generation Engineering is responsi-ble for controlling design work and administering design control activities (including design interfaces) for the modification of nuclear-safety-related structures, com-ponents, and systems.
These activities shall comply with Regulatory Guide 1,64 (October 1973) and the applicable requirements of ANSI N45.2.ll (Draft-May 1973)".
Also,
=
" Minor design and modification work cay be perforned by station engineers; however, when this alternative is utilized, the station engineers are subject to the Genera-tion Engineering design and modification control proced-ures.
In addition, the Manager-Generation Engineering retains the responsibility for the proper review and approval of design and modification documents."
Contrary co the above, the Manager-Generation Engineering has not approved AP-1016, has not issued approved Genera-tion design and modification control procedures to the plant staff, and has not issued a procedure which de-scribes the interface between the Plant and Reading Eng-incer'ing Staffs.
._
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1452 071
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-30-
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()J (2)
Section 8 of the Operational Quality Assurance Plan Rev. 6 (Design, Modification, Maintenance and Repair Control) states, " Design control is implemented by means of Generation Engineering Procedures which in-clude:
design considerations, design review require-ments, fnternal and external interface control considera-
.
- -
tions; and design document review, approval, distribution, control, and revision requirements.
Design considerations inc]ude, as appropriate:
physics, stress, materials, ther-mal hydraulic, radiation and accident analysis; appropriate design bases, codes, standards and regulations; acceptance and rejection criteria; and quality assurance / quality control requirements.
Design verification includes the use of formal design reviews, checks or tests as appro-
=
priate to ensure the adequacy of the design witn regard to the design considerations.
Design reviews may be conducted by means of the same, an alternate, or a sim-plified calculational method or by the performance of a suitable testing program.
A design review will be per-formed by an individual testing program.
A design review will be performed by an individual or group o'ther than the individual or group who performed the original design, but who may be from the same organization."
-
.)
The following are contrary to the above:
'
-
(a)
GP-1000, " Standard Memorandum".
Audit Team found limited evidence of its use.
(b)
GP-1001, " Engineering Calculations".
Audit Team found no evidence of its use.
.
(c)
GP-1003, " Control of Design Changes", is missing its attachment and the Audit Team found no evidence of its use.
(d)
GP-10ll, " Preparation, Changing, Up' dating, and Issuance of Specifications and Bills of Materials".
Audit Team found no evidence of its use.
(e)
GP-1026, " Control of Engineering Records", is miss-ing its attachment.
1452 072
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-31-
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_)
'
The audit findings were in the process of followup in accordance with the audit program at the time of the
_
inspection. -
These two licensee identified findings taken together indicate a failure to implement design control require-
~
ments and is a licensee identified Infraction level Item
=""
of Noncompliance for which no further inadequacies in corrective action were identified at this time.
-
c.
Transmittal of Safety Evaluations to General Office Rev_i_ew Board The Technical Specification, Section 6.1.C.5, requires that copies of evaluations pursuant to 10 CFR 50.59 for all pro-posed changes to procedures, equipment, tests and experiments be forwarded to the General Office Review Board (G0RB).
This function is being accomplished because the clerk has been told
_.
to do it, however, the procedures do not require it.
A
~~
licensee employee indicated that sending the evaluations to the GORB appeared inappropriate since they are not. required to review them except when specifically requested.
It was further stated that the procedures would be revised or other
=_
action taken to resolve the inadequacy by August 25, 1975.
,
....;
.
This is an unresolved item pending action by the licensee, d.
Tests and Equipment Technical Specifications, Section 6.1.C.3, require safety evaluations in accordance with 10 CFR 50.59 for test and experiments.
The Technical Specifications further define the review process for tests and experiments.
-
-
It could not be determined that there are procedures to implement these Technical Specification requirements.
The licensee stated that no tests or experiments, as defined by the Technical Specifications, had been conducted at Three Mile Island 1.
It was further stated that the procedures would be evaluated and revised as necessary to define the implementa-tion of the Technical Specification requirements.
.
This is an unresolved item pending action by the licensee.
1452 073
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8.
Surveillance Testing The following surveillance test procedures were reviewed for in-clusion of prerequisites, acceptance criteria, returning to ser-
vice, instrument calibration, test results in conformance with Technical Specifications, and appropriate performer and reviewer signatures.
Specific unresolved issues are noted with each of the
-
test procedures reviewed as found.
...
a.
Reactor Containment System Leak Rate SP 1303-1.1, Revision 4, dated 5-2-75, performed daily when RCS > 525F.
The purpose is to evaluate the reactor coolant system leakage in accordance with TS Table 4.1-2 item 7.
i+
The inspector noted that documentation was lacking,to verify that the DVM used was calibrated and traceable to the sur-veillance test performed.
Data sheets for 7/14-17/74 were reviewed.
The above was contrary to the requirements of 10 CFR 50,,
Appendix B, Criteria XI and XII.
This is a licensee dis-covered item, Reference A0 75-18, Details, Phragraph 10.d (2).
i Pending completion of changes to the procedure to correct this inadequacy, this item is unresolved, b.
.
SP 1301-3, Revision 2, dated 11/7/74, performed 5 times per week to month by month depending on results.
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The purpose is to insure complis.nce with TS 3.1.4,. Reactor Coolant System Activity, and TS 3.1.5, Chemistry, and also to insure compliance with the minimum sampling frequencies spec-ified in TS Table 4.1-3, item 1.
This applies to the maximum reactor coolant system activity permitted during operation; nuclides with half lives longer than 30 minutes shall not exceed 130/E microcuries per.m1 (TS 3.1.4).
1452 074
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TS 3.1.5 applies to acceptable concentrations of impurities for continuous operation of the reactor that is 02 <0.1 ppm, C12 <0.15 ppm, F2 <0.1 ppm with greater than 1.Oppm requiring immediate hot shutdown.
Data sheets for 7/7/75, 6/30/75 and 6/27/75 were reviewed.
.
The computer data sheet contained signatures of the performer and the reviewer.
The data sheets of the procedure require review for signoff and inclusion of units for the measured values.
==
No discrepancies were identified and the inspector had no further questions on this item.
c.
Reactivity and Power Control SP 1301-9.5, Reactivity Anomaly, SP 1301-9.5, Revision 2, dated 9/18/74 performed every 50 EFPD's or about every 50
,.
days.
,
The purpose is to provide a means of evaluation of'a reactiv-icy anomaly as required by TS 4.10 (difference of one percent in reactivity between the observed and predicted steady state concentration).
,
,
The inspector reviewed for:
Prerequisites and preparatio'n for the test; test and calibration of instrumentation specified; acceptance criteria and operational checks prior to returning equipment to service.
Also data sheets dated 5/19/75 and 5/10/75 were reviewed.
- No discrepancies were identified and the inspector had no further questions on this item.
'
d.
Core Power Map Distribution SP 1301-9.8, Revision 0, performed each 10 EFPD (about every 10 days).
The purpose is to obtaf.n a core power map to verify core power
distribution using the incore detector system in accordance with TS 3.5.2.
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1452 075
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The inspector did not inspect the calibration status of the 24 point recorder available in the control room nor the checks on
.
the two point recorder referenced in step 6.2.
It appears that this procedure relates to SP 1301-5.3 (See Details,
Paragraph 8.e below).
Data sheets 4/28/75, 5/6/75 and 5/16/75
_..
vere reviewed for appropriate signatures.
.
No discrepancies were identified and the inspector had no further questions on this item.
e.
Incore Neutron Detectogs SP 1301-5.3, Revision 1, dated 1/10/75, performed monthly.
The purpose is to check the function of the incore neutron detectors, including computer and recorder readout, in com-pliance with requirements of TS, Table 4.1.1, item 34; and to calibrate the back up recorders if necessary.
Data sheets 6/13/75 and 7/2/75 were reviewed.
The DVM being used in step 6.12 should be specified as equip-ment required and noted for traceability when used in this-
'
procedure for assurance of calibration, Reference A0 75-16, Details, Paragraph 10.d (2).
,
This is an unresolved item.
f.
Power Range Amplifier SP 1302-1.1, Revision 4, dated 2/12/75 performed daily or twice weekly.
The purpose is to verify that the power range amplifiers
are calibrated in compliance with the requirements of TS Table 4.1.1, item 3.
When the reactor power is above 15%, the heat balance is checked twice a week during steady state operation and daily when not in steady state.
If the computer readout of neutron power and heat balance differ by more than 1% or if console indicated neutron power and heat balance differ by more than 2%, the power range linear amplifier is adjusted to agree with the heat balance.
1452 076
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.. s Minor changes to the procedure, reference step 7, were dis-cussed with the licensee.
The licensee agreed to review the
=7 procedure step and make appropriate changes.
Data sheets 7/17/75, 7/16/75 and 7/15/75 were reviewed.
Similar verification of the use of a calibrated and traceable
,
DVM as mentioned in Details, Paragraph 10.d (2) also applies to this procedure.
This is an unresolved item.
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g.
Turbine Overspeed Testing
.
SP 1303-ll.19, Revision 2, dated 2/10/75, performed once per week and at each statup tests A and D, test C once every 6 months or after maintenance on the system.
Test B is per-formed every 6 months or after maintenance on the system following a successful test C.
Test E is performed every year
=-
and at each refueling interval.
-
Data sheets for 7/10/75 and 6/27/75 were reviewed.
Similar verification of the use of a calibrated traceable DVM for this test applies as mentioned in Details, Paragraph 10.d(2)..
--
)
This is an unresolved item.
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h.
SP 1303-4.17, Revision 1, dated 4/4/74, performed monthly.
"
The purpose is to test the main steam isolation valves in accordance to TS 4.8.1.
This is a check of the valve steam movement up to 10% when the unit is under normal flow'and Iced conditions.
i The inspector questioned step 3.3 as to how one insures the status of the valve to be tested.
The licensee agreed to review this step.
Data sheets 6/23/75 and 6/13/75 were re-viewed.
This item is unresolved pending licensee action on procedural step modification.
1452 077
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".iver Uater Discharge Sampling _
'g g SP 1301-9.10, Revision 2, dated 10/17/74, performed weekly.
The purpose is to ensure that plant river water discharge quality satisfies pH, disolved solids, and suspended solids
,
specifications as indicated in the environmental Technical Specification sections 2.2.2 and 2.2.3.
Data sheets 7/14/75, 7/7/75, and 7/2/74 were reviewed.
No discrepancies were identified and the inspector had no further questions on this item.
,
j.
Secondary Coolant Activity SP 1301-4.5, Revision 3, dated 4/4/75, performed weekly.
The purpose is to insure compliance with Three Mile Island Technical Specifications, Section 3.13, Secondary System Activity; and to insure c ampliance with the minimum sampling i
frequency specified in Table 4.1-3, item 5 of-the Technical Specification.
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Data sheets 7/16/75, 7/10/75 and 7/3/75 were reviewed.
)
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r No discrepancies were identified and the inspector had n6 further questions on this item.
k.
Station Batteries
.
SP 1301-4.6, Revision 0, dated 8/24/73, performed weekly, i
~
The purpose is to ensure that the station batteries are main-tained in a fully charged condition and to meet the require-ments of TMI Technical Specification 4.6.2.b for weekly read-
ings on four pilot cells in each battery.
The inspector reviewed data sheets 7/10/75, 7/3/75 and 6/20/75.
The inspector questioned the status of the Digital Multimeter calibration and notations in the procedure to assure trace-ability and calibration verification, reference Details, Paragraph 10.d (2).
==-
This is an unresolved item.
1452 078
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SP 1303-4.18, Revision 0, dated 3/13/74, performed monthly.
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The purpose is to test the operation of the undervoltage relays in accordance with requirements of Technical Specifi-cation Table 4.1-1.43.
The inspector reviewed data sheets f
(
dated 7/19/75, 6/4/75 and 5/12/75.
No discrepancies were identified and the inspector had no further questions on this item.
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m.
Emergencv Power System
__
SP 130'64.16, Revision 6, dated 4/26/75, performed monthly.
.
- ft22 f The purpose is to verify that the Emergency Diesel Generator can be canually started, synchronized with other power sour-ces and loaded.to 3000Kw in accordance with TS 4.6.1.A.
The inspector reviewed-data sheets dated 4/18/75, 5/19/75 and 4/2/75.
.
No discrepancies were identified and the inspector had no
,
further questions on this item, n.
Reactor Building Emergency Cooling and Isolation System Analog Channels sE SP 1303-4.13, Revision 2, dated 5/7/75, performed monthly.
The purpose is to verify the operation and various settings of
_
the analog logic of each channel of the Reactor Building N
Emergency Cooling and Isolation System in accordance with TS
)
Table 4.1,1 item 19a.
,
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Steps 6.2.7 for clarification of what is being reset, step 6.3.2.e for referenced QA procedure and step 6.3.9, need for DVM removal were discussed with the licensee.
The licensee has agreed to review these steps for possible changes.
The inspector reviewed data sheets dated 7/1/75, 6/11/75 and 5/1/75.
.
1452 079
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O e)
111 be reviewed by t te The traceaUlity and calibration 1:
-
This is similar to the actions's to be taken as licensee.
referenced in Details, Paragraph 10.d(2).
This is an unresolved item.
Reactor Building Sprav System Logic Channel o.
,
S. P. 13 0 3-4.14, Revision 5, dated 11/25/74, performed monthly.
-..
a The purpose is to verify that the Reactor Building 30 psig
~~ gr, logic channels and analog channels operate by means cf its i8r in accordance with TS Table. 1-1 item 20 and
==-
test circuit, The inspector reviewed data sheets dated 5/1/75, 7/9/75,
,h
21a.
6/20/7.5 and 5/7/75.
,
55l:
No discrepancies were identified and the inspector had no
- Jq
,
further questions on this item.
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Borated Mater Storage Tank p.
/
/
, Performed weekly and
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te ea 1 makeup h
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The purpose is to insure compliance with TS 3.3.1.la and to
.jfj insure compliance with the minimum sampling frequency specif-
~
ied in TS Table 4.1-3, item 2.
The " Equipment Required," step 5, lacks listing of specific equipment or the reference to procedures that would contain a listing of equipment for the performance of the Baron analysis.
i
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.
7/17/75, 7/10/75 and 7/3/f5 were reviewed.
I-The data sheets for It was noted by the inspector that the purpose of this test as
""
stated under TS 3.3.1.1.a does not agree in total with the This procedure re-performance required in this procedure.
ss quires the validation of the boron concentration of 2,270 ppm but does not address the 350,000 gallons nor the temperature requirement.
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1452 080
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The licensee stated that the water volume and temperatures are
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addressed in other appropriate procedures and that this pro-cedure will be changed to reflect the intent.
This is an unresolved item pending appropriate changes.
q.
Loading Secuences and Component Test and HP Logic Channel Test
SP 1303-5.2 (5.6, 5.10), Revision 4, dated 10/30/74, performed quarterly.
.
The purpose is to demonstrate that the emergency loading sequence is operable and to test the high presrure injection A and B logic channels, and high and low pressure injection components by using the safeguards auto and manual test circuits, in accordance with TS 4.5.1.2, Table 5.1-1 item 14 and 4'.5.2.4.
_ _ _.
The current procedure has a Temporary Change Notice (TCN)
attached dated 4/3,0/75.
TCN's are valid for a 90 day period when further rction is required.
The TCN appears -satisf actory.
-
The data sheet of 4/23/75 was reviewed and found to be.
appropriately signed.
.
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The inspector had no further questions on this item.
9.
Procurement The inspector reviewed procurement operations with respect to 10 CER 50, Appendix D, Criteria IV and VI, the TMI Operational Quality Assurance Plan, Revision 6 and associated bnplementing
~
procedures.
,-
a.
Components Selected
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The following safety-related items were selected for review in accordance with Section b below:
(1)
Gate Valve (P.O. No. 44097)
(2)
Swing Check Valve (P.O. No.13223)
(3)
Departure Bearing (P.O. No. 15823)
z_
(4)
AC lbtor (P. O. No. 12751)
(5)
Controller and Contacts (P.O. No. 14S39)
(6)
Scintillatica Detector (P.O. No. 12606)
(7)
E'ast'e System Parts (P.O. No. 120S5)
1452 081
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b.
Specifications The procurement specifications used in the purchase of the components in Section a above were checked to verify that they include the following:
.
(1)
Proper approval.
(2) Quality Control Inspection Requirements, es:
(3) Quality Record Requirements.
(4) A statement establishing the licensee's right of access to supplier's facilities and records for visits and audits.
The inspector identified no inadequacies in this area with the exception of item (41 With respect to iten (4), the inspector found that none of the procurement documen:s reviewed contained a statement in accord-ance with TM1 Procc 'ure No. GP 1011 regarding the licensee's right of access ta
- pplier's facilities and records for visits and audits.
No difficulties in obtaining access to-suppliers faciliti2s identified.
The licensee stated that, in the future, the abece access statement would be placed on all
)
procurement documents involving quality assu' red items.
The inspector will revi_w this item again at a subsequent inspection.
c.
Documentation
.
The inspector verified that documentary evidence was available onsite for the components listed in Section a above to support equipment and material conformance to procurement requirements, and had no further questions on that documentation.
~
d.
Spare Part Components The inspector verified that the following two (2) spare parts components, used in safety related functions, were processed as shown in the ne::: paragraph:
(1)
Isolation Amplifier (P.O. No. 46087)
(2)
Silicone Fluid (P.O. No. 10227)
1452 082
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's-s)
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D D
nn 10. <,
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a E SJ.m
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Comaencnt Processing e.
The above spare part components were processed as follows:
=
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(1)
Inspected upon delivery.
(2)
Properly handled in accordance with measures established
.
for control and separation of conforming and nonconform-
=
Ing materials.
The inspector had no further questions in receipt and handling of these items.
f.
Apur,.'ed Vendors The 'nspector reviewed the two (2) spare part components iden'"fied above with r act to the TMI Approved Vendors List wit!
~e follouing resuD n
.
.::.~
10 C.-R 50, Appendix B, C.;.crion IV, states in part, "....
Meer -res shall be estat'
'icd to assure that applicable regu-latc :, requirements c.
bases, ar.d other requirements which are necessary,to ".ure adequate quality are suitabl9 inc3m ed or referenced he documents.... "
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10 C"4 50, Appendix B, ccrion V, requireN that activities
"~
affer.ttng quality be acac >l1shed in accordance with pro-scribed procedures.
Sc<. cn 12.1 of the Operational Ouality
"-
.
Assurance Plan states
.c rt ".... Vendors must be on the approved vendors list...."
Procedure GP-1009 states in part
"....For nuclecr safety re?.ated items and services, Purchase Orders shall only be placc3 with vendors on the Approved Vendt.rs List...."
,-
Contrary to the above, tha two safety related items reviewed were parchased from vendora not on the licensee's approved vendor's list.
This is a Deficiency level Item of Noncom-pl 2nce.
Abnormal.ccurrences_ (A0's)
The following Abnormal Occurrences (A0's) have been reviewed a.
by the licensee's Plant Operations Review Committee (PORC),
c-..
l452 083
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(1)
A0 75-15, Out of Limit Setting for the Reactor Coolant Pressure Trip Setpoint; Reference PORC Meeting No. 285
=.
and 286.
(2)
A0 75-16, Out of Limit Setting for the Reactor Coolant Pressure Trip Setting; Reference PORC Meeting No. 286.
,
(3)
A0 75-19, Out of Specification Reactor Coolant Pressure Trip Setpoint; Reference PORC Meeting No. 287.
(4)
A0 75-21, Failure of a High Reactor Coolant Temperature Trip Bistable to Trip; Reference PORC Meeting No. 290.
(5)
A0 75-13,. Failure of a Rod Drive Breaker to Trip; Reference PORC Meeting No. 231.
' 0 75-20, Xenon Reactivity Stability Occurrence; Reference (6)
A PORC Meeting No. 287.
(7)
A0 75-17, Fai4ure of Reactor ""ilding Puide Isolation Valve to Pass Local Leak Rate Test; Reference., PORC Meeting No. 287.
(8)
A0 75-18, Inadequate Control of Vendor k'ork on Motor;
!
Reference PORC Meeting No. 287.
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b.
All of the above A0's were reviewed by the General Review Committee during meetings as listed below:
AO's 75-11,12 and 13 during meeting 75-13 held May. 8,1975; A0 75-14 during meeting 75-17 held on June 17, 1975; A0's 75-15, 16 and 17 during meeting 75-18 held on July 3, 1975;
.-
A0 75-18 during meeting 75-19 held on July 14, 1975; and AO's 75-19 and 21 during meeting 75-20 held on July 17, 1975; except A0 75-20.
This item remains to be reviewed and as such.is unresolved.
c.
Verification of review of the Abnormal Occurrences listed in 10.a above by the General Office Review Board, GORB remains to be performed and will be verified during subsequent inspections.
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d.
The licensee had initiated corrective action in all reviewed abnormal occurrences.
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(1)
A0 75-15, occurrence June 5,1975, out of Limit Settings for the Reactor Coolant Pressure Trip Set Point, TS 1.8a, and TS 2.3 Table 2.3-1.
The Reactor was in the cold shut-
.
down state and the pressure trip setpoints were being checked in accordance with Refueling Interval Survef.11ance Procedure 1302-5. 2 and '5.3.
The Limiting Safety System setting was less conservative than that established in the TS.
The trip setpoint required is 2355 psig and was found to be 2377 psig.
The cause was due to drift in the Reactor Coolant System pressure transmitter.
The setpoints for the 3 other RPS were within limits and would have performed their protective function within TS limits had an overpressure condition occurred.
The bistable was recalibrated and testeo' satisfactory.
It was noted on work request 8628 Page 36 that the date did not cer. iate to the date recorded on the abnormal occurrence.
The licensee acknouledged this discrepancy and will cche a review.
This is an unresolved item.
.
[
The long term corrective action require.s a TS change
which remains to be sub=itted.
This i*s also an unresolved item.
(2)
A0 75-16, occurrence June 5,1975, Out of Limit Settings for the Reactor Coolant Pressure Trip Setting.
This is an A0 as defined by TS 1.8a and TS
'.3 Table 2.3-1.
The reactor was in cold shutdown status.
During the performance of "RPS Surveillance" SP 1303-4.1, variable low reactor system pressure trip setpoints for 3 RPS channels were less conservative than required by the TS.
The channels were recalibrated and retested sat is f ac t ori.T.y.
The apparent cause was suspected to be either material or procedural, in that the voltmeter used was found to be out of calibration.
A report on the volt-meter remains to be documented.
This is an unresolved item.
1452 085
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Corrective actions include the checking of the trip setting for four RPS channels each week for a month, Reference Procedure 1303-4.1 and Work Request 9651.
Changes to surveillance procedure (s) renains to be completed.
The licensee plans to add to the data sheet the serial and model number of the special equipment used
,
in calibration of the bistables.
This item is contrary to requiremen*s of 10 CFR 50 Append-ix B, Criteria XI and XII.
This item is considered an Item of Noncompliance reported by the licensee and is considered to be an Infraction.
Completion of corrective action will be subsequently reviewed.
(3) A0 75-19, cccurrence June 18, 1975, out of Specification Reactor Coolant Pressure Trip Setpoint.
Reported under TS 1.8.a and TS 2.3 Table 2. 3-1.
The reactor was at 99%
of rated pouer.
While performing weekly checks on the RPS channels as'
described ur.dcr A0 75-16 above, the test results showed
"=
that the trip setpoint for one RPS chanpel was less
conse;vative than required by TS, with*the required value being 1831.5 and the measured value being 1831.2 psig.
The channel was recalibrated and retested satisfactorily, reference Work Request 9651.
The cause was due to tem-perature to pressure signal converter drift.
The cause of the drift is not known.
This item will be reinspected.
(4)
A0 75-21, occurrence June 25, 1975, Failure of a High Reactor Coolant Temperature Trip Bistable to Trip. "
Report requirements are defined by TS 1.8.d.
The reactor was at 99% of rated power.
The occurrence was found while conducting routine surveillance of the Reactor
"
Protective System.
The Reactor Coolant Temperature Trip Bistable for Channel C failed to trip.
The remaining three channels checked satisfactorily.
The defective component was replaced and checked satisfactorily, ref-erence Work Request 9781.
The failure was traced to a defective circuit board solder joint.
The inspector had
'
no further questions on this item.
1452 086
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(5 ) A0 75-13, occurrence April 25, 1975, Failure of a Control Rod Drive Breaker to Trip.
Report requirements are de-fined by TS 1.8.d.
The reactor was at 9S% of rated power.
Voltage was lost on channel D of the RPS causing Control Rod Drive breakers associated with Channel D to trip.
The voltage loss caused the breakers' undervoltage coils to
-
deenergize, thus tripping CB 3 and CB 4 associated with
,
Channel D.
CB 4 on being clcsed remained closed which should not have occurred when the undervoltage coil is deenergized.
The breaker was retested and found to trip or RPS trip signal then returned to service.
The cause of the malfunction was due to procedure inade-quacies which led to an out of adjustment condition of the mechanical linkage within CB 4 breaker.
Immediate corrective action was verified by discussion with the Lead Electrical Engineer.
The licensee h,as modified Surveillance Procedure 1303-4.1, Step 6.10.2.2a, Revision 10.
A Refueling Procedure E-36, Control Rod Drive Trip
_ _..
,
Breaker Check, was approved May 17, 1975.
The purpose of the procedure will be to define the. checks of the AC (
,
T:.
and DC trip breahcrs for proper operation and adjustr.cnt.
The inspector had no further questions on this item.
(6) A0 75-20, occurrence June 22, 1975, Xenon Reactivity Stability Occurrence.
The reactor pouer was increased above the power level cut off before Xenon reactivity was asymptotically approaching stability.
The report-ability of this occurrence is defined by TS 1.8.b, Limiting Condition for Operation.
Also Reference TS 3.5.2.5.c.
The reactor was at 82% power.
The occur-rence happened on returning to full power operation after a forced power reduction.
The occurrence was
,
discovered on analysis after the xenon stabilir.ed.
No corrective action was required.
The cause was due to a lack of procedure guidance for determining when xenon reactivity in asymptotically approaching stability for the power maneuvering in progress at the time of occurrence.
1452 087
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The licensee has revised Operating Procedure 1102.2 r >ference n.7,e 21, revision 11.
Curves have been drawn to give th; operator a better understanding of the
=
i.ecning of :symptot t cally approaching stability.
The curves are in terms of hold time versus power level for a family ci curves.
,
This item is contra y to TS 3.5.2.5.c which is a limit-
i, ;; condition for operation.
This is considered to be a correcte! Item of Noncompliance reported by the licen-see and in considered to be an Infraction.
Th inspect'c has no further questions on this item.
(7)
2C 75-17,..:urrence June 15, 1975, Failure of Reactor ruilding b ge Isolt*.lon Valve to Pass Local Leak Rate
'i<it.
Th.
eportat ity of this item is defined by TS 3. e (alt - refere~
TS 4.4.1.2.4).
The reactor was at 5% por The currence was discovered while con-
' e ting ti fearly ik rate testing of the Reactor rilding
- e Iso'
ion Valves, AH-VlA and AH-VlB.
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ve AH -
was f t
.I seated incorrectly.
The cause
- . ; due te
, impre
.r setting of limit switches.
The N-sive was xed anu tested satisfcetorily at 969 SCCM ('
I
- ak rate
.csus t1 administrative lihit of 1500 SCCM.
- a.
total ST was '.1,254 SCCM which was much less t'han 15 limit c.' O.6 L3
.ich is equal to 111,000 SCCM.
.he licen_
has b: -
inspecting this valve to gain
,
onfidence
'a it's erability.
Inspections hdve been cacumented.or 6/27, 7/11 and 7/25/75.
62 inspec:or had nc further question on this item.--
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(8)
75-18,
- urrence June 16, 1975, Inadequate-Control
.f Vendor
- formed ork as defined by TS 1.8g, in that ciu inadequ :e control of vendor performed work con-cuted Observed inadequacy in the implementation of inistre.ive or p> ^cedural controls that threatened to cc.use an un cife conultion in the operation of the plant.
1452 ogg
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The motor for Decay tient River h'ater Pump DR-p-1B was received from a vendor repair facility.
Q.'i/OC decumen-tation was lacking and not available from the vendor due to the motor not having been repaired in accordance with original design specifications.
An independent evaluation by Met-Ed Technical Support Staff indicated that repairs
.
were adequate for the pump to meet TS 3.3.1.4.d.
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The licensee stated that appropriate additional adminis-trative/precedural measures, in the form of a procedure, will be instituted by July 31, 1975 so as to prevent a recurrence of this type of situation.
This will be identi-fied as Stores Procedure No. 1 entitled " Procurement".
This will be reviewed by the inspector at a subsequent inspection.
This is an unresolved item.
11.
Chemistry Controls The inspector reviewed two (2) Primary System water sample analyses to 10 CFR 50, Appendix H, Criteria II, V, XII and XVII.
a.
Items Revieued
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'N During the conduct of the analysis identified in Detail ll.b
,
(
)
below, the inspector verified, by direct observation and/pr
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discussion with the Technician performing the analyses, that:
(1)
the appropriate approved procedure was followed; (2)
the curve used (procedure 1908 only) had been c'alibrated/
standardized within the previous six months as required by the licensee's procedure; (3)
the Technician was cognizant of the importance of out-of-specification results and the percon(s) to notify when/if abnormal results were obtained; (4)
reagents used were within the established shelf-life usage limits; and (5)
the Technician used acceptable laboratory techniques and observed appropriate safety practices during the handling, measuring, mixing and c1 caning of radioactive and/or corrosive, poisonous reagents, samples and laboratort apparatus.
i452. 089
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The inspector did not attempt to evaluate the accuracy of the
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results obt ained.
b.
Analyses Observed
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The inspector selected the analyses listed belou for review with respect to the areas listed in 11.a above as performed by the scheduled Technician on the Day Shif t of July 22, 1975.
(1)
Chloride Determination, Mercuric Thiocyanate Titration Method, as described in Procedure 1908, Revision 2, dated Pay 12, 1974 was observed.
(2)
Determination of Boron Concentration, Manitor/pH Meter Method, as described in procedure 1912, Revision 1, dated March 6, 1974 was observed.
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The inspector identified no inadequacies in Chemistry Controls.
12.- Records
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The inspector requested the records listed below to verify that the
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I
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licensee's program for control, storage, retention and retrieval
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of records met the requirements of Criterion XVII of 10 CFR 50, d$
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'
l Appendix B and the Technical Specifications, gfj.
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a.
Records Selected g.g
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(1)
(Reactor Ceolant Motors Surveillance Test Record)
(2)
Reactor and Power Control.
(Control Rod Drive Surveil-lance Test Record)
(3)
Core and Internals.
(Core Flooding System Surveillance
Test Record)
(4)
Power Conversion System.
(Turbine Generator Valve Test Surveillance Record)
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(5)
Auxiliary System.
(Liquid Waste Disposal System Pump Chech Record)
(6)
Elederical System.
(Generator Conditions Surveillance Te : Record)
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(7)
Energency Power.
("A" Diesel Generater Fuel pump and
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Air Start System Surveillance Test Record)
(8)
Containment System.
(Rcactor Bldg. Spray / Decay Heat Removal Surveillance Test Record)
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With the exception of subparagraph 12.b, following, no in-adequacies were identified in this area.
b.
Record Storage Audit 75-10, Record Storage, was conducted by the licensee from 4'/21/75 to 5/1/75.
The audit findings were as follous.
(1) The audit used the general requirements and guidelines of ANSI 45.2.9.
(2) TMI. Administrative Procedures 1007 and 1024 states....
" Records sl.all be stored in standard steel file cabinets".
Contrary to the above, some records which are maintained by the Chemistry, Health Physics and Operations Depart-ments are stored in cardboard containers.
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This is a licensee identified item of noncoppliance with no inadequacy identified in the licensee's corrective actions.
This item is Unresolved pending completion of required corrective action.
- 13.
Organization and Administration Selected segments of the licensee's organization / administration were reviewed with respect to:
10 CFR 50, Appendix B, Criterion I; ANSI N18.7; Technical Specifications; and the Operational Quality Assurance Plan.
The results are summarized below.
a.
Organizational Structure
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Technical Specification 6.1.8 states in part that:
....the Station Superintendent shall report to and be directly respon-sible to the Manager-Generating Stations per Figure 15.6-1."
.. _..
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The Operational Quality Assurance Plan, Section 1, states in part:
"The organization for Met-Fd 's Operating Ouali ty Assurance. Program for TMI is show-- in Figure IA-1."
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The Operational Quality Assurance Plan, Section 6.7, states in part:
"The Station Superintendent is assisted in carrying
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out the above responsibilities by the Unit Superintendent,
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the Maintenance Supervisor, and the Operations Supervisor and their staffs."
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Both Fi!
es lA-1 and 15.6-1 show the Station Superintendant
..m..
reportins to the Manager-Generating Stations.
Contrary to the above, since the promotion of the Station
,
Superintendent to Manager-Generation Operations-Nuclear on June 16, 1975, the position of Station Superintendent has been "hcant.
Failure to have an organization which meets the Technical c
Specification and Operational Quality Assurance Plan require-ments is a Deficiency level Item of Nonconpliance.
=
The inspector also noted that, while the licensee has submitted i
a preposed revicich to the Technical Specification (Change Request #5, Acendment 1, dated December 23, 1974), that pro-posed revision also included a position of Station Superin' tea-dont reporting to a Manager-Generating Stations and being re-ported to by the Unit Superintendent.
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In addition, F1 ure 13.1-1 of the Unit 2 FSAR (Amendment 28,
dated 5/30/75) and the narrative description in Section 13.1.3.2.1 (Amendment 28, dated 5/30/75) also indicate the position of Station Superintendent as a separate and distinct entity from the Unit Superintendent with different*responsi-
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bilities, authorities and reporting channels.
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The renbership of the Plant Operations Review Committee (PORC)
was reviewed with respect to the requirements of Technical Specification 6.1.I.
While current membership is the sate
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with respect to the persons actually indicated by the Technical Specification titles, the current titles of the members have changed.
The licensee produced a draf t revision to Technical Specifications (Change Request #5, Revision 3) which he stated will be forwarded for URR approval on or about August'll, 1975.
This item is Unresolved.
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c.
GORS The membership of the General Office Review Board (GORB) was reviewed to determine that, collectively, the members possessed competence in the ficids specified in ANSI N18.7 -1972, Section 4.2.2.2 as required by Technical Specification 6.1.I.
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3.a(3).
The inspector reviewed the resumes of the GORS member-ship by telephone conversation with the Chairman of the GORB because their resumes were unavailable at either the plant site or the Corporate Offices.
Based on these discussions, the inspector identified no inadequacies.
The licensee stated that, l:
for more ready access, copies of the resumes of GORS members
'
would be maintained and available at the Corporate Offices.
d.
Crew Composition The makeup of the shift crews, both titles and NRC Licenses,
$
was reviewed for conformance to the requirements of Technical Specification 6.1.F.
The inspector identified no inadequacies.
e.
Personnel Chance Reporting Technical Specification 6.7.1.a.7 requires including resumes of
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new appointees to s?ven (7) specified positions in the semi-i annual operating reports.
The two persons assigned new positions during the period (July - December 1974) of the last issued semi-annual report were included as required.
The inspector identified no inadequacies in this crea.
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