IR 05000289/1976017
| ML19276H164 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/14/1976 |
| From: | Knapp P, Plumlee K, Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19276H160 | List: |
| References | |
| 50-289-76-17, NUDOCS 7910150265 | |
| Download: ML19276H164 (29) | |
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IE:I Form 12 (Jc ',75) (Rev)
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U. S. NUCLEAR REGULATORY CO'CIISSION 0FFICE OF INSPECTION AND ENFORCD!ENT g
REGION I
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IE Inspection Report No:
50-289/76-17 Docket No:
50-289 Licensce:
Metropolf. tan Edison Company License No: DPR-50 P.
O.
Box 542 Priority:
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C Reading, Pennsylvania Category:
Safeguards
"P'
Three Mile Island I,
Mi d c' l e t ow n, PA
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Type of Inspection:
Routine, Uiiannounced July 20-23, 26, and 29-30, 1976 Da of Inspection:
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Dates of Previous Inspection:
M/
-Id-7b Reporting Inspector:/K!
E.
v-Plumi e,
Radiation Specialist DATE
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Accompanying Inspectors:
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Spe rd, /,
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Rea tor Inspector DATE
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h/d4 (i-N-70 DATE J. R./ White, R,adiation Specialist r
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DATE
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l P.'J.
Kna Radiation 9 - lN - 7(o Other.A(c ing Per
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support section DATE Reviewed By: 'k M-
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YMM ('
Cj - N - 7 c.
x P.
J. Knapp,' Chief, kad{ation Support Seccion DATE Fuel Facility and Materials Safety Branch-s
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SUMMARY OF FINDINGS
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Enforcement Action i
i Items of Noncompliance i
A.
Violations None.
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B.
Infractions
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1.
Technical Specification 6.11 states that radiation protection procedures shall be prepared consistent with the requirements
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of 10 CFR 20 and shall be approved, mair.tained and adhered to
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for all operations involving personnel radiation exposure.
Procedure HPP 1613 " Radiation Work Permits," developed l
a.
pursuant to the above, requires all personnel to be authorized by and logged in on Radiation Work Permits (RWPs) prior to entries into areaa posted with signs indicating " CAUTION:
Radioactive Materials, Airborne ()
Contamination, High Radiation Area, Radiation Area, and Contaminated Area."
Contrary to the above the following were allowed to occur:
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(1) An individual who was not authorized by a RWP was observed in a posted and roped off radiation area cn the 281 foot elevation of the Auxiliary Building j
at 2:50 p.m. on July 20, 1976.
(Details, Gection 1, Paragraph 5.a)
(2) Three individuals who had failed to log their reentry under RWP No. 0852 were observed in a posted and
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roped off radioactive materials area at 2:57 p.m. on j
July 20, 1976.
(Datails,Section I, Paragraph 5.a)
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(3) Seventeen RWP records for work completed between July 1, 1975 and June 30, 1976, were found to lack required entries.
(Details,Section I, Parcgraph 6)
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b.
Procedure HPP 1776, saupling of Unmonitored Release Paths," develorad p,rsuan; to Technical Specification e t samoles monthly, including one 6.11 specifies ci n
of the sewage system, t
Contrary to the above none of the eight specified sam-ples were obtained during February 1976, and only one monthly sample was obtained of the sewage system during the twelve month period July 1,1975 through June 30,
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1976.
(Details,Section I, Paragraph 7)
2.
A requirement of Techr.ical Specification 6.5.1.6.e is that
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PORC review items of noncompliance with regulatory require-nents.
Contrary to TS 6.5.1.6.e, PORC failed to review numerous
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j items of noncompliance with the TS or Operating License and j
of applicable federal statues, regulations and internal i
station procedures having nuclear safety significance as identified in 28 Station Nonconformance Reports and 5 QA Audit Reports covering the period of March 1 through June 30, 1976.
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(]}
Cortective and preventive action was initiated by the licensee prior to completion of the inspection. This action is accep-
- j table, and no response to this item is required.
(Details,Section II, Paragraph 6.b(7)(b) and (c))
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C.
Deficiencies Nor.e.
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Licensee Action on Previously Identified Enforcement Action A.
Corrective actiuns taken in response to NRC:I Inspection Report 50-289/76-01 were incomplete.
(Details,Section II, Paragraph ll.a)
B.
Corrective actions teken in response to NRC:I Inspection Report
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50-289/76-10 were completed.
(Details,Section II, Paragraph ll.b)
Design Changes None inspected.
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-3-i Licenece Events None.
Other Significant Findings A.
Current Findings 1.
Acceptable Areas No inadequacies were identified during inspection of the following areas:
a.
Details,Section I I
I (1) Checking of emergency equipment.
(Paragraph 8)
(2) Reactor water E-bar determination.
(Paragraph 9)
(3)
Procedures for handling spent resins and sludge.
(Paragraph 10)
(4) Procedures for surveying and mcnitoring.
(Para-
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graph 11)
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(5) "rocedures for radiation work permits.
(Para-graph 11)
(6) Procedures for chemical and radiochemical sampling l
l and analysis.
(Paragrapb 32)
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(7)
Records and control of radioactive releases.
(Paragraph 10)
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(8) Surveillance testing of monitors.
(Paragraph 12)
(9) Monitoring of radwaste releases.
(Paragraph 12)
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(10) Upkeep of radwaste systems.
(Paragraph 13)
(11) Records and reports of personnel exposures.
(Para-graph 11)
(12) Personnel monitoring.
(Paragraph 11)
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b.
Details,Section II (1)
Station manning.
(Paragraph 2)
(2)
(Paragraph 3)
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(3)
Exceeded safety limits action.
(Paragraph 4)
(4) Plant Operations Review Cotmittee (Paragraph 6, with the exception of subparagraphs 6.b(7)(b) and (c)
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Corporate Technical Support Staff.
(Paragraph 7)
(6) General Office Review Board.
(Paragraph 8)
l 2.
Unresolved Items
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None.
3.
Licensee Identified Items of Noncompliance
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a.
Infractions (}
(1)
Contrary to TS 6.8.1, during March 1 through June 30, 1976 there were 28 instances where procedures related to nuclear safety were not followed.
(Details, Section i
II, Paragraph 5)
i (2) Contrary to 10 CFR 50, Appendix B, Criterion V and the FSAR Appendix 1A, Operational Quality Assurance Plan, Section 10, during March 1 through June 30, 1976 there were 12 instances were 0QA Plan imple-menting procedures were not followed.
(Details, Sec-tion II, Paragraph 6.b.(7)(c))
(3)
Contrary to TS 4.4.2.2.A, the third inspection of the Reactor Building ring girder was not completed within the specified interval.
(Details,Section II, Para-l graph 9)
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Deficiencies (1)
Contrary to 10 CFR 50, Appendix B, Criterion XVII and the FSAR Section lA, Operational Quality Assurance Plan,
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Section 22, during May 25-28, 1976 QA Plan requirements
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for preparation, review, approval, and 1uplementation of QA Record Procedures were not being met at the Met Ed
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Corporate Office.
(Details,Section II, Paragraph
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6.b.(7)(b))
(2)
Contrary to 10 CFR 50, Appendix B, Criterion VI and
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the FSAR Section lA, Operational Quality Assurance Plan,
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Section ll, on May 16 and June 13, 1976 document control procedure requirements for TMI-l Technical Specifications and changes were not being met by members of the Corporate
Technical Support Staff.
(Details,Section II, Paragraph 6.b. (7) (b))
B.
Status of Previously Identified Unresolved Items 1.
The following items have been resolved:
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a.
GORB Review of ER 76-10/ L.
(Details,Section II, Para-
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graph 10.b)
b.
GORB Review of Proposed TS Changes 29 and 32.
(Details, f
Section II. Paragraph 10.c)
2.
The following items remain unresolved:
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a.
CTSS Review of Facility Procedure Changes.
(Details,Section II, Paragraph 10.a)
b.
GORB Review of Violations of TS and Liccase Requirements.
(Details,Section II, Paragraph 10.d)
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l Management Interview
A management interview was conducted at tihe Three Mile Island Facility j
on July 23 and 30, 1976.
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l Persons Present
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i Metropolitan Edison Company K. Beale, Radiation Protection Supervisor
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R. Dubiel, Engineer - Nuclear II *
R. Harbin, Engineer II Assistant *
G. Miller, Unit 2 Superintendent (Acting Unit 1 Superintendent)
J. O'Hanlon, Engineer Senior Nuclear I J. Romanski, Supervisor - Radiation Protection and Chemistry Nuclear Regulatory Commission
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R. Eores, Radiation Specialist **
K. Plumica, Radiation Specialist
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R. Spessard, Reactor Inspector *
J. White, Radiation Specialist *
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Items Discussed A.
Purpose of the Inspectien
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i This was an inspection of radiological protection and of opera-tions. The Sandia Statistical Sampling Inspection Program was O
used as a basis for inspection.
B.
Acceptable Areas The items discussed are as identified under the "Other Significant Findings" section of this report.
C.
Items of Noncompliance
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The items discussed are as identified under " Enforcement Action,"
section of this report.
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Present on July 23, 1976 only.
- Present on July 30, 1976 only.
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Prepared by
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DETAILS _
Reviewed by NcJ :% f f
P.J.Knapp\\\\\\
SECTION I
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1.
Persons Contacted
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K. Beale, Radiation Protection Supervisor R. Dubiel, Engineer - Nuclear II K. Frederick, Chemistry Supervisor
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R. McCann, Radiation Protection Foreman
C. Nixdorf, Office Supervisor i
J. Romanski, Supervisor - Radiation Protection and Chemistry 2.
Scope of the Inspection This was an incpection of 45 SSIP elements specifying time in-
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tervals over the period July 1, 1975 through June 30, 1976. The inspection also included observations of current conditions during the inspection.
3.
Plant Records and Procedures The inspector reviewed the following records and procedures for the periods or revisions indicated and found that they appeared g
to be acceptable, except as shown in the referenced paragraphs
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of the report.
a.
Plant Records
Radiation Work Permits (RWPs) for July 1,1975 through July 20, 1976.
(See Details 6 this Section)
Survey records for July 1,1975 through June 30, 1976.
l Personnel exposure records for July 1, 1975 through June 30, i
1976.
I Forms NRC-4 and NRC-5 (not segregated by dates of completion).
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Reports of exposures of individuals terminated during the period January 1,1976 to May 28,1976.
Semiannual report of radioactive effluents and solid waste for the period July 1, 1975 to December 31, 1975.
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Records of purges and releases of radioactive gases between July 1, 1975 and June 30, 1976.
(See Details 10 this Section)
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Records of radwaste shipments for the period July 1, 1975 to December 31, 1975.
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Record of Unmonitored Release Path Analysis for the period July 1, 1975 through June 30, 1976.
(See Details 7 this Section)
Records of radioactive liquid releases during the period
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July 1, 1975 through June 30, 1976.
Weekly surveillance check sheets for effluent monitors during January 1, 1976 through June 30, 1976.
Quarterly calibration checks of effluent monitors during December 1975 through July 23, 1976.
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l Check sheets for monthly and quarterly surveillance of emergency equipment during January 1976 through March 1976.
Records of reactor coolant activity, and of E-bar determina-()
tions during January 7, 1976 through June 30, 1976.
(See
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Details 9 this Section)
b.
Plant Procedures
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- Procedure Number Title or Topic Revision Numbers AP 1003 Radiation Protection Manual 6, 7 CA 1104-43 Nuclear Plant Sampling
CP 1908 Determination Chlorides 2, 3 CP 1909 Determination Fluorides 2, 3 CP 1910 Determination Dissolved Oxygen 0, 1 CP 1950 Determination Gross Beta 1, 2 CP 1950.3 Determination Gross Beta, Reactor Coolant
CP 1951 Determination of Tritium
CP 1958 Gamma Spectrometry
C" 1958.3 Gamma Spectrometry (CRAM)
CP 1959 Determination of E-Bar
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HPP 1602 Radiation Surveys 1, 2 HPP 1603 Neutron Surveys 1, 2 HPP 1604 Alpha Surveys 2, 3 HPP 1605 Air Sampling - Particulate 2, 3 HPP 1606 Air Sampling - Iodine 1, 2 HPP 1607 Air Sampling - Radioactive Gas 1, 2 HPP 1608 Air Sampli6g - Tritium 1, 2 HPP 1609 Surface Contamination Surveys
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HPP 1610 Establishing and Posting Areas 2, 3 HPP 1612 Monitoring for Personnel Con-tamination 2, 3 HPP 1613 Radiation Work Permits 3, 4 HPP 1615 Use of Personnel Monitoring
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HPP 1618 Radioactive Material Shipments 1, 2 HPP 1620 Radiation Control for Solid Waste 1 HPP 1621 Releasing Liquid Radwaste 3, 4, 5 HPP 1622 Releasing Gaseous Radwaste 7, 8, 9, 10 HPP 1629 HP Procedure - Liquid Waste
HPP 1631 Sampling Waste Gas Holding Tanks
HPP 1675 Radioactive Release Record
HPP 1676 Rad-Protection Responsibilities
for Planned and Unplanned Releases HPP 1776 Sampling Unmonitored Release Paths 0 O-HPP 1778 Emergency Equipment & Inventory
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RM 1105-8 Radiation Monitoring System
SE 1104-50 Sludge & Industrial Waste 0, 1 SP 1301-4.7 Weekly Check-Vent Monitors 3, 4 SP 1301-5.4 Emergency Equipment Check
SP 1301-5.9 Sampling Condenser Vacuum Pump Release
SP 1301-6.4 Ralease of Radioactive Gases
SP 1302-3.1 Quarterly Radiation Monitor Checks 12, 13 SP 1303-4.15 Monthly Checks of Radiation Monitors 6. 7 WDG 1104-27 Gaseous Waste Disposal 4, 5 WDS 1104-28 Waste Disposal System 0, 1
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- AP - Administrative Procedure
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CA - Chemistry Procedure CP - Chemistry Procedure HPP - Health Physics Procedure RM - Radiation Monitor (Operations) Procedure SP - Surveillance Procedure SE - Surveillance (Environmental) Procedure WDG - Waste Disposal (Cas) Procedure WDS - Waste Disposal (Solid) Procedure
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4.
Status of Facility The reactor was operating at nominally 1007. of the licensed power level during this inspection.
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Control of Access to Radiation Areas and Hich Radiation Areas
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Part of the inspection effort was to observe access controls to radiation areas and high radiation areas to verify compliance with requirements of 10 CFR 20,203 and TS 6.13.
Access controls
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were previously inspected on March 15-17, 1976 during a refueling
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outage and no items of noncompliance were identified.
(Inspection Report No. 50-289/76-07, Details 7)
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.. t Radiation Areas, Contaminated Areas and Radioactive Materials a.
Areas
A requirement of Technical Specification section 6.11 is that radiation protection procedures shall be prepared consistent with the requirements of 10 CFR 20 and shall be approved, maintained and adhered to for all operations involving per-sonnel radiation exposure.
Procedure HPP 1613, " Radiation Work Permits," developed ()
pursuant to the above, requires all personnel to be authorized by and logged in on RWPs prior to entries into areas posted with signs indicating: " CAUTION:
Radioactive Fbterials, Airborne Contamination, High Radiation Area, Radiation Area, and Contaminated Area."
During a tour of the facility an individual who was not authorized by a RWP was observed in a posted and roped-off radiation area on the 281 foot elevation of the Auxiliary
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i Building at 2:50 p.m. on July 20, 1976.
Three individuals who had failed te log their reentry were observed in a posted and roped-off radioactive materials area at 2:57 p.m. on July 20, 1976, under RWP No. 08521.
The inspector identified the above as an item of noncompliance with the referenced requirements.
The licensee representative immediately instituted a briefing for the personnel involved.
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b.
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Requirements of 10 CFR 20.203.c(2) and T1 6.13.1.b include
l provision of barricades and locked doors to prevent unautho-rized entry into high radiation areas, and establishment
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of these controls in such a way that no individual will be
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prevented from leaving a high radiation area.
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During a tour of the facility three padlocked temporary doors were observed, at the decant slurry pump room and makeup system valve alley ent.rances.
t The licensee representative stated that precautions were taken to avoid locking personnel in these areas and that I
permanent doors were to be installed which would snap locked when closed but would always allow easy egress from the high radiation area.
The licensee representative stated that the temporary doors were installed to avoid noncompliance until the permanent doors were installed.
The inspector reviewed the licensee's documentation (job order) for installation of the three doors.
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The inspector observed measurements of radiation levels at several locations in the facility which verified that radia-tion areas and high radiation areas were identified and properly controlled.
The inspector has no further questions on this item at this time.
The permanent doors will be inspected when completed.
6.
Procedures and Records on Management of Personnel Exposures Part of the inspection effort was to observe work in progress (See Details 5.a this Section) and to review procedures and records necessary for management of personnel exposures.
Review of RWP records for compliance with requirements of TS 6.11 and HPP 1613 " Radiation Work Permits," included a detailed review of 200 RWP's.
Seventeen were found to lack entries required by
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the procedure.
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The follouing ten RWPs lacked entries identifying the job foremen responsible for the workers on these jobs:
Nos. 7009, 7061, 7186, 7213, 7634, 7649, 7674, 7714, 7719 and 7724.
The following seven RWPs lacked entries identifying the initiator responsible for the job: Nos. 5164, 7029, 7061, 7503, 7634, 7714 and 7724.
l The following five RWPs lacked one or moie of these entries -
authorization signatures, radiation level on the job, and com-pletion signature: Nos. 4982, 5100, 5107, 5145 and 5164.
i Othr.r questions on RWPs were resolved by discussion with the licensee representative.
The inspector identified the seventeen RWPs listed above as exam-ples of noncompliance with the referenced requirements.
f 7.
Sampling of Unmcaitored Release Paths
.j Part of the inspection effort was to verify that licensee's sam-pling of unmonitored release paths indicated that 10 CFR 20 and Technical Specification limits on releaces were not being ex-()
ceeded, and that no unidentified releases were occuring by these paths.
Procedure HPP 1776, " Sampling of Unmonitored Re-lease Paths," required monthly samples from eight points about the facility, one being the sewage system.
(The sewage has been trucked out to date because the processing facility is not fully operational.)
f A review of the records indicated that only one monthly sample had been obtaineel of the sewage system during the twelve month period July 1, 1975 through June 30, 1976, and that none of the required eight semples was taken during February 1976.
The inspector identified the above as an item of noncompliance with the Technical Specification and referenced procedural require-ment. No detectable releases were identified by the available information on unmonitored release paths.
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Checking of Emergency Radiation Instruments A record review was made to verify that during January through March 1976 there was an approved procedure and routine checks were performed in accordance with the requirement of Technical Specification Table 4.1-1 item 35 for monthly checks of emer-
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gency radiation instrument batteries.
I Review of Unit i Surveillance Procedure 1301-5.4, Revision 3, December 9, 1974 and the completed checksheets verified that the required procedures and checks were in order.
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The inspector has no further questions on this item.
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9.
Reactor Coolant Activity Part of the inspection effort was to verify by a review of pro-f cedures and records of required periodic determinations that reactor water activity did'not exceed the limits required by
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TS 3.1.4.1 during April through June 1976.
The limit for gamma I
emitters is a function that varies inversely with E-bar, the average energy of emissions, and a requirement of the above ()
referenced technical specification is to include >95% of the gamma activity of the sample in the calculation of E-bar.
It was lh noted that the licensee's records used all of the gamma emitters that were identified in the measurement for the E-bar calcula-tion, but no evaluation or specific criterion was provided that positively assure that >95% of the gamma activity had been iden-tified.
i The inspector's review indicated that acceptable procedures and equipment were provided, which were typical of the industry,
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and that the activity of the reactor coolant typically was below l
25% of the limit.
No item of noncompliance was identified. The inspector has no further questions on this item at this time.
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10.
Procedures, Records and Reports on Control, Processing and Dis-I posing of Radwastes i
Part of the inspection effort was to verify by a review of pro-cedures, records and reports that management of radwaste gases, liquids, solids and sludge complied with regulatory requirements during the period July 1, 1975 through June 30, 1976.
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No problems were identified with compliance to limits or quanti-ties, concentrations and rates of releases of radioactive materials.
The licensee representative had previously identified an error in a gaseous release record but failed to indicate on that record what quantity had been included in the total shown in the semi-annual report.
The licensee representative corrected the record during the inspection.
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No other problems were identified.
l This licensee does not bury or incinerate radioactive materials.
11.
Procedures, Records and Reports on Control of Personnel Exposures Part of the inspection effort was to verify that procedures, records and reports were properly maintained for control of per-sonnel exposur-s.
Procedurec, records and reports were reviewed
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covering ths following subjects:
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a.
Area surveys.
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b.
Radiation Work Permits (RWPs).
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Dosimetry records.
d.
Forms NRC-4 and NRC-5.
Licensee reports to terminated individuals.
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Required licensee reports to NRC of exposures.
Telephone checks were made to verify that recent reports to NRC were received.
Telephone checks were also made with three in-dividuals of a total seven individuals selected to be contacted
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l to verify that licensee reports were made to those who were termin-ated.
No negative replies were given, however four indiv.i als
were not contacted in three attempts made during:
(1) normal
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working hours; (2) evening; and (3) Saturday.
Problems with controls are given in. Details 5 and 6.
No other problems were identified, k_.)
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Procedures and Records on Chemical and Radiochemical Sampling, Testing of Monitors, and Monitoring of Releases Part of the inspection effort was to review procedures and records on sampling and monitoring of coolant and of radio-active effluents.
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An apparent audit problem was identified in that the input to the computer had shown a January 3, 1975 completion date for a required weekly surveillance check that actually was done on January 3, 1976, and no problem was indicated by the computer printout. A review with the cognizant individual evealed that the computer program did not audit individual completion dates but audited only the date when these items were processed into the computer.
The longhand record was corrected during the inspi.ition and the cognizant individual stated that the computer record would be corrected.
No item of noncompliance was identified.
The ir ector has no further questions on this item.
13.
Review of Air and Vent Monitors and Radwaste Systems In addition to reviewing surveillance checks and management of radwaste (Details 10 and 12) the inspector reviewed licensee event reports and PORC reviews of reportable occurrences and maintenance l
problems to verify that any necessary corrective maintenance to the radwaste systems during the perio'd February 1 to 29, 1976 were carried out.
Licensee's event reports dated February 5 and 26,1976, dis-cussed problems involving operational oversights that tempor-
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arily affected the function of an air particulate monitor on I
February 4, 1976 and a flow recorder and alarm on February 19, i
1976. No excessive releases or conditions developed because of these problems.
Acceptable corrective action was reported, and was verified by Inspection No. 50-289/76-10 (Detail. 3.b. (1) and (2)).
No other problems were identified.
The inspector has no further questions on tl.is item.
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Review of Licensee's Instructions to Individuals Entering a Restricted Area A requirement of 10 CFR 19.12, " Instructions to Workers" is that all individuals working in or frequenting any portion of a re-stricted area shall be informed of specified conditions, health protection problems, Commission regulations and other topics e
l applicable to the area.
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Inspection was directed to the licensee's instructions to a
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television team that had entered the restricted area.
The li-censee representative stated that the applicable procedure did not specify what was required for personnel who were not Metro-politan Edison Company employees and in this case oral instruc-tions were given by personnel who escorted these visitors con-tinuously while on site.
l The inspector reviewed the procedural requirement (AP 1003
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sections 3.0 to 3.4) and noted that the instructions to be given
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to visitors and contractors were not specified.
The inspector asked how management was assured that adequate training was pro-vided.
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The licensee representative stated that incoming personnel were given instructions appropriate to their needs based on a review prior to admitting the newcomers to the site, and records are being kept of training provided individuals who are allowed in the controlled area without an escort.
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i The inspector has no further questions on this item.
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Prepared by _ f'M i
R. L. Spe sard (]
Reviewed by
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A. B. Davis j
DETAILS SECTION II l
1.
Persons Contacted
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Mr. T. Book, Control Room Operator l
Ms. R. Brown, Technical Analyst III Mr. W. Cotter, Supervisor, Quality Control
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Mr. J. Herbein,Ibnager, Generation Operations - Nuclear Mr. M. Johnson, QC Assistant Mr. R. Klingaman, Fbnager, Generation Engineering Mr. G. Kunder, Supervisor, Operations I
Mr. L. Lawyer, Manager, Operational Quality Assurance Mr. B. McCutcheon, Quality Assurance Engineer j
Mr. G. Miller, Unit Superintendent Mr. J. Moran, Engineer II
,
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Mr. J. O'Hanlon, Engineer, Senior I - Nuclear
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Mr. W. Potts, Section Head - Licensing Mr. M. Shatto, Engineer, Associate I Mr. G. Wallace, Shift Supervisor 2.
Station Manning Requirements (]
The inspector reviewed the following records to verify that
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licensed operators were at the station during the period of March 1 through June 30, 1976 as required by Technical Speci-fication 6.2.2.b.
a.
Daily Attendance Sheets.
E.
Monthly Time Reports for SRO's.
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c.
Control Room Operators Log Book.
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d.
Shift Assignment Sheet.
c.
Shif t Schedule for December 1975 - December 1978.
Findings were acceptable.
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Additionally, discussions were conducted with licensed operators on July 23, 1976.
Based on these discussions and the above review, the inspector determined that the station was manned as required l
by T.S. 6.2.2.b on July 23, 1976 and that procedures existed to l
ensure continued compliance with this requirement.
3.
Shutdown Marcin Requirements
,
The inspector reviewed the following records to verify that the-available shutdown margin of the core during the period of April 1 through June 30, 1976 was equal to or greater than 17. delta K/K as required by Technical Specification 3.5.2.1.
a.
Station Daily Log Sheets.
I I
b.
Shutdown Margin Calculation per OP 1103-15, Revision 13.
i Findings were acceptable.
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j 4.
Exceeded Safety Limits Action The inspector reviewed licensee event reports for the period of
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July 1, 1975 through June 30, 1976 and determined that no safety ()
limits had been exceeded. Additionally, discussions were conducted with the licensee on this subject, and the inspector was informed that no safety limits had been exceeded during this period. There-fore, the requirement of Technical Specification 6.7 governing
,
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licensee action if a safety limit is exceeded was not required to be performed.
5.
Procedural Adherence The inspector reviewed 226 Nonconformance Reports and 10 Audit Reports covering activities for the period of March 1 through June 30, 1976 to determine if failure to follow nuclear safety-related procedures was involved.
From the information contained in the NCRs and Audit Reports, the inspector determined that 28 cases of failure to follow procedures related to nuclear safety had been identified by the licensee (25 were NCRs and 3 were audit findings).
Each of the cases were identified to the licensee, and the licensee concurred with the inspector's findings.
These cascs are in non-compliance with Technical Specification 6.8.1, and this is an Infraction.
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-19-The licensee's actions to correct these Items of Noncompliance their recurrence had either been completed or were and to prevent in progress consistent with the requirements of the OQA Program.
These actions are acceptable, and no response to this item is required.
l 6.
Plant Operations Review Committee (PORC)
The inspector reviewed PORC activities for the period of
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a.
January 1 through June 30, 1976.
This review consisted of the following:
(1) PORC minutes of meetings 324 through 341 covering the PORC minutes period of March 1 through July 2, 1976.
of meetings 315-323 covering the period of January 2 through February 29, 1976 were reviewed during a pre-vious NRC:I Inspection (Report No. 50-289/76-10, De-tail 10).
(2)
Superintendent's Ops. Memo No. 6, Revision 5 (September i
5, 1975), Revision 6 (January 31, 1976) and Revision 7
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(February 10, 1976).
( )'
(3) Discussions with the PORC Chairman and Secretary and
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other members of the plant staff.
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The inspector's findings with respect to adherence to Techni-b.
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cal Specifications (TS) were as follows:
(1) PORC membership was in accordance with TS 6.5.1.2 during the period of January 1 through June 30, 1976.
(2) PORC meeting frequency and quorum requirements were in accordance with T_S 6.5.1.4 and 6.5.1.5 during the period of March 1 through June 30, 1976.
(3) A total of 22 new procedures and 115 changes to existing procedures were approved for implementation during the
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j period of May 1 through June 30, 1976.
PORC review of
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these items was in accordance with TS 6.5.1.6.a.
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I (4) No tests and experiments were conducted during the period of May 1 through June 30, 1976.
Therefore, the requirement of TS 6.5.1.6.b.1 governing PORC review
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j relative to an unreviewed safety question was not re-quired to be performed.
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(5) PORC review of significant operating abnormalities and indications of unanticipated deficiencies in nuclear safety related structures, components or systems that-occurred during the period of May 1 through June 30, 1976 was accomplished pursuant to TS 6.5.1.7.b.
t f
(6) PORC review of reportable occurrences that occurred during the period of March 1 through June 30, 1976 (total of 14) was accomplished pursuant to TS 6.5.1.6.e.l.
(7)
PORC review of violations of TS or Operating License and violations of applicable federal statues, codes, regulations and internal station procedures and instruc-i tions having nuclear safety significance that occurred during the period of March 1 through June 30, 1976 was not accomplished in all instances pursuant to TS 6.5.1.6.e.
Items requiring PORC review and the action taken and/or planned by the PORC were'as follows:
(a)
The 10 items identified in NRC:I Inspection Reports 50-289/ 76-07, 76-08, 76-09, 76-10, 76-11 and 76-13 were reviewed by the PORC.
(b) Audit Report 76-02 identified noncompliance with AP
,
1025. Audit Report 76-05 identified noncompliance with the 0QA Plan in the area of QA records control at the corporate office. Audit Report 76-06 identi-fied noncompliance with AP 1001. Audit Report 76-07
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identified noncompliance with the 0QA Plan in the area of document control at the corporate office.
Audit Report 76-09 identified noncompliance with AP i
1016.
The items of noncompliance identified in Audit Re-ports 76-02, 76-06 and 76-09 were previously addres-sed in Detail 5 of this section of this report.
The items of noncompliance identified ta Audit Reports
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O-21-l
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i 76-05 and 76-07 represent violations of 10 CFR 50, Appendix B, Criterion XVII and Criterion VI, respec-tively and the FSAR, Appendix 1A, Operational Quality Assurance Plan Sections 22 and 11, respectively.
These items are Deficiencies.
The licensee's actions to correct the-items of noncompliance and to prevent their recurrence had either been completed or were in progress consistent with the requirements of the OQA Program. These actions are acceptable, no response to these items is required.
PORC review of the above items was neither accom-plished nor scheduled for accomplishment as of July
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21, 1976.
This is an item of noncompliance with TS 6.5.1.6.e, and this item, (when taken with the other
example as listed in subparagraph (c) below,) is an Infraction.
During this inspection, PORC review of these items was accomplished on July '.2, 1976 (Meeting No. 344).
Additionally, the PORC Cha irman stated, t
that to prevent recurrence, all future audit reports would be reviewed to determine if audit findings
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delineated therein warranted PORC review pursuant to TS 6.5.1.6.e and that those audit findings so identi-(~)
fied would be included in the PORC's existing out-standing action items review program.
The licensee's
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actions to prevent recurrence are acceptable and no response to this item is required.
(c)
Items of noncompliance identified in 25 NCRs were previously addressed in Detail 5 of this section of this report.
These items represent violations of TS 6.8.1, and they related to nonadherence to AP 1001, AP 1010, AP 1011, AP 1012, AP 1016, OP 1104-43, Si'
1301-1 and Standing Procedure 1410-Y-30.
Additionally, 12 other NCRs identified nonadherence to GP 0026, GP 1008 and GP 4409 which are implementing procedures of the OQA Plan.
These represent violations of 10 CFR 50, Appendix B, Criterion V and the FSAR Appendix 1A, Operational Quality Assurance Plan Section 10, and this is an Infraction.
The licensee's actions to correct the items of. noncompliance and to prevent recurrence had either been completed or were in progress consistent with the requirements of the OQA Program.
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M i410 !l9
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i These this it i
PORC re I
9 of
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the view of
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plished an Item.
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this item
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listed
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in
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These NCR
283, 76-25
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l 76-213, 76 170, 76-16 c
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76-133, 76-
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The PORC C
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above would The licensee this same
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tion (Reportre p-
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by letter dat
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the
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correctiv
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this item in
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The inspector mented the letter in act tified in theearly ceiv d PORC re r
e j
viously discuss
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to the time wh
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~j correctiv
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reviewed, actio-e the isolated instan on
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PORC based on e
Control.
l eva tional m The POR easur, t
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f discussed at a e
cases th sub members. e NCR 's go of No The licen ncompliance table, and no an<
respo l
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(4) CTSS review of violations of TS and license requirements and violations of applicable federal statues, codes, regu-lations, orders and internal station procedures and instruc-tions having nuclear safety significance that occurred during the period of March 1 through June 30, 1976 (total of 52 which were previously identified in Detail 6.b. (7)
of this section of this report) was accomplished pursuant to TS 6.5.2.A.2.e and f.
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(5)
CTSS review of proposed changes to the TS and Operating License submitted to the NRC during the period of January
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1 through February 29, 1976 was accomplished pursuant I
to TS 6.5.2.A.2.d.
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8.
General Office Review Board (GORB)
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The inspector reviewed GORB activities for the period of April l
a.
1 through June 30, 1976.
This review consisted of the following:
(1) GORB minutes (Draf t) of meeting 23 conducted on June 7, 1976.
(2)
GORB minutes of meeting 22 conducted on March 9, 1976.
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Discussions with site personnel and CTSS members.
b.
The inspector's findings with respect to adherence to Technical Specifications (TS) were as follows:
(1) The Unit Superintendent, PORC Chairman, Manager, Generation Engineering and Manager, Generation Operations - Nuclear, did not deem it appropriate to refer any proposed changes
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to procedures, equipment, or systems to the GORB for their review during the period April 1 through June 30, 1976. Therefore, the requirement of TS 6.5.2.B.7.a was not required to be performed.
(2)
CORB review of operating abnormalities and deficiencies in design or operation of nuclear safety related equip-ment relative to an unreviewed safety question identified during the period of April 1 through June 30, 1976 was accomplished pursuant to TS 6.5.2.B.7.d.
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9.
Reactor Building Ring Girder Inspection I
Reference: Met Ed letter to NRC:I, dated July 9, 1976.
The above reference reported that the third inspection of the
Reactor Building ring girder, which was begun on April 20, 1976, was satisfactorily completed on July 2, 1976 after encountering many delays.
TS 4.4.2.2.A required this inspection to be com-
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pleted within 2 years after the Structural Integrity Test (com -
pleted March 9, 1974).
Additionally, TS 4 permits specified intervals to be adjusted plus or minus 25% to accomodate test
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schedules.
In this case the test interval is one ' year between l
the second, third and fourth inspections; therefore, the allowed adjustment is plus or minus 3 months.
Therefore, the third l
inspection was required to be completed during the period of j
l December 9, 1975 - June 9, 1976, and as reported in the above i
reference, the inspection was about 75% complete on June 9,1976.
Failure to complete the third inspection of the Reactor Building ring girder within the required inspection interval as previously described is contrary to TS 4.4.2.2.A.
This Item of Noncompliance
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f is an Infraction.
This matter was discussed with members of the plant staff and the CTSS since the, referenced letter reported
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that no violation of the Technical Specifications had occurred.
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The inspector observed that this item had been reviewed by the PORC pursuant to TS 6.5.1.6.e and the CTSS pursuant to TS 6.5.2.
A.2.e. and f.
Additionally, actions to prevent recurrence con-sisted of counseling responsible personnel relative to completion
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of surveillance tests within the required interval and the issu-
,
ance of an Action Item request from the Manager, Operational Quality Assurance to the Manager, Generation Operations - Nuclear i
regarding the completion requirements for the next Reactor Building ring girder inspection.
The actions taken by the licensee are acceptable, and no response to this item is required.
10.
Previously Reported Unresolved Items CTSS Review of Facility Procedure Changes a.
Reference: NRC:I Inspection Reports 50-289/76-01, Detail 14.b. (4) and 50-289/76-10, Detail 13.a i
1418 122
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l Based on review of memoranda from the Manager, Generation Engin-
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I eering to the Unit 1 Superintendent concerning procedure changes (PCRs) made during the period of November 1 through December 31,
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1975, the inspector determined that CTSS review had been completed on 66 of the 71 changes.
The 5 remaining PCRs requiring CTSS
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review are 75-435,75-433, 75-410,75-409 and 75-472 and these
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have been assigned for review via the Generation Engineering Task
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This item remains unresolved pending completion by the System.
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licensee.
The above referenced reports delineate CTSS review of PCRs' covering'
1974, 1975 and 1976.
The inspector reviewed applicable records concerning these activities and had the following findings:
(1) QA closed their audit finding on May 12, 1976.
(2) As of July 26, 1976, 64 of 88 PCRs from the existing backlog which were deemed to have a significant affect on plant opera-tions had been reviewed by the CTSS.
Assignment and review of the remaining 24 PCRs on a priority basis was continuing.
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I (3) Weekly review of the status of the backlog by the Manager, Generation Engineering was continuing.
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(4) The PCR status as of July 23, 1976 was as follows:
l (a) For 1974, of the 514 PCRs generated, 252 had been re-viewed, 71 had been assigned for review, and the re-l maining 191 had not been assigned.
l (b) For 1975, of the 542 PCRs generated, 339 had been re-viewed, 55 had been assigned for review, and the re-
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maining 148 had not been assigned.
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(c) For 1976, of the 415 PCRs generated, 291 had been re-viewed, 74 had been assigned for review, and the re-l maining 50 had not been received from the site.
The licensee is continuing to meet the commitments made to NRC:1.
This matter will continue to be reviewed during subsequent inspec-tions.
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-27-GORB Review of Nonroutine Event Report ER 76-10/3L b.
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Reference: NRC:1 Inspection Report 50-289/76-10, Detail 3.b.(6)
GORB review of the subject report was accomplished during meeting 23 conducted on June 7, 1976.
This item is resolved.
GORB Review of Proposed TS Changes 29 and 32 c.
Reference:
NRC:I Inspection Report 50-289/76-10, Detail 8.b.(4)
GORB review of the subject TS changes was accomplished on January 7, 1976 and June 7, 1976. This item is resolved.
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GORB Review of Violations of TS and License. Requirements d.
Reference:
NRC:I Inspection Report 50-289/76-10, Detail 8.b.(4)
i GORB review of violations of TS and license requirements i
occuring during the period of January 1 through March 31, 1976 was accomplis'.ed during meetings 22 and 23 for those items delineated in Event Reports ER 76-3, 76-6 and 76-8 and NRC:I Inspection Reports 50-289/76-01, 50-289/76-02 O
and 50-289/76-07.
GORB Review of these items delineated in NRC Inspection Reports 50-289/76-03 and 50-289/76-08 had not been completed. This item remains unresolved pending completion by the GORB.
Items 11.
Corrective Action for Previously Identified Enforcement a.
NRC:1 Inspection Report 50-289/76-01, NRC:1 letters dated February 27 and April 1, 1976 and Met Ed letter dated March l
22, 1976.
Apparent Infraction The GORB reviewed this infraction and the intended correc-i tive and preventive actions during meeting 22 on March 9, 1976.
A review of the Draft minutes of CORB meeting 23 conducted on June 7, 1976 and discussions with members of the CTSS revealed that the GORB had not reviewed the Items 1413 124
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i of Noncompliance delineated in NRC:I Inspection Reports l
50-289/75-01, 75-04, 75-06, 75-08, 75-13, 75-14, 75-15, 75-20 and 75-23 in accordance with the commitments stated
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I in the referenced Met Ed letter.
i The Manager, Operational Quality Assurance stated that a GORB review of these items would be accomplished, but he was unable to provide a date by which this would be com-pleted.
The inspector expressed concern that Met Ed had failed to meet their stated commitments relative to correc-tive action for an Item of Noncompliance and that this matter was apparently unknown to Met Ed management until identified by the inspector.
The Manager, Operational Quality Assurance acknowledged the inspector's statements and stated that he could not address this matter since
the GORB is advisory to the Company President. The in-spector stated that this matter would be addressed in the NRC:I documentation letter for this inspection, and that a response would be requested.
,
The inspector reviewed the system established by the Manager, Operational Quality Assurance as delineatad in the referenced Met Ed and NRC:I correspondence (preventive actions) and ('}
found that the system had been implemented in accordance
, '
with Met Ed's commitments.
For example, the Items of Non-
. compliance delineated in NRC:1 Inspection Reports 50-289/
76-07, 76-10, 76-11 and 76-13 had been sent to the GORB l
Chairman by the Manager, Operational Quality Assurance via a Work Item Request. The inspector had no further questions on this matter at this time; however, the inspector in-formed the Manager, Operational Quality Assurance for infor-mation purposes that the system could be enchanced, if it
,
had a loop closing feature, i.e.,
the receipt of and the completion of Work Items are not tracked by the current system.
b.
NRC:I Inspection Report 50-289/76-10, NRC:I letters dated May 24 and June 30, 1976 and Met Ed letter dated June 14,
.
1976.
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(1) Apparent Infract!on A
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The P',RC has revised their methods of tracking and closing outstanding action items.
The new method in-cludes a closecut form for each item. The form is signed by the PORC Chairman when the action item is closed, and the form provides by reference the basis for closure.
This system has been implemented since PORC meeting 334 conducted on May 10-16, 1976.
Addi.
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tionally, the corrective action delineated in ER 76-03/
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l 10 and ER 76-8/40 relative to revision of procedures,
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which had been incorrectly closed by the PORC as pre-viously reported, was observed by the inspector to be satisfactorily completed in accordance with the licensee's conmitments documented in Details 3.b. (1)(a) and 3.b.
(2) of the referenced report.
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(2) Apparent Infraction B The licensee's actions were reviewed and found to be
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complete, as previously documented in Detail 6.b.(7)(c)
of this section of this report.
l I
("N This completes the licensee's corr'ective action for these Items
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of Noncompliance.
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