IR 05000289/1977035
| ML19256D133 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/09/1977 |
| From: | Davis A, Kellogg P, Napuda G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19256D116 | List: |
| References | |
| 50-289-77-35, NUDOCS 7910170611 | |
| Download: ML19256D133 (11) | |
Text
-
..
U.S. NUCLEAR REGULATORY COMMISSION
,o 0FFICE OF INSPECTION AND ENFORCEMENT Region I Report No.
50-289/77-35 Docket No.
50-289 C
License No. DPR-50 Priority Category
--
Licensee:
Metropolitan Edison Company P. O. Box 542 j
.
l Reading, Pennsylvania 19603
'
Facility Name: Three Mile Island Nuclear Station, Unit 1 j
Inspection at:
Middletown and Reading, Pennsylvania
,1977 Inspection conductad: N mber
-
!
Inspectors:
f P
_
/
4'ffy c
Ins date Signed B N
<
pector il/-,.,
{
P.
O G. Na udd, Reactor Inspector da'te' si g'ned W
./
dk7 Approved by:
/
A. B. Day 1s, Lnlet, Keactor erojects Section date signed No. 1, RO&NS Branch
.
Insoection Summary:
I spection on November 7-10,1977 (Report No. 50-289/77-35)
' Areas Inspected: Routine, unannounced inspection of procurement control; QA program review; QA audits; records and drawings; and licensee action on previous inspection findings.
The inspection involved 129 inspector-hours onsite by three NRC inspectors and accompanying personnel.
Results: Of the six areas inspected, no items of noncompliance were found in four areas; two apparent items of nonexnpliance were identified in two areas (deficiency - failure to provide proper record storage - Paragraph 7; deficiency -
failure to maintain drawing control - Paragraph 7.b).
}44b \\b
<s -
[f1 Region I Form 12 s
(Rev. April 77)
79101W
'
o t
._
_
--
-. _ -
-
-.
-..
-.
-
--
..-.-
_._.
--
- -. -.
{
.
.
'
O J
,
DETAILS I
1.
Persons Contacted I
Mr. S. Bailey, Mechanical and Systems Engineer
'
Ms. R. Brown, Technical Assistant - Generation
- Mr. W. Cotter, Supervisor of Quality Control Mr. R. Doty, Stores Supervisor
- Mr. C. Hartman, Lead Electrical Engineer
- Mr. J. Herbein, Vice President - Generation Mr. D. Hosking, QC Assistant
- Mr. R. Klingaman, Manager - Generation Engineering Mr. G. Kunder, Supervisor of Operations Mr. G. Loignan, Quality Assurance Engineer Ms. K. McKently, File Clerk Senior Mr. L. Noll, Shift Foreman
- Mr. J. O'Hanlon, Unit Superintendent
,
- Mr. W. Fctts, Supervisor of Licensing
,
'
- Mr. R. Prabhakar, Supervisor - Quality Assurance Mr. M. Shatto, PORC Secretary O
- Ms. J. Shirls, Technical Assistant - Generation
- Mr. G. Troffer. Manager - Operational Quality Assurance denotes those present at exit interview on November 9,1977.
<
- denotes those present at exit interview on November '0,1977.
Other Accomoanyina NRC Personnel D. A. Beckman, Reactor Inspector 2.
Licensee Action on Previous Insoection Findings (0 pen) Unresolved item (289/77-29-01): Status of open Nonconformance Reports (NCRs).
As of October 31, 1977 the licensee has closed 62 previously open NCRs and has significantly reduced the total number
'
!
from 82% as of September 30, 1977 to less than 65%.
The inspector i
examined 18 open NCRs on a sampling basis and verified that imediate corrective actions had been taken with subsequent follow-up and loop closing remaining to be accomplished.
In addition the licensee has revised Generation Procedure GP-4012, Nonconformance Reports and Stop Work Orders, to include a viable mechanism for folicw-up actions on overdue nonconformance reports.
This procedure is expected to be issued and implemented by December 1, 1977.
L.
}O4b
~
.
-
.
-
-
-
.
..-
-
-.-
-
.--
-.
.
.
!
O,
~.
This item remains unresolved pending implementation of procedure GP-4012 and subsequent actions by the licensee.
3.
Procurement Control i
a.
References
!
10 CFR 50, Appendix B, Criteria IV, VII, VIII, XV.
--
l TMI Operational Quality Assurance Plan, Rev. 6.
--
GP 1009 Procurement Document Control, Rev.1.
--
.
l GP 1011 Preparation, Changing and Issuance of Specifications
--
and Bills of Materials, Rev. 1.
j
'
i GP 1016 Vendor Evaluation and Selection, Rev. O.
--
.
.
GP 1022 Handling, Storage and Shipping Requirements, Rev. 2.
--
GP 1008, Quality Assurance Systems List, Rev.1.
--
Oc
_
GP 4005, Review of Procurement Documents, Rev. 2.
--
GP 4008, Receipt Inspection of Material and Equipment, Rev. 4.
--
GP 4010, Approved Vendors List, Rev. 1.
i
--
b.
Procurement Document Review
'
The inspector selected and reviewed the seven recantly purchased safety-related items listed below to verify the procurement specifications utilized to purchase the components or materials included proper approval, QC inspection requirements, and QC record requirements:
P.O. 32408, Spare Parts for DH-P-1A/B
--
P.O. 3854, Fuses for Emergency Diesel Generators
--
P.O. 32104, Spare Parts for 480v Motor Control Centers
--
P.O. 31961, Spare Parts for ASCO Solenoid Air Valves
--
P.O. 31817, Spare Parts for 480v Motor Control Centers
--
'
}d4b bb
_
__
._
_
. _
_
_
-_
..
.
I
o.j
~
'
P.O. 16020, Safety Valve for ICC System
--
P.O. 22338, Weld Electrodes
--
The inspector additionally verified for the Purchase Orders listed above that:
l
-
i documentary evidence is available onsite to support
--
equipment conformance to procurement requirements; l
the spare pi ts, components or materials were inspected
--
'
upon delivery;
!
the spare parts, components or material were being handled
-
--
in accordance with measures established for control and separation of conforming and nonconforming materials,
'
parts and components; and the spare parts, components or materials were supplied by
--
l an approved vendor.
I No items of noncompliance were identified.
i.
4.
Quality Assurance Program Review I
The inspector reviewed the changes made to the Operational QA Plan i
I and the implementing administrative procedures since the last NRC
'
QA inspection during October 1976.
The revisions were reviewed for consistency with the licensee's FSAR conmitments and 10 CFR 50, Appendix B criteria.
The procedures listed below were selected as a sample and reviewed:
AP 1021, Plant Modifications, Revision 0
--
GP 1003, Control of Design Change / Modifications, Revision 3,
--
Change 2 GP 1008, Quality Assurance Systems List, Revision 1, Change 4
--
GP 1012, Numoering System for Generation Division Drawings,
--
Revision 0 GP 1015, Preparation, Approval, and Revision of TMI Drawings to
--
Show As-Built Conditions, Revision 2 y Q(3
,Y s
_
.. -...
... _
__ __
_
I
.
.
-
O
,
-
GP 1024, Identification and Evaluation of Nonconforming
--
Materials, Parts, and Components, Revision 3
!
GP 1026, Control of Engineering Drawings, Revision 1
--
GP 4015, Audit Finding Closecut Program, Revision 3, Change 2
--
GP 4016, Audit Program, Revision 3, Change 3
--
No items of noncompliance were identified.
5.
Audits The inspector reviewed the audits conducted by the Quality Assurance Department to verify that they were conducted as follows: in accord-ance with written checklists / procedures; by trained personnel not
having direct responsibilities in the area (s) audited; with audit
,
i findings documented and reviewed; with followup actions completed /
'
l initiated / closed out; and, with audit frequencies and general audit j
conduct in accordance with established schedules and procedures.
Oc
'
-
l a.
References
!
10 CFR, Appendix B, Criterion XVIII
--
GP 4015, Audit Finding Closecut Program, Revision 3, Change 2
--
I GP 4016, Audit Program, Revision 3, Change 3
--
b.
Licensee Quality Assurance Audits i
The audits conducted by Quality Assurance personnel were reviewed with respect to the criteria specified above for the period October 1976 through October 1977.
The audits and licensee identified discrepancies, with respect to established require-ments, are listed below.
,
i 76-12, EIL (vendor)
--
76-18, Procurement Document Control
--
76-20, Emergency Plan
'
--
76-22, Spe:ial Processes
--
76-25, Co' rective Action
--
76-26, SFJ Checks
--
(
) 4 0 ()
,
,
_
_. _ _
_
. _ _
l
.
.
-
,a
76-27, Refueling Procedures
--
76-28, Identification and Control of Materials, Parts and
--
!
Components 76-29, Control of Measuring and Test Equipment
--
76-31, Test Control j
--
76-32, Security Plan
--
76-33, Radiation Control
--
!
76-34 Inspections
--
76-35, Handling, Storage and Shipping
'
--
76-36, Worthington Pump (vendor)
--
,
77-02, Design Control
--
77-03, Organization
--
77-04, Instructions, Procedures and Drawings
!
--
77-05, Nonconfonning Materials, Parts and Components
--
77-07, Document Control
--
77-10, Radiation Control
--
j 77-15, Inspection, Test and Operating Status
--
77-16, Special Nuclear Material
--
77-17, Refueling
--
77-18, ISI
'
--
77-19, Major Modification D
--
d 77-22, Corrective Action
--
77-25, Audits
--
77-33, Dresser Valve (vendor)
--
i During the conduct of the above audits, the licensee identified j
a number of items requiring followup action with respect to 10 CFR 50,. Appendix B Criteria and FSAR requirements.
These
items are categorized as follows:
Criteria I, 3 Items Criteria XII, 9 Items
'
Criteria III,1 Item Criteria XIII,1 Item Criteria V, 38 Items Criteria XIV, 2 Items Criteria VI, 4 Items Criteria XVI, 5 Items Criteria VIII,1 Item Criteria XVII, 2 Items
Criteria IX, 3 Items Criteria XVIII, 3 Items
Criteria XI,1 Item FSAR, 5 Items I
No 1tems of noncompliance with the performance of these audits
'
were identified.
6.
Desian Chances and Modifications a.
References 10 CFR 50, Appendix B, Criterion III
)44b l9
--
AP 1021, Plant Modifications, Revion 0
--
-.
.
. - -. _. -.
.-
.
-.. -
- - - -
-
. _ _ _
._
.
I
'
l
C.
GP 1000, Standard Memorandum, Revision 4
--
GP 1003, Control of Design Change / Modifications, Revision 3,
--
Change 2
.
t CP 1008, Quality Assurance Systems List, Revision 1, Change 4
--
GP 1015, Administrative Controls for Preparation, Approval,
'
--
and Revision of TMI Drawings to Show As-Built Conditions,
,
,
j Revision 2 l
b.
Review and Findings The inspector selected and reviewed the design changes / mod-ifications listed below to verify as applicable that:
they are accomplished in accordance with 10 CFR 50.59 and the licensee's QA Program requirements; code requirements and specifications were included; acceptance tests including
.
values and standards were specified; records of equipment
'
performance were reviewed and accepted; and prints / '.rawings and operating procedures were revised.
by
-
The selected design change packages were:
MOD 797, Replacement of Reactor Protection System Power Range
!
--
Indicators (not yet installed)
i
!
MOD 806, Control Rod Drive (temporary)
--
,
!
MOD 814, Furmanite Injection into Decay Heat Valve DH-V-I
--
MOD 824, Decay Heat River Concrete Pipe Replacement
--
MOD 826, Reactor Building River Water Emergency Cooling River
--
Water Pipe Replacement MOD 903, Reactor Coolant LOCA Restraints
--
Areas of concern are discussed in the following subparagraphs.
(1)
Aperture Cards for B&W prints 153872 (MOD 903), Revision 4 and 36416000 (MOD 814), Revision 3. were not marked to indicate that they did not reflect as-buil! ;.lant conditions.
This is contrary to 10 CFR 50, Appendix B, Criterion VI and AP I00I and constitutes one example of the failure to control drawings as discussed in Detail 7c.
'
,
(
'
1446 192
.
..
. _ _ _.
..
-
..
. - -.....
-
--
-
.. _ _ _
.-
..
.
..
,
O.
,
(2) The site files did not contain Aperture Cards for GAI prints 400-538 and 553 (MOD 824).
Further investigation identified that the computer printout (Master Index) did not list any of the 400-xxx series prints.
This is contrary to 10 CFR 50, Appendix B, Criterion VI and GP 1015, tha latter of which
,
i
.
specifically requires this series of prints to be distributed i
to che site.
This is another example of failure to control j
drawings as discussed in Detail 7b.
i l
(3) The Change / Modification Checklists for the above modification i
packages were stored at the Corporate Engineering offices in
!
-
ordinary comercial file cabinets.
It was identified that this is a general practice with all such checklists.
This
,
storage of nonduplicated copies in the described manner is
-
contrary to the requirements of ANSI-N45.2.9 and is one example
-
of the failure to store quality documents discussed further in Detail 7b.
7.
Records and Drawings a.
References O
'
l 10 CFR 50, Appendix B, Criteria VI and XVII
--
I
'
TMI Operational Quality Assurance Plan, Rev. 6
--
GP 1012 Numbering System for Generation Drawings, Rev. O.
--
,
GP 1015, Preparation, Approval, and Revision of TMi Drawings
--
,
to show As-built Conditions l
!
GAI Drawing Index, dated August 31, 1977
--
GP 1029 Review and Evaluation of Significant Operating Experience,
--
Rev. 1 GP 4407, Regulatory Retention and Storage of Quality Control
--
Department Records, Rev. 1.
AP IOOI
--
b.
Record Storage, Retention, and Retrieval The inspector selected the following specific records in order to verify the licensee'. capability to control, store, and retrieve records:
s 1446 193
-
._
-.
.---
-
...
- -... -. -
..
._
..
..
.
i n
g
.
-
Computer printout for-power distribution for February 12-18,
--
1977 Surveil'ance Procedures results for SP 1302-5.20, 1303-4.14
--
Reactor Coolant System Hot Leg Temperature Recorder Chart for
--
December 1-15, 1976 j.
Work Requests 17755, 17759 on Makeup Valve, MU-V-20
--
Surveillance Procedure Results for SP 1301-I, Shift and Daily
--
{
Checks for January-October 1977 i
I Completed Checkoff Lists for Operating Procedure 1107-I
--
The inspector had no further questions on the retrieni of these records.
During a subsequent tour of the record storage area, the in::pector noted the area did not meet the criterion of ANSI
,
45.2.9 for record storage.
Examples of this include, but are (~)
not limited to, the lack of a door, the lack of a forced-air
-
l circulation with filter system, water piping other than that providing fire protection to the storage facility is located within the facility, and the lack of access to and control of the files.
,
This failure to provide adequate / duplicate storage for the
control room log book, shift foremens' log, logs and graphs
!
providing documentry evidence of operating within the Technical i
Specification limits, and the Change / Modification Checklists as noted in Detail 6 is contrary to 10 CFR 50, Appendix B,
,
Criterion XVII, and the Approved Quality Assurance Plan, Rev.
-
6, Section 22.
This item of noncompliance is a Deficiency (77-35-01).
c.
Engineering Drawing Control The inspector reviewed engineering drawings to verify that they are being maintained in accordance with procedures.
The results of comparing the site and corporate indices with site and corporate aperture cards are as follows:
1446 194
'
--
-
.. -
...
-
._
.
.
... -
.
-.
. -.
-.
.
_.
n
-
..
Site Corporate Site Corporate Aperture Aperture Index Index Card Card
Drawing Revision Revision Revision Revision
!
Number Number Number Number Number l
201-053 Sh 1
2i
21 l
201-091
25
26 *
l 208-308
4
4 208-433
6
6 210-109
16
15 *
210-371
11
11 210-862
0
0 218-052
15
15
224-336 Sh 9
8
8
-
224-505 Sh 1
27.
27 I
229-150
9
9 307-079 Sh F
9
8*
307-102
5
5 308-351
2
2 C
308-804
5
5 313-021
8
8 319-001
4
4 521-004
12
12 521-103
11 1.1
526-101
7
7
- In these cases the revision as noted on the controlled aperture cards differed from the as-built index dated August 31, 1977.
This example of apparent lack of control of as-built drawings,
,
the failure to mark aperture cards as required for systems that have been modified as noted in Detail 6, and the failure to distribute drawings in accordance with GP 1015 as noted in Detail 6 are contrary to 10 CFR 50 Appendix B, Crite ion VI and the Approved Quality Assurance Plan, Rev. 6, Section 22.
-
This item of noncompliance is a Deficiency.
(77-35-02)
i l
l d.
The inspector verified by review of procedure GP 1029 (Review l
and Evaluation of Significant Operation Experience, Rev.1)
and discussion with personnel that the record-keeping of reactor operations and equipment performance is sufficient to permit review to detect long-term equipment degradation or adverse trends.
The inspector had no further questico.4 at this time.
.
1446 195
.-
-
-.
-.
.-
-
.-
_ -.
. _ _. _
.. _ _ _ _
. _ _.,
__
. _ _ _....
.
.
o
,
I f) -
,-
-
.
e.
The inspector verified during review of procedure changes, work requests, and change / modification packages that records of tests and experiments are being maintained as described in 10 CFR 50.59(b).
The inspector had no further questions in this area.
'
o 8.
Exit Interview The inspectors met with licensee representatives (dencted in Para-graph 1) on November 9, 1977, at Three Mile Island, Unit 1 and at the Generation Engineering Offices on November 10, 1977, at the conclusion of the inspection.
The inspectors sumarized the purpose and scope of the inspection and the findings, s
\\
O
-
,
.
I d
'\\ g 4 6 \\ %.
'
f
.
.==euwm.
.wmNew--*,-=
p-e
+me..
se e.=gww-
.e.msn.-