IR 05000289/1978009
| ML19210B600 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/25/1978 |
| From: | Beckman D, Keimig R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19210B594 | List: |
| References | |
| TASK-TF, TASK-TMR 50-289-78-09, 50-289-78-9, 50-320-78-18, NUDOCS 7911110035 | |
| Download: ML19210B600 (13) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I 289/78-09
) ort No. ??c /79 19 50-289 Occket No.
50-320 DPR-50 C
License No.
DM-73 Priority Category B-2
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Licensee:
t/etrocalitan Edison Cemcanv P. O. Box 542
- eadino. Pennsv1vania 19603
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Facility Name: Three Mile Island Nuclear Station - Units 1 and 2 Inspection at: Middletown, Pennsylvania Inspection conducted:
Ma-9-12, 1978 Inspectors:
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M./[-[8
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[0.A.Bepman, cto nspector cate signed date signed
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date signed
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Approved by:
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/- M*/d R
.Keimy, Chi Nuclear Support cate signed Section IfD. 2, S Branch
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Insoection Summary:
Insoection on May 9-12, 1978 (Combined Reoort Nos. 50-289/78-09 and 50-320/78-18)
Areas Insoected: Routine, unannouncea inspection of licensed operator requalifi-cation training, general employee training, craft personnel training, quality assurance for the Startup Test Program, startup test recorcs, and licensee action on previous inspection findings.
The inspection involved 33.5 inspector-hcurs onsite by one NRC inspector.
Results: No items of nonccmoliance were identified.
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DETAILS 1.
Persons Contacted
N. Brown, Training Administrator
- W. Cotter, QC Supervisor
.E. Daniels, QC Group Leader J. Everhart, Repair an R. Harper, Supervisor of Instrument and Control Maintenance D. Kinter, Instrument Man C. Korchnak, Clerk-Typist J. Madaras, Associate Engineering (Babcock and Wilcox)
J. McGarry, Supervisor of Mechanical Maintenance J. Moyer, Repairman C. Nixdorf, Administrative Supervisor
- J. O'Hanlon, Unit 1 Superintendent J. Plott, Clerk-Typist, Manpower Services, Inc.
J. Powell, QC Assistant D. Shovlin, Superintendent of Maintenance
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A. Stowe, Record Retention Administrator
- R. Toole, Test Superintendent (GPUSC)
R. VanStry, Training Administrator
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W. Yeager, Instrument Man
- R. Zechman, Supervisor - Training The inspector also interviewed other licensee employees during the conduct of this inspection. They included operations, main-tenance, quality control, and office personnel.
- denotes those present at the exit interview.
2.
Licensee Action on Previous Insoection Findinas (Closed) Unresolved Item (289/77-29-03)f Review training records for station Fire Brigade Members.
The inspector reviewed a " Staff Training Status" computer printout, a sample of indiv.idual Fire Brigade member training records, and the course outline for the station's fire fighting training.
The inspector determined that all personnel currently assigned to the fire brigade have completed 1566 272
the licensee's training program.
At the time of the inspection, five newly assigned Auxiliary Operators were participating in a full time training program which will include the above training.
The licensee stated that these individuals are scheduled to receive the fire fighting training during the week of May 30, 1978, and such training will be completed prior to their assignment to shift work as Fire Brigade members.
3.
Licensed Ocerator Recualification Trainino a.
Proaram Review The licensee has ;mplemented the accepted program for requal-ification training of licensed operators common to both Units 1 and 2.
The program for Unit 1 has been in place and func-tioning since 1974 and that program, appropriately revised, was implemented for Unit 2 on May 8, 1978.
The inspector determined, through review of records and interviews with licensee personnel, that the combined program includes:
a preplanned lecture schedule wnich provides for both
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dual unit and single unit lectures on a regular and continuing basis;
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documentation of lecture attendance including a followup
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system for administering makeup training for individuals absent frcm required lectures; and, identification of specific training aids and/or self-
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study methods to be used in lieu of an instructor.
The first annual requalification program written examination for the operators licensed on Unit 2 is scheduled for approximately March 1, 1979 (based upon the operators' license issue dates and the date of program implementation).
Until that time, the licensee is basing lecture attendance requirements and mandatory self-study assignments en the results of the indi-vidual operators' NRC administered licensing exarpination.
Lecture attendance and completion of self-study assignments are being required for each ocerator in those subject areas in wnich the need to upgrade the individual's knowledge was identi-
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fied.
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The program, as currently established, includes on the job training requirements listed below and methods of documenting their accomplishment; required reactivity control manipulations;
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discussions / reviews of changes in facility design, pro-
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cedures, and facility license; and,
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review of abnormal / emergency procedures.
The inspector noted that, while the accepted requalification training program for Unit 2 had not been formally implemented until May 1978, a lecture based training program had been established in coordination with the Unit 1 program.
This training was administered during the period between issuance of the new Unit 2 operators' licenses and implementation of the mandatory requalification program and included the general subject matter required by the mandatory program.
No items of noncompliance were identified.
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b.
Record Review The inspector selected and reviewed the recorcs of three
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licensed operators to verify that each contained the following documentation:
completed course and yearly examinations with answers;
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manipulation of controls for reactivity changes required
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by the program; simulation and/or discussion of emergency / abnormal pro-
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cedures and responses; and,
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the results of supervisory evaluations.
The inspector also reviewed individual records for proper completion of remedial training required by the program for those operators scoring less than 80% on one or more sections of the annual examination.
The remedial training was being accom lished as required and cral re-examinatiens were being administered and documented in accordance with the acceoted pr: gram.
10 'tems of nonc roliance were icentifiec.
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4 General Emoloyee Training a.
Procram Definition The inspector reviewed the licensee's program with respect to the program definition requirements of:
10 CFR 50, Appandix B, Criterion II; 10 CFR 19.12; 10 CFR 73.50; and ANSI N18.1.
The program, as currer.tly established, provides for formal training of:
new employees; temporary personnel; nonlicensed personnel; technicians; and craft personnel.
The established training curricula provide, as appropriate to job category, training which includes: administrative controls and pro-cedures; radiological health and safety; controlled access.and security; industrial safety; emergency plans and procedures; ani quality assurance orientation.
Formal training is also proeided for female e::ployees on the contents of Appendix A to Reguintory Guide 8.13.
No items of noncompliance were identified.
b.
Procram Particioation The inspector reviewed the licensee's records to assure that the required training had been given.
In addition, the in-spector conducted interviews with those individuals whose records were reviewed.
The interviews verified that:
the scope of t'he training was similar to that contained in the licensee's records; the training as conducted was meaningful to those attending; and, that the subjects presented were covered accurately and sufficiently from the participant's point of view.
Records were reviewed for and interviews conducted with:
two relatively new employees;
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two employees with more than one year of service;
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two temporary employees; and,
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two female employees.
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In all cases, the interviews substantiated the licensee's records.
No items of noncomoliance were identified.
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c.
Fire Fichtina Trainina In addition to the fire fighting training provided to members of the Fire Brigade, the licensee administers fire fighting training to those personnel whose work normally takes place in-plant.
Each station department assigns their employees to attend the scheduled training sessions at the discretion of the department's supervision. A review of records for this activity indicated that nearly all of the noncierical staff has received this training and that a continuing schedule
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for training of the remainder of the staff and new hires
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has been established.
The fire fighting training for such personnel includes:
chemistry, develcpme'nt and classes of fires;
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station fire fighting apparatus (portable and permanently
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installed);
station procedure review;
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fire fighting techniques including aoplication of water
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on energi:ed electrical fires; and, field training which includes " hands-on" use of fire
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fighting apparatus and live fires.
No items of noncompliance were identified.
5.
Craft and Technician Trainina a.
Procram Review The inspector reviewed the licensee's program for training and retraining of craft and technician personnel who are avail-able for assignment to either unit.
A portion of this review was directed at determining whether the licensee has satisfied
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the requirements for providing appropriate training for craft and technician personnel as stated in the Unit 2 FSAR.
Defined and documented training programs covering classifications frem probationary periods through job foremen are established for all I&C, Mechanical, and Electrical maintenance perscnnel and are included in the job specifications for each position.
Oeview of licensee recorcs incicated that the following ty;es f training are :roviced:
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related technical training and vendor familiarization;
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intermediate health physics training;
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on-the-job training in maintenance procedures and
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techniques; on-the-job and formal training in administrative pro-
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cedures; and, specific familiarization training prior to the performance
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of sensitive or complex tasks (e.g. containment leak rate testing).
No items of nonccmpliance were identified.
b.
Record Review and Personnel Interviews The inspector reviewed the records for and ccnducted interviews with the employees listed below to verify that the required training had been conducted; that the selected individuals understood the informaticn which had been presented; and, that they were able to describe how these instructions apolied to their job positions.
Interviews were condycted with:
two repairmen; and,
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two instrument men.
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The inspector identified no discrepancies or inconsistencies between interview results and licensee's documentation.
No items of noncompliance were identified.
6.
Overall Trainina Procram Administration The Supervisor-Training is resconsible for the conduct and admini-stration of the station training program.
Review of,the various course outlines, lesson plans, and other related documentation indicate that the programs are receiving periodic evaluation and are revised when necessary to include new material or increase their sco::e.
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The licensee is currently developing and has partially implemented a new, company-wide training program which will be administered at the station for all,iob classifications.
The inspector reviewed a portion of the documentation which has already been developed for
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this program. When implemented, the program will be based upon a two year, cyclic curriculum for each individual (by job classifi-cation) and will include both on-and off-site instruction and schools, correspondence courses, and vendor presentations.
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curricula reviewed included specific courses, appropriate to specific job classifications, in the following general subject areas:
general technical or job skill related courses or instructien;
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radiological safety and health;
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general safety;
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Quality Assurance;
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specialized technical training;
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job related fundamental education (nathematics, physics,
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etc.); and,
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professional and managerial development.
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The licensee stated that this program was being im;51emented for the Quality Control and Operations Departments at the time of this inspection, with implementation for other departments to follow as their respective segments of the program were comoleted.
The portions of the above training program, which will supplant exist-ing required training programs, will be reviewed during future inspections.
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7.
Quality Assurance for the Startuo Test procram - Unit 2 a.
Inscection Resconsibilities The inspector reviewed the below listed documents to ascertain that requirements have been established and procedures developed for inscection of startup test activities on a vagular basis.
The folicwing documents were reviewed:
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FSAR, Section 17.3, Quality Assurance for Startup and Test, Paragrach 17.3.10; 1566 278
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FSAR, Section 14, Initial Tests and Operation;
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OA Plan for Startup and Testing including Aopendix A;
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and, Three Mile Island Nuclear Generating Station Test Manual
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and associated Test Instructions.
The inspector determined that recuirements and procedures have
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been established, consistent with the licensee's FSAR commit-ments, for the performance of inspection of the following activities by the licensee's Startup Test and CA organizations:
conduct of testing;
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tracking of test deficiencies; and,
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test documentation.
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The measurino and test equipment used for the performance of startup testing is being provided by the licensee's maintenance department and is centrolled under the Operational Quality Assurance Prcgram. The responsibilities for inspection of activities related to the control of measuring and test equip-ment have been assigned to the licensee's Quality Control Department' and are implemented via station Administrative Procedures.
The inspector reviewed AP-1022, Control of Measuring and Test Equioment, and determined that procedural direction exists for performance of QC surveillances, QC processing of out-of-calibration equipment, and QC determination of the need to retest based on the use of out-of-calibration test equip-ment.
The inspector additionally reviewed completed CC surveil-lance checklists that documented the results of surveillances '
perfomed on equipment calibrated by service vendors after its return to the station. The QC organization's schedule for performance of periodic surveillance also includes surveillance of site performed calibrations.
The inspector determined, by interviews, that the key personnel in the licensee's startup test and quality assurance orcaniza-tions understand thair basic responsibilities as applied to the Startuo Test Program.
No items of nonconcliance were identified.
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b.
Corrective Action The licenste's Startuo Test Program utilizes " Problem Reports" to identify and document nonconformances and other deficiencies identified during testing.
The Problem Reports are controlled in accordance with Test Instruction No. 4 and provide the vehicle for obtaining and documenting corrective action. The inspector selected and reviewed the Problem Reports listed below (including the documentation of their resolution, cor-rection and retest) in order to determine that corrective action was taken as required by the QA program.
The following were reviewed:
Problem Report 5309, Reactor Building Purge and Exhaus_t
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System Low Flows
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Problem Report 5315, RCS Loop delta-T Out of Scecifica-
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tion during TP 800/32 Problem Report 5335, AH-C-19A & B Failure to Meet Test
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Acceptance Criteria Problem Report 5335, Radwaste Gas Valves not controlling
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pressure as required No items of noncompliance were identified.
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c.
Audits
The General Public Utilities Service Corporation (GPUSC)
Quality Assurance Department is responsible for performing audits of all aspects of the Startup Test Program.
The audits are conducted in accordance with the Quality Assurance Plan for Startup and Test, Appendix A, titled " Procedure for Per-formance of Audits of Startup and Test Activities."
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The inspector reviewed the current audit schedule and inter-v.ewed the GPU Lead QA Auditor. The inspector determined that all scheduled audits had been completed up to, but not includ-ing, those pertaining to the Zero Power Physics Test Sequence and Power Escalation Test Sequence.
The audit o.f Zero Power Physics Test Sequence activities is still in progress due to slippage in the test program schedule.
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The inspector selected and reviewed three recently performed audits of the test program to determine that:
they were per-formed in accordance with the requirements of the FSAR and the Quality Assurance Plan for Startup and Test; they were perfomed on a predetemined schedule; and that adequate, timely resolution was effected for all identified deficiencies.
The inspector reviewed the following audits performed by the GPUSC Audit Group:
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77-21, Audit of Startup and Test Compliance with Test
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Instructions Nos. 1-5, 7-11, 14, 18, 19, and Various Test Procedures.
77-16, Audit of Startup and Test - Control of Test Records,
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STE Log, Repair Removal Authorizaticns, Conduct of Test, Test Procedure Documents, and Test Briefing and Dry Run.
77-11, Audit of Selected Administrative Controls for Reactor
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Coolant System Hydrostatic Test.
The inspector noted that the scope of each of the above audits was quite broad and that audit performance spanned one or more months. Audit corrective action, however, was initiated promptly after identification of an unacceptable audit finding, preceding the issuance of the complete audit report when circum-stances dictated.
The inspector determined that, for the sample selected, audit findings were being closed out-in a timely manner with adequate resolutions being provided.
The inspector addi-tionally reviewed the status of outstanding audit findings for all previous GPUSC Test Program audits and determined that audit corrective action and followup were consistent with the require-ments of the QA program.
No items of noncompliance were identified.
8.
Startuo Test Records - Unit 2 a.
Maintenance of In-Process Test Records The inspector reviewed the following documents to determine that administrative controls have been established for maintaining records of startup test procedures, test results, power level plateau data analysis, and 0A/QC audits and surveillances prior to their turnover to the licensee from GPUSC:
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Quality Assurance Plan for Startup and Test;
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FSAR, Section 17.3, Quality Assurance for Startup and
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Test; and, GPU Test Instruction No. 4 Control of Test Records.
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The above documents provide for the GPUSC Startup and Test Group to retain completed test procedures and other quality related test documents, in accordance 'with Test Instruction No. 4, until completion of the unit's test progran.
At that time, the original copies of all such documents will be trans-mitted to the station Superintendent for retention.
During.
the period prior to this transfer, all such records are assigned to the responsibility of the GPU Technical Engineer.
Test Instruction No. 4 establishes requirements for:
temporary storage of records in fireproof cabinets; controlled access of personnel; periodic audits of records; and, controlled distri-bution of specific record types.
Records of GPUSC Quality Assurance audit activities are retained by the auditing organization until the unit is placed in
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commercial operation. At that time, these records will be transmitted to the licensee's Operational Quality Assurance Department.
The inspect'or determined that the records above were being maintained and controlled in accordance with the requirements of the Quality Assurance Plan for Startup and Test.
No items of noncompliance were identified, b.
Maintenance and Storace of Records - Post-Turnover As documented in NRC:RI Inspection Report No. 50-320/78-10, the licensee has notified the Commission of their inability to satisfy the requirements of ANSI N45.2.9, " Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants" prior to June 1,1979 and has requested an extension until that date for implementation.
Inspection of the licensee to the requirements of ANSI Nd5.2.9 is pending NRC disposition of that request and is the subject of a crevious Unresolved Item (320/78-10-03).
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In view of the above, the inspector reviewed the licensee's plan for turnover, accountability / inventory, and interim storage of the test program related records to be received frem GPUSC.
Discussion with licensee representatives indi-cated that informal planning is taking place, particularly with regard to the interim storage location and physical facilities.
Final arrangements, however, have not yet been made for the turnover and interim storage for these records.
This item is. unresolved pending flRC:RI inspection of the turnover of test program related records and the arrangements for their storage until permanent facilities are available.
(320/78-18-01)
9.
Unresolved Items Unresolved items are matters about which more information is rcquired in order to ascertain whether they are acceptable items, items of nonccmpliance, or deviations. An unresolved item identi-fied during this inspection is discussed in Paragrsph 8.
10.
Exit Interview
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. The inspector met aith licensee representatives (denoted in Para-graph 1) at the conclusien of the inspection on May 12, 1978.
The inspector presented the purpose, scope, and findings of the inspection as stated in this report.
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