IR 05000289/1980004
| ML19318B268 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/07/1980 |
| From: | Ebneter S, Gage L, Paolino R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19318B266 | List: |
| References | |
| 50-289-80-04, 50-289-80-4, NUDOCS 8006250186 | |
| Download: ML19318B268 (7) | |
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V U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No. 50-2R9/80-04 Docket No. 50-289 License No. DpR-50 Priority Category C
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Licensee:
Metropolitan Edison Company
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P.O. Box 542 Reading, Pennsylvania 19603 Facility Name:
Three Mile Island, Unit 1 Inspection at:
Middletown, Pennsylva'nia Inspection conducted:
Febr ary 5 - February 29, 1980 Inspectors:
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L. Gage, Ryactorf Inspector
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date signed
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' dat'e signed R.P[obn,ReactorInspector r/r/a Ja n (M A. Var 61a, eactor Inspector
' date signed JM, * A/
c/sho P. Koltaf, Redctor' Inspector
'cate signed S. D. Ebneter f/ 7 d
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Chief, Engineering Support Section #2
/ date signed Approved by: h[
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S. D. EbWter, Chief ddte signed.
Engineering Support Section #2 Insoection Summary:
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Inspection on February 5 - February 29, 1980 (Recort No. 50-289/80-04)
Areas Inspected:
Routine, unannounced inspection by regional-based inspectors of work activities and records associated with the Unit 1 Restart Program, including: engineering design, quality-assurance audits, electrical and instrumentation (modifications nos. RM-1, RM-4, RM-8, RM-10, and LM-8A), fire protection (modification no. NM-40), installation of the hydrogen recombiner (modification no. RM-12),
and tendon surveillance.
The inspection involved 162 inspection hours on site by four NRC regional-based inspectors and one regional-based section chief.
R;gion'I Form 12 (Rev. April.77)
8006250\\gG
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DETAILS 1.
Persons Contacted General Public Utilities Service Corporation (GPUSC)
- N. Ka' anas, Manager of Quality Assurance z
- B. 3allard, QA Modification / Operations Manager
- R. Fenti, Supervisor, QA Audits J. Wright, QC Manager R. Prabhaker, Supervisor, Generation QA Engineering W. Shumaker, QC Lead Engineer, Electrical
- E. Steudel, EP&I Section Manager Metropolitan Edison
- G. Miller, Unit 1 Director, Restart
- G. Troffer, Unit 1 Restart Project
- M. Shaffer, Engineering Assistant C. Hartman, Lea 6 Electrical Engineer
- R. Toole, TMI Unit 1 Manager L. Zubey, Task Manager Gilbert Associates, Inc.
- W. Acker, Dept. Supervisor, Unit 1 Restart J. Yost, Unit 1 Restart Engineer U.S. Nuclear Regulatory Commission
- T. Fasano, Chief, Site Operations Section, TMI
- D. Havercamp, TMI-l Senior Resident Inspector
- denotes personnel present at exit interview T
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2.
Identification of Safety-Related ECMs The inspector reviewed a selection of engineering change memos (ECMs) that had been generated for the Unit 1 Restart Program.
These ECMs were primarily associated with restart tasks RM-1 and RM-10:
heat-shrink tubing / butt splicing and power-operated relief valve position indication, respectively.
The inspector identified ECM number 057, revision 0, dated 12/5/79 as an ECM which was classified as a non-safety change, but which appeared to be safety related. This ECM addressed the instellation of instrumentation to monitor the pressurizer electromatic relief valve and pressurizer code safety valves.
Paragraph 4, on page C8-13 of the NRC " Status Report on the Evaluation of Licensee's Compliance (dated January ll, 1980) states: "Our position, as stated in our October 30, 1979 letter, is that the position indication (and therefore all equipment required to function to support its operation) must be seismically and environmentally qualified as stated above."
The inspector later was shown a Met Ed memo, dated 1/28/80 (0AEM/67)
which identified eleven ECMs which should be classified as being within the scope, that is, within the quality-assurance program, and therefore safety-related -- in view of the importance to safety of the items involved.
Revision 1 to ECM 057, dated 2/5/80, which does not supercede revision 0, but adds to it, was classified as safety related.
The problem was considered to be time related:
ECMs generated prior to licensee review of the " Status Report on the Evaluation of Licensee's Compliance" and the " Recommended Requirements for Restart of TMI-1" and the revisions thereto may now not reflect the up-to-date definition of " safety-related". The document that defined " safety-related" for these ECMs was GP-1008, Revision 2, dated 9/25/78.. Therefore, qualification requirements, 10 CFR Part 21 requirements, and 10 CFR 50 Appendix B requirements --
that would normally be cons Dered for a safety-related ECM --
might not be incorporated in early ECMs.
This was therefore identified as an item of concern by the inspector.
The licensee recognized the inspector's concern and indicated that they would consider reviewing all "non-safety" ECMs generated prior to their incorporation of the " Status Report" and " Restart" riocuments into their progra.
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The inspector stated that the licensee's review of these non-safety ECMs would be evaluated during a subsequent NRC inspection.
(80-04-01)
3.
_ Review of the Audit Program for Engineering Design The inspector interviewed licensee personnel and reviewed related documents to determine if the licensee was performing audits of the engineering-design activity. Among the documents reviewed were:
Audit Report S-TMI-79-09 (a site audit performed 12/5, 7, 10-
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14,17-21, and 26/79).
Audit Report 0-TMI-1-V-79-01 (a subcontractor audit -- Gilbert
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Associates, Inc. -- performed 8/14-16/79.
Audit Report 0-TMI-1-79-01 (a GPU - Mountain Lakes audit
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performed 12/11-13/79).
No items of noncompliance were identified.
Subsequent to this inspection, the NRC conducted an inspection of the licensee's engineering-design effort at his corporate office.
The results of this inspection are contained in I E report no.
50-289/80-05.
4.
Fabrication of Butt Splices The inspector examined the following licensee documents, in reviewing the fabrication of butt splices for tasks RM-1. Pfi-4, and LM-8A.
ECP-3.2, revision 34, dated 2/2/78
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QC surveillance reports El-001 thru El-172
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ECP-3 (revised version of ECP-3.2 for TMI-1)
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AP1043 revision 0, dated June 12, 1979
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GP1008 revision 8 (draft copy)
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Surveillance procedures 1302-5.15 and 1302-5.4
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ECM nos. S-003, S-022, S-027, and S-037
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FQ-R70
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. Purchase Order Nos. 86005, 86006, 86070, 86082, 86097, 86233,
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86285, 86520, 86549 and 8655.
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The inspector noted that procedure ECP-3.2 for fabrication of electrical butt splices did not incorporate the entire vendor (Raychem) recommended procedure for making splices that could be-qualified for the LOCA environment.
For nuclear type WCSF-N heat shrink sleeving, the vendor furnishes Installation Guide 1050 which provides instructions for preparing cable surfaces prior to applying heat shrink sleeving.
These are not a part of procedure ECP-3.2.
Discussion with licensee QC personnel (who witnessed 100 percent of all butt splices) indicated that there was no preparation of the cable surfaces per the vendor Installation Guide 1050.
This concern extends to the training and qualification of personnel fabricating the butt splice, since the personnel training program does not include instructions on preparation of cable surfaces.
The inspector identified the fabrication of the butt splices as an item of concern.
He stated that it would be examined further during the NRC review of the licensee qualification data, in response to IE Bulletin 79-018.
(80-04-02)
5.
Fire Protection The inspector examined the following licensee documents for the fire protection modifications associated with task NM-40 and compared them with the requirements identified in Amendment No. 44 to the license.
SECM-063
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SECM-067
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SECM-069
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ECM-86
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ECM-87
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No items of noncompliance were identified in this initial review.
However, the inspector scheduled a subsequent, in-depth review of the NM-40 ECMs.
6.
Fire Hazards Analysis - Butt Splices The inspector examined the fire hazard analyses associated with the following ECMs, in reviewing the fabrication of butt splices for task RM-1:
S-003
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S-022
'S-027
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S-037
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The analyses stated that there were no additional combustible materials used in fabricating the butt splices.
The inspector requested the licensee to provide the basis for this statement, noting that the red sealant used in the splicing process is combustible.
The inspector identified this as an item of concern.
(80-04-03)
7.
Certificate _ of Compliance The inspector examined the following purchase orders associated with task RM-1:
86082, 86097 and 86522.
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The inspector questioned the adequacy of the certificates of compliance supplied by the vendors.
In P.O. 86082: the purchased item is intended for use in the
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containment, requiring exposure to a LOCA environment.
The certificate does not address qualification of the item for a LOCA environment.
In P.O. No. 86097: The certificate does not state compliance
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with any specification requirements, only that certain listed materials have been supplied.
In P.O. No. 86522:
The certificate states compliance with the
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IPCEA flame test rather than the applicable IEEE-383 flame test.
The certificate states compliance with ASTM-B-8 and ASTM-B-33; however, the Purchase Order specifies the latest editions of ASTM-B-8 and ASTM-B-33 or ASTM-B-173.
The inspector identified this as an item of concern.
(80-04-04)
8.
Installation of Hydrogen Recombiner The inspector reviewed the installation * requirements for the hydrogen recombiner that are associated with task RM-12, inspected the facility to observe the status of the work in progress, and reviewed structural and mechanical quality-control records.
The inspector noted an apparent variation in the method in which the licensee documented inspection criteria in their engineering change memos. A quality control instruction was drafted by the licensee to resolve this.
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The inspector identified the draft instruction as an item of concern; he stated that it would be reviewed, in its final form, by an NRC inspector during a subsequent inspection.
(80-04-05)
9.
Tendon Surveillance The inspector interviewed the licensee to review the technical requirements, the schedule, and the quality-control involvement in the tendon surveillance project.
He determined that VSL has been awarded a contract for the entire project, including first-level quality-control.
The project is expected to start in April 1980 and run for two months.
It is not considered part of the Unit 1 Restart Program.
However, additional NRC inspecti'on of the project has been scheduled.
No items of noncompliance were identified.
10.
Exit Interview The inspector met with the licensee representatives (denoted in paragraph 1 ) at the conclusion of the inspection. The licensee acknowledged his findings.
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