IR 05000289/1980005
| ML19337A200 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/04/1980 |
| From: | Greenman E, Napuda G, Paolino R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19337A194 | List: |
| References | |
| 50-289-80-05, 50-289-80-5, NUDOCS 8009090250 | |
| Download: ML19337A200 (7) | |
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jM U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No.
80-05 Docket No.
50-289 Category C
License No.
DPR-50 Priority
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Licensee:
Metrooolitan Edison Comoany 100 Interoace Parkway Parsiocany. New'Jersev 07054 Facility Name:
Three Mile Island Nuclear Station, Unit 1 Inspection at:
Parsippany, New Jersey Inspection conducted:
February 27-29, 1980 f/2f d
Inspectors:
y, a)
/ datg signed G.8Nj)puda,ReactorInspector Mvkae a hr/#o R.fdolino,-ReactorInspector
< fate / signed date signed f /q[p
. Approved by:
E. Greenman, Chief, Nuclear Support
'd6t6 signed
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Section No. 2, RO&NS Branch Inspection Summary:
Inspection on February 27-29, 1980 (Report Number 50-289/80-05)
Areas Inspected: Special, announced inspection by two region based inspectors of the Quality Assurance Program (QAP) implementation in the areas of Design Changes /
Modifications; Procurement; and Unit 1 Restart Program.
The inspection involved 49 inspector-hours at the corporate offices by two region based inspectors.
Results: A deviation, affecting all three areas inspected, was identified.
(Devia-tion - failure to incorporate recommended restart requirements into established
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Engineering Department procedures - paragraph 3.b).
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Region I Form 12 (Rev. April 77)
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DETAILS 1.
Persons Contacted GPU J. Bansch, Lead QA Engineer P. Boucher, Engineering Standards Manager G. Donovan, Design / Drafting Engineer
- N. Kazanas, Manager - QA R. Keaten, Manager - Systems Engineering
- D. Croneberger, Manager - Engineering Design
- P. Magitz, Senior Engineer - QA
- C. Paczolt, Supervisor Manufacturing Assurance D. Slear, TMI Project Engineering Manager
- C. Smyth, Licensing Engineer
- M. Stromberg, Methods /0PE
- E. Wallace, Licensing Manager
- R. Wayne, Design / Procurement QA Manager The inspectors also held discussions with and interviewed other members of the corporate office administrative, engineering and technical staffs.
- denotes those present at the exit interview.
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General
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The purpose of this inspection was to ascertain if the licensee had esta-blished appropriate instructions comensurate with the status of engineering activities associated with the Unit 1 restart effort; that those instructions incorporated the QA Program and other requirements; and, that selected activities were being accomplished in accordance with those requirements.
3.
QA Program
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a.
References FSAR Chapter 17.2
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Operationsi QA Plan, Revision 7 (0QAP)
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Recomended Requirements for Restart of TMI Nuclear Station Unit
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I 1, Volumes 1, 2 and 3 (RRR)
l Implementing procedures listed in subsequent paragraphs of this
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j report identified by an asterisk b.
Program Review
. The inspector reviewed the changes made to the implementing quality assurance procedures to determine if they were consistent with the 0QAP and RR.
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A deviation and an unresolved item are discussed below.
i (1) The RRR is a' three volume document that had been-submitted by the licensee'to NRC-NRR describing the~ control and requirements to be
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imposed on Unit.1 restart activities. The inspectors noted that in a ' number of instances this document imposes requirements in addition to those found in the QA Program and implementing pro-
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cedures such as GP-1008.
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The inspector identified that those additional RRR requirements
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were not included or referenced.in any implementing. instructions /
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procedures, includin architect / engineer.(g engineering tasks assigned to the licensee's three specific examples are-discussed in paragraphs 4.c and 5.b of this report).
The failure to incorporate' those additional requirements into i.
11mplementing instructions / procedures is considered to be a devia-
~ tion since the RRR is 'a written comitment to the NRC (289/80-05-01),
(2) The inspector noted one instance where a controlled copy of the
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0QAP. did not contain two recent revisions and determined this to be an isolated instance. The inspector. also noted that the controlled copy distribution list was in need of review and revision.
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The GPU representative stated that they had just recently accepted the responsibility of controlling / distributing the 0QAP and that the controlled copy distribution list was in the process of being reviewed / revised to assure that all designated copy holders possess up-to-date copies.
Pending review of the stated action
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-thisitemisunresolved(289/80-05-02).
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4.
Design Changes / Modifications a.
. References
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ES-002, Format and Content of Project Design Criteria Document,
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-Revision 1*
ES-003, Identification of Power Plant Systems, Revision 1*
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ES-004, Format.and Content of GPUSC Specifications, Revision 1*
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ES-005, Format'and Content of GPUSC System Design Descriptions,
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Revision 0
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ES-Oll, Classification of TMI-1 Systems and Components, Revision
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ES-012,- Format and Content of TMI-1 Valve / Equipment /Line/Instru-
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ment / Motor / Drawing Lists, Revision 1*
EP-005, GPUSC Sy' stem Design Descriptions, Revision 1*
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EP-006, Preparation, Documentation and Control of Calculations,
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EP-007, Control and Distribution 'of Procedures and Standards,
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Revision 0 l
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-EP-008, Control, Evaluation and Resolution of Review Comments on
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Design Documents, Revision 0 EP-009, Design Verification, Revision 1*
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EP-010, Review of Architect Engineer Engineering Documents, Revi-
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sion 0 EP-011, Use of Design Changes Notice for GPUSC Originated Design
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Documents,' Revision 1*
EP-014, Project Design Criteria Document, Revision 1*
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EP-3-2, Electrical Cable Terminations / Splices, Revision 34
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b.
Program Review The documents listed above were reviewed to determine whether admin-
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istrative controls for design changes / modifications have incorporated the requirements as described in the TMI Operational Quality Assurance Plan, Revision 7.
This review determined that administrative controls have been esta-blished which verify the following:
procedures for control of design changes / modifications have been
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developed design document control has been established
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channels of communications between the design organization and'
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the individual responsible for implementation exist design change /nodification packages are being converted into
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plant records
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methods exist for identifying and reporting those design changes /
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modifications which are within the scope of 10 CFR 50.59 procedural controls exist for temporary modifications, lifted
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leads and jumpers responsibilities have been delineated in writing to assure the
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implementation of the above
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The inspector stated that he did not complete the review of the. entire design control program.
The licensee acknowledged the inspector's statement.
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No items-of noncompliance were identified, however an unresolved item is discussed below.
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(1)' The' inspector noted that Procedure EP-3-2 (Section '4) did not
, address the cleaning 'of surfaces prior to the application of heat shrink sleeving as recommended by the manufacturer.
The in-spector interviewed licensee QC personnel, who had performed QC
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surveillance of cable splicing, in order to determine whether
. workmen had followed the manufacturer's recomended procedure for maki_ng LOCA' qualified splices. The interviewed personnel stated that they had not witnessed any cleaning of surfaces during 100%
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inspection of such splicing.
The licensee stated that the manner in which the splicing had been done would be reviewed, evaluated g
and appropriate action taken.
'This' item is unresolved pending verification that the subject had been addressed and satisfactorily dispositioned (289/80-05-03).
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Environmental, Safety and Seismic Classification
-L The inspector reviewed the purchase documents associated with the below referenced modifications to determine if design, quality, regula-l tory and other appropriate requirements had been included as necessary.
(1) Section 2.1.1.5.2, Item 6, of the RRR (Volume 1), which discusses
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containment isolation, states in part, "All new instrumentation r -
shall meet the environmental and seismic requirements of IEEE-
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323." Item 8 of this section eliminates seismic requirements :for the non safet Further, paragraph 4 (y-related radiation isolation signal.page c8-13) of the NR
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1979 states in part, "Our position, as stated in our October 30,
1979 letter {"Short Term Lessons Learnad"} is that the position
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qualified as stated above." The inspector identified that the following purchase orders associated with the stated modifications
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were designed as "Non Q" and as such had no environmental or
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seismic requirements imposed for the procured items:
RM-5, Containment Isolation; purchase order. 86070.- Radiation
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Monitoring System RM-10 (ECM-057), PORV Position Indication; purchase orders
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86016-tubing,.86017-valve manifolds, 86023-differential.
transmitters / pressure gages, 86027-valve monitoring system, 86034-power supply, 86046-dual / single alarm system, 86029-i
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globe valves This apparent conflict in the classification of safety and non
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= safety-related systems as reflected in the licensee's procurement and engineering design documents versus the requirements as stated f
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in the NRC's " Status Report of August 9,1979" and "Short Term Lessons ~ Learned" letter dated October 30, 1979 is an unresolved item pending further NRC review of the licensee's basis for classification of systems involved in the Unit 1 Restart Program (80-05-C4).
5.
Procurement Control a.
References FSAP. Chapter 17.2
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0QAP, Revision 7
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RRR
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Applicable procedures listed in Paragraph 4
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b.
Record Review The inspector examined purchase orders 86000, 86007, 86009, E6011, 86018, 86019, 86022, 86023, 86029, 86030, 86049, 86082, 86056A, 86097, 86233, 86239, 86240, 86267, 86269 and 86549, which were associated with modifications listed in Paragraph 4.c.
The inspector reviewed these documents to determine that they incorporated:
FSAR, 0QAP, RRR and applicable procurement specification requirements; specified the required QC inspection (s) and quality records; and, utilized approved vendors.
No items of noncompliance were identified, however three unresolved items were discussed below.
(1). The inspector identified that purchase orders 86018, 86019, 86022, 86082, 86097 and 86549 did not invoke 10 CFR 21 require-ments. The licensee stated that the involved items were procured under the provisions of 10 CFR 21 Amendment 7590-01-M1 (October 19,1978), Supplementary Information, fourth paragraph, which
- states in part, "... Part 21 is being amended to remove from the scope of 10 CFR Part 21, during specific stages of procurement, those items of a comercial grade...that are (1) not subject to design or specification requirements unique to ft:1i: F es or activities licensed by the Commission...." However, the in-spector noted that the items purchased in the above purchase orders are to be installed in the Containment and that specific requirements have been established in the RRR (reference Para-
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graph 3.b)for such items to ensure their operability.
This item is unresolved pending further NRC review of the licensee's basis for not invoking 10 CFR 21 for procurement of safety-related components designated for use in areas having specific
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requirements (80-05-05).
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(2) The inspector also identified that the purchase orders referenced in (1) above did not delineate specific conditions / requirements established in the RRR (reference Paragraph 3.b) for which the items must qualify (i.e. environmental).
The procured items appeared to be off-the-shelf, suitable for commercial application and not for use in a specific nuclear environment.
This item is unresolved pending further NRC review of licensee data and evaluations qualifying these commercial items for the specific nuclear environment in which they will be used (80-05-06).
(3) The inspector examined the certificates of compliance (C0C)
issued by the applicable vendors for items procured on purchase orders 86019, 86097 and 86522.
The inspector noted that the certificates did not reference the items or materials used to either a purchase order or specification requirements in that:
The COC for 86019 qualified the item to a catalog number
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The COC of 86097 simply certified that the item had been
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shipped and no changes were made The C0C of 86522 did not specify the type of flame test that
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was utilized for qualification
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This item is unresolved pending further NRC review of licensee acceptance criteria for certificates of compliance (80-05-07).
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6.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncom-pliance, or deviations. Unresolved items are discussed in Paragraphs 3.b(2),4.b(1),4.c(1)and5.b(1),(2)and(3).
7.
Exit Interview The inspectors met with the licensee representatives (denoted in paragraph 1) at the conclusion of the inspaction on February 29, 1980 The inspectors summarized the purpose, scope and findings of the inspection.
During this meeting,. the unresolved items and deviation were identified.
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