IR 05000289/1980027
| ML19345D631 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/08/1980 |
| From: | Bettenhausen L, Keimig R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19345D630 | List: |
| References | |
| 50-289-80-27, NUDOCS 8012160309 | |
| Download: ML19345D631 (11) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No.
50-289/80-27 Docket No.
50-289 License No.
DPR-50 Priority Category C
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Licensee:
Metropolitan Edison Company 100 Interpace Parkway Parsippany, New Jersey 07054 Facility Name:
Three Mile Island - Unit 1 Inspection at:
Middletown, Pennsylvania Inspection conducted:
September 10-30, 1980 Inspectors:
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7/do L. Be'ttenhausen, Ph.
D., Reactor Inspector date signed date signed Approved by:
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[ R. R. Kei d Chief actor Projects date signed Section '. 1, Rg a Branch Inspection Summary:
Inspection on September 10-30, 1980 (Report No. 50-289/80-27)
Areas Inspected:
Unannounced inspection of maintenance activities related to con-
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cerns expressed in pre-hearing proceedings of Atomic Safety and Licensing Board. The l
inspection involved 50 inspector-hours onsite by one NRC region-based inspector.
l Results:
No items of noncompliance were identified.
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Region I Form 12 (Rev. April 77)
8()12 0 309 L
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DETAILS 1.
Persons Contacted R. Barley, Lead Mechanical Engineer G. Dirk, Quality Assurance Enginaer D. Dyckman, Supervisor, Corrective Maintenance
- L. Harding, Licensing Engineer Z. James, Quality Assurance Engineer M. Ross, Supervisor of Operations C. Seitz, Operations Engineer
- H. Shipman, Operations Engineer
- D. Shovlin, Superintendent of Maintenance M. Snyder, Supervisor, Preventative Maintenance
- R. Toole, Manager, Unit 1 P. Velez, Supervisor, Radiological Controls
- J. Wilson, Attorney J. Wright, Quality Assurance Manager The inspector also contacted foremen, records clerks, administrators and similarly classified staff members.
- Denotes persons present at Exit Interview on October 3,1980.
2.
Introduction The purpose of this inspection was to examine concerns that became evident-in review of depositions of present and former Metropolitan Edison plant staff regarding maintenance activities.
The following concerns were used as the basis for the inspection:
Operators deactivating audible alarms in the Control Room;
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Cancellation of safety meetings during outages;
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Boron accumulations in drains and on floor of Reactor Building;
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Budget cutbacks in Maintenance Department in 1979; Inadequate Quality Control surveillance;
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Various concerns with leakage, vibrations and other indications of maintenance inadequacies;
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Delays in performance of work requests; allowing problems to exist until an outage.
This inspection report discusses tha inspection conducted into each of these areas of concern and the results of that inspection.
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3.
Removal of Control Room Instruments and Alarms from Service Area of Concern:
Deactivation of audible alarms by control room operators.
The administrative control for out-of-service (00S) instruments and read-out devices is Administrative Procedure 1036, Revision 2, approved 7/18/79.
The original procedure was issued 3/1/78. This procedure requires control room operators to identify and log 00S instruments, then assure Work Re-quests are submitted to correct the identified problems. The inspector audited the 00S instrument log and compared the 00S tags on control room instruments with the log entries.
The 00S instrument log has 80 active entries; over half of these are consequences of restart modification work or long-term layup of secondary plant equipment. The inspector's spot check of 00S tags on control room instruments and indicators revealed no discrepancies between 00S instrument log entries and tags. Of 600 panel alarms, 9 bore 00S tags.
The inspector noted an informal practice of placing a white sticker with handwritten notes on an annunciator whose circuit card was pulled.
Two such white stickers were observed.
In one case, the operator placed the sticker and pulled the circuit card on a system which was actively being worked upon; the operator had notes of the activities on his scratch pad and noted the name of the working technician on the sticker.
The operator stated that it was his intention to replace the card and remove the sticker at the end of his shift.
In the other case, a white sticker annotated
" card pulled" was placed on annunciator panel 0-1-4, " Heat Trace Troubles."
The inspector was ~ unable to ascertain from the operators why that sticker had been placed and the alarm card pulled.
When the inspector identified the situation to the Shift Supervisor, the sticker was removed, the alarm circuit card replaced and the alarm light lit.
The inspector discussed the causes of this alarm with the Shift Foreman and j
the Shift Supervisor.
The inspector was shown switching and tagging orders l
dating back to 1975 to open heat trace breakers which would result in the alarm. The Shift Foreman also presented current progress in a recent effort l
to identify all tagged equipment and problem areas in heat tracing. An l
operators' status report on heat tracing is anticipated on/about October 3, l
1980.
The inspector's review of the instrument out-of-service procedural controls and interviews with Unit 1 and Unit 2 control room operators did not reveal
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any intentional, systematic deactivation of audible alarms.
The procedural
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control and operator familiarity with the controls appeared effective in identifying instrument and alarm problems.
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4.
Industrial Safety Meetings Area of Concern:
Cancellation of safety meetings during outages.
Metropolitan Edison (Met Ed) company policy on industrial safety meetings is set forth in a memorandum " Safety Meetings - Departmental," August 12, 1980,(superseding 11/7/74 memo).
The policy memorandum states that safety meetings are important to Met Ed's safety program and that it is company policy that all employees attend safety meetings scheduled for their depart-ments.
The memorandum states that most departments meet bi-monthly.
In addition, each generating plant shall have a Plant Safety Committee that meets bi-monthly, preferably in the month following the regular general safety meeting (memorandum " Safety Committees, Plant-Generation," July 2, 1975).
The committee is to be composed of a minimum of 4 members, 2 from management and 2 union members.
The inspector reviewed the minutes of the Safety Committee meeting held at
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Three Mile Island on June 20, 1980, and the General Safety Meeting held April 11,1980, the most recently held meetings.
The General Safety Meeting of April 1980 was the first held since July 20, 1979.
General industrial safety meetings were held regularly at two-month intervals until the March 28, 1979 accident at TMI Unit 2.
The July 20, 1979, meeting was held subsequent to the accident.
The Met Ed safety manager then decided to suspend general safety meetings because of the widespread personnel changes and temporary assignments which had occurred.
Company policy on general safety meetings was reaffirmed on August 12, 1980 in the aforementioned memorandum. A licensee representative stated that this policy !s now in effect.
The inspector reviewed attendar.ce records of the April 11, 1980, meeting and verified that about 245 individuals attended.
The inspector also noted that an additional presentation on one of the principal meeting topics -
back problems and lifting - was presented on April 23, 1980, to 10 main-tenance employees who missed the general meeting.
Records were also reviewed for general safety meetings held August 22, 1978; October 9, 1978; December 8, 1978; February 2,1979.
This covered the time period just before the 1979 refueling outage.
The next regularly scheduled safety meeting would have been held in April,1979.
This meeting was postponed (the Unit 2 accident)
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and was conducted on July 20, 1979.
The inspector had no further questions.
On the basis of policy statements, discussions with licensee representatives and attendance records, the inspector could find no evidence that safety meetings were cancelled during the 1979 refueling outage.
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5.
Housekeeping Inspections:
Identification of Leaks, Trash Accumulations, Safety Hazards and General Conditions of Cleanliness Area of Concern:
Boron accumulations, valves leaking.
Plant housekeeping inspections are done weekly as set forth in Administra-tive Procedure AP 1008, " Good Housekeeping," Revision 7, dr:ed 3/10/80.
This revision differed little from Revision 4, dated 9/26/78.
The pro-cedure was initially adopted 3/30/77.
Inspections of the various plant areas are conducted by department supervisors or their designates. A written report of discrepancies is forwarded to the Superintendent of Maintenance for his action. The 17 plant areas to be inspected are rota-tionally assigned to the 9 department supervisors, including the Unit Manager.
The procedure suggests, but does nct require, that the record of findings be maintained for 12 consecutive inspections.
The inspector reviewed inspection findings from 1/7/80 to 9/12/80. Only one report of the 324 reviewed noted any leakage; three minor leaks were noted on components located on the 281' elevation of the auxiliary building in the course of the housekeeping inspection of 2/15/80. The leakage was identified on job tickets for the areas or components where the leaks were noted.
Since a record of findings is not required and, therefore, not retained, the results of other previous inspections were not available to the inspector.
In another approach to identification and repair of leaking valves, the in-spector identified two Licensee Event Reports (LER) from the 1979 refueling outage period involving leaking valves.
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LER 79-005/03L identified leakage of the Decay Heat Removal System in ex-cess of Technical Specification 4.5.4.1 during performance of a leakage surveillance on 2/25/79. Valve packing glands on DH-V-15A, DH-V-158, OH-V-6A, DH-V-5A and BS-V-3B were identified as leaking. Work requests for removal of boron encrustation and adjustment of the packing glands were i
made on 2/25/79. The field work was completed on 3/4/79. A retest by performance of leakage surveillance procedure SP-1303-11.16 was done on 3/6/79. The results were satisfactory.
The inspector reviewed both sur-veillance tests, the unsatisfactory one on 2/25/79 and the satisfactory one l
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The inspector had no further questions.
LER 79-006/3L identified unsatisfactory performance of the, valve CA-V-5B during a local leak rate test on 2/28/79. Repair work was done with an existing work request, #25568. Field work was completed 3/1/79 and the
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valve successfully leak tested. The inspector reviewed the notations in the
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machinery history file for these valves and the completed work reques.
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The inspector discussed the leak reduction program for systems outside containment with cognizant licensee representatives.
This leakage reduction program is described in 52.1.1.8 of the Three Mile Island 1 Restart Report, November, 1979.
The program incorporates existing leakage surveillance tests and identifies tests and surveillances to be developed to meet the program goals. This program has been reviewed by NRC and found to meet the requirements of a Leakage Reduction Program (NUREG-0680 p. C8-32).
No tests had been completed under this program at the time of this inspection.
The inspector concluded that existing and developing methods of leakage identification and correction are adequate.
On the basis of the sample reviewed, leakage in systems important to safety was corrected in an appro-priate interval of time.
6.
Maintenance Budget Cuts Area of Concern:
Maintenance budget cuts affect safety-related maintenance.
The inspector discussed the TMI 1 and 21979 maintanance budget cuts with the Superintendent of Maintenance (S/M).
The S/M offered the following budget figures to place the budget into perspective:
1979 Maintenance Budget
$5,800,000 Proposed Budget Reduction,
$622,000 5,178,000 including Defe ral of LP Turbine Inspection (TMI-1)
200,000 and
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Contract Force (TMI-1)
180,000 Net Reduction in budget
$242,000 Net reduction as percentage of reduced budget 4.7%
Further discussion of effects of the proposed budget cuts are speculative.
The LP turbine inspection (B and C sections) was included as an add-on option to -the turbine-generator inspection contract.
The option was to be f
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exercised if outage time und funds were available.
The LP turbine inspection / overhaul was act due until the projected 1980 outage. When the outage remained on schedule and a budget reduction was needed, the LP turbine inspection option was dropped.
Reduction of other contract maintenance - Gilbert Associates technical support, Mercury Company instru;nent preventative maintenance, Catalytic Contract maintenance - was in progress in March, 1979.
A significant portion of contract maintenance reduction - elimination of continuing contracted on-site maintenance support - was not scheduled to be imple-mented until April,1979, following the refueling outage at TMI-1.
Interviews with maintenance foremen and supervisors concerning the impact of budget cuts on maintenance activities elicited responses that there was no impact upon the size of the Met Ed maintenance force and no measurable impact on performance of maintenance.
The inspector also determined that, on 3/28/79, the combined Met Ed maintenance forces for Unit I and Unit 2 were 173 persons,. excluding contractor support.
The present (September 1, 1980) Met Ed maintenance force for Unit 1 alone is approximately 170 per-sons, excluding contractor support.
The inspector could find no evidence that the 1979 maintenance budget cuts affected safety-related corrective maintenance in this review of budget areas cut or scheduled to be cut.
The inspector could not determine the effects of apparent preventive maintenance deferral on safety-related equipment since this would only be speculation.
7.
Oudity Control for Maintenance Activities Area of Concern:
Inadequate quality control surveillance of maintenance activities.
Quality control for maintenance activities was a routine area of NRC in-spection. An examination of eleven NRC inspection reports in the period 1976-1979 which documented inspection of corrective and preventive main-tenance during routine plant operations and outaces did not reveal any un-
- acceptable conditions involving quality control.
The licer.see substantially :evised the Operations Quality Assurance Plan and implementation of quality catrol surveillance. Sections 6.2.1.10 thru 6.2.1.12 of the Operational Quality Assurance Plan, Revision 8, April 18, 1980, address quality control of preventive and corrective maintenance and surveillance testing and inspection necessary to assure that systems released l
for maintenance are returned to operable status. The quality control inspection program is defined in TMI-10-M0-002, Revision 0, effective 5/19/80,
"QA Modification / Operations Section - Inspection Program."
Inspection docu-mentation for this program is found in the "QA/QC Plant Inspection Report,"
(PIR), set forth in procedure M0-108-1, Revision 0.
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The program was staffed and implemented on a pilot basis in June,1980 and fully implemented effective 9/2/80.
For corrective and preventive maintenance, the QC inspection staff parallels the maintenance disciplines:
mechanical, electrical and instrumentation / control.
The inspector discussed the QC implementation with principal inspectors in mechanical and instru-mentation / control areas.
The QC rn iew begins with a review of all work requests involving systems important to safety.
The review includes work to be performed, appropriate instructions and procedures, and material controls.
If the procedures to be performed have not received QC surveil-lance within the past two years, it is stamped for QC notification 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> prior to performance and appropriate hold or witness points marked in the procedure. A surveillance plan is developed to inspect the work, the pro-cedural performance, testing, housekeeping and other significant features of the job. A QC inspector is then notified when the job is to be performed and inspects according to the previously developed plan and his overall knowledge. A Plant Inspection Report is completed for the job and is cross-indexed by job ticket, procedure, discipline and a unique PIR number.
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the QC staff is included in the closecut review chain of the work request.
The inspector verified PIRs and QC surveillance on Work Request C3503 per-formed by Mechanical Maintencnce on 9/7/80 and Work Request C3523 performed by Instrumentation and Control on 8/7/80.
Due to new organization and opera-tions, these were the only surveillances performed on Unit 1 maintenance activities in these disciplines under the PIR system.
The inspector concluded that the QA/QC PIR system is beginning to functica effectively on the basis of this initial sample.
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Maintenance Work Requests Area of Concern:
Delaying work order performance.
The formal system for identifying and tracking corrective maintenance for TMI Unit 1 is described in Station Corrective Maintenance Procedure 1407-1, Revision 6, dated 10/15/79.
Any plant staff member can identify the need for corrective maintenance and document it on a work request form, desig-nating the component (s), the request date, the recommended priority for correction, the malfunction or problem and the cause, if known.
The form is then routed to the plant staff member's supervisor and to the Superintendent of Maintenance (S/M).
The S/M or his designate assigns a unique Job Ticket Number; Work Order Number and Component, Location, Accounting, and Plant Condition Codes.
On the basis of component and malfunction descriptions, job priority is assigned (usually agreeing with the requestor) and a review for further involvement is made as applicable:
QC for quality-listed components, Health Physics for Radiation Work Permit and ALARA considerations, need for special procedures and review for safety considerations.
When the
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job package - including special or routine procedures tnd notification or hold points for Quality control - is complete, it is routed to the discipline foreman who will be responsible for the job.
The foreman assigns the work crew.
The work crew obtains and completes the Tagging Application for removing equipment from service, if required, and obtains the Shift Foreman's approval to begin the work.
On completion of the field work and the foreman's review, the job performer clears equipment tags and obtains the Shift Foreman's assurance that tags are cleared and the component is properly aligned for post-maintenance testing.
Upon satisfactory completion of the testing, the maintenance foreman annotates the work request and returns it through the original approval chain to the S/M for closecut.
The Work Request file is a manual system with compaterized logging ar.d tracking.. The ir,3pector analyzed the licensee's Job Ticket tracking data for 1980 to obtain the following monthly averages for the first 8 months:
Priori ty
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4 New Jobs
78 105
Completed Jobs
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1 Jobs Outstanding
300 427 100 An average of 41 jobs per month were cancelled because of duplication, work withet adequate justification, consolidation with similar job or related reasons.
The monthly average of job tickets outstanding for the pr.riod April - August,1980, was 883.
The inspector reviewed the computer printout for Corrective Maintenance Component History Job Tickets completed in the period August 1-31, 1980; 114 jobs were completed in this period and, in addition, 17 were cancelled.
In terms of priority, they were Priority 1,10 jobs; Priority 2, 31 jobs; l
Priority 3, 73 jobs; and Priority 4, no jobs.
The inspector selected all
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jobs designated Priority 1 and certain of those designated Priority 2 or 3 l
for a detailed review of the completed job package.
These job tickets are l
sumarized in the table below:
Job'No.
Request Field Work Complete Priori ty Brief Description
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C 1298 6/29/79 2/ 21 /80 8/11/80
Install signs @ Scott Air Packs C 2959 4/11/80 8/15/80
Calibrate instrumi.ats for Ventilation, Aux & FH Bldg
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Job No.
Request Field Work Comoleg Priori ty Brief Description C 0207 1/12/79 Cancelled 8/14/80
Modify CR Ventilation Control-Change not desired C 3745 7/31/80 8/13/80
Bad Level Indication -
Aux Boiler Steam Drum
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C 3345 6/6/80 6/27/80 8/21/80
Core Flood Valve Indicator C 1487 7/31/79 8/7/80
Reset Relays When 340 hp Motor Replaced on DH-P-1B C 3024 4/24/80 6/12/80 8/12/80
Repair Emergency Diesel as Identified by Annual Irspection 15477 5/18/76 Cancelled 8/12/80
Duplicate of 25441 C 0519 2/17/79 6/26/80 8/4/80
Nkeup Valve 139D Covered w1 3 Boron; Packing Leak C 3217 6/9.1/80 8/4/80 8/8/80
LT-2 and LT-3 differ by 14 inches C 2342 1/18/80 3/15/80 8/11/80
Chain Nitrogen Bottles (Safety)
C 3677 7/21/80 8/1/80 8/11/80
Recharge Portable Eye-wash (Safety)
C 3665 7/22/80 7/30/8C 8/5/80
Replace Lock Guards (Security)
C 1076 5/28/79 6/7/79 8/11/80
feplace Door Closers (Security)
C 2490 2/10/80 6/25/80 8/14/80
Inop Fence Alarms (Security)
C 1982 11/2/79 Cancelled 8/13/80
SR Pump Doesn't Work -
Included in WR 0962 (See following job no.)
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(0962)
11/2/79 11/6/79 i
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Job No.
Request Field Work Complete Priori ty Brief Description C 1503 8/4/79 8/5/79 8/11/80
Repair Control Room Doc' Closer
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C 1801 9/27/79 10/1/79 8/8/80
Door Closer; Door Latch (Security)
C 0027 12/8/78 12/15/79 8/11/80
Repair r =r::s'h (Safety)
C 3060 4/25/80 7/22/80 8/8/80
Install Ladder Extension (Safety)
On Job Number C 1076, there was no approval signature by the Unit Superin-tendent agreeing that an approved procedure was not required for the work.
When the inspector pointed this out to the licensee representatives, they annotated the job ticket with the fact that the job involved door closers for security purposes and had no impact on operational nuclear safety.
The inspector reviewed the computer generated list of corrective mainte-nence outstanding job tickets for 9/8/80.
There were 1260 outstanding jobs. Of these, 320 had field work completed awaiting paperwork, 334 were workable and 606 were identified as not workable for such reasons as await-ing parts, needing engineering evaluation or QC review or requiring proce-dJre development.
On the basis of this sampling and other reviews of maintenance work, the inspector concluded that actual maintenance field work is accomplished in a timely fashion, consistent with priority and importance to safety.
It is also evident that the closecut review of work completed lags, in some cases,18 months behind actual job performance.
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Exit Meeting The inspector met with representatives of the licensee ( as denoted in i
paragraph 1) on October 3, 1980.
The purpose and findings of the inspec-tion were presented.
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