IR 05000289/1989082

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-289/89-82

ML20058P804
Person / Time
Site:	Three Mile Island
Issue date:	08/15/1990
From:	Gallo R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Hukill H GENERAL PUBLIC UTILITIES CORP.
References
NUDOCS 9008200099
Download: ML20058P804 (2)

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Docket'No. 50-289- AUG 15 NGO-GPU Nuclear Corporation ATTN: Mr. H. D. Hukill Vice President and Director of TMI-1 P. O. Box 480 Middletown, Pennsylvania 17057 Gentlemen:

. Subject: Inspection No. 50-289/89-82 This refers to your. letter dated July 9,1990, in response to our letter dated April 12, 1990.

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Thank'you for informing us of the actions to enhance maintenance activities as documented =in your letter. These actions will be examined during a future inspection of your licensed program.

Your cooperation with us is appreciated.

Sincerely,

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Origina1 Signed By n

ROBERT M. GALLO

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Robert M. Gallo, Chief Operations Branch Division of Reactor Safety

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CC: . .

T..G. Broughton, Operations and Maintenance-Director, TMI-1 C. W. Smyth, Manager, TMI-1 Licensing R. J. McGoey, Manager. PWR Licensing E. . L.' Blake, Jr. , Esquire THI-Alert (TMIA)

Susquehanna Valley Alliance (SVA)

Public Document Room (PDR)

Local Public Document Room.(LPDR)

Nuclear'SafetyaInformation Center (NSIC)

NRC~ Resident Inspector

' Commonwealth of Pennsylvania n \

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C"3D (50/

OFFICIAL RECORD COPY BAVNACK/50-289/7/26/90 - 0001,0.0

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-l GPU Nuclear Corporation N U CI M F- Post Office Box 480 Route 441 South Middletown, Pennsylvania 17057 0191 717 944 7621 TELEX 84 2386 Writer's Direct Olal Number: -

C311-90-2094 U. S. Nuclear Regulatory Commission Document control Desk Washington, D.C. 20555 ,

Dear Sir Three Mile Island Nuclear Station Unit I, (THI-1)

Operating License No. DPR-50 Docket No. 50-289 GPUN Response to Weaknesses Identified in Inspection Report 89-82 NRC Maintenance Team Inspection a-This letter transmits GPUN's responses to the. weaknesses identified in the Maintenance Team Inspection report (IR) 89-82. The report requested notifica-tion of the actions taken or planned in order to enhance.the maintenance activities pertaining to the weaknesses described therein. In the: case of each of the six identified weaknesses, actions taken ar planned to enhance the-Maintenance Program by their resolution are provided.

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Sincerely, t

l D. Hu 111 Vice President & Director, THI-1-HDH/WGH Attachment cc R. Hernan AT." Martin l 7 J. Stols F. Young h UO7J 90 Uh I --

$PC GPU Nuclear Corporation is a subsidiary of General Public Utilities Corporation

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Attachment 1 Weakness 1 identified three specific problems with the use of engineering-evaluation requests (EERs) by Plant Engineering as addressed below:

1 An inspector was unable to locate several EERs from the 1986 time-frame. These EERs were hand carried and not properly routed and con-trolled as required by procedure. As noted by the Inspection Report the EERs were located in the work package. The problem occurred when EERs were hand carried through the approval chain by the end user. The end user was unaware of the need to go through the Engineering Clerk to close'out log entries and make formal distribution.

Response To prevent recurrence, the EER number will be assigned by-Plant Engineering, thus ensuring Plant Engineering knows the EER is active and is engaged in addressing it. The QA Engineers have been

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. instructed to provide a copy of the signed EER to the end user and return the original to the Engineering Clerk for administration and distribution.

, 2 A quality deficiency report (QDR) noted by an inspector identified that the EER procedure was not properly implemented-in that work was com-plated prior to the completion of the EER routing and disposition.

Response Both Plant Materiel and Plant Engineering personnel have been reminded to assure that documented approval is'obtained prior to proceeding with the work. The QDR has been closed.

3 The inspector noted that the EER backlog was almost double the goal established and that the on site engineering staff is somewhat over-loaded with work in this area.

Response: The number of EERs in Plant Engineering is excessive.

Actions are underway to 1) reduce that portion of the EER total which is " backlog" (chronologically late items) and 2) to work off the new, incoming EERs on a schedule which keeps Plant Engineering current.

Our plan of attack for backlog work reduction in 1) to schedule the backlog items for work execution by appropriate engineers so that between July and December 1990 the backlog items are appropriately.

addressed and 2) by December those items remaining as " outstanding backlog" are acceptable both in number and content and are also accept-able with regard to future completion dates.

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Our. plan of attack for new, incoming EERs is to assign to.them pre-

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established work execution spans (60 days) and.to manage them in ,

earnest according to those spans.

Further, we plan to change the procedure which governs Plant Engineer-ing's effort on EERs to ensure front-end agreement is reached between the requestor and engineer on the priority, due date (if other than 60 !

days) and technical content of the requested evaluation.

In the interim, sufficient controls are in place to prevent adverse +

impact on safety. The sources of most EERs are Materials Management

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(Purchasing / Stores), Plant Operations or Plant Materiel. Those EERs '

determined to be more significant to safe operation of.the unit are from operations and Plant Materiel. Priority items are identified at the F.aily and monthly planning meetings. In addition, periodic meet-ings are held with operations and Plant Materiel Departments to review their open requests.

Weakness 2 states that " Generic procedures are frequently used in work packages without indication as to which portions of the generic procedure are

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applicable to the work to be performed". .

Response GPUN believes that the use of generic procedures fulfills the objectives of its maintenance philosophy. The objectives in the use of generic procedures are:

{ e to maintain a reasonable number of procedures vice an extremely large number which would result from providing an unnecessary level of detail for qualified workers and e provide good quality generic procedures which provide the user with options for many conditions and contingencies that may be encountered.

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The technicians are qualified through a formal process to perform the work-l identified in the procedures; this includes understanding when to. follow an alternative path because the conditions dictate.

H We agree that work packages can be improved by making it clearer which portions of generic procedures apply to a specific job. Guidelines will be developed for work package preparation to reference, extract or' identify in some appropriate way the portions of the generic procedures which are applica-ble, when this can be determined during the planning process.

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Weakness 3 centered on three issues identified in the area of Vendor Document control. The inspector addressed lost manuals, preventing use of lost replaced manuals and manuals that are not entered into the control system.

Response The responses to these issues. follow in respective order:

1 There are about 45 unique distribution points for the approximately 10,000 manuals issued. An audit of the manuals was performed in 1989, three years af ter the control program was implemented. Thirty-six manuals were identified as missing by the audit. Although this is.a relatively small percentage of missing manuals over the three year

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period, it is expected that the number can be further reduced. In that vein, a memo has been issued to all major distribution point department heads stressing the importance of proper sign out of manuals and overall document control.

2 Cognisant department heads must request, in writing on a proprinted form, a replacement manual once a manual is determined to be lost.

This form requires the department to destroy the lost. manual if found.

This form was in place at the time of the inspection and was reviewed, e- by the inspector. These controle are currently more stringent than the controls on procedures. They are viewed to be adequate and no further action will be taken.

3 A number of " personal copies" of vendor manuals do exist. These docu-monts are considered training materials and as such, may be used as references for' understanding equipment operation. The documents may be annotated by their owners and are not controlled or updated. Direction has been given to all Maintenance personnel to destroy uncontrolled manuals which are no longer useful and to stress the Laportance of compliance to the administrative procedure prohibiting use of anything but controlled manuals for work on safety related equipment.

Weakness 4 identified the need to improve the storage of some material in the warehouse.

Responset The Nuclear Warehouse Manager has/will take the following actions to improve the conditions of stored material as addressed belows e A meeting'was held with Warehouse Supervisors / Administrators to discuss the condittons identified by IR 89-82. These personnel were directed to increase their awareness and identification of storage conditions that require improvement during regular and informal inspections / tours

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and during the normal course of work. Thev were also directed to be responsive to conditions identified by empidy==c or visitors that may need attention.

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A training program was developed specifically to address storage condi-tions as established by GPUN procedures and ANSI standards. Training, L

of most warehouse personnel has been completed and will be scheduled in

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the near future for those who have not yet attended. The material will i

be included as a training subject for warehouse personnel biennially.

e The Warehouse will also be scheduling personnel to conduct a row by row physical inspection / corrective action activity. This hands on activity-is intended to correct not only the items specifically addressed, valve caps and snubbers, but also any additional items that might be identi-fled.

It is intended to complete this activity by October 31, 1990.

Weakness 5 identified inadequate correcti.e action for quality assurance findings associated with in-plant storage of equipment in shop areas and the control of test equipment. 4

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Responset Though corrective actions specified in response to our internal -

GPUN Quality Deficiency Report (QDR) 027-89 have had a positive effect, they did not meet all of the program requirements. Plant Material Department management recognizes the inadequacy of that action and has developed correc-tive actions which will address this weakness. These actions were described as part of the response to the Notice of Violation 89-82-01 items B and C, and include increasing the scope and frequency of checks on in-plant stored materials and measuring and test equipment, providing training to responsible persons on procedural requirements and purging uncontrolled / unneeded materi-ale.

Weakness 6 identified the failure of periodic procedure reviews to identify significant deficiencies in the procedures associated with slings and hoisting I equipment contro !

Response The quality of the procedure reviews is a recognized weakness.

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a result, in March 1989, as part of a significant effort to upgrade mainte-nance procedures, a staff position was created to produce a procedure writer's p

guide, provide training on its use and finally provide input on procedure revisions. The procedures cited were biennially reviewed prior to the new review program's implementation and the inspection. The procedures are currently in the review cycle having had improvements made to them. The upgrade process is on going with the initial review cycle improvements to all

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maintenance procedures to be completed by November 1991.

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