IR 05000320/1976005
| ML19220B318 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/25/1976 |
| From: | Mccabe E, Ruhlman W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19220B314 | List: |
| References | |
| 50-320-76-05, 50-320-76-5, NUDOCS 7904250631 | |
| Download: ML19220B318 (7) | |
Text
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I Form 12
(Jan 75) (Rev)
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U. b. NUCLEAR REGUL\\ TORY CC'CIISSIO:i
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OFFICE OF I:iSPECTION MiD EliF02CCIE::T
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REGION I
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IE Inspection Report No:
50-320/76-05 Docket No:
50-320 Licensce:
Metropolitan Edison Co:::pany License No: CPPR-66 Box 542
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Priority:
Reading Pennsylvania 19603 Category:
w _3 Safeguards Loca tion:
Three Mile Island, Unit 2 Middletown, Pennsylvania pe of Licensce:
' PWR (B&W) 2772 Mut Type of Inspection:
Routine, Unannounced, SU&T OA Procram Dates of Inspection:
March 18 and 19, 1976 Dates of Previous Inspection:
February 23-25, 1976 Reporting Inspector:
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W. A. Ruhlman, Reactor Inspector Accotspanying Inspectors:
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DATE DATE EATE
Other Accenpanying Personnel None DATE
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I.avicued By: \\
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DATE E. C. Mc be, Jr., Actin Section Chief Nuclear Support Section No. 2
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SUMMARY OF FINDINGS
Enforcement Action Nene.
Licensee Action on Previously Identified Enforcemear Items Not inspected.
Reportable Occurrances None identified.
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Othcr Significant Findings A.
Current 1.
Unresolved Items These are items for which more information is needed to determine if the items are acceptable, Deviations, or Items of Nonce =pliance.
a.
76-05-1:
Resolution of discrepancies between the TMI-2 FSAR, Chapter 17.2 and the Startup and Test Quality Assurance Plan.
(Detail 2.a)
b.
76-05-2:
Revision of Section XVIII of the Startup and Test Quality Assurance Plan to document management's intert?.ons with respect to the qualification and training of QA audit personnel.
(Detail 2.d)
c.
76-05-3:
Issuance and implementation of a procedure / program for training and qualification of QA audit personnel.
(Detail 2.d)
2.
Followup Ite=s These are items which require additional research and inspection thac vill be followed up during a subsequent inspection, a.
76-05-4:
Rev:ev of completed surveillance and inspection documentation for systems under the S tartup and Test Quality Assurance Plan.
(Detail 2.b)
b.
76-05-5:
Review of completed audit reports documenting audits conducted under the Startup and Test Quality Assurance Plan.
I (Detail 2.c)
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B.
_ Status of Previousiv Unresolved Items The Unresolved Itea identified in Report 50-320/76-03 at 76-03-3 is
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resolved.
(Detail 3)
Management Interview An exit management interview was held onsite on March 19, 1976 at the completic of the inspection; the persons listed below were attendees.
]Hetropolitan Edison Cocoany Mr. G. P. Miller, Unit 2 Superintendent (by phone and copy of exit minutes)
General Public Utilities Serv'ce Corporation Mx. R. F. Fenti, Quality Assurance Auditor Mr. P. A. Levine, Quality Assurance Auditor Mr. M. A. Nelson, Technical Engineer Mr. R. J. Toole, Test Superintendent The inspector discussed the implementation of the Startup and Test Quality Assurance Plan with respect to three Unresolved Items identified and documented in the attached inspection report.
76-03-3 was also identified.
The resolution of item e
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i DETAILS
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Persons Contacted Metropolitan Edison Company (Me t-Ed)
Mr. J. R. Floyd, Supervisor of Operations-Unit 2 Mr. G. P. Miller, Unit 2 Superintendent General Public Utilities Service Cornoration (GFUSC)
Mr. R. F. Fenti, Quality Assurance Auditor Mr. P. A. Levine, Quality Assurance Auditor Mr. M. A. Nelson, Technical Engineer Mr. M. J. Stromberg, Seniar Site Quality Assurance Audito:
Mr. R. J. Toole, Test Superintendent Mr. R. F. Wilson, Manager af Quality Assurance (phone only)
Mr. J. E. Wright, Site Quality Assurance Manager United Engineers and Constructors, Incorcornted (UE&C)
Mr. R. T. Carlson, St a.rtup Engineer Mr. S.
Kakarla, % rtup Engineer 2.
Startup and Test Qt211tv Assurance Program The inspector reviewed the Startup and Test Quality Assurance Program with respect to the description in the application (FSAR Chapter 17.3)
and the Metropolitan Edison Company QUALITY ASSURANCE PLAN FOR STARTUP AND TEST, THREE MILE ISLAND NUCLEAR STATION - UNIT 2 (QA Plan). The licensee has designated a service organization (CPUSC) the responsibi-lity for execution of the QA Plan.
The results of the review, based on naterial furnished by and discussions held with licensee and licensee representative personnel, are summarized below, a.
Program Manacement The inspector interviewd approximately 50% of the key personnel in the onsite QA organization to verify that they understood their basic respontibilities; no inadequacies were identified.
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-4-The inspector reviewed the QA Plan, Revision 3 dated 2/27/76, to determine that formal requirements relating to authority and responsibility of individuals and groups managing the quality assurance program or performing quality related functions, in-cluding the responsibility for periodic review / audit of the status and adequacy of the Plan itself, were establisheu and in accord-ance with Chapter 17.3 of the FSAR.
During that review, the in-consistencies noted below were found.
(1) The FSAR states in part in Chap ter 17.3.1.l(2) that the Met-Ed Test Auditor reports to the Met-Ed Vice President; the QA Plan states in part in item 1.A.2 that he reports to the Manager of Operational Quality Assurance.
The FSAR reference also included, as part of the Test Auditor's responsibilities, the duty to assure that tests do not cause a deviation f rom "... warranties or design require-ments"; these quoted duties uere not assigned in his write-up in the QA Plan.
(2) The FSAR states in part in Chap t er 17. 3.1. l (1) t ha t the GPUSC Project Manager is responsible for initial fueling activities; Revision 3 to the QA Plan eliminated this aspect of responsibi-lity from those listed for the CPUSC Proj ect Manager in iten I.B.l.
(3) References in the FSAR (e.g. Chapter 17.3.1. 2 (4 )) to a "Vice President, Design and Construction" parallelled QA Plan references to a "Vice President, Generation Division".
According to the licensee representative, the latter title is correct.
The licensee representative stated that he would review Chapter 17.3 of the FSAR and that, in addition to the specific inconsistencies identified above by the inspector, any other inconsistencies found between the FSAR Chapter 17.3 and the QA Plan would be resolved by changes / revisions to the appropriate document (s).
The licensee representative further stated that these changes / revisions would be
. targeted for ccmpletion by July 1, 1976.
Until the revision / changes have been completed, this is an Unresolved Item (76-05-1)
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Surveillance and Inspection The inspector reviev nd "QC" procedures / checklists which had been established for the onsite QA/QC organization's use for review and monitoring cf Startup and Testing activities.
Collectively, these procedures / checklists covered: conduct of testing; tracking of test deficiencies; test documentation; document control; cont ol of neasuring and test equipment; cleanliness control; field c'.aages and modifications; main-
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tenance during preoperational testing; a_d quality assurance records.
The inspector also verified, both by document review and by direct questioning of personnel, that responsibilities had been established f or conducting the required surveillance and inspections.
Controls were also establfshed to assure notification of individuals or groups responsible when significant deficiencies are identified and for assuring corree-tive actions, including reinspection where appropriate, are taken on identified deficiencies.
While the inspector identified no inadequacies in the estab-lishment of the controls and responsibilities, actual im-plementation by review of completed documentation was not com-pleted at this time since no activities under the Startup and Test Phase of the Program had been ccepleted.
This item (76-05-4) will be followed up in a subsequen inspection after the defined program has been implemented, c.
Audits The inspector verified, both by direct ques t ionina f personnel and review of documents, that responsibilities ha. been assigned for: overall management of the audit progra=; approval of audit procedures / checklists; assuring corrective actions are taken where required; determination of reaudit requirements; issuance of audit reports; and, periodic review of the audit program to determine its status and adequacy.
In addition: subj ect areas to be audited and audit schedules had been defined; methc ds/
prc 2dures were defined for taking corrective actions on audit fin.ings; and, distribution requirements had been delineated.
While the inspector identified no inadequacies in the controls listed dbove, actual implementation by review of Completed audits was not completed at this time since no audits had been completed under the Startup and Test Thas= af the Program.
Audits were scl.eduled to start in March; the fi. t audit was scheduled for the week of 1brch 22, 1976. This item (76-05-5) will be followed up in a subcequent inspection af ter the defined program has been i=plemented.
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d.
Training, Oualification and Independence of Audit Personnel The inspector verified that written requirements had been
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established in.the FSAR f or the minimum education / experience requirements for supervisory personnel in both the onsite and offsite organization and for QA surveillance, inspection and audit personnel.
By review of selected resumes, the inspector verified that the offsite supervisor, onsite supervisor, senior auditor and other audit personnel met or exceeded the established minimum qualifications.
The inspector noted in his review of the QA Plan that while other aspects of Critcrion XVIII of 10 CFR 50, Appendix B were addressed, the intentions of management with respect to qualifications and training of QA/QC personnel was not in-cluded. The licensee representative stated that this aspect of Criterion XVIII would be addressed and included in the QA Plan by May 1, 1976.
Until the plan har been revised to in-clude this infor=ation, this item (76-05-2) is Unresol red.
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While a draf t procedure had been prepared for comment covering the program for training / qualification of QA personnel, the procedure had not been approved or issued.
The licensee representative stated that a procedure / program specitying the requirements f or QA personnel training and qualification would.
be issued and implementation started by July 1, 1976. Until the procedure / program is issued and implemented, this iten (76-05-3) is Onresolved.
All personnel currently scheduled to perform audit activities have independence by nature of the organizational structure.
The licensee representative acknowledged that, at soce time in the future, personnel not organizationally independent might be used. The representative further stated that, if and when such personnel were used, independence would be assured and docu=ented.
The inspector had no further questions on this item at this time.
3.
Previousiv Identified Unresolved Item Detail 9 of Report 50-320/76-03 identified an item (76-03-1, with respect to control of measurement and test equipment which was un-resolved.
The inspector reviewed the controls and f ound that a sign-in, sign-out log had been instituted and was being used.
This item (76-03-3) is resolved.
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