IR 05000320/1977003
| ML19207B232 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/28/1977 |
| From: | Fasano A, Keimig R, James Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19207B231 | List: |
| References | |
| 50-320-77-03, 50-320-77-3, NUDOCS 7908230640 | |
| Download: ML19207B232 (19) | |
Text
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II:I Forn 12 Qar 75) (Rev)
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U. S. NUCLEAR REGULATORY CC1Cd.ISSION 0?? ICE OF I:is?EC ICN CD E i?ORCDir.fr
REGION I
IE Inspection Report No:
50-320/77-03 50-320 Decket No:
Lic ensee :
Metropolitan Edison Company License No :C? ? R-6 6 s
Box 542
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Reading, Pennsylvania 19603
Ca tego ry:
Safecuards
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Lcca tio n:
Three Mile I s'l a n d Unit 2,
Middletown, PA
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Type of Inspection:
Routine, Unannounced Dates of Inspec tion:
January 12-11.,
1977 Dates of Previcus Inspection:
January 10-13, 1977
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Reporting Inspector:
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th, h tor Inspecdor CAII I
J Acco:panying Inspectors:
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) _2.V/7 7 A.
N. In a n ce Reactor Inspector
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G. Nap /da, Reactor Inspector DATE DATE Other Accenpanying Personnel:
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Raviesed 3y:
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K ep'i g, Chief., Nuclear Support S e : :. o r I DA~E R.
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Reactor Operations and Nuclear Support 3ran:h l
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SDDdARY OF FINDINGS
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Enfo rce=ent Action None.
Licensee Action on Previousiv Identified Enforcement Items Not inspected.
Design Chances None reported.
Recortable Occurrences None identified.
Other Sicnificant Findines A.
Current Findincs 1.
Acceotable Areas (These are areas which were inspected on a sa=pling basis and findings did not involve an Ite: of Noncompliance, De-viation, or an Unresolved ites.)
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Surveillance Testing and Calibration.
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Test and Measurement Equiptent.
2.
Unresolved Items (These are items for which more information or additional time is required to deter =ine if the item is Acceptable, a Deviation, or an Item of Noncompliance.)
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a.
77-03-01 - Procedure not available which describes the tethods to be used to assure that the cuality program reviews are properly conducted.
(Detail 3)
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b.
77-03-02 - All procedures that describe the functions of independent review bodies, as required by ANSI 13.7 1972, were not available.
(Detail 3)
c.
77-03-03 - Procedures do not describe how confir=ation of corrective action will be acco=plished or the need and criteria for reauditing.
(Detail 4)
d.
77-03-04 - Procedure AP 1001, Revision 5, does not specifically address control over P&ID 's.
(De tail 5.a)
e.
77-03-05 - Inspection criteria for =2intenance activi-
- ties.
(Detail 6.a)
f.
77-03-06 - Recording identification of person or persons performing inspection of work.
(Detail 6.a)
g.
77-03-07 - Recording cause for =aintenance activity.
(Detail 6.a)
h.
77-03-08 - Assess =ent of adequacy of the Preventative Maintenance Prograc.
(Detail 6.a)
.
1.
77-03-09 - Fire watch connunication capability :: the control room.
(Detail 6.a)
j.
77-03-10 - Incorporation of design changes and modifi-cations into operation training progra=s.
(Detail 7)
k.
77-03-11 - Procedure GP 0031 does not implement ANSI N45.2.9 in that record receipt control is not addressed.
(Detail 3.a)
1.
77-03-12 - Procedure GP 4407 does not i=plecent ANSI N45.2.9 in that the packaging and storage of special processed records is not addressed.
(Detail S.b)
n.
77-03-13 - Procedure G? 4407 does not i=plement ANSI N45.2.9 in that the storage of records to prevent danage from condensation is not addressed.
(Detail 8.b)
n.
77-03-14 - No procedures available to cover the areas of transfer of construction phase records, agreement of records with transmittal document, retention periods of records not covered by the FSAR or Technical Spec-ifications, and authorization for dispo sal of records no longer required.
(Detail S.d)
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3.
Deviations None identified.
B.
Status of Previousiv Unresolved Itens None inspected.
Managenent Interview A.
Entrance Interview An entrance interview was conducted at the site on January 12, 1977, with the Unit 2 Superintendent and the Supervisor of Quality Control.
During the meeting, the inspectors described the scope, estinated duration, personnel to be contacted, and records to be reviewed as part of the inspection.
3.
Exit Interview An exit interview was conducted at the site on January 14, 1977, at the. conclusion of the inspection with the following licensee attendees:
Metropolitan Edison Concany (Met Ed)
Mr. R.
W.
Bensel, Electrical Engineer Mr. M. Be: illa, PORC Secretary Mr. W.
W.
Cotter, Supervisor of Quality Control Mr. D. Dubiel, RP Supervisor Mr. G. P. Miller, Unit 2 Superintendent Fz. J. E. Morck,.NMchanical Engineer Mr. D. Shovlin, Supervisor Maintenance Mr. J. F. Stacey, Security Supervisor Mr. A. Tsaggaris, Training Supervisor Mr. N. A. Willians, PCRC Chairnan, Unit 2 General Public Utilities Service Corcoration (GPUSC[
Mr. R.
F. Fenti, Quality Assurance Auditor Mr. M. A. Nelson, Technical Engineer Mr. R. J. Toole, Test Superintendent The scope and objectives of the inspection were discussed and the inspection findings were presented as detailed in the report.
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DETAILS 1.
Persons Contacted Metrocolitan Edison Cocoany (Met Ed)
Mr. R. W.
Berrsel, Electrical Engineer Mr. 'M. Be: illa, PORC Secretary Ms. S. H. Bonneville, Adminis trative Assistant Mr. W. W. Cotter, Supervisor of Quality Control
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Mr. 'D. Dubiel, HP Supervisor Mr. G. P. Miller, Unit 2 Superintendent Mr. J. E. Morck, Mechanical Engineer Mr. J. P. O' Eanlon, PORC Chair =an, Unit 1 Mr. D. Shovlin, Supervisor Maintenance Mr. J. F. Stacey, Security Supervisor Mr. A. Tsaggaris, Training Supervisor Mr. N. A. Williams, FORC Chairman, Unit 2 General Public Utilities Service Corocration (GPUSC)
Mr. R. F. Fenti, Quality Assurance Auditor Mr. M. A. Nelsen, Technical Engineer Mr. R. J. Toole, Test Superintendent 2.
Inscection Bases The bases for this inspectica included 10 CFR 50, Appendix 3 criteria, Section 17.2 of the FSAR - Quality Assurance Progra:
for Station Operations, and the implenenting procedures.
The inspectors reviewed the procedures that i=ple=ent Section 17.2 of the FSAR to determine that they are in co=pliance with regu-latory requirements and the licensee's co==itments.
3.
QA/0C Administration The inspector verified that the licensee had established proce-dures to:
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Identify the ite=s and associated activities within the a.
scope of the QA program; guy 41 q Q a
e,
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a b.
Control any changes as to the applicability of the QA progra=;
Control the approval / distribution cycles of the QA/QC Depart-c.
=ent procedures.
The procedures reviewed included the following:
GP 0001, Origination, Pro =ulgation, and Revision of Generation
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Divisi n Procedures, Revision 4.
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GP 00 Te=porary Changes to Procedures, Revision 1
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GP 0018, The General Review Co==ittee, Revision 1
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GP 1008, Quality Assurance Syste=s Lists, Revision 1 GP 1008, Quality Assurance Syste=s Lists, Revision 1
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GP 4016, Audi Program Revision 2
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The licensee is co==itted to perfor= periodic overall reviews of the ef fectiveness of the QA progra: and assigns this responsibility to the Vice President and Manager - Generation.
However, the in-spec:or identified that there is no procedure that describes the
=ethods by which it can be deter =ined that this review is acco -
plished within the require =ents of governing regulations and standards and to assure that these reviews and the conclusions drawn therefrom are indeed valid.
This ite=, 77-03-01, QA Progra= Ef fectiveness Review, is unre-solved.
The licensee has assigned the responsibility to perfor= the required (ANSI 13.7-1972) idependent reviews to two co==ittees, identified as GRC and GCR3.
The procedure defining the charter for GCR3 was unavailable.
The licensee stated that such a procedure has been established and will be cade available.
This ite=, 77-03-02, Independen: Review Bodies, is unresolved pending review of the addi:ional documents by an NRC inspector.
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4.
Audits The inspector verified tha: the licensee has established procedures defining:
'/90076
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a.
The scope of the audit program, b.
The independence, qualification and training of auditors.
c.
Audit scheduling and i=plementation requirement >.
d.
Audit report distribution and response channels.
e.
Quality personnel duties and responsibilities.
The procedures reviewed included the following:
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GP 4001, QC Personnel Authority, Responsibilities and Duties, Revision 0.
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GP 4003, Quality Assurance Personnel Training, Revision 1.
GP 4015, Audit Finding Closecut Progra=, Revision 2.
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GP 4016, Audit Program, Revision 2.
ANSI 18.7 and 45.2.12 require that corrective action inple=enta-tion be confirmed and reaudits perfor=ed when necessary.
The inspector identified that these subjects were not addressed in the available procedures.
The licensee stated that this area would be reviewed.
This ite=, 77-03-03, Corrective Action Confir:ation and Reaudits,
is unresolved.
5.
Docu=ent Control a.
Drawing Control The licensee's procedures were reviewed and it was verified that ad=inistrative controls have been established for drawings that:
(1)
Require that current as-built drawings will be pro-vided to the plant site in a timely canner;-
(2)
Provide for the control of obsolete drawings ;
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(3) Assure that discrepancies found between as-built drawings and as constructed f acility are handled as 'tesign Changes ;"
(4)
Responsibilities are assigned in writing to assure the above items will be inplemented.
The following procedures were reviewed for verification of the findings above.
Where verification was lacking it is so noted as an unresolved ites.
.AP 1001 Revision 5 TMI Procedure Control GP 1015 Revision 2 Preparation, Approval, and Review of As Built Drawings.
AP 1001 Revision 5, Enclosure 11, Drawing and Operator Card Control.
As a result of the above review, the following unresolved ites was identified:
77-03-04, Procedure AP 1001, Revision 5, Enclosure 11, 'trawing and Operator Card Control," does not specifically cover control of Piping and Instru=ent Diagra=s (PSID 's).
b.
Master Indices The licensee's procedures were reviewed to verify that they require the =aintenance of naster indices for drawings, =anuo.s,
Technical Specifications, FSAR's, and procedures, which indicate the current revision and censures are docu=ented that.
(1)
Provide a =echanism for their issuance and distribution; (2)
Require that they be periodically reviewed; (3)
Assign responsibilities in writing to assure the above will be i=plemented.
The following procedures were reviewed for verification of the findings above:
AP 1001, Revision 5, IMI Procedure Control GP 1015, Revisien 2, Preparation, Approval and Review of As Euil: Drawings.
'i30G763
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6.
Maintenance a.
Corrective Maintenance The licensee's corrective =aintenance progra= i=ple=enting procedures have been reviewed to verify that criteria and responsibilities have been established for:
(1)
Review and approval of =aintenance requests including e=ergency =aintenance requests; (2)
The basis f'or designating the activity as safety /non-safety related; (3)
The designation of perfor=ance of work inspection of
=aintenance activities.
The licensee's corrective maintenance was also reviewed to verify that:
(4)
Written procedures have been established for initiating requests for routine and e=ergency =aintenance; (3)
Provisions and responsibilities have been established for the identification of inspection hold points re-lated to naintenance activities; (6)
Methods and responsibilities have been designated for perfor=ing functioning testing following =aintenance work and/or prior to being returned to service; (7)
Administrative controls for =aintenance activities record; have been established; (8)
Responsibilities to asse=ble and review =aintenance records have been established; (9)
A progra= has been established for reviewing co=pleted corrective =aintenance records to assess the adequacy of the preventive maintenance progra=, to identify repetitive failures of parts, co=ponents, and to identi-fy design deficiencies;
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(10) Responsibilities have been assigned to assure i=ple-mentation of records review; (11) Work control procedures require special authorization for activities involving welding, open flame, or other ignition sources and that they take cognizance of nearby flammnble caterial, cable trays, or critical processes equipment;
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(12) Work control procedures require a fire watch, with capa-bility for cot =unication with the control room, if an
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activity identified in -(11) above is to be perfor:ed.
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The following procedures were reviewed for the verification of the above.
Where verification was lacking it is so noted as an unresolved item.
The following procedures were reviewed:
GP 1003, Revision 2, Control of Design Changes / Modifications; A? 1001, Revision 5, TMI Procedures Control; A? 1002, Revision 5, Tagging; AP 1016, Revision 9, !=plementation and Control of Station Maintenance and Modification,'
GP 4004, TCM #1, Revision 0, Review of resign Specificatica and Require =ents; GP 1008, Revision 1, QA Syste=s List; G? 4001, TCM #1, Revision 0, QC Personnel :uties, Authority, and Responsibilities;
.
GP 4012, Surveillance Program, Nonconfor= ante Reports and Stop Work Orders; G? 1021, Evaluation of Tests and Test Results;
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A? 1007, Controls of TMI Records; GP 0035, Levision 0, Reporting of Significant Operation Ex-perience;
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GP 1029, Revision 1, Review of Evaluation of Significant Operational Experiences; GP 1019, Revision 1, Qualification of Personnel Perfor=ing Special Processes; GP 0026, Revision 1, Control of Welding History Records for TMI; GP 1017, Revision 1, Control of Met Ed Perforced Special Processes; 1410-Y-26, Welding and Cutting Procedures for Fire Safety; AP 1020, Cleanliness Require =ents.
The above procedures were reviewed resulting in the following unresolved ite=s:
77-03-05 - The use or designation of criteria to be used in the perfor=ance of work inspections by the inspector of =ain-tenance activities appeared to be lacking;
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77-03-06 - In tha activity of administrative controls for maintenance records of recention, notation was lacking that specifies the identification of persen or persons performing inspection of work; 77-03-07 - Administrative controls for =aintenance records of retention, specifying cause for caintenance activity, appears to be lacking; 77-03-08 - With respect to a program for reviewing ccepleted corrective maintenance records, there is lacking specific reference to an analysis progra to review correc:ive main-tenance activities (records) to assess the adequacy of the Preventive Maintenance Progran, and to identify repetitive failures of parts and cocponents; 7-03-09 - With respect to work ccr trols, especially in the activities requiring a fire *-atch, requirements f or cot:unica-tion capability to the control rco= and control roo= contact when work starts, is in progress, and is ccepleted, appears to be lacking.
9000 _
11 b.
Preventive Maintenance The licensee's ?reventive Maintenance program was reviewed for the inclusion of the following:
(1)
Responsibility for the program; (2)
Master schedule for preventive =aintenance; (3)
Docu=entation and review of co=pletion of preventive
=aintenance activities;
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(4)
Responsibilites and methods for establishing preven-tive maintenance frequencies.
The inspector had no further questions on the Preventive Maintenance Program.
c.
Cleanliness Control Procedures have been developed for the cleaning of safety related cocponents and syste=s.
The inspector nad no further questions in this area.
7.
Design Char.ges Design Change Control The licensee's procedures were reviewed to verify that controls have been established for:
Design and codification change requests; a.
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Design control responsibility;
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c.
Design docu=ent control; d.
Administration of design changes and modifications to assure that they will be incorporated into:
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(1)
Plant procedures; (2)
Operating training programs; (3)
Updating plant drawings.
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The following procedures were reviewed for verification of the findings above.
b'here verification was lacking it is so noted as an unresolved item.
AP 1016, Revision 9, I=ple=entation and Contrc ? of Station Main-tenance and Modifications.
GP 0018, Revision 1, Generation Review Committee.
GP 1003, Revision 2, Control of Design Changes / Modifications.
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GP 1015, Revision 2, Preparation, A; proval, and Review of As Built Drawings.
GP 4004, TCM #1, Revision 0, Review of Design Specifications and Require =ents.
As a result of the above review the following unresolved item was identified:
77-03-10, Procedure GP 1003, Revision 2, " Control of Design Changes /
Modificat;-
3," does not i=placent the requirecents of the licensee's co=siement to ANSI N 45. 2.11, paragraph 2. 2, item 7, in that no provision has been =ade to assure that desi7n changes and modifica-tions will be incorporated into operator et ining progra:s.
further review of the Design Changes / Modifications implementing a
procedures sill be conducted at a fu:ure inspection.
S.
Records a.
Records to be >Mintained The licensee's procedures were reviewed to verify that require-
=ents and provisions to maintain the follow.ng types of records have been established:
(1)
Preoperational and startup tests; (2)
Nor=al reactor operation including operatin'g logs; (3)
Principal maintenance activities:
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(4)
Design changes and =odifications including safe:y evalua-tions associated with 10 CFR 50.59 type changes; (5)
Reportable occurrences; (6)
Surveillance test results; (7)
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Baseline data id inservice inspections; (3)
On and offsite safety co=mittee =eeting =inutes; n'
(9) Procure =en documents; (10) Receipt inspection and testing; (11) QA audit reports; (12) Personnel training records; (13) Safety related calibration results; (14) Personnel qualification records; (15) Special reactor tes: and experi=ents It was verified that responsibilities have been assigned in the procedures to assure that the above records will be main-tained.
The following precedures were reviewed for verification of the findings above.
Where 7erificarica was lacking it is so noted as an unresolved itet.
A? 1007, Revision 0, Control of Records.
GP 0031, Revision 0, Quali:y Assurance Records Collection, Storage and Maintenance for TMI.
As a result of the abree revie.., the following. unresolved ite was identified:
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77-03-11, Procedure GP 0031, Revision 0, does not i=ple=ent the require =ents of the licensee's co=mit=ent to ANSI.N45.2.9, Paragraph 4.3, dealing with record receipt control, which states: "As a =ini=u=, a receipt control syste= shall include:
1.
A records check list designating the required quality assurance records.
2.
A record of quali:y assurance records received.
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3.
Procedures for receipt and inspection of inco=ing re co rds. "
b.
Record Storate The licensee's procedures were reviewed to verify that record storage controls have been established in accordance with FSAR co==it=ents which acco=plished :he following:
(1)
Describe the record storage facili:y for the records identified in 8.a above.
(2)
Designate a custodian in charge of record storage faci-lities.
(3)
Describe the
'ing syste= to be used to allcw for the retrieval of records.
(4)
Make provisions for governing access to files and for
aintaining an accountability of records renoved fr:
the storage facili:y.
The following procedures were reviewed for verification of the findings above.
- ihere verification was lacking, it is so noted as an unresolved ite=.
AP 1007, Revision 0, Control of TMI Records.
GP 0031, Revision 0, Quality Assurance Records C611ection, Storage and Maintenance for TMI.
GP 1026, Revision 1, Control of Engineering Records.
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GP 4407, Revision C. Regulatory Recention and Storage of Quality Control Department Records.
As a result of :he above review, the following unresolved items were identified :
77-03-12 - Procedure GP 4407, Revision 0, "Regulatery Re-tention and Storage of Quality Control Depart =ent Records,"
does not address the require =ents of the licensee 's co==it-
=ent to ANSI N45.2.9, paragraph 5.4, ite= 3, which states:
"Special processec records (such as radiographs, photographs, negatives, and =icrofil=), which are ligh: sensi:ive, pressure sensitive and te=perature sensitive, shall be packaged and stored as recoc= ended by the =anufacturer of these =aterials."
77-03-13 - Procedure GP 4407, Revision 0, does not address the require =ents of the licensee's co==it=ents to ANSI N45.2.9 paragraph 5.4, ite= 1, which states :
" Provisions shall be
=ade in the storage arrange =ents to prevent damage fro:
condensation."
c.
Record Retention The licensee's procedure No. AP 1007, Revision 0, " Control of TMI Records," was reviewed te verify that provisions have been =ade which establish the retention period for the type of records iden:ified in 3.a.
d.
ANSI N45.2.9 I=ple=entation The licensee's co==i:=ent to ANSI N45.2.9 has not been fully i=ple=ented in the form of procedures.
ANSI N15.2.9, para-graph 2.1 states in part "...the quality assurance records syste= should be defined, i=plemented and enforced in accor-dance with vritten procedures...." No procedures were available which adiressed the following areas:
(1)
The assign =ent of responsibilities and controls to assure the transfer and retention of construction phase records.
.
(2)
Confir=ation that the record trans=ittal document is in agree =ent with the records received.
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(3)
The assign =ent of responsibility for es:ablishing re-tention periods for records not covered by the FSAR or Technical Specifications.
(4)
Providing authorication for the disposal of records no longer required.
(77-03-14)
9.
Surveillance Tes tine and Calibration The inspector verified that the licensee had es:ablished proce-dures describing the:
.
Master scheduling requirements and sys tem responsibilites ;
a.
b.
Review and evaluation of obtained data and any necessary followup; Calibrati~cn cycle program status and work requirements; c.
d.
Inclusion of all safety related itecs as well as those appearing in the Technical Specifications.
The docurents/ procedures reviewed included the following:
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Master Instrument Lis: (computericed).
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Standard Technical Specifications - Section 6, Administra-tive Controls, Revision 0.
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A? 1010, Technical Specification Surveillance, Revision 10.
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AP 1022, Control of Measuring and Test Equipment, Revision 2.
10.
Test and Measurement Equiptent The inspec:or verified that the licensee had established procedures describing the:
a.
Equipment inventory and recall requirement;
,
b.
Calibration cycle, reference standards and work requirements; Evaluation / reinspection of itens accepted wi:h defective c.
equipment; 730087
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d.
Identification and control of calibrated equip =ent; Duties and responsibilities for the calibration system.
e.
The procedures reviewed included the following:
AP 1022, Control of Measuring Test Equiptent, Revision 2.
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AP 1023, Test Equip =ent Recall, Revision 1.
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11.
Preoperational Progra: Status and Schedule
.
Emergency Plan - June 1, 1977 Security Plan I=ple=enting Procedures - March 1, 1977 (Plan) and July 15, 1977 (procedures)
Operational QA Progra I=ple=entatien - August 15, 1977.
Power Ascension Test Program Procedures - July 18, 1977.
Radiation Health Physics Procedures - June 1, 1977.
Operating Procedures - June 1,1977.
Environ = ental Monitoring Progra: !=ple=entation - On going.
Plans are to have an Emergency Plan drill in late August 1977.
The following is a su==ary of the current status of Facility Procedures:
Total No.
Cecole ted ' o.
1 Co=cleted Operational Procedures 113
58 Surveillance 161
20
"
E=ergency
21
"
Maintenance
26 S1
"
Ad=inistrative "
14
"
Security
16
Health Physics "
49
Chemis t ry
53
"
Fuel Handling
35
"
Overall Facility Procedures Co=pletion 537.
Alar = Responses 1250 756 6 0P.
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The Structural Integrity Test and the Integrated Leak Rate Test are expected to be conducted in August 1977.
The Cold Hydro Test procedure (draf t) is expected to be co=pleted by March 1, 1977.
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The Hot Functional Test is tentatively scheduled for July 1977.
Test procedures are expected to be co=pleted in June 1977.
Fuel Leading is tentatively planned for >'ld October 1977.
Fuel loading procedure are expected to be complete by nid July 1977.
The zero power test procedures should be co=plete by July 1977.
The Power Ascension procedures have not been written to date.
Initial writing of these procedures is expected to begin by March 1, 1977.
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