IR 05000320/1977004
| ML19220B645 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/03/1977 |
| From: | Architzel R, Dante Johnson, Keimig R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19220B644 | List: |
| References | |
| 50-320-77-04, 50-320-77-4, NUDOCS 7904270162 | |
| Download: ML19220B645 (13) | |
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U. S. NUCLEAR REGUL\\ TORY CC:DiISSION OFFICE OF INS?ECTION AND ENFORCDiE!TT RECION I E Inspection Report No: _ 50-320/77-04 Docket No:
50-3?0 Licensee: Metropolitan Edison Comeanv License No:
coco _cc Box 542 Priority:
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Reading, Pc-ylvania 19603
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Category:
B1 Safeguards
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Group:
Location: Middletown, Pennsylvania (TM1-2)
Type of Licensce:
Typ of Inspecticn:
Poutine. t!n=nnnunced Dates of Inspection: ___ Fe bru a ry 1-3. 1977 Dates of Previous Inspection:
_ January 1?-14, 1977 Reporting Ins ~rtor:
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D. F. Jahhson, Reactor In pector DATE Accompanying Inspectors:
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R. E. Architzel, Reactor Inspector DATE I
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DATE Other Accc=panying Personnel:
fl0NE DATE Reviewed By:
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R.f.Keimig, ef, N -
'ar Support Section No. 2, dATE
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's Reactor Ope'
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SUMMARY OF FINDINGS Enforcement Action
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None.
Licensee Action on Previously Identified Enforcement Items
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Not inspected.
Desion Chances None identified.
Unusual Occurrences
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None identified.
Other Significant Finoings A.
Current Findings
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Acceptable Aeeas
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These are areas which were inspected on a samplit ;
findings did not involve an Item of Noncompliance basis and
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or an Unresolved Item.
. Deviation, Administrative Controls for Review and Approval of a.
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Facility Procedures.
(Details 2.b c, d, and h)
b.
Administrative Controls for the Preparation, Revision and Issuance of Facility Procedures, Including Tempo Changes.
(Detail 2.e)
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Administrative Controls for Special Procedures c.
2.f)
(Detail
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d.
Scope of Coverage for Facility Procedures.
exceptior, of items 2.d and e. below)
(with the (Detail 3)
Format of Administrative Procedures.
e.
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f.
Administrative Controls for Operi. ting Logs and Shift Turnover.
(Detail 6)
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Unresolved items Tha.e are iteme far which more information is required to determine if tr ; '~.m is acceptable.
a.
T,-04-01 Completion Status of FacilP.y Procedures.
(Detail 7)
b.
77-04-02 Periodic Review of Facility Procedures.
(Detail 8)
c.
77-04-03 Administrative Controls for Starding Orders.
(Detail 9)
d.
77-04-04 Scope of Procedural Coverage for General Plant Operating Procedures.
(Detail 3.c)
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77-04-05 Scope of Procedural Coverage for Administrative Pro-cedures.
(Detail 3.d)
f.
77-04-06 AP-1009, Station Organization and Chain of Command.
(Detail 5.a)
g.
77-04-07 AP-10ll, Controlled Key Locker Control.
(Detail 5.b)
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h.
77-04-08 AP-1012, Shift Relief and Lig Entries.
(Detail 5.c)
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77-04-09 HP-1630, Reactor Building Entry.
(Detail 5.d)
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Status of Previously Identified Unresolved Items B.
Not inspected.
Manacement Interviews A.
Entrance Interview A pre-inspection meeting was held onsite with Mr. G.
The following items were discussed:
Technical Support.
1.
Purpose and scope of intpection; 2.
Tentative duration of inspection; Organization and responsibiliites of the plarit staff; and, 3.
4.
Recent industry events.
B.
Exit Interview A manage ent meeting was held onsite at the conclusion of the inspection on February 3,1977, to discuss the findings of the ins.nection as detailed in this report.
The following personnel were in attendance-Mr. M. Bazilla, PORC, Secretary Mr. G. Miller, Unit 2, Superintendent Mr. J. Seelinger, Unit 2, Superintendent, Technical Support Mr. A. Tsaggaris, Training Supervisor Mr. N. Williams, PORC, Chairman Mr. R. Architzel, USNRC Mr. D.' Johnson, USNRC Mr. W. Ruhlman, USNRC Mr. A. Fasano, USNRC (_
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_ DETAILS 1.
_ Persons Contacted Mr. M. Bazilla, PORC, Secretary Mr. J. Brummer, Instrument and Control Engineer
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Mr. J. Floyd, Supervisor of Operations Mr. C. Gutherie, Shi f-t Foreman Mr. R. Hutchison, Shift Foreman Mr. T. Mackey, Engineer, Nuclear Mr. G. Miller, Unit 2 Superintendent Mr. D. Neumann, Shift Foremar.
Mr. J. Seelinger, Unit 2 Superintendent, Technical Support
A. Tsac aris, Training Suparvisor Mr. G. West, Control R]om Operator Mr. N. Williams, PORC, Chairman 2.
Administrative Controls for Facility Procedures The inspector reviewed the following Administrative Proced
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ures:
(1)
AP-1004, " Emergency Plans and Procedure l
(2)
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October 28, 1976.
. 6, (3)
AP-1007, " Control of Records," Rev. O, October 26 (4) AP-1016. " Implementation and Control of Station Maint
, 1973 and Modifications," Rev.11, November 19, 1976, b.
that administrative controls have been estab cedures review and approval of the following categories of procedu r the res:
(1) Administrative; (2) General Plant Operation; (3)
Startup, Operation and Shutdown of Safety Related Systens; (4)
Combating Emergencies, and Other Sig (S)
(6)
Control of Radioactivity; (7)
Control of Measuring and Test Equipment; (8)
Maintenance; (9)
Chemical and Radiochemical Actiiities;
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(10)
Refueling; and, (11) Emergency Plans.
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The inspector verified that the review and approval specified c.
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in the above listeJ administrative prccedures, is in accordance with ANSI N.18.7 " Administrative Controls for Nuclear Power Plants" Section 5.4 and the requirements of the Technical Specifications, Section 6.8.2.
d.
The inspector verified by review of the above listed procedures and interviews held with licensee pers;nnel that responsibilities have been assigned to assure that the procedures icentified in 2.b above will be reviewed and approved as required.
The inspector verified that controls have been established for e.
the following:
(1)
Preparation of proceoures listed in 2.b above including the required format and content.
(2)
Issuing new and revised procedures.
(3) Control / disposal of outdated procedures.
(4)
Controlling temporary changes to procedures.
(5) Assuring procedures will be approved at the same level and organization that approved the original document.
(6)
Assure that the training organization is apprised of a i
change to procedures.
f.
The inspector verified that administrative controls for Special Orders have been established that:
(1)
Provide a mechanism for their issue and distribution.
(2) Require that they be periodically reviewed and updated.
(3)
Responsibilities were assigned in writing to assure 2.f.(1) and (2) above will be implemented.
(4) Limitations on what type of instructions may be issued as Special Orders.
The inspector reviewed the following procedures on a sampling g.
basis:
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(1)
2103-1.1, Filling and Venting the Reactor Coolant System, Rev. O, June 24, 1976 (2) 2104-1.1, Core Flood, Rev. O, December 9,1975.
(3)
2202-1.8, Loss of Decay Heat Removal, Rev. O, October 18, 1975.
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(4) 2204-8.Al, Reactor Buildi.1g Pressure Hi.
Rev. O,
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September 14, 1976.
(5) 1602, Radiation Dose Rate Survey, Rev. 3, September 13, 1976.
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(6)
IC-5, Level Lcoo Calibiation, Rev. 1, December 16, 1976.
(7)
2301-M4, Remote Shutdown Instrumentation,Rev. O, December 7,1976.
(8) 2401-1.3, Reactor Coolant Pump Motor P.emoval and Installation, Rev. O, June 7,1976.
(9)
2502-1.12, October 1,1976. Auxiliary Neutron Detector System, Rev. O, (10)
100a. Emergency-Plan and Procedures Volume I, Rev. 6, October 28, 1976.
(11)
1001, Document Control, Rev. 6. December 6,1976.
h.
The inspector verified that the procedures listed above were reviewed and approved in accordance with the licensee's administrative controls identified in items 2.a and b a i.
control of superseded procedures were in ac licensee's administrative controls identified in it and (3) above.
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The inspector verified that working copies (c
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No discrepancies were identified.
3.
Scope of Coverage of Facility Procedures The inspector reviewed the licensee's index of procedures a.
(dated January 24, 1977)
following categories:
for completeness of coverage in the i
(1) Administrative Procedures (2)
General Plant Operating Procedures Procedures for Startup, Operation, and shutdown of Sa V{
(3)
Related Systems
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b.
Within the scope of this review the inspec
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Systems,the licensee had met or exceeded the requirements ae i
Regulatory Guide 1.33, Appendix A, November,1972
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c.
The procedures identified by the licensee in Category (2),
General Plant Operating Procederes, had in the most part not been written.
This precluded a detailed review of the pro-cedures to ensure coverage.
This item (77-04-04) is Unresolved,pending the issuance of procedures by the licensee in this area and subsequent review by NRC.
d.
Within the scope of this review the inspector found that for Category (1), Administrative Proced.;res, the licensee had met or exceeded the requirements of Regulatory Guide 1.33 with the following exception:
Regulatory Guice 1.33, Appendix A, Section A.4 lists a re-I quirement for a written procedure to cover the area of Pro-cedural Adherence.
In addition, ANSI 18.7-1972 Section 5.1.2 specifies that the requirements for use of procedures shall be prescribed in writing and that guidance should be provided to identity the manner in which procedures are to be implemented.
It does not appear that the licensee has a procedure covering the area of procedural adherence and implementation.
The licensee stated that he would review this area to determine r
completeness of coverage.
This item (77-04-05) is Unresolved pending the licensee's actions.
4.
Format of Administrative Procedures The inspector reviewed the following administrative procedures and verified that each was in the appropriate format as specified in ANSI 18.7-1976 and his administrative controls:
Procedure No.
Revision Issued Title 1012
1/12/77 Shift Relief and Log Entries 1010
12/1/76 Technical Specification Surveillance
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Program 1013
10/8/76 Bypass of Safety Functions and Jumper Control 1002
8/6/76 Rules for the Protection of Men Working on Electrical and Mechanical Apparatus 1009
3/6/75 Station Organization and Chain of Command 1011
'10/26/76 Controlled Key Locker Control l
No discrepancies were identified.
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Technical Content of Facility Procedures The inspector reviewed the procedures listed below to verify that their technical content was adequate to assure satisfactory per-formance of intended functions.
Procedure No.
Revision Issued Title 1002
8/6/76 Rules for Protection of Men Working or.
Electrical and Mechanical Apparatus 1009
3/6/76 Station Organization and Chain of Command i0li
10/26/76 Controlled Key Locker Control 1012
1/12/77 Shift Relief and Log Entries 1013
10/8/76 Bypass of Safety Functions and Jumper
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Control 1630
7/1/76 Reactor Building Entry 2107-1.1
11/24/76 B0P Auxiliary Electrical With respect to the stated review criteria, the inspector identi-fied four Unresolved Items as discussed in Details 5.a through d below.
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AP-1009, Station Organization and Chain of Command The procedure stated the responsibilities and author; tics of the plant staff, however, those stated did not appear to completely cover the minimum requirements stated in ANSI 18.7-1972 specifically:
(1) The reactor operator's authority and responsibility for shutting the reactor down when he determines that the safety of the reactor is in jeopardy or when operating parameters exceed any of the reactor protection circuit setpoints and automatic shutdown does not occur.
(2) The responsibility to determine the circumstances, analyze the cause, and determine that operations can proceed safely before the reactor is returned to power after a trip or an unscheduled or unexplained power reduction.
(3) The senior reactor operator's responsibility to be present at the plant and to provide direction for returning the reactor to power following a trip or an unscheduled or unexplained power reduction.
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(4)
The responsibility to believe and respcnd conservatively to instrument indications unless they are proven to be incorrect.
This item (77-04-06) is Unresolved and will be reinspected during a subsequent inspection'by NRC.
b.
AP-10ll, " Controlled Key Locker Control'
This procedure includes the assignment of valves and their normal locked arrangement (open, closed) to the " Locked Valve Book" to satisfy Technical Specification requirements and FSAR P&ID drawing positons.
The procedure assigns responsibility for the addition, deletion, and changing of normally assigned position of these valves to the Operations Supervisor.
Since'
the Locked Valve List is an integral part of the Controlled Key Locker Control Procedure, any changes to AP-101.1 " Controlled Key Locker Control" or the Locked Valve List must be made in accordance with the requirements of Technical Specification 6.8.2 regarding procedure changes, which require a higher management level of approval and review than solely the Operations Supervicor.
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I The addicion, deletion, and changing of normal positions of valves in the Locked Valve Book by the Operations Supervisor is an Unresolved Item (77-04-07)
and subsequent review by NRC:1.
pending action by the licensee AP-1012. " Shift Relief and Log Entries" c.
This procedure includes a list of recommended books, logs, and procedures to be reviewed by the plant operating staff prior i
to relieving the off going shift.
AP-1001 Document Control, requires a daily review of the TCN (Temporary Change Notice)
Book and the Revision and Review Book.
The Revision and Review Book is included in the list of recommended books,
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logs, and procedures, however, the TCN book is not.
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exists between Procedure 1001 which requires a review, and procedure 1012 which recommends the review.
The list of i
recomended reviews does not appear to satisfy the require-ments of Regulatory Guide 1.114 which specifies that administra-tive procedures should be written to describe what is required and should include, as a minimum, a definition of proper relief.
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This item (77-04-08) is Unresolved and will be reinspected during a subsequent inspection by NRC.
d.
HP-1630, Reactor Building Entry This procedure incorporates a check sheet for use by the technician making the reactor building entry.
Blocks are utilized for the recording of as-found data, such as tritium, oxygen, explosive gas, particulate gaseous and radioactive iodine airborne, however, the acceptance criteria for these sample results are not included on the check sheet.
This item (77-04-09) is Unresolved and will be reinspected during a subsequent inspection by NRC.
The inspector had no further questions in this area.
6.
Administrative Controls for Operating Logs and Shift Turnover The inspector reviewed the following procedures:
AP-1001, Document Control, Rev. 6, December 6,1976.
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AP-1012, Shift Relief and Log Entries, Rev. 6. January 12, 1977.
The inspector verified, based on review of the above procedures, that the licensee has established administrative controls for the preparation and correction of operating logs, shift turnover activi-ties, and log reviews.
7.
Comoletion Status of Facility Procedures The inspector obtained the following current status of completion as of February 2,1977 for the facility procedures program.
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Procedure Category
- of Procedures
- reviewed by PORC % completed Operating Procedures 114
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Surveillance Procedures 1 61 64.9
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Abnorral and Emergency
24.2 Procedures
71.9 Maintenance Procedures
27 Administrative Procedures
90.0-15 68.2 Health Physics Procedures
51 52.6 Chemistry Procedures
53 68.8 Fuel Handling Procedures
37 84.1 l
Security Procedures
17 94.4
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d The inspector stated that the above procedures should be comple by three months prior to fuel load.
The licensee concurred with the inspector's comment and stated target date for completion is June,1977.
The inspector further stated that the Office of Inspection and d
Enforcement NRC:1, would review the above procedures when dures to determine with reasonable assurance that the licensee's proce are adequate to guide the safe operation of the facility.
is Unresolved pending the licensee's completion This item (77-04-01)
of the above procedures and review by NRC:I.
Periodic Review of Facility Procedures _
8.
The inspector identified that the current revisio specifies a three year review for plant procedures.
The inspector stated that ANSI N18.7 Section shall be reviewed by an individual knowledgeable (
to determine if changes are necessary or desirable."
The licensee concurred with the inspector's comment and stated A 1001 " Document Control" would be revised to include a two year periodicity for review of plant procedures.
is Unresolved pending the licensee's revision This item (77-04-02)
of AP-1001.
Administrative Controls For Standing Orders 9.
The inspector's review of the licensee's admin
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areas:
A methanism for their issuance and distribution.
Requirements that they be periodically revi a.
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and (b) above will be implemented.
c.
Limitations on what type of instructions may be issued as d.
Standing or Special Orders.
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ANSI N18.7 Section 5.2.3, Operating Orders, states in part "a mechanism shall be provided for dissemination to the plant staff of instructions of general and continuing applicability to the conduct of business... Provisions should be made for periodic review and updating of standing orders.
This item (77-04-03) is Unresolved pending action by the licensee
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