IR 05000320/1978010
| ML19220A895 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/28/1978 |
| From: | Beckman D, Keimig R, Markowski R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19220A876 | List: |
| References | |
| 50-320-78-10, NUDOCS 7904250071 | |
| Download: ML19220A895 (16) | |
Text
U..C. NUCLEAR REGULATORY COMMISSION OFFIt.E OF INSPECTION AND ENFORCEMENT Region I Report No. 50-320/78-10 Docket No.
50-320 Category B(2)
License No.
OPR-73 Priority
--
Licensee:
Metrocolitan Edison Comoany P. O. Box 542 Readino, Pennsylvania 19603 Facility Name:
Three Mile Island Nuclear Station, Unit 2 Inspection at:
Middletown, Pennsylvania Inspection conducted:
February 22-24, 1978 Inspectors:
$ JUN&O /
/2f !70 Rf 5 M rK kl, Reactor inspector date igned
/
sh /
'~ut Secxman, xeactor inspector
' data signed
.
date signed
.
Approved by:
[
g.g[. M Nuclear Support date signed
/R. R.M, Ch Sec ion so. 2, NS Branch Inspection Summary:
Insoection on February 22-24, 1978 (Recort No. 50-320/78-10)
Areas Insoected:
Routine, unannounced inspection of QA/QC administration; audits; document control; maintenance; design changes and modifications; surveil-lance testing and calibration control; records; and, test and measurement equip-ment control. The inspection involved 55.5 inspector-hours onsite by two NRC inspectors.
Results: Of the eight areas inspected, no items of noncompliance were identified in six areas; two apparent items of noncompliance were identified in two areas (Infraction - two examples - failure to distribute drawings and drawing revisions, Detail 4.b; failure to mark and segregate out of calibration torque wrenches, Detail 9.b(1); and, Infraction - inadequate calibration procedure for torque wrench tester and torque wrenches, Detail 9.b(2)).
t
._
I 7.l. l S 1 Region I Form 12 l
(Rev. April 77)
7904250015
_
DETAILS 1.
Persons Contacted
J. Brummer, I&C Engineer A. Conrad, Maintenance Foreman
- W. Cotter, QC Supervisor E. Daniels, QC Group Leader R. Harper, I&C Supervisor W. Heysek, QC Specialist J. Hilbish, Station Nuclear Engineer
- G. Kunder, Unit 1 Superintendent - Tech. Support C. Leonard, Mechanical Maintenance Foreman - Welding T. Mackey, Engineer
!
J. McGarry, Mechanical Maintenance Supervisor j
W. Metzger, Maintenance Foreman C. Nixdorff, Admin. Supervisor
- J. O'Hanlon, Unit 1 Superintendent J. Potter, QC Specialist - NDE Coordinator J. Powell, QC Assistant
- J. Seelinger, Unit 2 Superintendent - Tech. Support D. Shovlin, Maintenance Superintendent A. Stowe, Record Retention Administrator D. Weaver, I&C Foreman The inspectors also interviewed other licensee employees during the conduct of this inspection. They included engineering, operations, maintenance, quality control and office personnel.
- denotes those present at the exit interview.
.
2.
QA/0C Administration
-
The inspector reviewed the licensee's implementation of QA program elements regarding quality control activities in order to determine if QC activities were conducted in accordance with established QA program requirements and that such activities adequately interfaced with maintenance, operations and other plant activities. The in-spector also reviewed and observed the following t'o determine if:
--
Scheduled QC surveillance activities were conducted using pre-pared checklists which included key inspection points and acceptance criteria;
,
The results of QC surveillance inspections sere documented in
--
and issued by formally prepared surveillance reports; t
-
i 71-1S2
s
Nonconformance reports were appropriately issued when noncon-
--
fonning conditions were noted; f
-
--
The schedule for QC surveillance activities was developed in an orderly manner by the site GC staff, coordinating the scheduled QC surveillances for both Units 1 and 2; QC personnel nominally assigned to Unit 2 were aware of and
--
were implementing the QC surveillance schedule; QC personnel were initiating unscheduled QC surveillances appro-
--
priately, based upon their routine review of Unit 2 Work Re-quests ;
^
Issued QC Surveillance Reports were in conformance with the
--
applicable procedures and instructions; and, Applicable Station Administrative Procedures and Quality Con-
--
trol Instructions were reviewed.
Subsequent interviews of station QC personnel indicated t'.at the procedures were under-stood and were being implemented.
No items of noncompliance were identified.
3.
Audits a.
References
~
(1)
10 CFR 50, Appendix B, Criterion XVIII.
(2) GP-4016, Audit Program, Revision 3, Change 7.
(3) GP-4015, Audit Finding Closecut Program, Revision 3, Change 4.
b.
Imolementation Review The inspector reviewed the below listed audits in order to de-termine that an appropriate audit checklist had been prepared and used; auditors were independent of responsibility for activ-ities audited; identified deficiencies were being properly dis-positioned by review of both written responses from the audited organization and review of implemented corrective action; and, appropriate distribution of audit reports and responses were made. The audits reviewed were:
L gr1S3
-
Audit 77-21 - Fire Protection.
--
Audit 77-22 - Corrective Action.
--
Audit 77-29 - Control of Measuring and Test Equipment.
--
The inspector also reviewed the current audit schedule and verified that areas to be audited and audit frequencies are consistent with the licensee's progrsm requirements.
No items of noncompliance were identified.
4.
Document Control a.
Reference AP-1001, Document Control, Revision 13.
b.
Drawino and Drawino Chance Control
-
Utilizing the Master Drawing Index (Burns and Roe Drawings),
and the " official copy" of the TMI Nuclear Station Unit 2 Drawing Distribution List (dated January 1,1978), the below listed controlled drawing sample was selected and specified controlled drawing locations were inspected to verify that the drawings were stored there and that the drawings were the latest revisions.
Drawinc #
MI AP CR MM I&C EM QC, 2414 16* 17
15* 17 NA 15*
2517
9
8*
8*
NA
3015
9
NA NA
NA 3044; Sh. 1
4 NA NA
NA 3094, Sh. 134
6*
NA
6*
NA 2532
8
8
NA
3020, Sh.4A
7
NA 6*
NA 3041, Sh. 2
4 NA NA NA
NA 3042, Sh. 9
1 NA NA NA
NA 2076EF, Sh. 1
9 9***
7*
NA
s I
.
_
Legend:
MI-Master Index; AP-Aperture Card; CR-Control Room; MM-Mechanical Maintenance; I&C-Instrumentation and Control; EM-Electrical Maintenance; QC-Quality Con-trol; *-Superceded revision; **-document not located in the area; ***-two copies stered in the same area:
one controlled and the correct revision, one uncon-trolled and not the current revision.
As depicted in the above table, one or more drawings in four
-
of six designated areas were not of the current revision; two cut of six designated areas did not have the designated draw-ings; and, one aperture card stored in central drawing files was not the proper revision. These findings indicated that drawings and drawing revisions are not being distributed in accordance with AP 1001
" Document Control", which prescribes the roethod of distribution and control of drawing revisions.
This is contrary to 10 CFR 50, Criterion V and the licensee's Operational Ouality Assurance Program (FSAR Section 17.2.7).
This item in conjunction with the item discussed in Paragraph 9.b(1) consitutes an infraction level item of noncompliance (320/78-10-01).
c.
Administrative Procedures The inspector selected a representative sample of adainistra-tive procedures end, utilizing the appropriate master index and distribution list, verified that administrative procedures in place in the control room and maintenance trailer were of the proper revision.
No items of noncompliance were identified in this area.
5.
Maintenance a.
References
.
(1) AP-1026, Corrective Maintenance and Machinery History, Revision 3.
(2) AP-1020, Cleanliness Requirements, Revision 2.
(3) AP-1008. Good Housekeeping, Revision 2.
'W 7. S!5
.
(4) MP-1410-P-1, Repacking Pumps, Revision 1.
(5) MP-1410-V-10, Disassemble Clean, Inspect and Repair Gate and Globe Valves, Revision 3.
(6) AP-1027, Preventive Maintenance, Revision 3.
b.
Doctrjentation Review - Corrective Maintenan:e,
.
The inspector reviewed completed routine maintenance activities to verify that work requests were properly processed; appropri-
'
ate procedures were utilized during the maintenance activity; QC inspections were performed and documented in accordance with designated inspection hold points; personnel and procedures used for the performance of special processes were properly qualified; post m.aintenance functional testing was performed, if applicable; the cause and corrective action for equipment malfunctions, were
'
documented; replacement parts and materials were identified; appro-priate cleanliness and housekeeping controls were applied; and, equipment was released for maintenance in accordance with pre-scribed procedures.
Work Reouest Description 2204 NR-V-888 Does Not Open Fully
'
2164 MU-P-lC Trips When Control Switch Returned to Auto After Start 2168 NS-P-1A Packing Gland Stud Bent 1957 DH-V-226A Body to Bonnet Leak 2172 Remove Broken Bolt From NI-1.5
.
Detector Well 1661 BWST - Remove / Reinstall Manways for Inspection No items of noncomoliance were identified.
I
_
$
e
.
.g
.
,
c.
Maintenance in Proaress The inspector witr.essed two maintenance activities in progress to determine that the applicable administrative controls were being implemented at work locations.
--
Work Request 2351 - Repack Turbine Driven Emergency Feed Pump.
Work Request 2001 - Correct Gross Packing Leakage on MU-V-17.
--
The inspector verified that the proper documentation was available at work locations; work was proceeding in accordance with.specif-ied maintenance procedures; material used was properly identified and controlled; post maintenance retesting was performed as spec-ified; and, rework was initiated following unsatisfactory retest-
,
ing if required.
No items of noncompliance were identified.
d.
Preventive Maintenance The inspector reviewed quarterly and weekly preventive maintenance schedules, computerized Preventive Maintenance Checksheets, and
~ Preventive Maintenance Results Record sheets in order to deter-mine whether the required preventive maintenance activities were performed and documented in accordance with station proced-I ures. The following preventive maintenance tasks were selected for review:
DH-P-1B Change Component Oil
'
{
--
NR-P-1A Sound Analysis (IRD) - Electric l
--
Motor
!
OPSURV5042 Spent Fuel Pump Check & Lube
--
OPSURV5028 6900V RC Pump - AMP / Volt Check
--
'
WT-P-9 Dielectric Check - Insulation, Motors
--
and Cables No items of noncompliance were identified.
(
I r a -4 grs (.i u. s
.
-
e.
Personnel Interviews The inspector interviewed two licensee personnel responsible for designation of maintenance classifications (safety related/
,
non-safety related) in erder to determine their awareness of program classification r,uirements. The inspector also re-viewed the reference material currently in use for making the determination of maintenance classifications.
No items of noncompliance were identified.
-
6.
Desian Chances / Modification The licensee representative stated that no design changes /modifica-tions had been conducted under the Operational' Quality Assurance Pro-gram subsequent to the issuance of the operating license (February 8, 1978).
'
,
This was confirmed by a general review of the appropriate work.
schedules which specified organizations responsible for completion of field change request (FCR) items.
'
This area will be reviewed during subsequent inspections.
7.
Surveillance Testing and Calibration Control
-
a.
References (1) Three Mile Island, Unit 2, Technical Specifications.
(2) AP-1010, Technical Specifications Surveillance Program, Revision 12.
b.
Surveillance Test Program Imolementation
.
The inspector selected a number of surveillance requirements from the facility's approved Technical Specifications and determined that procedures for performance of the test and inspections iden-tified by Technical Specifications had been prepared and approved.
The inspector reviewed the master schedule for performance of
.
the sampled surveillance requirements for conformance to Tech-
.
nical Specification requirements.
t
!
711 ES i
Technical Surveillance Soecification Procedure No.
-
Subject 4.9.1.2 2304-304 Boron Concentration / Refueling Ops 4.9.9 2303-R13 Containment Purge and Exhaust Isolation System / Refueling Ops 4.7.6.1.1 2301-S1 Flood Protection - Water Level at Intake Structure 4.5.2.a 2301-S1 ECCS System Operability - Valve
,
Lineup 4.6.1.3.b 2302-SA2 Containment Air Lock Operability 4.6.2.1.b 2302-M24 Containment Spray Pump Operability 4.7.10.1.1 2331-W1 Fire Suppression Weter System Operability 4.8.2.2 2301-W1 AC Distribution - Shutdown Oper-ability 4.7.3.2.a 2301-Mll Decay Heat Closed Cooling Water System - Operability 4.7.3.1.b 2301-M10 Nuclear Services Closed Cycle Cooling Water System - Operability 4.7.10.4.b 2331-R2 Fire Hose Station - Operability 4.8.2.4.1 2301 -W1 DC Distribution - Shutdown Oper-ability 4.2.1 2301-S1 Axial Power Imbalance 4.3.3.5 2301-M4 Remote Shutdown Instrumentation -
Operability 4.4.6.1 2303-M9 RCS Leakage Detection System - Oper-ability 4.5.4.b 2301-S1 Borated Water Storage Tank - Oper-ability 71-159
@
,
.
Technica*
Surveillance Specificatt y Procedure No.
Subject
.
4.7.1.2 2303-M14/a/b/c Emergency Feedwater System - Oper-ability 4.1.2.7 2302-M26 Boric Acid Pumps - Operability 4.1.1.3.2 2311-F4 Moderator Temperature Coefficient 4.1..l.1.1 2311-1 Shutdown Margin The inspector noted that the licensee is implementing a computer based scheduling system for Technical Specification required surveillance and is currently in the process of entering base-line dates of the initial performance of each surveillance pro-cedure.
The licensee is also maintaining a parallel, manually maintained schedule as part of the unit's Plan of Day for interim use until the ba.eline dates have been computerized.
During the review of Surveillance Procedure 2311-F4, " Moderator Temperature Coefficient", the inspector noted that the values of the coefficient provided in the procedure did not agree with the values provided by the corresponding Limiting Condition for Operation in the facility's approved Technical Specifications.
This disagreement was apparently due to a change to the Tech-nical Specification immediately prior to their issuance (approx-imately two weeks prior to this inspection). The inspector con-firmed that the licensee had identified the need for surveillance procedure revision and had initiated this revision. This item is unresolved pending RI review of the revisions to procedure
,
'
2311-F4.
(320/78-10-02)
c.
Calibration Control
_
The inspector selected a sample of safety related instruments which are not specifically required to be calibrated by Tech-nical Specifications but are utilized for ensuring conformance to Technical Specification requirements. The inspector deter-
'
mined that each of the selected instruments have been included in a master calibration program and schedule and that calibra-tion procedures have been prepared and approved.
.
.
'
i 71-190 I
.
Technical Calibration Instrument Specification Procedure 4.6.2.1 2632-RI &R2 Containment Spray Pump Disch.
Pressure 4.5.2.f 2632-RI & R2 HPI & LPI Pump Discharge Pressure 4.1.2.9.b 2301-R19 BWST Temperature Indication 4.5.1 2302-R24 RCS Core Flooding Tank Level 4.8.1.1.2 2602-R18 Diesel Generator F.O. Day Tk.
Level 2602-R17 Diesel Generator F.O. Storage Tk. Level 4.4.6.2.c'
2602-R22 RC Pump Seal Leakage Flow No items of noncompliance were identified.
8.
Records a.
References (1) GP-0063, Record Control, Revision 0, Change 2.
(2) AP-1001, Document Control, Revision 12.
.
(3) AP-1007, Control of Records, Revision 2.
(4) AP-1024, Control of TMI QC Records, Revision 1.
b.
ANSI N.45.2.9 Implementation The licensee, in a letter dated January 25, 1978, notified NRC:NRR of their inability to satisfy the requirements of ANSI N45.2.9
" Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants" prior to the date The letter requested requested for Operating License issuance.
This an extension to June 1, 1979 to satisfy the requirements.
matter was under evaluation by NRC:NRR at the completion of this inspection.
Inspection of the licensee's confonnance to the requirements of ANSI N45.2.9 or acceptable alternates is pending NRC disposition of the licensee's request.
.
.
.-
.e..
t
,
-
.
This item is unresolved.
(320/78-10-03)
c.
Record Retrieval The licensee is presently in t.he process of receiving con-
-
struction records, preoperation test records, as well as generating operating records.
The below listed sample of record types was selected to verify that the records were:
retrievable;
--
not loosely stored;
-
--
suitably protected;
--
traceable to a suitable storage location; and,
--
that the record storage custodian is aware of document
--
retention requirements.
The records sampled were:
Radiographs 2DH-95 "A" and 2M1J-174 "B";
--
Purchase Order 5097 - QC Controlled SS Plate and Angle;
--
Purchase 7 rder 55403 - QC Controlled Hardware for Elec-
--
trical Conduit and Raceways; Purchase Order 47752 - YIS Inc, Calibration Services for
--
Digital Voltmeter #0825017;
--
Welding Oualification and Welding Proficiency Records for three individuals; NDE Qualification Records for two certified individuals;
--
Surveillance Test 2301-Mll Revision 3-Decay Heat Closed
--
Cooling-System Operability - January 1, 1978; Surveillance Test 2304-304 Revision 0 - Refueling Canal
-
--
Baron Concentration / Refueling Ops - February 6, 1978;
'
.
t
.
.
'
i
-
Calibration 2303-A29, Revision 0 - Containment Spray Pump
--
Flow Instrument (BS-1-DPT-1) - January 15, 1978; Calibration 2602-R18, Revision 1 - Diesel Generator Fuel
--
Oil Day Tank Level - January 12, 1978; MTX-175.5 - Spent Fuel Cooling System Preoperational
--
Test; and, MTX-141.1 - Reactor Building Spray Instrumentation Cali-
--
bration (TP 250/2).
No items of noncompliance were identified.
d.
Record Index i
The inspector noted that procedure GP-0063 required that the records that are to be managed in accordance with ANSI N45.2.9 were to be identified in an index which include such informa-tion as:
record type, retention periods, storage loca'. ion and the responsible organization.
Currently available indices do not include the construction recoros being transferred.
The licensee representative stated that such an inder was being prepared for Unit i records with the intention of making it applicable to the records of both units.
This item is unresolved pending issuance of the index required by GP 0063 and subsequent review by RI.
(320/78-10-04)
9.
Test and Measurement Ecuipment a.
References (1) AP 1022, Control of Test and Measurement Equipment, Revision 7.
,
(2) AP 1023, Test Equipment Recall, Revision 1.
(3)
PM-M-48, Torque Wrench and Torque Wrench Testar Cali-bration, Revision 0.
.
.
,
h
!
.
rir 1S3
,
i
'
,
b.
Equioment Review The inspector telected the below listed eqeipment to verify that administrative controls established Fad been 'mplemented for the following: storage, identific.ation and status of cal-ibration; calibration proc.edures issued as applicable; equip-ment calibrated at the frequency specified; cclibration accuracy traceable to recognized standards; cognizant supervisory person-nel knowledgeable of administrative controls; and, usage cun-sistent with established administrative controls.
Digital Voltmeter 0825017
--
Voltage / Current Source 61260567
--
Decade Resistance Box 18397
--
Counter / Timer 102
--
--
Strobotac 39435 Heise Gage CMM 19242
--
pH solution BIN 5100 14
--
Level MEC-78
--
Depth Micrometer Set MEC-24
--
Torque Tester
_
MEC-1
--
Torr,ue Wrench MEC-7
--
Torque Wrench MEC-10
--
Torque Wrench MEC-32
--
The inspector's' findings are as delineated in the following subparagraphs.
'
-
q '[F O l
.
(1) Administrative Procedure (AP) 1022 required segregation and identification out-of-calibration (uncalibrated)
equipment.
On February 23, 1978, the inspector requested that Locker B, which contained Mechanical Maintenance calibrated equipment, be opened.
Within Locker B (desig-nated as a storage location for in-calibration equip-ment), the inspector found that torque wrenches MEC-7, MEC-10, and FEC-32 which were out-of-calibration by virtue of exceeding the specified frequency of calibra-tion, were stored and not identified bv means of a " hold" tag as required by AP 1022.
This finding constitutes one example of 'an item of non-compliance with the requirement of 10 CFR 50, Appendix B, Criterion V and the licensee's administrative procedure (AP 1022) which implement the accepted Operation Quality Assurance Program.
(320/78-10-05)
Prior to the complet%n of the inspection (February 24, 1978), the licensee i.elabeled the applicable storage cabinets; restored the torque wrenches; and, afixed
" hold" tags to the torque wrenches.
Based on these immediate actions, the inspector deter-mined'that no response to the item of noncompliance which includes the failure to segregate and label out-of-calibration torque wrenches was required.
.
(2) The inspector requested and received the calibration data
.
associated with the Torque Wrench Tester (dated December, 1976) and lorque Wrench MC-32 (dated June, 977).
Review of the calibration data indicated that the taster and torque wrenc!. were not within the manufacturer's specified tolerance of acceptability (specified as the source of the acceptance criteria in Preventive Maintenance Procedure (PM) M-48) and had been accepted as being satisfactorily calibrated by licensee personnel.
The inspector reviewed PM M-48 and noted that:
the quantitative acceptance criteria had not been specified in the body of the procedure or on the data sheets; provisions had not been incorporated for logging the amount of data necessary for " averaging" valves to estab-lishsthe acceptability of the torque tester (a secondary standard); and, provisions for or evidence of supervisory review and evaluation of the data were not incorporated.
C 71'LSU
,
.
.
.
.
..
.
.
.
-
-
. ' _.
.'.
l
_
..
~l,
'?
..
.
..
,
10 CFR 50, Criterion V requ:res that activities affecting quality be prescribed by procedures which include appro-priate acceptance criteria to determine that important activities have been satisfactorily acccmplished.
Although PM-M-45 referred to the source of the acceptance criteria (manufacturer), the above deficiencies indicate that the calibration of those items had not been satis-
-
factorily accomplished.
This constitutes an infraction level item of noncompliance.
(320/78-10-06)
10. Unresolved Items
,
Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items or items of noncomplianc.e.
Unresolved items identified during the inspection are discussed in Paragraph 7.b, 8.b and 8.d.
11. Exit Meetina The inspectors met with licensee representatives (denoted in Detail 1) at the conclusion of the inspection on February 24, 1978.
The inspectors summarized the purpose and scope of the inspection and the findings as stated in this report.
-
.
.
%,
"/1-1SS