ML19308B488
| ML19308B488 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/08/1979 |
| From: | Herbein J Metropolitan Edison Co |
| To: | Grier B NRC Office of Inspection & Enforcement (IE Region I) |
| Shared Package | |
| ML19308B487 | List: |
| References | |
| GQL-1233, NUDOCS 8001030325 | |
| Download: ML19308B488 (17) | |
Text
.
O Metropolitan Edison Company
'.i./
e ~
Post Office Box 542 Reading Pennsyl/ania 19640 215 929 3601 Writer's Direct Dial Number October 8,1979 G2L 1233 Office of Inspection & Enforcsent Attn:
B. H. Grier, Director -
Region 1 U. S. Nuclear Regulatory Ca mission King of Prussia, Pennsylvania 19406
Dear Sir:
Three Mile Island Nuclear Station, Units 1 & 2 (TMI-l & TE-2)
Operating License No. DPR-50 (DE-1) & DPR-73 (D1I-2)
Docket tb. 50-289 (DE-1) & 50-320 (UiI-2)
As discussed in a phone conversation between L. W. Harding, of my staff, and D. Haverka:rp of the NPC Region 1, on October 1,1979 enclosed are our responses to the cmbined Inspection Peport 50-289/79-16 and 50-320/
79-20 which are being sutmitted late.
Sincerely, J. G. Herbein Vice President-Nuclear Operations JGH:DiR:IFK Enclosure J
01030 E M l
80 Metropolitan Ecson Company is a Member of the General Public Utit:es System
RESPCNSE 'IO COBINED INSPECTIOB7 REPORP 50-289/79-16; 50-320/79-20 Apparent Infracticn A (Units 1 and 2):
10 CFR 50.59(b) states in part "The licensee shall maintain records of changes in the facility and of changes in procedures made pursuant to l
this section, to the extent that such changes canstitute changes in procedures described in the safety analysis report....
These records shall include a written safety evaluaticn which provides the bases for the determination that the change...does not involve an unreviewed safety question. 'Ihe licensee.shall furnish to the appropriate NBC Fegional Office...with a copy to the Director of Inspection and Enforcement...an-nually...a report containing a brief description of such changes... including a susnary of the safety evaluation of each."
Contrary to the above, the Operational Quality Assurance Plan (OQAP),
Revisicn 7, dated September 26, 1978 changed the Quality Assurance Pro-gram for Operations as described in FSAR Section 17.2, however, the changes were not submitted to the NBC in the subsequent annual report.
The followmg are examples of such changes:
i OQAP Figures 1, 2 and 4 differ frm FSAR Figures 17.2-1, 2 and 4 respectively and new OQAP Figure 6 was added.
The Station / Senior Unit Superintendents respcnsibilities differ between that stated in OQAP Pages 8 and 9 and FSAR Pages 17.2-8 and 9 (List 8).
Various reporting responsibilities / titles differ between OQAP Page 9 and FSAR Page 17.2-9.
OQAP Page 13 changes the revision numbers of the ANSI Standards as listed in FSAR Page 17.2-12.
OQAP Page 14 deletes the requirement of FSAR Page 17.2-13 that inde-pendent design verification will be performed for design work dcne by "other organizations".
OQAP Page 14 deletes the FSAR Page 17.2-13 requirement to review and approve modificaticns prior to inplementation.
i OQAP Page 22 description of "off the shelf" item procurement deletes i
FSAR Page 17.2-19 requirments that such itms will be evaluated to j
determine that their end use will not adversly affect safety.
OQAP Page 22 permits vendors to provide services / work prior to an evaluation of that vendor's QA Program but does not establish the specific surveillance requirements that will assure cmpliance with 10 CFR 50, Appendix B, Criterion VII.
I OQAP Page 27 cmpletely revises the intent of FSAR Page 17.2-24 with respect to requirements for inspection personnel independence, qualifications and duties.
l l
OQAP Page 28 deletes certain requirments and respcnsibilities descrifwl in FSAR Page 17.2-25.
OQAP Pages 34 and 35 do not address auditor independence, qualification or responsibility that is specifically delineated in FSAR Page 17.2-34.
4 RESPOtEE TO INETUCTICN A:
Corrective Action Taken:
TMI-2 FSAR, Sectica 17.2 was found acceptable by the NRC on War 17, 1975.
Since that tLme there have been four changes to the Operational QA Plan issued.
These include cne general change (Ibvision 7) and three minor changes oovered by change memoranda. Each of these changes was performed in a controlled 1
manner and included a review for unreviewed safety questions as required by 10 CFR 50.59 (e). Ibcords of these controlled changes and the safety review evaluations were provided to the audit team for their review. In general, it was Met-Ed's interpretation that unless a major change in policy cr ccmnitrent was made, no formal review subnittal was required.
The NBC Inspection team determined that in their opinion, substantive changes to the program had been made. Hence, the pr % am should have been subnitted to the NPC with the subsequent annual report along with a sumrary of the safety evaluation.
Met-Ed's records indicate that although these changes were subnitted to the Director, Office of Nuclear Material Safety and Safeguards on June 22, 1979 (in conjunction with expanding the coverage of the CA Program to include implemntation for shipping packages of radioacti/e material) and subsequently accepted, there were no additional submittals concerning this matter.
As you are aware, GPU has identified to the NBC (reference letter G2L 1006 dated August 6,1979) its new organizational structure for supporting the Becovery Operations ccncerning Unit 2.
The new organizational structure is consistent with the requirements of 10 CFR 50 Appendix B, and provides for the establishmnt of an independent Quality Assurance Departnent which reports to top management.
The TMI Generatien Group has recently announced for: ration of an integrated QA/QC organization as described in Attachment 1.
This organization is comprised of former members of the GPU and Met-Ed QA/QC staffs. The new QA Department will have a ccx:prehensive organizaticn better equipped with the resources necessary to satisfy program requirements.
Pevision 7 of the Operaticnal QA Plan will be revised and issued on January 15, 1980. The specific concerns addressed by the NBC Inspectors will be considered heavily in the planned revision along with program evaluations and reccrmendation provided by our cmn audit teams and other independent audit and program evaluation teams.
f
In response t, major itens provided in your report, Met-Ed through its ammitment to specific regulatory guides, is (via Revision 7 of the Operational QA Plan) ocmnitted to:
a.
A design control program confornung to ANSI N45.2.11, b.
an engineering and quality review of all procurement for safety related items.
c.
a procurement ocntrol program consistent with Appendix B and ANSI N45.2.13, d.
provide independent inspecticn personnel qualified to ANSI N45.2.6, and e.
provide an audit program with independent and qualified auditors satisfying the requirements of ANSI N45.2.12.
Corrective Iction to Prevent Pecurrence:
Internal procedures will be nodified by Dembr 1,1979 to irclude a require-ment to subnit, for NBC review, those major changes to the Operational QA Program which affect:
a.
Organization Changes (structure) b.
Policy Changes c.
Changes to ccanitment documents, such as, regulatory guides and ANSI documents.
i ATTAC1IMENT #1 - GPU QA Department VP Met-Ed Generation i
Director of Reliability Engineering i
l Manager of Quality Assurance I
I I
Audit Group Methods Material j
[
and Technology i
Operations Group Site Audit' Group I
l Design Assurance Manufacturing Modifications /
Section Assurance Operations Section.
Assurance Section (Site)
Site OA Engineer Site Si' e t
Apparent infraction B (Unit 1):
10 CFR 50, Appendix B, Criterion VI, Doctment Control states in part,
" Measures shall be established to control the issuance of documents such as... drawings... These measures shall assure that documents...are approwd for release by authorized perscnnel..."
The Three Mile Island Unit 2 FSAR* Section 17.2.10 states in part, "The Manager-Generaticn Engineering is responsible for the issuance and approval of... installation requirments... These documents require those performing the work (either Met-Ed or Contractor personnel) to have and to follow appropriate instructions, drawings and procedures."
Procedure GP 1003 states that any changes to plant systens structures or ccmponents shall be shown on interim drawings. All interim drawings will be conspicuously marked with a stamp which states " Interim Drawing Pro-posed Design Change per Approved for Ccnstruction by Date The ' Approved for Constructicn' block is for signature by the Cognizant Engineer indicating approval of the design change and the drawing.
Contrary to the above, modificatica R4-1, Butt Splicing and Application of Heat Shrink Tubing, which was 95% ccmplete cn July 27, 1979, was being performed with drawings which were not approved for construction in accordance with GP 1003.
Pesponse to Infraction B:
1.
By July 27, 1979 all drawings for RM-1 were approved for construction.
The IMI-l Project Engineering Mananger or his representative are approving all interim drawings for construction. As a result, drawings currently being used to perform modifications at IMI-l are approved for construction by authorized perr.cnnel.
2.
The TMI Generation Group is reassessing the masures used to control interim drawings. GP 1003 will be rewritten as a GPU Engineering Procedure and will include measures to assure that drawings are approved for release by authorized perscnnel. The measures used will ccroply with 10 CFR 50, Appendix B, Criterion VI and the 7MI Operations OA program.
3.
We have been in full ccmpliance with the requirements of GP 1003 since July 27, 1979. Until a new procedure is in effect, we will ccntinue i
the use of the " Approved for Ccnstruction" stamp on interim drawings in accordance with GP 1003.
Infraction C (Unit 2):
10 CFR 50, Appendix B, Criterion II, Quality Assurance Program, states in part, "We applicant shall identify the structures, systes and cmponents to be covered by the quality assurance progau...
We quality assurance program shall provide control over activicies affecting the quality of the identified structures, systems and cmponents."
The Three Mile Island Unit No. 2 FSAR, Section 17.2.7, states in part, "A smmary of structures and systems covered in whole or in part by this program are identified in Table 17.2-1.
The actual boundaries of these systes and structures will be specified in the quality assurance systems list."
GP 1008, Quality Assurance Systems List, states that the nuclear sampling syst s is covered by the Quality Assurance Prograa. GP 1008 further states, by way of reference to the equipment classification list and valve list, that the nuclear sampling syst s sample containers and associated tubing and valves are covered by the Quality Assurarce Program and therefore require quality assurance controls.
Contrary to the above, modification 04-0343, Replacement of Nuclear Sampling System Sample Container Isolation Valves, was ampleted on February 2,1979, without QA controls of the implementation of the modification or the procured materials. Further, it was identified that the four sample containers within the Nuclear Sampling System were procured without QA controls.
Pesponse to Infraction C Their is a difference of opinion between the A/E and NSS vendor with regard to imposing QA/QC pro.mu requir ments on the isolation valves. At the time w
of procurement review, engineering and quality assurance agreed upon the appropriate quality requirements to be applied. An oversight was cxmmitted in not changing the classification list in GP 1008 to reflect this decision.
GPUSC engineering is in the process of resolving this issue by evaluating the extent to which such equipment is to be considered within QA program requirements, and the QA systes list (GP 1008). Equignent classification lists and valve lists will be modified as necessary to indicate the results of that evaluation. Until such time as this evaluation is completed, the sample bmb modified by C/M 0343 will be maintained cn hold and will not be used to obtain samples.
4
t Infraction D (Units 1 and 2):
10 CFR 50, Appendix B, Criterion VI, states in part that " Measures shall be established to control the issuance of... drawings, including changes thereto... These measures shall assure that documents, including changes, are reviewed for adequacy and approved for release...and are distributed to and used at the location where the prescribed activity is perforned..."
The Unit 2 FSAR*, Section 17.2.11, states that "The Generation Division document control procedure requires that documents be controlled...
Types of docu:ents which are controlled... include... drawings... The Generation Division document control procedure further requires that...ob-solete or superceded documents are eliminated frm the system and not used..."
Contrary to the above, the following conditions existed on July 31, 1979:
Unit 1 8 drawings / aperture cards had Drawing Change Notice (DCN) stampings but no identifying DCN number.
29 drawings / aperture cards did not have the required DCN stamping.
7 obsolete drawings /aperature cards were retained but not identified as such.
3 drawings were affected by two DCN's but had only one DCN number stamping.
5 drawings were missing frm the designated locations.
1 drawing was not listed on the Master Index.
A book of uncontrolled drawings labeled " Group II Prints" was in the Control Focm (a perfunctory examination identified that many were obsolete).
Unit 2 8 drawings were missing frm the designated locations.
5 drawings were not of the latest revision.
1 drawing was stamped both " Controlled" and "Information only" 4 drawings were not stamped " Controlled".
3 drawings did not depict as-built conditions.
1
RESP 0 HSE TC INFRACTIOW D:
1.
All cf the discrepancies identified in Appendix A, Paragraph D of Inspection Report 50-289/79-16; 50-320/79-20, have been reviewed in detail and have either been already corrected or are in the process of being corrected.
All identified discrepancies are expected to be corrected by October 12, 1979 2.
As a res' tit of the March 1979 incident, on TMI-2, Met-Ed and GPUSC are in the process of reorganization.
All of the Met-Ed Generation Engineering Departments TMI related responsibilities vill be either transferred to GPUSC or to the Met-Ed staff on site.
The Generation Procedures relating to drawings vill be cancelled and now procedures vill be required at the site.
The entire area of dravir.g control is under review due to the organizational changes and new procedures will be prepared to address and implement the new system.
Training as necessary will be provided to appropriate personnel on new procedures.
3.
It is anticipated that the new system and procedures are expected to be in place and functioning by Januagf 1,1980.
Apparent Deficiency E (Unit 2):
10 CFR 50, Appendj x P, Critericn V, states in part that, " Activities affecting quality :aiall be prescribed by docunented instructions, proce-dures or drawing, of a type appropriate to the circumstances, and shall be accarplishe6 in accordance with these instructions, procedures or drawings..."
The Unit 2 FSAR, Section 17.2.10, states that, "...The Unit liuperintendent is responsible for ensuring that the instructions and procedures associated with the administation, operat ion.. arc rctiamd...in accordance with this Quality Assurance Plan..."
Table 5 of the Operation QA Plan for Three Mile Island Nuclear Station, Pevision 7, states that Three Mile Island Nuclear Station is comtitted to the requirements of ANSI N18.7-197r.. ANSI N18.7-1976, paragraph 5.2.15, states in part, "... Plant procedu.es shall be reviewed by an individual knowledgeable in the area affected by the procedure no less fregtently than every tw years to determine if changes are necessary or desirable.
A revision of a procedure coratitutes a procedure review..."
Administrative Procedure AP-1001 states in part, ".. 3.9.1 requirenent -
All procedures relating to nuclear safety must be periodically reviewed to ensure that they are up-to-date and correct...
3.9.2 Review Frequency Pequired - The review frequency for procedures is as follows:
(all procedures) Muumum Frequency Every 2 Years... The Unit 2 periodic review will ccmnence upon camercial operation..."
Contrary to the above, there were nunerous TMI Unit 2 pr,: h s which had not been reviewed within the required 2 year review pet 1od at the start of Ccmnercial Operation in December 1978 or exceeded their 2 year review period during the time period fran Ccmnercial Operation until the accident of March 28, 1979. Additionally, as of July 24, 1979, a proce-dure review prwaun for Unit 2 procedures has not been established.
l l
RESPCNSE 'IO DEFICIENCY E:
There were Unit 2 procedures which had not been revised nor had written documentation of a review having been performed within two years of their issue date. However, our interpretation of the two year review requirement for Unit 2 procedures, which was to ccnmence upon ecumercial operation, was as follows:
All Unit 2 procedures would be reviewed within two years of ccmnercial operation. Upon ocupletion of this first s
"two year review" all Unit 2 procedures wyuld be maintained current.
(Current meaning not older than two years.)
This interpretation was based upon staff discussions with NBC I&E representatives.
The following statement, "...a procedure review program has not been established",
is not entirely correct. Staticn procedures applicable to both Unit 1 and Unit 2 are being reviewed by the Station Staff under the direction of the Unit 1 "2 year review program"; these reviews are assuned to satisfy the Unit 2 "2 year review program" requ.trenent also.
A program is being developed to identify those Unit 2 procedures applicable while in the Recovery Mode. Upon cenpletion of the program, a "2 year review program" will be implemented to ensure ccupliance with ANSI N18.7-1976.
Deficiency F (Unit 1):
10 CFR S0, Appendix B, Criterion V, states in part that, " Activities affecting quality shall be prescribed by documented instructions, proce-dures..."
The Three Mile Island Nuclear Station Unit 2 FSAR*, Section 17.2.10, states in part that, "Each Manager is responsible for... reviewing, ap-proving his group's procedures... The Manager-Generation Quality As-surance is responsible for the review and concurrence with these pro-cedures..."
The Quality Assurance Plan for Pestart bbdifications to DII thit 1, Section 4.0, states in part that, "GPLEC Iogistics Support shall develop a documented system indicating the flow of procurenent documents, such as requisiticos purchase orders and their revisions." Section 6.0 further states that, "the review, approval and issue of documents which affect quality...shall be controlled in accordance with procedures to assure they are adequate..."
Contrary to the above, as of July 27, 1979, numerous purchase orders had been issued to vendors in conjunction with Unit 1 Pestart Modifications in accordance with a field purchasing procedure which was neither reviewed nor approved.
Response to Deficiency F:
7.orrective Steps Taken The field purchasing pro dure issued by the Iogistics Manager to provide inse.ruction to the buyers for preparing and placing purchase orders was reviewed for interface control and distribution requirements on August 10, 1979.
A revision to that procedure (revision 2), incorporating resolution to the QA ccmnents generated was issued Septenber 26, 1979. Final approval of this procedure is anticipated by October 5, 1979.
Corrective Steps Taken to Preclude Recurrence The Logistics Manager has been notified that all interface procedures which affect quality should be reviewed and concurred with by the inter-facing departments prior to issuance.
It should be noted that this procedure is not intended to be a controlling procedure on quality, but merely instructions and.a listing of constraints to buyers on what they can and cannot do.
It also provides distribution lists for purchase orders.
All quality and engineering requirenents for products to be purchased are included on the controlled purchase requisition which is not mntrolled by this procedure.
No additional actions are planned on this item.
i l
l l
Deficienc9 G (Units 1 and 2):
10 CFR 50, Appendix B, Criterion XIII, states in part that, " Measures shall be established to control the... storage...of material and equipment...
in accordance with work and inspection instructions to prevent damage or deterioration."
The Three Mile Island Nuclear Station Unit 2 FSAR*, Section 17.2.18, states in part that, "The perfomance of activities...shall emply with ANSI N45.2.2-1972."
ANSI N45.2.2-1972, Section 6.2, states that " periodic inspections shall be performed to assure that storage areas are being maintained..."
Section 6.4.1 states that, " Inspections and examinations shall be performed and documented on a periodic basis to assure that the integrity of the it s...is being maintained."
Listed below are three examples of failure to perform specific requirments of impleenting procedures.
The Operation QA plan for Three Mile Island Nuclear Station,Section XIII, states that, " Supervisor-QC is responsible for... surveillance of... storage...of material..." AP 1018, Section 13.3.5 states that "the QC Department shall cxanduct periodic surveillances...to assure cmpliance with established warehouse procedures." GP 4014, Change bhro 1, states that "surveillances shall be performed with an approved checklist."
Contrary to the above, as of August 1,1979, the licensee did not have an approved surveillance procedure for warehouse storage areas nor was he performing periodic surveillances of said areas.
The QA Plan for Restart Modifications to thit 1, Section 13.3, states tint, " Regularly scheduled inspections of materials, cmponents and equipment ja storage shall be performed by GPUSC/QA... Results of these inspections shall be docummted..."
Contrary to the above, as of August 1,1979, inspection parsuant to this requirement had not been perfomed.
Procedure QCP-M-002, Storage Control (For Unit 2 Modifications) states in part, that " Surveillance of storage areas which contain nuclear related materials shall be conducted monthly... All inspec-tions shall be documented..."
Ccntrary to the above, as of August 1,1979, no documented inspections of these Unit 2 storage areas had been performed.
i 6
Pespcnse to Deficiency G:
The respcnses to each of the three examples of the apparent failure to perform specific requirements of implementing procedures are as follows:
EXAMPIE I - The NRC's finding states in part "...the licensee did not have an approved surveillance procedure for warehouse storage areas nor was he performing periodic surveillances of said areas."
Response - Procedure GP 4014 defines the necessary steps to perform any surveillance deemed necessary by the Supervisor-Quality Control. Surveillance Report 78-13 was issued in June 1978 covering storage of nuclear safety related material, and was conducted in accordance with GP 4014. This surveillance met the requirment of perfonning a periodic surveillance as required in AP 1018.
i Action - In addition, to avoid future misunderstandings regarding the require-ment of periodic surveillances, a change to AP 1018 will be subnitted to require a surveillance quarterly.
EXAMPIE II - The NBC's finding states that " Regularly scheduled inspections of materials, compcnents, and equipnent in storage shall be performed by GPUSC/QA... Results of these inspections shall be documented.
Response - Prior to the NEC's inspection, no Unit I Restart bbdification material, ccmponents and equipent had been stored in the warehouse; therefore, an inspection of the area was damni unnecessary. Upon receipt of material that is stored in the warehouse, regularly scheduled inspections will be conducted.
EXAMPIE III - The NBC's finding states in part, " Surveillance of storage areas which contain nuclear safety related material shall be conducted mcnthly...
all inspections shall be docummted...no docunented inspections of these Unit II storage areas had been perfomed."
msponse - During the accellerated modifications activity period, GPUSC assigned three (3) qualified receipt inspectors to the Unit II warehouse for the purpose of ccmpletely monitoring receipt activities in accordance with the approved plan. Daily observations of storage conditions were made by these inspectors.
Only limited anounts of nuclear safety related materials were received during this period. Except for filters, these materials were prcmptly released to installation as their need was great.
1 corrective Measures On August 6, 1979, a surveillance was performed at Unit II warehouse and electrical storage. Appropriate checklists were employed. On August 21, 1979 a followup surveillance was performed and appropriate checklists were exployed.
%ese lists are on file at site. On Septenber 26, 1979 a surveillance was performed at Unit II warehouse employing appropriate checklists.
We storage control procedure QCP-M-002 (for Unit II modifications) will be revised to require surveillance of storage areas on a qu' rterly basis or nore a
frequently as directed by the site QC Manager.
Infraction H (Units 1 and 2):
10 CFR 50, Appendix B, Criterion XVI, states that, " Measures shall be established to assure that conditions adverse to quality...are prorptly identified and corrected..."
The Three Mile Island Ntx: lear Station Unit 2 FSAR*, Section 17.2.23 states in part, that, "It is the responsibility of the cognizant manager...
to review the atriit report and to ensure that corrective action is accortplished in a timely manner..."
Contrary to the above, as of August 2, 1979, corrective action has not been perfomed in a timely manner subsequent to the conduct of the internal audits listed below:
76-13, Requalification/ Training Program; performed August, 1976 77-02, Design Control; performed January, 1977 77-19, Major Modifications; performed June,1977 77-21, Fire Protection; performed June,1977 (corrective action can-pleted July,1979)
~
78-05, Control of Purchased Material, Equignent and Servi s (Nuclear);
performed February, 1978.
)
RESPONSE *TO IWFRACTIOli H:
Corrective Action Taken:
On August 28, 1979 a memo was issued to cognizant managers, identifying all open findings in a detailed matrix, identifying priorities, and soliciting prompt corrective action. On July 30, 1979, a reorganization of major functional areas at TMI was announced.
Hence, the responsibility for implementation of corrective action of the outstanding audit findings is,in many cases, being re-assigned.
In addition,130: Generation Group's QA Department has established a full-time QA Auditing Staff at the Site whose responsibilities include programmatic auditing, close-out and follow-up of corrective action for timeliness and effectiveness. With respect to current outstanding audit findings - the site audit staff 'till coordinate the establishment of a schedule for milestone dates with the appropriate managers for resolution of all significant outstanding e.udit findings.
This schedule is expected to be complete by December 15, 1979 Corrective Action to Prevent Recurrence:
A Site QA Audit Staff has been established to better coordinate and manage audit activities and provide management with increased awareness of the adequacy and implementation of the QA Program.
Specifically, the following actions are anticipated by the dates indicated:
(10/30/79) A) Revise the current auditing procedure to better define responsibilities, provide simplified audit reporting and better follow up of problem areas.
(10/30/79) B) Revise the current scheduling practices / procedures to assure adequate and complete coverage of activities affecting safety.
Provide a managed approach to assure adequate follow up.
(10/30/79)
C) Review the current corrective action procedure for QA Audits to provide better guidance so that corrective actions address measures to preclude recurrence.
( h/01/80) D) To establish a co=puterized audit status system to provide better management visibility of problem areas and to determine trends.
(10/01/791 E) A conserted effort to establish priorities of audit findings and to commit the appropriate level of management, via the post audit conference, to provide corrective actions that ensure the commitment of sufficient resources.
In addition to the above actions, the.Vice President-Nuclear Operations will issue a meno by October 15, 1979 to reinforce and amplify managements commitment to 10 CFR 50 Appendix B, Criteria XVI for prompt corrective action.
Date Full Compliance vill be achieved:
Full compliance vill be achieved by April 1, 1980.
Interim implementation dates are as identified above.
- O a nac gi oq(o UNITED STATES
~g NUCLEAR REGULATORY COMMISSION y y v>
g REGION I
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631 PARK AVENUE KING OF PRUSSIA, PENNSYLVANI A 19406 Docket Nos. 50-289 50-320 Metropolitan Edison Company ATTN:
Mr. R. C. Arnold, Sr.
Vice President 100 Interpace Parkway Parsippany, New Jersey 07054 Gentlemen:
Subject:
Combined Inspection 50-289/79-16 and 50-320/79-20 This refers to your letter dated October 8,1979, in response to our letter dated September 7, 1979.
Thank you for informing us of the corrective and preventive actions documented in your letter.
With regard to your response to Deficiency E, our position continues to be that the biennial review of procedures for Unit 2 should have commenced at the time of commercial operation and that all Unit 2 procedures should have been incorporated into the schedule so that those which were due for review at that time were reviewed promptly.
Your Administrative Procedure AP-1001 does not conflict with this, and ANSI N18.7-1976, to which you are committed, states that the review is to be done "no less frequently than every two years." Your interpretation would permit a procedure which had not been reviewed for two years at the time of commercial operation to exist for as much as an additional two years without being reviewed.
Additionally, you responded that station procedures applicable to both units are being reviewed by the station staff as part of the Unit 1 "2 year review program," and that this satisfies the Unit 2 "2 year review program" recuirement also. This would not be true for common procedures which were revised as a result of the review unless the revised procedure was approved by the Unit 2 PORC.
This apparently is not a feature of your Unit 1 "2 year review program,"
since our inspector made specific inquiry in this area and your staff could not produce any documentation or procedure to the contrary.
Your actions will be examined during a subsequent inspection of your licensed program including those applicable to the Recovery Mode.
o Metropolitan Edison Company 2
NOV 2 61979 Your cooperation with us is appreciated.
Sincerely, s
t if ce H. Grier Director cc:
J. G. Herbein, Vice President Nuclear Operations E. G. Wallace, Manager Licensing G. P. Miller, Manager Support Services and Logistics G. P. Miller, Acting, Superintendent Unit 1 W. E. Potts, Unit 1 Superintendent - Technical Support J. B. Logan, Superintendent Unit 2 G. A. Kunder, Unit 2 Superintendent - Technical Support l
J. J. Colitz, Manager Plant Engineering
- 3. F. Wilson, Director TMI-2 Recovery, Acting I. R. Finfrock, Jr.
R. W. Conrad G. F. Trowbridge, Esquire J. B. Lieberman, Esquire Ms. Mary V. Southard, Chairperson, Citizens for a Safe Environment John T. Collins, Deputy Director, NRC/TMI Site Resident Office i
i
Metropolitan Edison Company e h.
Post Office Box 542 Reading Pennsylvania 19640 215 929 3601 Writer's Direct Dial Number October 8,1979 G2L 1233 Office of Inspecticn & Enforcerent Attn:
B. H. Grier, Director-Pegion 1 U. S. Nuclear Pegulatory Ccmnission King of Prussia, Pennsylvania 19406 Der Sir:
Three Mile Island Nuclear Staticn, Units 1 & 2 (TMI-1 & 'IMI-2)
Operating License No. DPR-50 ('IMI-1) & DPR-73 ('IMI-2)
Ibcket tb. 50-289 (TMI-1) & 50-320 (ntI-2)
As discussed in a phone ccnversation between L. W. Harding, of my staff, and D. Haverkamp of the NFC Pegion 1, cn October 1,1979 enclosed are our responses to the ccrrbined Inspection Peport 50-289/79-16 and 50-320/
79-20 which are being subnitted late.
Sincerely, J. G. Herbein Vice President-Nuclear Operations JGH:DNR: INK Enclosure l
I Metropolitan Edison Company is a Member of the General Public Utrhties System
RESPCNSE TO OCMBINED Ibm;nON REPORr 50-289/79-16; 50-320/79-20 Apparent Infraction A (Units 1 and 2):
10 CFR 50.59(b) states in part "The licensee shall maintain records of changes in the facility and of changes in procedures made pursuant to this section, to the extent that such changes constitute changes in procedures described in the safety analysis report....
These records shall include a written safety evaluaticn 'which provides the bases for the determination that the change...does not involve an unreviewed safety question. The licensee.shall furnish to the Popropriate NBC Pegicnal Office...with a copy to the Director of Inspection and Enforcement...an-nually...a report containing a brief description of such changes... including a stmnary of the safety evaluaticn of each."
Ccntrary to the above, the Operational Quality Assurance Plan (OQAP),
Revisicn 7, dated Septenber 26, 1978 changed the Quality Assurance Pro-gram for Operations as described in FSAR Section 17.2, however, the changes were not subnitted to the NPC in the subsequent annual report.
The follcwing are examples of su:h changes:
OQAP Figures 1, 2 and 4 differ frcm FSAR Figures 17.2-1, 2 and 4 respectively and new OQAP Figure 6 was added.
The Station / Senior Unit Superintendents responsibilities differ between that stated in OQAP Pages 8 and 9 'and FSAR Pages 17.2-8 and 9 (List 8).
Various reporting responsibilities / titles differ between OQAP Page 9 and FSAR Page 17.2-9.
OQAP Page 13 changes the revision numbers of the ANSI Standards as listed in FSAR Page 17.2-12.
OQAP Page 14 deletes the requirement of FSAR Page 17.2-13 that inde-pendent design verification will be performed for design work done by "other organizations".
OQAP Page 14 deletes the FSAR Page 17.2-13 requirenent to review and approve modificaticns prior to inplementaticn.
OQAP Page 22 descripticn of "off the shelf" item procurement deletes FSAR Page 17.2-19 requirenents that such itens will be evaluated to determine that their end use will not adversly affect safety.
OQAP Page 22 permits vendors to provide services / work prior to an evaluaticn of that vendar's QA Program but does not establish the specific surveillance requirements that will assure ccmpliance with 10 CFR 50, Appendix B, Critericn VII.
OQAP Page 27 ccmpletely revises the intent of FSAR Page 17.2-24 with respect to requirements for inspecticn personnel independence, qualificaticms and duties.
OQAP Page 28 deletes certain requirenents and respcnsibilities described in FSAR Page 17.2-25.
OQAP Pages 34 and 35 do not address auditor independence, qualificaticn or respcnsibility that is specifically delineated in FSAR Page 17.2-34.
1 IE9. 0NSE 'IO INFPACTICN A:
Corrective Action Taken:
M-2 ISAR, Section 17.2 was found acceptable by the NRC on _%r 17, 1975.
Since that time there have been four changes to the Operational QA Plan issued.
'Ibese include one general change (Pevision 7) and three minor changes covered by change memoranda. Each of these changes was performed in a controlled manner and included a review for unreviewed safety questions as required by 10 CFR 50.59 (e). Pecords of these controlled changes and the safety review evaluations were provided to the audit team for their review. In general, it was mt-Ed's interpretation that unless a major change in policy or cmmitment was trade, no formal review subnittal was required.
The NBC Inspection team determined that in their opinion, substantive changes to the program had been trade. Hence, the program should have been subnitted to the NRC with the subsequent annual report along with a sumrary of the safety evaluation.
Nt-Ed's records indicate that although these changes were subnitted to the Director, Office of Nuclear ltterial Safety and Safeguards on June 22, 1979 (in conjunction with e.Wg the coverage of the QA Progn to include implenentation for shipping packages of radioactive material) and subsequently accepted, there were no additional subnittals concerning this tratter.
As you are aware, GPU has identified to the NRC (reference letter (DL 1006 dated August 6,1979) its new organizational structure for supporting the Recovery Operations concerning Unit 2.
The nea organizational structure is ccnsistent with the requirements of 10 CFR 50 Appendix B, and provides for the establishment of an independent Quality Assurance Departtent which reports to top managemnt.
The M Generation Group has recently announced for: ration of an integrated ON'QC organization as described in Attachmnt 1.
This organization is comprised of former nurbers of the GPU and Met-Ed QN'QC staffs. The new QA Depart: ment will have a cmpreher.sive organization better equipped with the resources necessary to satisfy program requirements..
Fevision 7 of the Operational QA Plan will be revised and issued on January 15, 1980. The specific ccncerns addressed by the NPC Inspectors will be considered heavily in the planned revision along with program evaluations and recumeidations provided by our own audit teams and other independent audit and program evaluation teams.
In response to major items provided in your report, Met-Ed through its ocmnitment to specific regulatory guides, is (via Revision 7 of the Operational QA Plan) cxminitted to:
a.
A design cx:ricrol program conforming to ANSI N45.2.11, b.
an engineering and quality review of all procurement for safety related items.
c.
a procurement otntrol program consistent with Appendix B and ANSI N45.2.13, d.
provide independent inspection personnel qualified to ANSI N45.2.6, and e.
provide an audit program with inde -dent and qualified auditors g
satisfying the requirements of ANSI N45.2.12.
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Corrective Actim to Prevent Becurrence:
Internal procedures will be modified by rx:catur 1,1979 to include a require-i ment to submit, for NBC review, thor.a major changes to the Operaticnal QA P% tmu which affect:
a.
Organization Changes (structure) b.
Policy Changes c.
Changes to comnitment docaxnents, such as, regulatory guides and ANSI documents.
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ATTACIDfENT #1 - CPU QA Department VP Met-Ed Generation
~
l Director of Reliability i
Engineering I
Manager of Quality Assurance I
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Audit Group Methods Material
[
and Technology I
Operations Group Site Audit' Group l
[
Design Assurance Manufacturing Modifications /
Section Assurance Operations Section Assurance Section
' ~
(Site)
Site QA Engineer Site Si' e t
Appar'ent Infraction B (Unit 1) :
10 TR 50, Appendix B, Criterion VI, Document Control states in part,
" Measures shall be established to control the issuance of documents such as... drawings... Wese measures shall assure that documents...are approved for release by authorized perscnnel..."
The Three Mile Island Unit 2 FSAR* Section 17.2.10 states in part, " me Manager-Generaticn Engineering is responsible for the issuance and approval of... installation requirments... @ese doc ments require those performing the wark (either Met-Ed or Contractor personnel) to have and to follow appropriate instructions, drawings and procedures."
Procedure GP 1003 states that any changes to plant systens structures or cmponents shall be shown cm interim drawings. All interim drawings will be conspicuously marked with a stamp which states " Interim Drawing Pro-posed Design Change per Approved for Ccnstruction by Ihte The ' Approved for Constructicn' block is for signature by the Cognizant Engineer indicating approval of the design change and the drawing.
Contrary to the above, modification PM-1, Butt Splicing and Applicaticn of Heat Shrink Tubing, which was 95% cmplete cn July 27, 1979, was being performed with drawings which were not approved for ccnstructica in accordance with GP 1003.
Response to Infraction B:
1.
By July 27, 1979 all drawings for PM-1 were approved for construction.
The 'IMI-l Project Engineering Mananger or his representative are approving all interim drawings for construction. As a result, drawings currently being used to perform modificaticos at 'IMI-l are approved for construction by authorized perscnnel.
2.
The 'IMI Generation Group is reassessing the measures used to control interim drawings. GP 1003 will be rewritten as a GPU Engineering Procedure and will include measures to assure that drawings are approved for release by authorized perscnnel. %e measures used will cmply with 10 GR 50, Appendix B, Critericn VI and the 'IMI Operations OA program.
3.
We have been in full empliance with the requirements of GP 1003 since July 27, 1979. Until a new procedure is in effect, we will ccntinue the use of the " Approved for Ccnstruction" stamp on interim drawings in accordance with GP 1003.
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Infraction' C (Unit 2) :
10 CFR 50, Appendix B, Criterion II, Quality Assurance Propani, states in part, "The applicant shall identify the structures, systems and crxtponents to be covered by the quality assurance program... The quality assurance program shall provide control over activities affecting the quality of the identified structures, systems and caponents."
The Three Mile Island Unit No. 2 FSAR, Section 17.2.7, states in part, "A simnary of structures and systems covered in whole or in part by this program are identified in Table 17.2-1.
The actual boundaries of these systems and structures will be specified in the quality assurance systens list."
@ 1008, Quality Assurance Systems List, states that the nuclear sampling systen is covered by the Quality Assurance Program. GP 1008 further states, by way of reference to the equiptent classification list and valve list, that the nuclear sampling systen sample containers and associated tubing and valves are covered by the Quality Assurance Program and therefore require quality assurance controls.
Contrary to the above, modification C4-0343, Replacement of Nuclear Sampling System Sample Container Isolation Valves, was ampleted on February 2,1979, without QA controls of the implementation of the modification or the procured i
materials. Further, it was identified that the four sample containers within the Nuclear Sampling System were procured without QA controls.
Ibsponse to Infraction C Their is a difference of opinion between the A/E and NSS vendor with regard to imposing QA/QC propen requirenents en the isolation valves. At the time of procurenent review, engineering and quality assurance agreed upon the appropriate quality requirements to be applied. An oversight was cmmitted in not changing the classification list in @ 1008 to reflect this decision.
@USC engineering is in the process of resolving this issue by evaluating the extent to which such equignent is to be considered within QA program requirements, and the QA systens list (@ 1008). Equignent classification lists and valve lists will be modified as necessary to indicate the results of that evaluation. Uhtil such time as this evaluaticn is cmpleted, the sample bcznb nodified by C/M 0343 will be maintained cn hold and will not be used to obtain samples.
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Infragion D (Units 1 and 2):
10 TR 50, Appendix B, Criterion VI, states in part that " Measures shall be established to ecntrol the issuance of... drawings, including changes thereto... These measures shall assure that documents, including changes, are reviewed for adequacy and approved for release...and are distributed to and used at the location where the prescribed activity is performed..."
The Unit 2 FSAR*, Section 17.2.11, states that "The Generation Division document control procedure requires that documents be controlled...
Types of documents which are controlled... include... drawings... Tim Generation Division documnt control procedure fur-her requires that...cb-solete or superceded docunents are eliminated frun the systen and not used..."
Contrary to the above, the following conditions existed on July 31, 1979:
Unit 1 8 drawings / aperture cards had Drawing Change Ibtica (DCN) stampings but no identifying DCN number.
29 drawings / aperture cards did not have the required DCN stamping.
7 obsolete drawings /aperature cards were retained but not identified as such.
3 drawings were affected by two DCN's but had only one DCN number stamping.
5 drawings were missing frun the designated locations.
1 drawing was not listed on the Master Index.
A book of uncontrolled drawings labeled " Group II Prints" was in the Control Roan (a perfunctory examination identified that many were obsolete).
Unit 2 8 drawings were missing frun the designated locations.
5 drawings were rot of the latest revision.
1 drawing was stamped both "Cbntrolled" and "Information Only" 4 drawings were not stamped " Controlled".
l 3 drawings did not depict as-built conditions.
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RESPON8E TO INFRACTION D:
1.
All of the discrepancies identified in Appendix A, Paragraph D of Inspection Report 50-289/79-16; 50-320/79-20, have been reviewed in detail and have either been already corrected or are in the process of being corrected.
All identified discrepancies are expected to te corrected by October 12, 1979 2.
As a result of the March 1979 incident, on THI-2, Met-Ed and GPUSC are in the process of reorganization.
All of the Met-Ed Generation Engineering Departments TMI related responsibilities will be either transferred to GPUSC or to the Met-Ed staff on site.
The Generation Procedures relating to drawings vill be cancelled and new procedures vill be required at the site.
The entire area of drawing control is under review due to the organizetional changes and new procedures vill be prepared to address and implement the new system.
Training as necessary vill be provided to appropriate personnel on new procedures.
3.
It is anticipated that the new system and procedures are expected to be in place and functioning by January 1,1980.
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Apparm t deficiency E (Unit 2):
10 CFR 50, Appendix B, Critericn V, states in part that, " Activities affecting quality shall be prescribad by docunented instructions, proce-dures or drawings, of a type appropriate to the circunstances, and shall be acccrnplished in accordance :lth these instructions, procedures or drawings..."
The Unit 2 FSAR, Section 17.2.10, states that, "...The Unit Superintendent is responsible for ensuring that the instructions and procedures associated with the administraticn, operation...are reviewed...in accordance with this Quality Assurance Plan..."
Table 5 of the Operation QA Plan for Three Mile Island Nuclear Station, Fevision 7, states that 'Ihree Mile Island Nuclear Staticn is ccanitted to the requirenents of ANSI N18.7-1976. ANSI N18.7-1976, paragraph 5.2.15, states in part, "... Plant procedures shall be reviewed by an individual knowledgeable in the area affected by the procedure no less frequently than every two years to determine if changes are necessary or desirable.
A revision of a procedure constitutes a procedure review..."
Administrative Procedure AP-1001 states in part, ".. 3.9.1 requirement -
All procedures relating to nuclear safety must be penodically reviewed to ensure that they are up-to-date and correct...
3.9.2 Review Frequency Required - The review frequency for procedures is as follows:
(all procedures) Minimum Frequency Every 2 Years...
The Unit 2 periodic review will ccmnence upon ccmmercial operation..."
Contrary to the above, there were nunerous 'IMI Unit 2 procedures which had not been reviewed within the required 2 year review period at the start of Ccomercial Operation in % 1978 or ex eded their 2 year review period during the time period frcm Ccmnercial Operation until the accident of March 28, 1979. Additicnally, as of July 24, 1979, a proce-dure review propcuu for Unit.2 procedures has not been established.
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RESPCNSE 'IO DEFICIENCY E:
There were Unit 2 procedures which had not been revised nor had written documentation of a review having been performed within two years of their issue date. Ibwever, our interpretation of the two year review requirement for Unit 2 procedures, which was to ccmnence upon camercial operation, was as follows:
All Unit 2 procedures would be reviewed within two years of camercial operation. Upon cortpletion,of this first "two year review" all Unit 2 procedures wyuld be maintained current.
(Current meaning not older than two years.)
This interpretation was based upon staff discussions with NPC I&E representatives.
The following statement, "...a procedure review program has not been established",
is not entirely correct. Staticn procedures applicable to both Unit 1 and Unit 2 are being reviewed by the Station Staff under the direction of the Unit 1 "2 year review program"; these reviews are asstned to satisfy the Unit 2 "2 year review pmg.cuu" requirement also.
A program is being develeped to identify those Unit 2 procedures applicable while in the Recovery Mode. Upon cortpletion of the program, a "2 year review program" will be implenented to ensure ccupliance with ANSI N18.7-1976.
1Property "ANSI code" (as page type) with input value "ANSI N18.7-1976.</br></br>1" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process.
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Deficiency F (Unit 1):
10 CFR 50, Appendix B, Criterion V, states in part that, " Activities affecting quality shall be pre W W by documented instructions, proce-dures..."
The Three Mile Island Nuclear Station Unit 2 FSAR*, Section 17.2.10, states in part that, "Each Manager is responsible for... reviewing, apr-proving his group's procedures... The Manager-Generation Quality As-surance is respcnsible for the review and concurrence with these pro-cedures..."
The Quality Assurance Plan for Restart Modifications to 'IMI Unit 1, Section 4.0, states in part that, "GPUSC Ingistics Support shall develop a docmented system indicating the flow of procurenent documents, such as requisitims purchase orders and their revisions." Section 6.0 further states that, "the review, awroval and issue of <b mnts which affect quality...shall be controlled in accordance with procedures to assure they are adequate..."
Contrary to the above, as of July 27, 1979, numerous purchase orders had been issued to vendors in conjunction with Uhit 1 Restart Modifications in accordance with a field purchasing procedure which was neither reviewed nor approved.