ML19308B490
| ML19308B490 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/07/1979 |
| From: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Herbein J METROPOLITAN EDISON CO. |
| Shared Package | |
| ML19308B487 | List: |
| References | |
| NUDOCS 8001030335 | |
| Download: ML19308B490 (2) | |
See also: IR 05000289/1979016
Text
_
/ytec4o,
UNITED STATES
'j
NUCLEAR REGULATORY COMMISSION
7
'
'
3p(
ti (
.n C
REGION 1
't ,
[
s
631 PARK AVENUE
% .' .% #,o
KING OF PRUSSIA, PENNSYLVANI A 19406
...
Docket Nos. 50-289
gp g 7 g3
50-320
Metropolitan Edison Company
ATTN:
Mr. J. G. Herbein
Vice President - Generation
P. O. Box 542
Reading, Pennsylvania 19603
Gentlemen:
Subject:
Combined Inspection 50-289/79-16; 50-320/79-20
This refers to the inspection corducted by Mr. G. Napuda of this office on
July 17-31, and August 1-2, 1979 at Three Mile Island Nuclear Power Station,
Units 1 and 2, Middletown, Pennsylvania, at General Public Utilities Service
Corporation offices at Parsippany, New Jersey, and your Reading, Pennsylvania
corporate offices of activities authorized by NRC License Nos. DPR-50 and
DPR-73 and to the discussions of our findings held by Mr. Napuda with Messrs.
W. E. Potts and G. Troffer of your staff at the conclusion of the inspection,
and to a subsequent telephone discussion between Mr. Napuda and Mr. G. Troffer
and Mr. N. Kazanus on August 15, 1979.
Areas examined during this inspection are described in the Office of Inspection
and Enforcemen'. Inspection Report which is enclosed with this letter.
Within
these areas, the inspection consisted of selective examinations of procedures
and representative records, interviews with personnel, and observations by the
inspector.
Based on the results of this inspection, it appears that certain of your
activities were not conducted in full compliance with NRC requirements, as set
forth in the Notice of Violation, enclosed herewith as Appendix A.
These
items of noncompliance have been categorized into the levels as described in
our correspondence to you dated December 31, 1974.
This notice is sent to you
pursuant to the provisions of Section 2.201 of the NRC's " Rules of Practice,"
Part 2, Title 10, Code of Federal Regulations.
Section 2.201 requires you to
submit to this office, within twenty (20) days of your receipt of this notice,
a written statement or explanation in reply including:
(1) corrective steps
which have been taken by you and the results achieved; (2) corrective steps
which will be taken to avoid further items of noncompliance; and (3) the date
when fuli compliance will be achieved.
In addition to the need for corrective
action reg 1rding these specific items of noncompliance, we are concerned about
the implemeitation of your quality assurance program that permitted them to
occur.
Consequently, in your reply, you should describe in particular, those
actions taken or planned to improve the effectiveness of your quality assurance
program.
.
e
8001030 M (
,
,
RESDOWSE'TO IRFRACTIOR 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, TMI 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 vill
coordinate the establishment of a schedule for milestone dates with the
appropriate managers for resolution of all significant outstanding audit
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) 3) 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.
( 4/01/80) D) To establish a computerized 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 cc=mitment of sufficient resources.
In addition to the above actions, the Vice President-Nuclear Operations will
issue a memo 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.
__
_.
__ -_ - _ _
.
.
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 prtruptly
identified and corrected..."
The Three Mile Island Nuclear Station Unit 2 FSAR*, Section 17.2.23
states in part, that, "It is the responsibility of the cognizant manager...
to review the audit report and to ensure that corrective action is acca plished
in a timely manner..."
Contrary to the above, as of August 2,1979, corrective action has not
been performed 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 ccm-
pleted July,1979)
78-05, Control of Purchased Material, Equignent and Services (Nuclear) ;
-
performed February, 1978.
l
l
l
,
. _ _ _ _ _ - _ -
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -
.
.
i
Response to Deficiency G:
The respcnses to each of t'te three examples of the apparent failure to perform
specific requirenents of unplementing procedures are as follows:
EXAMPLE I - The NRC's finding states in part "...the licensee did not have
an approved surveil].ince procedure for warehouse storage areas nor was he
performing periodic, surveillances of said arew."
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 accordanm with GP 4014. This surveillance met
the requirenent of performing 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 NPC's finding states that " Regularly scheduled inspections of
materials, compcnents, and equipment in storage shall be performed by
GDUSC/QA... Results of these inspections shall be documented.
Response - Prior to the NPC's inspection, no Unit I Restart bbdification
material, ccmponents and equipment had been stored in the warehouse; therefore,
an inspection of the area was deemed unnecessary. Upon receipt of material
that is stored in the warehouse, regularly scheduled inspections will be
conducted.
EXAMPIE III - The NPC's finding states in part, " Surveillance of storage areas
which contain nuclear safety related material shall be conducted mor_hty ...
all inspections shall be documented...no @,wmted inspections oI these Unit II
_
storage areas had been performed."
Pesponse - During the accellerated nodifications activity period, GPUSC assigned
three (3) qualified receipt inspectors to the Unit II warehouse for the purpose
of ccrrpletely nonitoring receipt activities in acmrdance 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 prcrnptly released to
installation as their need was great.
Corrective hbasures
On August 6, 1979, a surveillance was performed at Unit II warehouse and
electrical storage. Appropriate checklists were enployed. On August 21, 1979
a followup surveillance was performed and appropriate checklists were enployed.
These lists are on file at site. On Septenber 26, 1979 a surveillance was
performed at Unit II warehouse employing appropriate checklists.
'Ihe storage control procedure QCP-M-002 (for Unit II nodifications) will be
revised to require surveillance of storage areas on a quarterly basis or nere
frequently as directed by the site QC hhnager.
l
!
l
l
.
Deficienc? G (Units 1 and 2) :
10 CFR 50, Appendix B, Criterion ZII, states in part that, " Measures
shall be est ahl khed to control the. . . storage. . .of material and equignent. . .
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 perfonnance of activities. . .shall emply with
ANSI N45.2.2-1972, Section 6.2, states that " periodic inspections shall
,
be performed to assure that storage areas are being maintained..."
i
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
item...is being maintained."
Listed below are three examples of failure to perform specific requirenents
of implenenting 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 conduct periodic surveillances...to assure
cmpliance with established warehouse procedures." GP 4014, Change
Meno 1, states that "surveillances shall be perfonned 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 Lhit 1, Section 13.3,
states that, " Regularly scheduled inspections of materials, cx2nponents
and equignent in storage shall be performed by GPUSC/QA... Results
of these inspections shall be documented..."
Contrary to the above, as of August 1,1979, inspection pursuant to
this requirement had Int been performed.
-
Procedure QCP-M-002, Storage Control (For Unit 2 bbdifications)
states in part, that " Surveillance of storage areas which contain
nuclear related materials shall be conducted monthly... All inspec-
tions shall be documented..."
i
Contrary to the above, as of August 1,1979, no documented inspections
of these Unit 2 storage areas had been performed.
.
3
.
,
.
Pesponse to Deficiency F:
Corrective Steps Taken
The field purchasing procedure issued by the Iogistics Manager to provide
instruction to the buyers for preparing and placing purchase orders was
reviewed for interface control and distribution requirments on August 10,
1979.
/
A revision to that procedure (revision 2), incorporating resolution to
the QA cm ments generated was issued September 26, 1979. Final approval
of this procedure is anticipated by October 5, 1979.
.
Corrective Steps Taken to Preclude Recurrence
The Ingistics 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 requirments for products to be purchased are
included on the controlled purchase requisition which is not controlled
by this procedure.
No additional actions are planned on this item.
1
.
_ _ _ _ _ _
\\
r
s
0 / 19 79
Metropolitan Edison Company
2
Item nur.cer D, shown in the Notice of Violation enclosed with this letter, is
)
a recurrent or uncorrected item.
In your response please give this matter
your particular attention.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2,
Title 10, Code of Federal Regulations, a copy of this letter and the enclosures
will be placed in the NRC's Public Document Room.
If this report contains any
information that you (or your contractor) believe to be proprietary, it is
necessary that you make a written application within 20 days to this office to
withhold such information from public disclosure.
Any such application must
be accompanied by an affidavit executed by the owner of the information, which
identifies the document or part sought to be withheld, and which contains a
statement of reasons which addresses with specificity the items which will be
considered by the Commission as listed in subparagraph (b)(4) of Section
,
2.790.
The information sought to be withheld shall be incorporated as far as
j
possible into a separate part of the affidavit.
If we do not hear from you in
1
this regard within the specified period, the report will be placed in the
,
Public Document Room.
Should you have any questions concerning this inspection, we will be pleased
to discuss them with you.
Sincerely,
e
?
Bo ce H. Grier
Director
Enclosures:
1. Appendix A, Notice of Violation
2. Office of Inspection and Enforcement Inspection
Report Numbers 50-289/79-16; 50-320/79-20
cc w/encls:
E. G. Wallace, Licensing Manager
J.
1 Barton, Project Manager.
R. C. Arnold, Vice President - Generation
L. L. Lawyer, Manager - Generation Operations
G. P. Miller, Manager - Generating Station
~ Nuclear
J. L. Seelinger, Unit 1 Superintendent
J. B. Logan, Unit 2 Superintendent
W. E. Potts, Unit 1 Superintendent - Technical Support
G. A. Kunder, Unit 2 Superictendent - Technical Support
I. R. Finfrock, Jr.
Mr. R. Conrad
G. F. Trowbridge, Esquire
J. Lieberman, Esquire
Miss Mary V. Southard, Chairman, Citizens for a Safe Environment (Without Report)
Chief, Resident Office TMINS
u