ML19308B491
| ML19308B491 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/31/1979 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19308B487 | List: |
| References | |
| 50-289-79-16, 50-320-79-20, NUDOCS 8001030344 | |
| Download: ML19308B491 (7) | |
Text
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O APPENDIX A NOTICE OF VIOLATION Metropolitan Edison Company Docket Nos. 50-289 50-320 Based on the results of an NRC inspection conducted on July 17-20, 23-27, and July 30 - August 2,1979, it appears that certain of your activities were not conducted in tell compliance with conditions of your NRC Facility License Nos.
DPR-50 and DPR-73 as indicated below.
Items A, B, C, D and H are Infractions.
Items E, F and G are Deficiencies.
Units 1 cnd 2 A.
10 CFR 50.59(b) states in part "The licensee shall maintain records of chanoas 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 evaluation which provides the bases for the determination that the change...does not invo've an unreviewed safety question.
The licensee shall furnish to the appr>priate NRC Regional Office...with a copy to the Director of Inspection and Enforcement...an-nually...a report containing a brief description of such changes... including a summary of the safety evaluation of each."
i Contrary to the above, the Operational Quality Assurance Plan (0QAP),
Revision 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 NRC in the subsequent annual report.
The following are examples of such changes:
0QAP Figures 1, 2 and 4 differ from FSAR Figures 17.2-1, 2 and 4 respectively and new 0QAP Figure 6 was added.
The Station / Senior Unit Superintendents responsibilities differ between that stated in 0QAP Pages 8 and 9 and FSAR Pages 17.2-8 and 9 (List 8).
Various reporting responsibilities / titles differ between 0QAP Page 9 and FSAR Page 17.2-9.
0QAP Page 13 changes the revision numbers of the ANSI Standards as listed in FSAR Page 17.2-12.
0QAP Page 14 deletes the requirement of FSAR Page 17.2-13 that inde-pendent design verification will be performed for desion work done by "other organizations".
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APPENDIX A 2
0QAP Page 14 deletes the FSAR Page 17.2-13 requirement to review and approve modifications prior to implementation.
OQAP Page 22 description of "off the shelf" item procurement deletes FSAR Page 17.2-19 requirements that such items 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 evaluation of that vendor's QA Program but does not establish the specific surveillance requirements that will assure compliance with 10 CFR 50, Appendix B, Criterion VII.
0QAP Page 27 completely revises the intent of FSAR Page 17.2-24 with respect to requirements for inspection personnel independence, qualifications and duties.
OQAP Page 28 deletes certain requirements and responsibilities described in FSAR Page 17.2-25.
0QAP Pages 34 and 35 do not address auditor independence, qualification or responsibility that is specifically delineated in FSAR Page 17.2-34.
Unit 1 B.
10 CFR 50, Appendix B, Criterion VI, Document Control states in part,
" Measures shall be established to control the issuance of documents such as... drawings...
These measures shall assure that documents...are approved for release by authorized personnel..."
The Three Mile Island Unit 2 FSAR* Section 17.2.10 states in part, "The Manager-Generation Engineering is responsible for the issuance and approval of... installation requirements...
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 systems structures or components 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 Construction by Date The ' Approved for Construction' block is for signature by the Cognizant Engineer indicating approval of the design change and the drawing.
- By letter dated December 23, 1976, from Arnold (Met-Ed) to Reid (NRR), the Operations QA Program described in TMI-2 FSAR would be implemented at TMI-l by March 14, 1977.
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APPENDIX A 3
Contrary to the above, modification RM-1, Butt Splicing and Application of Heat Shrink Tubing, which was 95% complete on July 27, 1979, was being performed with drawings which were not approved for construction in accordance with GP 1003.
Unit 2 C.
10 CFR 50, Appendix B, Criterion II, Quality Assurance Program, states in part, "The applicant shall identify the structures, systems and components 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 components."
The Three Mile Island Unit No. 2 FSAR, Section 17.2.7, states in part, "A summary 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 systems list."
GP 1008, Quality Assurance Systems List, states that the nuclear sampling system is covered by the Quality Assurance Program.
GP 1008 further states, by way of reference to the equipment classification list and valve list, that the nuclear sampling system 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 CM-0343, Replacement of Nuclear Sampling System Sample Container Isolation Valves, was completed on February 2, 1979, without QA cintrols of the implementation of the modifi-cation or the procured materials.
Further, it was identified that the four sample containers within the Nuclear Sampling System were procured without QA controls.
Units 1 and 2 D.
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 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...
The Generation Division document control procedure further requires that...ob-solete or superceded documents are eliminated from the system and not used..."
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By letter dated December 23, 1976, from Arnold (Met-Ed) to Reid (NRR), the
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Operations QA Program described in TMI-2 FSAR would be implemented at TMI-l by March 14, 1977.
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APPENDIX A 4
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 from 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 Room (a perfunctory examination identified that many were obsoltte).
Unit 2 8 drawings were missing from 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.
Unit 2 E.
10 CFR 50, Appendix B, Criterion V, states in part that, " Activities affecting quality shall be prescribed by documented instructior;, prcce-dures or drawings, of a type appropriate to the circumstances, and shall be accomplished in accordance with 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 administration, operation...are reviewed...in accordance with this Quality Assurance Plan..."
5 AP'ENDIX A 5
P Table 5 of the Operation QA Plan for Three Mile Island Nuclear Station, Revision 7, states that Three Mile Island Nuclear Station is committed to the requirements 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 dete mine 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 periodically 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 i
procedures) Minimum Frequency Every 2 Years...
The Unit 2 periodic review will commence upon commercial operation..."
Contrary to the above, there were numerous TMI Unit 2 procedures which had not been reviewed within the required 2 year review period at the start of Commercial Operation in December 1978 or exceeded their 2 year review period during the time period from Commercial Operation until the accident of March 28, 1979.
Additionally, as of July 24, 1979, a proce-dure review program for Unit 2 procedures has not been established.
Unit 1 F.
10 CFR 50, 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 Restart Modifications to TMI Unit 1, Section 4.0, states in part that, "GPUSC Logistics Support shall develop a documented system indicating the flow of procurement documents, such as requisions, 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..."
^ By letter dated December 23, 1976, from Arnold (Met-Ed) to Reid (NRR), the Operations QA Program described in TMI-2 FSAR would be implemented at TMI-l by March 14, 1977.
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APPENDIX A 6
Contrary to the above, as of July 27, 1979, numerous purchase orders had been issued to vendors in conjunction with Unit 1 Restart Modifications in accordance with a field purchasing procedure which was neither reviewed nor approved.
Units 1 and 2 G.
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 performance of activities...shall comply with...
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 item...is being maintained."
Listed below are three examples of failure to perform specific requirements of implementing 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 compliance with established warehouse procedures." GP 4014, Change Memo 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 Unit 1, Section 13.3, states that, " Regularly scheduled inspections of materials, components and equipment in storage shall be performed by GPUSC/QA...
Results of these inspections shall be documented..."
^ By letter dated December 23, 1976, from Arnold (Met-Ed) to Reid (NRR), the Operations QA Program described in TMI-2 FSAR would be implemented at THI-l by March 14, 1977.
APPENDIX A 7
Contrary to the above, as of August 1, 1979, inspections pursuant to this requirement had not been performed.
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..."
Contrary to the above, as of August 1, 1979, no documented inspections of these Unit 2 storage areas had been performed.
Units 1 and 2 H.
10 CFR 50, Appendix B, Criterion XVI, states that, " Measures shall be established to assure that conditions adverse to quality...are promptly 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 accomplished 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 com-pleted July, 1979) 78-05, Control of Purchased Material, Equipment and Services (Nuclear);
performed February, 1978.
- By letter dated December 23, 1976, from Arnold (Met-Ed) to Reid (NRR), the Operations QA Program described in TMI-2 FSAR would be implemented at TMI-1 by March 14, 1977.
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