ML20003D190
| ML20003D190 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/17/1981 |
| From: | Haverkamp D, Keimig R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20003D189 | List: |
| References | |
| NUDOCS 8103190543 | |
| Download: ML20003D190 (37) | |
Text
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O STAFF 3/17/81 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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METROPOLITAN EDISON COMPANY, ET AL.
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Docket No. 50-289
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(Three Mile Island Nuclear Station,
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Unit 1)
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NRC STAFF TESTIMONY OF RICHARD R. KEIMIG AND DONALD R. HAVERKA14P IN RESPONSE TO THE BOARD QUESTIONS CONCERNING AUDITABILITY OF MAINTENANCE PRACTICES IN THE SAMPLE YEAR, 1978, AND CURRENTLY
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Q.1 What is the purpose of this testimony?
A.1 During presentation by TMIA of its affirmative case on its Contention 5, the presiding Atomic Safety and Licensing Board (Board) was motivated by Licensee oral testimony and TMIA's summary, (TMIA proposed Exhibit No. 1),
to " inquire further into whether, prior to November 1979, the Licensee had in place a reliable method of identifying nuclear safety-related work requests which required maintenance, and whether the Licensee had in place a reliable system of records which would identify and assure that the work was either dory or made unnecessary for some other reason."
(Tr. 3352).
The Board 8tated they wished "to have evidence produced in this record which would address the issue of whether or not there was in place a reliable method for identifying safety-related work requirements, and was there in place a reliable method of maintaining records which deltonstrated that the work was identified and performed?" -(Tr. 3355-56).
The Board later stated they were " talking basicaliy about QA/QC, operational QA/QC, was there a method in place to identify nuclear safety related work which needed to be done, and was there a method of record keeping in place which assured that the wark would be duly reported and completed?"
(Tr. 3358).
It was agreed by the parties and the Board that the system in place during 1978 would be an appropriate sample period.
(Tr. 3835-36).
The Board subsequently narrowed the scope of its request for Staff testimony on this subject to a description of the auditability of the Licensee's maintenance work both in 1978 and currently.
(Tr. 13661-66).
2 Licensee written testimony, dated February 17, 1981, " Licensee's Response to the Board Question Concerning Maintenance Practices in the Sample Year 1978", provides substantial information relevant to the Board's question including, (1) background regarding Licensee's maintenance management systems and practices prior to 1978, (2) the maintenance system in place during 1978, (3) the work request system and conduct and significance of Plan of the Day meetings, and (4) the Quality Assurance Group's role regarding periodic maintenance program review and audit, continuing review of' documents governing QC component corrective and preventive maintenance, and selected surveillance (or monitoring) of the performance of each generic maintenance procedure.
The above testimony was revieweo by the NRC Staff and was determined to be an accurate representation of the Licensee's maintenance and QA/QC programs and practices prior to and during_1978, based on information previously obtained during the conduct of routine NRC inspections in those areas.
The Licensee's testimony on specific of work requests initiated in 1978 and their disposition, and the results and resolution of the 1978 QA maintenance audit and QC maintenance surveillances and reviews was new information.
The NRC Staff has made no attempt to sub-stantiate those data because the statistics and status information did
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not appear unreasor.able to'the NRC reviewers nor did it indicate major
. program inadequacites.
In addition, that specific information was not further evaluated because the NRC Region I Office of Inspection and L
3 Enforcement Staff had conducted numerous inspections of the Licensee's Maintenance Program and Maintenance QA/QC prior to and during 1978.
This NRC Staff testimony, then, refers to the performance and results o/ those independent NRC inspections conducted during the sample year, 1978, to respond to the Board's inquiry concerning the auditability of maintenance practices in that y6ar, as well as currently.
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4 Q.2 What requirements are imposed by NRC on the Licensee's maintenance program?
A.2 The Licensee's program for the administrative control and conduct of safety-related maintenance activities must comply eith requirements of the Licensee's Technical Specifications; Regulatory Guide 1.33, Quality Assurance Program Requirements; and, ANSI 18.7, Administrative Controls for Nuclear Power Plants.
These documents specifically require Licensee compliance with the following items related to safety-related maintenance activities:
that Technical Specification Limiting Conditions for Operation requirements are met while equipment is out of service; that maintenance associated with a reportable occurrence is included in the Licensee Event Report; that required QA/QC administrative approvals are obtained to perform the work; that approved procedures are used, where appropriate; that maintenance activities are inspected in accordance with the Licensee's established QA/QC requirements; w
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5 that systems / components are functionally tested and/or calibrated prior to return to service;
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that maintenance activities are accomplished by qualified personnel; that records to substantiate quality of work and parts used are available (this includes documentation associated with procurement, inspections and test results); and,
.that maintenance activities are performed in compliance with established administrative controls for the completion of " Work Request Approval" forms and for procedural coverage associated with the maintenance activity.
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6 Q.3 What IE inspections of the Licensee's mairitenance program and its conduct were performed during 1978?
A.3 Six separate inspections were conducted of the Licensee's maintenance program and maintenance activities by ths. NRC Region I Office of Inspection and Enforcement during calendar year 1978.
T's specific activities which were reviewed are documented in 36 separate maintenance work requests, with the work in various stages of completion, which were initiated for plant modifications, corrective maintenance, preventive meintenance and special component testing.
These inspections were conducted either on a predetermined periodic basis or on a "when required" basis, as defined by the NRC's Office of Inspection and Enforcement light water reactor inspection program, which applied to all power reactors during the licensed operations phase.
During the annual inspection of the Licensee's maintenance program implementation
-(IR No. 50-289/78-14), 23 safety-related (or safety significant) work requests and related documentation were reviewed.
During the annual ir4pection of the Licensee's fire prevention / protection
-program (IR No. 50-289/78-25), including maintenance activities which indicated probable involvement with fire protection, 4 work requests were reviewed..During'the inspections of.the 1978 refueling outage, including maintenance cond mted duringlthe outage (IR No. 50-289/78-05) and post
7 refueling plant operations (IR No. 50-289/78-19), 7 work requests were reviewed.
The remaining 2 work requests reviewed during 1978 were asso-ciated with.the "8" spent fuel pool modification inspection (IR No.
50-289/78-04) and a diesel generator voltage control rhelstat modifica-tion followup inspection (IR No. 50-289/78-13).
The specific work requests reviewed are listed in Table A, " Summary of TMI-1 Work Requests Reviewed by NRC Region I During 1978", which is further described later in this testimony.
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8 Q.4 During the six NRC inspections of maintenance conducted in 1978, what j
specifically did these inspections encompass?
l A.4 The purpose of these inspections was to determine Licensee compliance with the requirements stated in response to Question 2, above.
Specifically, these inspections included-(1) reviews of the Licensee's administrative and QA/QC procedures for control of safety-related maintenance activities; (2) reviews of maintenance documentation including completed (or in crocess) work requests, caintenance procedures, facility legs (for plant conditions), completed surveillance tests, QC material acceptances, tagging applications, QC surveillance reports, and personnel experience and qualification forms as well as training and experience records; and, (3) interviews'with plant management and bargaining unit personnel.
The inspections also incluced direct observations of maintenance activities in progress, when possible, during both normal plant operations and during the 1978 refueling outage.
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9 Q.5 What were the results of these IE inspections?
A.5 The 1978 IE inspections of maintenance program implementation and QA/QC of maintenance activities resulted in no items of noncompliance being identified.
Additionally, the findings of these inspections in those areas sampled were acceptable in all respects with one exception.
During Inspection 50-289/78-05, the inspector identified that, for Work Requests 22625 and 23128, the Shift Foreman's approval to start work was not indicated ~on the Work Request Form.
The inspector determined that opera-tions personnel were aware of maintenance in progress by means of the tag control system but that maintenance oersonnel were not complying with the administrative procedures to document proper work approvals.
The inspector discussed the matter with the Fiant Superintendent, who committed to issue a memo to plant personnel to stress the importance of complying with the administrative controls of AP 1026, " Corrective Maintenance and Machinery History." The corrective action was instituted by issuance of Supervisor of Maintenance Memorandum, dated April 17, 1978.
10 Q.6 What additional NRC reviews were conducted of Licensee maintenance activities during 1978 and what were the results of those reviews?
A.6 Table A lists those work requests chosen by IE for inspection during 1978, primarfly based on the safety significance of the component or system associated with the maintenance activity.
These work requests were obtained from the Licensee in November 1980, and were re-examined by the NRC Staff to ascertain their auditability, i.e., the completeness and adequacy of documentation r,f the records as well as the priority assignec and timeliness of repair.
Tne'results of this re-examination are summarized below:
Maintenar,ce activity review, approval, accomplishment, and testing were generally prompt and appropriate for the nature and significance of the originating equipment problem.
A few apparent exceptions to this finding were identified initially but the delays were satisfac-torily explained during the course of this re examination, as discussed in notes contained in Table A.
There were no examples of inappropri-ately deferred or canceled safety-related maintenance, identified in the selected sampling.
Record keeping associated with the maintenance activities was complete
.and auditable.
The work requests showed that all. necessary reviews and approvals for work.were obtained as required by applicable ETechnical Specifications, regulatory guides and standards, and Licensee procedures.
11 Q.7 What are your conclusions concerning the Licensee's maintenance practices during 1978?
A.7 Based on the IE inspections of Licensee maintenance activities during 1978 and a re-examination of those activities and inspections, and based on subsequent review of specific work requests, it is determined that the Licensee had implemented an acceptable system for identifying safety-related work requirements.
In addition, the Licensee had in place an acceptable and auditable method of maintaining records which demonstrated that the work was properly identified and either performed or determined to be unnecessary for appropriate reasons.
Finally, the Licensee's maintenance records provided an acceptable method of obtaining necessary work review,
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approval and reporting.
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Q.8 What IE inspection of the Licensee's current maintenance orocram end its conduct was performe1?
A.8 The Licensee's current malntenance program was one of eight TMI-1 restart related management control system areas inspected by the IE Program Appraisal Branch during the Management Appraisal (MA) inspection conducted in July 1980.-
The objectives of the performance appraisal function are discussed in NUREG-0680, Suoplement 1, Appendix B and in the transmittal letter and report for Inspection 50-299/80-21.
Copies of that letter and report were provided to the Board and parties having an interest in the management capability issue.
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13 Q.9 During the IE Management Appraisal (MA) inspection, what specifically did the inspection encompass regarding current maintenance?
A.9 The MA inspection effort covered licensed activities in selected functional areas, including the Licensee's maintenance program.
In each of the functional areas, the inspectors reviewed written policies, procedures, and instructions; interviewed selected personnel; and reviewed selected records and documents to determine whether:
the Licensee had written policies, procecures, or instructions to provide. management controls in the subject area; the above policies, procederes, and instructions were adequate to assure compliance with the regulatory recuirements; the licensee personnel who had responsibilities in the subjict areas were. adequately qualified, trained, and retrained to perform tl'eir responsibilities;
.the individuals assigned responsibilities in the subject area under-stooo their responsibilities;.and, the requirements of the subject area had been implemented to achieve
~ compliance, and activities sampled had been appropriately dccumented.
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14 Specific regulatory requirements, renulatory guides, codes, standards, and the commitments relative to the Licensee's current maintenance program were used to provide the basis for evaluating the adequacy of the Licensee's management program in the maintenance area.
Those items used for the
. inspection basis and those procedures and records reviewed by the MA inspectors, which the Licenseu uses to establish and implement management controls over corrective and preventive maintenance activities, are listed in Attachment 1, Excerpt (Pages 60-61) of IE Appraisal Report No.
50-289/80-21.
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15 Q.10 What were the results of the MA inspection concerning the Licensee's maintenance program?
A.10 No items of noncompliance resulted from the MA inspection in the area of maintenance.
One weakness, also categorized as a potential enforcement finding, was identified concerning the omission of QA Modification / Operations inspection and monitoring of Instrument and Control (I&C) calibration activities.
That item is scheduled by the NRC Region I Staff for additional inspection to determine the final disposition of the finding, as described in NUREG-0680, Supplement 1, Appendix B.
The Licensee has informed the NRC Region I Staff, however, that I&C calibration activities are now being inspected and monitored in accordance with 10 CFR 50, Appendix B, Criterion X requirements.
Other weaknesses were identified in the area of workman qualifications and training, as they related to assurance of quality maintenance activities and overall program effectiveness.
Those weaknesses also were reported as being corrected by the Licensee.
Nont of the weaknesses identified duri1g the MA inspection were related to auditability of the Licensee's maintenance activities or records, or to the maintenance system itself.
The detailed results of the MA inspection, regarding the adequacy of the Licensee's program to control safety-related maintenance activities, are listed in Attachment 1, Excerpt (Pages 62-68).
Those results include the weaknesses described above, as well as numerous acceptable observations.
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16 Q.11 What are your conclusions concerning the Licensee's current maintenance program?
A.11 Based on review of the current Licensee maintenance program during MA Inspection 50-?89/80-21, the Licensee's report that the weaknesses were corrected and no noncompliances being identified, we conclude that an acceptable' maintenance program is established.
This includes the overall maintenance system and auditsbility of maintenance related records.
The Licensee's management control systens for maintenance, which were improvec c and enhanced since 1978, ccntinue to snow, among other things:
(1) tnat the Licensee has implemented an acceptable system for identifying safety-related work requirements; (2) that the Licensee has in place an acceptable and auditable method of maintaining records which demonstrate that work is properly identified and either performed or made unnecessary for appropriate reasons; and, (3) the Licensee's maintenance records provide an acceptable' method of obtaining necessary work' review, approval, and reporting.
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l AllLE A
SUMMARY
OF TMI-l WORK REQUESTS REVIEW [D BY WRC REGI0tl I DilRiflG 1978 LICEriSEE lilSPECT10fl5 (Item '.i (Item 16)
(ltem 17)
(Item 18)
(Item 19)
(Item 70)
(Item ?!)
(Item 72)
(Item 23)
Sup. of Shift Halnt.
shift Shift qC Dept.
Sup. of War l Halnt.
Foreman Foreman foreman for enan iteview Haint.
Request Origin-OC Dept.
Approval Apprcral Work tsork Testing ofifork/
Work Req.
st0RK DCSCRlritori Anu ihmter/
ation Review To Work To W-k Reviewed Complete Complete ic. ting Complete NRC EVALUAT10rl C0f 0ENIS Priority Date Date Date Date Date D te Date Date (late
Reference:
NRC Region I_
Inspection Report 50-289/78-0 Para. 2 Inspection Dates:
March I-12, 1978 21923/lA 12/7/77 12/14/77 12/14/77 12/14/77
,1211/78 12/7/78 12/7/78 12/19/78 l_2/29/78 Installation of new compact General spacing spent fuel storage Note rack per Change / Modification (C/M) #983.
Comment This work was to increase the future storage capa-bility of the spent fuel pool and was not required for plant operation.
- Also, the scope of work and engineering required by this work request was very substantial. The one year period to complete, therefore is considered acceptable.
General Note Dates underlined were af t er completion of refcrenced inspection.
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'I APl I R, SIIMMAltY Of Tf11-1 WOflK ftEQQESTS ItEVl[WED fly fil:C I?I Glori I I)llitiflG 19731 !Cl flS(( IllT.I'ECT10f1S (Item 4)
(Item 16)
(Item 11)
(item til)
(Itrw 19)
(Itew 20)
(lttm ?!)
(ltr-m 7/)
(leem 71)
'up, of Sup, of
$ht' flaint.
'lil f t "lelft 44 liep t.
Unek flai n t.
Ior e *n foreman Ice emm I or twa n PrvIrw itiin t.
Rrquest Origtn-Or Dept.
Approval Approval Enk Wor k Icst le:1 est the t/
tbek Req.
WODK OC5tRIPTIort f.f!D f:,m tier /
atton fiev iew To Work To Work Reviewed ferplete
( neple te instlwl Complete NRC TVAtt1Allal furtthis h ine lly lu te Date Date Date Date tu t e lhte Dale flate
Reference:
NRC Rep,lon I Inspection Report. 50-289/78-O' Parn. 4 Inspection Djites:
Marcli 28-31, 1978 22625/ID 2/8/78 3/13/78 3/13/78 3/29/78 4/25/J8 4/27/78 5/3/78 5/10/78 6/1/78 Replacement of decay tient Note 1 pump shaft; not for failure but for reilenty,n of keyway.
(outar,e Work) 23tl8/lA 3/9/78 3/23/78 3/23/78 4/16/78 4/_16/78 4 /lfi/JH 4/18//8 4//4/J8 4/25/_78 inntallat ion of ellesel Note 1 y,enerator oil pressure nwi tclien per C/f t #2'39 20021/lp 5/18/77 3/17/78 3/18/78 4]9/78 4[5/78 4/9/78 5/ft/J8 5/5/78 5/12/78 Replacement of i n t ermeil l a t e Note 2 coo 1Inc, valve IC-V-IA ne.it r i ny,s.
(On t a r,e Work)
Note 1:
Slit f f I'o r ema n approval van not ilorumen t cil by nly, nature prfor to st art -
Iny, work.
Problem in alls-cunneil in Inspection Report 78-05.
Note 2:
Wor k rerpie9t lielit for procenniny,untiI plant was in sliut ilown out ar.e con-all t lon.
22117/ID 12/29/77 3/20/78 3/21/78 3/22/78 4 / lH / 7tl 4/18/78 4/18/.78
(,/7/78 6/.12/78 Replacement o f' l e t ilown cooler Mil-C-1II.
(Ou t ar.c Work)
TRi3LE A
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StJMMARY OF TMI-1 WORK REQUESTS REVIEWED BY flRC REGI0ft I DURiflG 1978 LICEllSEE INSPECTIONS (Item 4)
(Iton 16)
(Item 17)
(Item 18)
(Item 19)
(Iten 70)
(Item ?!)
(Item 72)
(Item 23)
Sup. of Shift itiin t.
shift Shift (JC t>pt.
Sup. of Work flaint.
Foreman Foreman foreman For en.an Review itaint.
Request Drigin-QC Dept.
Approval Approval Work llos k Testing of !!orkf Work Req.
WORK DCSCRIPTIOri AtiD t!imber/
ation Review To Work To Work Reviewed Complete Complete festing Complete NRC EVALUATI0tt (fff1Etlis triority Date Date Date Date Date Date Date Date Date
Reference:
NRC Region 1 Inspection Report 50-289/78-1 Para. 2 Inspection Dates:
June 5-9, 1978 19516/lA 3/29/77 8/23/77 8/24/77 9/13/77 10/11/77 10/11/77 10/11/77 10/18/77 10/20/77 Replacement of emergency Note 3 diesel generator automatic voltage control rheostats per C/M #875.
Note 3: Delay
'.n obtaining QC Dept. review primarily due to need to obtain cor-porate engineering review /
approval.
_Tpf%E, A_
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SuttMARY OF TMI-1 WORK REQUESTS REVIEWED BY flRC REGI0fl I DURiflG 1978 LICEfiSEE IftSDECTIONS (Item 4)
(Item 16)
(Item 17)
(Item 18)
(Item 19)
(Iten 20)
(Item 21)
(Item 22)
(Item 23) '.
Sup. of Shift Maint.
Shift Shift QC Dept.
Sup. of Ucrk Maint.
Foreman Foreman Foreman Fo.eman Pcview Maint.
Fequest Origin.
QC Dept.
Approval Approval Work llork Testi.7 of Mort /
Work Peq.
140=.'. DCSCRIPTI0ri AND thmter/
ation review To Work To Work Reviewed Complete Complete Tes tire)
Complete NRC EVALUAilott CatfEttiS Priority Date Date Da {
Date Date Date Date Date Date
Reference:
NRC Region I Inspection Report 50-289/78-1 Para. 6b Inspection Dates:
June 12-15, 1978 22'.77/ID 1/13/78 1/16/78 1/16/78 3/31/78 3/31/78 3/31/78 3/31,78 4/20/78 5/1/78 Unclogging of boric acid Note 4 lines.
(Outare Work)
Note 4:
Shift Foreman (SF) approval delayed for appro-priate plant outage con-dition.
22498/lD 1/13/78 3/6/78 3/6/78 3/22/78 3/23/78 3/23/78 1/23/78 4/11/78 4/13/78 Cleaning and tightening CRDM connections, (Outage Work) 21914/lA 11/14/77 11/14/77 11/14/77 11/14/77 11/14/77 11/14/77 11/21/77 12/1/77 12/2/77 Operability check of reactor trip rnodule-Channel C.
22435/iA 1/10/78 1/16/78 1/16/78 1/16/78 1/19/78 NA NA 1/23/78 1/24/78 Recalibration of reactor building spray pump discharge pressure gauge.
21388/lA 9/19/77 9/19/77 9/19/77 9/19/77 9/23/77 9/23/77 9/23/77 10/6/77 10/12/7 Replacement of leads and capacitors in reactiyr coolant pump motor controller.
MIR ^
SUMMARY
OF THI-1 WORK REQUESTS REVIEWED BY flRC REGI0fl I DURIrlG 1978 LICErlSEE IllSPECTI0ftS (Item 4)
(Item 16)
(Item 17)
(Item 18)
(! tem 19)
(Item 70)
(Item 71)
(Itr-m 77)
(Item 23)
Sup. of Shift 11a int.
shift Shift 4C tupt.
Sup. of Work Hafnt.
Foreman Foreman Foreman f or enan liev iew ttaint.
Request Drfgin-OC Dept.
Approval Approval Work work Testing of work /
Work Req.
HoaK ttstRiritor: Arro Ionber/'
ation Review To Work To Work Reviewed Complete Complete lesting Complete NRC EVALUATI(tl CfttENIS rrierity Date Date Date Date Date Date Date Date Date 21514/2A 10/4/77 10/10/77 11/4/77 1/3/78 1/5/78 N/A N/A l/13/78 1/16/78 Ilydrostatic test of removed letdown cooler.
22838/14 2/14/78 2/23/78 2/27/78 2/28/78 3/6/78 3/9/73 3/9/78 3/13/78 3/15/78 Replacement of pressure transmitter and buffer amplifier for engineering safeguard actuation system cabinet 8.
22083/lA 12/3/?7 12/3/77 12/3/77 12/3/77 12/3/77 12/4/77 12/4/77 12/7/77 12/8/77 Replacement of cam follower on reactor building personnel access door.
20336/2A 6/13/77 1/14/78 2/10/78 2/10/78 4/5/80 4/15/80 4/15/80 4/21/80 4/22/80 Rebuilding of nuclear service river water strainers.
22621/lA 1/26/78 1/26/78 1/26/78 1/26/78 1/27/78 1/27/78 1/27/78 2/6/78 2/8/78 Cleanfog and repair of transformer in nucleir service river water strainer motor controller.
--Ca nc el ed Apparent problem with diesel 22793/lA 2/10/78 (Reason for cancell ition of urk reques t was tha generator start relay.
the stari relay va 4 found to work sati sfactorii upon subi lequent te sting.)
T ABI F_ A.
SUMMARY
Of TMI-l WORK REQUESTS REVIEWED BY flRC REG 10ft I DURiflG 1973 LICEriSEE If1SPECTI0f15 (Item 4)
(Iton 16)
(Item 17)
(! tem Irl)
(Item 19)
(Item 70)
(Ifra ?l)
(llem ??)
(Item 23)
Sup. of Shift liaint.
%if t
$hift f)r tupt.
h p. of Unik Itai n t.
Foreman Foreman foreman Foreman revieu
'aint.
Pequest Origin-OC Dept.
Approval Approval Work Wrn L Testing of thrt/
h u k Req.
WOPK PE%CitIPTif*1 Afl0 lbm ber/
ation Review To Work To Work Reviewed Complete Compicte Testing Complete fiRC EVALUATI0ff CfFrittilS referity Date Date Date Date Date Date Date Date Date Reference
- NRC Region i Inspection Report 50-289/78-l>
Para. 6e 22012/2A 11/23/77 12/9/77 12/9/77 12/10/77 12/11/77 12/10/77 12/10/77 12/22/77 12/23/77 Inspection of a waste disposa liquid tank.
22054/2A 11/30/77 1/6/78 1/6/78 1/7/78 2/6/78 2/6/78 2/6/78 2/13/78 2/15/78 Replacement of reactor building purge supply fan flow switch.
22032/ID 12/2/77 4/12/78 4/12/78 4/12/78 4/12/78 4/13/78 5/1/78 5/5/78 5/8/78 Repair of lagging on main feed pump B flow orifice root valves.
(Outage Work) 22098/2A 12/3/77 12/22/77 12/23/77 1/30/78 2/1/78 2/1/7R 2/1/78 2/14/78 2/16/78 Repair of local start swi t ch on reclaimed boric acid pump.
22117/lA 12/6/77 12/8/77 12/13/77 12/13/77 12/13/77 12/11/77 12/13/77 12/22/77 12/23/77 Frequency adjustment on IC inverter.
22122/lA 12/7/77 12/7/77 12/7/77 12/7/77 12/8/77 12/8/77 12/20/77 1/9/78 1/10/78 Repair of valve positioner on letdown block orifice isolation valve.
22169/2A 12/13/77 12/15/77 12/15/77 12/15/77 12/15/77 12/15/77 12/15/77 12/22/77 12/23/77 Replacement. of f requency met ei on IC inverter.
22218/2A 12/19/77 12/20/77 12/20/77 12/20/77 1/14/78 1/14/78 1/14/78 1/19/78 1/24/78 Repacking of decay heat removal river water pump.
TAI 9EA
SUMMARY
Of TMI-l_ WORK REQUESTS REVIEWED BY t'HC REG 10ft I DURIllG 19781.!CErlSEE IflSPECTIONS (Itcio 4)
(Item 16)
(ltemth (Itm 18)
(ltem 19)
(item 70)
(Item ?!)
(Itm ??)
(Item 23)
Sup. of
$hlft fla int.
Shift Shift IJC f>pt.
Sup, of Unrk flaint.
Forenian foreman foreman f or cenan Pcview flaint.
Request Origin-OC Dept.
Approval Appioval Work unk Icsting of ihn->/
nn k Req.
Wont DCstRIritori Ario
!!ua t cr/
ation Review to Work To Work Reviewed toniplete tonf ete les t ler; Conplete NRC EVAlt!ATI0ri Crrtttr415 l
rgority Da'a Date Date Date Date pate Date Ditn liate 22877/2D 2/3/78 2/22/78 2/24/78 4/5/78 4/28/78 4/28/78 4/28/78 5/2/78 5/3/78 Obtaining pressurizer heater resistance readings.
(Outage Work) 23665/lA 4/28/78 5/23/78
' 5/23/78 6/28/78
_6/28/78 6/_28] 78 6/28/78 6/28/78 7/6/78 Repair of B OTSG feedwater inlet gauge.
23d W/IA 5/1/78
./1/78 5/1/78 5/1/78 5/1/78 s/i/zH s/1/78 s/3/78 5/3/78 Resetting of three fire service deluge valves in B cooling tower area.
22783/lA 2/10/78 2/15/78 2/15/78 2/15/78 2/16/78 2/16/78 2/16/78 2/22/78 2/23/7F Resetting of fire service deluge va1ves in B cooling tower area.
O
r T Atti I:.A_
SUMilAP,Y OF_TMI-l WORK REMESTS rey _IE_l{ED.IlY NRC REr.10rl I, imitir.1978 L ICEllSEE.lflSPECTIONS
( I t n1 4)
( i t *n 16)
(Item 17)
(Item 10)
(Itna 19)
~(Itew.'o)~~
(Itew ?I) ~
(Ite m 7/)
(It<w 23)
Sup. of Stil f t ita l n t,,
%if t shift
- 10 trpt.
Sirp. of Unek ftaint.
Foreman Foreman f oreman Foirman Pcview ttaint.
3 Rnriest Origin-OC Ocpt.
Approval Appioval Work W<n t ic.t le,9 ofthuk/
w<n k Peq.
W0nx DrstPirtiott Ano tLm ber /
ation Iteview To Work To Work Peviewed t<waplete Comrictc 1cs t irig Conplete MC EVALUATiori ritriars reitrlty Pete Date Date Date Date Date Date Datn lia te
Reference:
NRC Region _1_
Inspectton Report 50-789/78-l' Para. 4 Inspection Dates:
November 7-9 and 13-17,_1978 22416/lD 12/29/77 3/6/78 3/6/78 3/18/78 4/28/78 4/28/78 4/28//8 5/3/78 5/5/78 Inspection / replacement of reactor coolant purip RC-P-IC seals.
(Outane Work) 22415/112 12/29/77 3/6/78 3/6/78 3/18/78 4/23/78
'./24/73 5/5/78 5/9/78 5/12/78 Inspection / replacement of reactor coolant pump RC-P-Ill sea l s.
(Ontane Wort) 23626/ID
'./ 2 7 / 78 4/27/78 4/27/78 4/27/78 4/20/78 4/28/78 4/78/1H 5/t/78 5/3/78 Replacement of nukeup valve 1111-V-16Il pack i ng.
(Outage Work)
.T AP_l E A.
StlitlARY Of TMI _1 WORK RE90,ESTS REyl_EWED_ BY flRC ffG10fl_l,ptlRiflG,1978 I ICffl5I E_lflSPECT10fis (iteu 4)
(Item 16)
(Item 11) litm III)
(Item 19)
(Itew 70)
(Itew 71)
(Item 77)_
(Item 23)
Sup. of shift Maint.
%lf t Shift oc is pt.
sup. of e
line k Haint.
foreman forrman lorivan F os coun Peview Halnt.
Request Drigin.
OC Dept.
Approval Appsoval Wos k 4> k f es t led of l!ne t/
unk Req.
WORE ternirII0tt Arsu ihmter/
ation Review To Work To Work Reviewed Crmplete Crm,ple t e irsting Complete NRC TVAtUAilfti C(Vittilf5 referity Date Date Date Date Date Date Date lute Date
Reference:
NRC Regios3.,1
_Innpectton Report _ 50-289 / 7_8_-2j Para. 31>
Inspection Daten:
Decemlier 12-15, 1978 25341/lA 9/25/78 10/16/78 10/16/78 10/23/78 10/23/7H 10/71/78 10/21/7H 10/74/78 11/3/78 Inventir,ation/ repair of fire nervice alarm for l'I.- II 3.
25342/lA 9/25/78 10/16/78 10/16/78 10/23/78 10/23/78 10/21/78 10/?)//8 10/?4/7H 11/3/78 inventir,ation/ repair of fire nervice alarm lor Pl.- B 3.
25518/ID 12/5/78 12/15/78 12f_1_8]78 10/31f79 3f24/80 1/25/H0 1/25/_HO
'./ 79 /80
!./l10/80 Installatinn of crImpe.1 Note 5 connectionn on reactor coolant pumpa RC-P-I A/ lil/ IC/11) rno t o r leails per C/M 991.
(Ontar,c Work) 25561/2A 10/8/78 5/lfif 79, 5]_18/79 5/18/79 5/26/79 5/18/79 5./lH/19 10/17/79 10/l8/79 Installation of lockiny.ilevic<
on fire nervice pump I'S P-l fuel tank out let valve.
Note 5:
Thin work (licennee ini t lat eil equipment.imprimemer moill f Icat lon) wan firnt ncheilulcel for accomplInhment
TABLE A
SUMMARY
OF TMI-1 WORK REQUESTS REVIEWED BY flRC PEG 10ft I DURIllG 1978 LICEllSEE IflSPECTI0ftS (Item 4)
(Iton 16)
(ltem 11)
(Iten 18)
(Itcu 19)
(Itm 20)
(Item 21)
(Item 22)
(Item 23)
Sup. of Shift Itaint.
Shift Shift I)C f>pt.
Sup. of Work Maint.
Foreman Foreman Foreman loveman iteview fla in t.
Request Origin-OC Dept.
Approval Appr oval Work Work Testing of 1:ork/
Work Req.
WORK DCSCRIPTIOft Min thm ber/
ation Prview To Work To Work Reviewed Complete Complete Testing Ccmplete NRC EVALUAT10ft tfttttrais Priority Date Date Date Date Date Date Date Dste Date Note 5 continued:
during the spring 79 refuelini outage. 18. wever, the necessa:
parts to perform the work wer<
not available until after the start of that outage. The work was then canceled for that outage and later scheduled and completed during the TMI--2 Accident Outage. The deferral of this work was acceptable for the reasons described above.
. ~ -.... -......
. _ -.... ~
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t I
t A l t rw.9,..h.
1 4
4 l
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Excerpts (Pages 60-63) of I
IE Appra' sal Repcrt f
4 No. 50-289/80-21 4
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6.
Maintenance
/
The objective of this section of the inspection was to determine the adequacy of management controls over the corrective and preventive maintenance activities, a.
Documents Reviewed (1) Three Mile Island 1 Restart Report, November 1979 Section 1.0, Introduction and Report Organization
~
Section 3.0, Procedural Modifications Section 5.0, Three Mile Island Nuclear Station Organization (2) Three Mile Island Unit 1 Technical Specification (TS), Section 6.0, Administrative Controls (3) Three Mile Island Operational Quality Assurance Plan (0QAP),
revision 8 (4)
Licensee Correspondence To NRR (Denton) from Met Ed/GPU (Herbein) September 12, 1979 To NRR (Denton) from Met Ed/GPU (Herbein) April 28, 1980 (5) TMI-1 Restart Project Organization and Responsibilities Document (PORD), revision 0, June 13, 1980 (6) Quality Assurance Modifications / Operations Section Procedures TMI-A-MO-001, Managerial / Supervisory Work Assignment and Followup Action System, revision 0 TMI-5-M0-001, Preparation, Review and Approval of QA Modifications / Operations Section Procedures, revision 0 TMI-10-MO-001, QA Modifications / Operations Section Monitoring Program, revision 0 TMI-10-M0-002, QA Modifications / Operations Section -
Inspection Program, revision 0 TMI-10-M0-003, Indoctrination and Certification of Quality Assurance Modification / Operations Section Monitors, revision 0 TMI-14-MO-001, Inspection / Examination /Honitoring Scheduling and Planning, revision 0.
7-10-MO-004, Indoctrination and Certification of Quality Assurance Modifications / Operations Section Inspectors, revision 0 (7) Administrative Procedures (AP)
AP 1002, Rules for the Protection of Employees Working on Electrical and Mechanical Apparatus, revision 18 AP 1008, Good Housekeeping, revision 7 AP 1009, Unit #1 Organization and Chain of Command, revision 4 AP 1013, Bypass of Safety Functions and Jumper Control, revision 7 AM 1026, Corrective Maintenance and Machinery History, revision 11 AP 1027, Preventive Maintenance, revision 9 AP 1019, Qualification of Personnel Performing Special Processes, revision 2 AP 1020, Cleanliness Requirements, revision 6 AP 1022, Control of Measuring and Test Equipment, revision 10 AP 1023, Test Equipment Recall, revision 4 AP 1030, Control of Access to Primary System Openings, revision 2 (8) Maintenance Procedure 1407-1, Station Corrective Maintenance Procedure, revision 6 (9) Surveillance Procedure 1302-5.31, 4160V D and E Bus Undervoltage Relay System, revision 3 (10) Maintenance Work Request Procedure 1450-005, 4160V Bus IE-Bus Backup Overcurrent Relay Function Test, revision 0 1450-012, Bus Overcurrent Relay Maintenance, revision 0 (11) Unit 1 Jumper Log (12) Engineering Procedure, GP-1008, TMI-1 Quality Assurance System Lists b.
Observations The following observations include general information items and the perceived strengths and weaknesses in the licensee's management controls which may not have specific regulatory requirements but will provide the basis for subsequent performance evaluations.
(1) The OQAP established the policies and responsibilities for controlling safety-related maintenance activities and included the following items:
(I)
Organizational structures defined Station maintenance activities conducted in accordance with the OQAP Biannual review of implementing procedures Corrective maintenance to maintain structures Preventive maintenance to insure that immportant-to-safety (ITS) items were adequately maintained in the original condition Maintenance activities preplanned and performed in accordance within appropriate controls Appropriate inspection and testing performed to attain conformance level Clearance procedures and equipment control specified Radiation protection provided Special controls and identification methods Maintenance activity properly reviewed QA/QC review and concurrence with maintenance activities QA/QC monitoring and inspection of maintenance activities as appropriate Itemized-numbered maintenance tasks Records retention requirements Notification of the code inspector (ANI) when reouired Names and dates recorded
Special processes requirements Post Maintenance Testing (2) AP 1026 utilized a job ticket (work request) control form to ensure appropriate administrative processing of the work task.
The routing control form also included the requirement to note retest, work complete, release for normal use, QA/QC review, and review by the Supervisor of Maintenance.
(I)
(3) AP 1026 and maintenance Procedure 1407-1 controlled all safety-related corrective maintenance activ1ri s and included t
ti.: following items:
(I)
Plant Manager approval of maintenance procedures affecting nuclear safety and minimizing radiation exposure Radiation work permit (RWP) requirements Approvals reouired for commencing the maintenance activity, including the Shift Foreman, as appropriate Generation Maintenance Computer System forms and reports Component identification and classification Plant status Work scope NPRD data Housekeeping and cleanliness Fire protection requirements Priority Post maintenance testing requirements Procedure requirements Measuring and test equipment QA/QC review and approval Work assignment and personnel requirements, special tools, materials, and qualifications Tagging requirements and workmen protection Shift Foreman approval to commence work-
. h
QA/QC review of completed activity, if required Data and records requirements Use of generic and standing procedures Control and use of spare parts (4) AP 1027, Preventive Maintenance, described the requirements and responsibi!..es for the implementation of the preventive maintenance program and included the following items:
(I)
~
Computerized scheduling of preventive maintenance and storage of results Assignment of a Unit GM5 Coordinator Corrective action requirements Operations approval to commence the activity QA/QC notification Review of failure results and initiation of appropriate actions (5) The 0QAP was available in the department supervisor's of# ices for reference and use.
Implementing procedures for the correc-tive and preventive maintenance programs were available for use.
(I)
(6) Quality Assurance Modification / Operations reviewed and approved safety-related maintenance activities.
The review and approval assured quality requirements were being established for QA monitoring activities and QC inspection activities.
Quality assurance monitoring and inspection plans were'being prepared based on the OQAP.
In the interim period the supervisors were attending the POD meetings and establishing monitoring and
~ inspection activities accordingly.
Record reviews and inter-views indicated that the majority of the safety-related maintenance areas were being inspected and/or monitored.
The a ta of Instrument and Control (I&C) calibration activities.
appeared to have been omitted. (W)
This potential enforcement finding was discussed with the licensee and will be followed up by the IE Regional Office.
(7)
Interviews and record reviews revealed that the maintenance department was involved in two major efforts which included a walkdown of systems by on-shift maintenance personnel to identify discrepancies and an overall review of the preventive -
maintenance program to revise and update the program.
These two major efforts were planned to be completed by the end of 1980.
(I)
(8) The maintenance department was divided into two separate groups consisting of Corrective Maintenance and Preventive Maintenance.
Each group was staffed and actively involved in their respective activities. Interviews revealed the corrective maintenance backlog was approximately 800 items and was trending dowr. ward, and the preventive maintenance tasks list included approximately 139 tasks and was trending downward.
The licensee had estab-lished shift maintenance coverage and the maintenance activities of Unit 1 and Unit 2 were separated (with the exception of the shift maintenance activities which were to be separate with increased staffing).
Interviews revealed that the man hours spent performing preventive maintenance had increased to about 45 percent of the overall maintenance effort.
The continuing effort in the corrective and preventive maintenance area was adequate to reduce the outstanding work to a normal level by the end of 1980.
(I)
(9) The licensee u6ilized POD meetings in order to schedule maintenance activities, including support services such.as radiation protection, equipment tagging, and QA/QC coverage.
Interviews revealed that the use of POD meetings had improved the department efficiency.
(I)
(10) The licensee routinely used traveling maintenance workers (company) during outages.
These workers were borrowed from other_ system maintenance groups.
(I) l (11) The licensee had issued a memorandum in February 1980, concerning working hours in response to NRC I.E. Circular 80-02.
The memo established a new policy concerning working hours within the operations and maintenance departments; and required Plant Manager-Unit #1 approva), with documentation of the reason, for deviation from the guidelines.
The working hours guidelines applied to supervisors and union personnel.
Interviews revealed that the policy had been implemented.
The scheduling of maintenance (POD and outage coordination) and the l
provision of on-shift maintenance, coupled with an increased staff, had improved the maintenance department response to the outstanding work items within normal working hours.
(I)
(12) The maintenance organization was supported by an onsite engineering group under the Manager, Plant Engineering who reported to the Vice President, TMI-1.
The Superintendent of Maintenance reported to the Manager, TMI-1, who reported to the
'Vice President, TMI-1.
The engineering support group included mechanical, electrical, and I&C engineers.The engineering group was involved in writing maintenance procedures as needed.
(I)
4 6
(13) The maintenance group utilized a foreman call-out list to provide the extra personnel during unusual conditions.
Union personnel call-out followed the contract rules which provided for offering the overtime to personnel with the least number of overtime hours worked.
Interviews revealed the overtime had been minimal recently.
(I)
(14) The corrective maintenance program, including all of the controls, was utilized to implement modifications performed onsite.
Contract work forces also utilized the approved maintenance program and procedures to perform work at the site.
(I)
(15) The licensee routinely used contracted maintenance forces to supplement the normal maintenance force, particularly during major outages.
(I)
(16) The licensee maintenance program included establishing the priority of maintenance activities in order to expedite and schedule maintenance as necessary.
Interviews revealed that the priorities established by the Supervisor of Corrective Maintenance as recommended by the initiatcr of the work request (WR) was working well.
Tne Supervisor of Maintenance indicated that the abuse of tty priority system had been corrected through the improved maintenance department staffing, on-shift maintenance, and communications during the POD and outage coordination meetings.
AP 1026, Corrective Maintenance, and Maintenance Procedure, 1407-1 addressed the use of the WR form which included the " job priority" requirements.
Interviews revealed that the priority of a job was based upon plant conditions, safety, and license considerations.
(I)
(17) AP 1026 and Maintenance Procedure 1407-1 included the identifica-tion and classification of the systems and maintenance activities affecting nuclear safety-related.
The initial classification was made by the initiating supervisor, reviewed by the Supervisor of Maintenance (or designee), and reviewed by the QA/QC group.
Additionally a Review Classifica-tion Routing Control (RCR) form was utilized to ensure the appropriate approvals *ere received, including QC.
The classifi-cation of the maintenance activity was accomplished utilizing GP-1008, TMI-1 Quality Assurance System Lists.
Interviews revealed that the specific maintenance was also evaluated for impact upon a " quality" system.
Approved procedures were required to be used for all " quality" related maintenance.
activities, except when authorized by the Plant Manager.
Interviews revealed that the quality of maintenance activities being performed on. nuclear safety-related or non safety-related.
~
systems did not differ, even though additional procedural controls were required for nuclear safety-related activities.
(I)
(18) Continued workman qualifications were maintained through on-the-job (0JT) training and personal knowledge.
The maintenance department personnel received general employee training routinely (radiation protection, security, emergency plan), but the employees did not routinely receive refresher training in the administrative and technical aspects of their jobs.
(W)
(19) Workman qualification for a particular maintenance activity was determined by the foreman and/or supervisor.
Documentation and tracking of continued qualifications was not provided.
(W)
(20) Contracted maintenance personnel received approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of initial indoctrination and training, examinations, and practical factors associated with radiation controls. Subse-quently the contractor employees were given work assignments in the plant.
Interviews revealed that tne newer employees were worked with experienced employees to provide further on-the-jcb training (0JT).
The contractor employees were pro"ided with annual refresher training including site security, radiation protection, and emergency plan activities. Interviews revealed that the initial training given was considered a little " heavy" for personnel who may have never seen a nuclear facility prior to reporting to the plant. (W) The contractors had built a
" core" of experienced personnel who were routinely utilized at TMI-1 because personnel who could not pass the general employee examinations given by the licensee were not given unescorted access to the facility and could not work at the facility.
(I)
(21) The FSAR was not maintained current and the present maintenance organization, responsibilities, and authorities were not reflected by the FSAR.
The present organization was presented in the TMI-1 Restart Report.
(I)
-(22) TS, Secticn 6, did not reflect the present maintenance organiza-tion; however, the NRC had been kept informed concerning the organizational changes through the submittal of the TMI-2 Restart Report.
(I)
(23) General position descriptions were available for the maintenance department supervisory personnel, inclusive of the foreman level; and specific job descriptions concerning administrative responsibilities were provided in the department procedures.
(I)
-(24) Maintenance personnel met the qualification requirements of ANSI N18.1 - 1971.
(I)
(25) The OQAP provided a cross-reference between the requirements and the maintenance controlling documents; however, a detailed cross-reference between the OQAP and other commitments and the implementing procedures was not developed. (I) c.
Conclusions The licensee's program to control safety-related maintenance activities appeared to be adequate.
The establishment of a complete training and retraining program would further enhance the overall program effectiveness.
The complete implementation of the OQAP, including adequate coverage of all maintenance programs by the QA/QC group and a program for establishing and maintaining workman qualifications including tracking of OJT, should provide additional assurance of quality maintenance activities.
The overall management controls associated with the safety-related maintenance programs were considered average..,