ML20003D191
| ML20003D191 | |
| 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 8103190550 | |
| Download: ML20003D191 (35) | |
Text
'
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STAFF 3/17/81 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
METROPOLITAN EDISON COMPANY, ET AL.
)
Docket No. 50-289
)
(Three Mile Island Nuclear Station,
)
Unit 1)
)
NRC STAFF TESTIMONY OF RICHARD R. KEIMIG AND DONALD R. HAVERKAMP IN RESPONSE TO TMIA CONTENTION 5 s
MAINTENANCE AT TMI-l 8108190%DD
4 Q.1 What is the purpose of this testimony?
A.1 TMIA (Revised) Contention 5 states:
"It is contended that Licensee has pursued a course of conduct tnat is in violation of 10 CFR 50.57, 10 CFR 50.40, 10 CFR 50.36, 10 CFR 50.71 and
'10 CFR 50 Appendix B, thereby demonstrating that Licensee is not
' technically... qualified to' operate TMI Unit 1 'without endangering the health and safety of the public,'
This course of conduct includes:
deferring safety-relatea maintenance and repair beyond the point a.
esta:ilished by its own procedures (see e.g. A.P. 1407);
b.
disregarding the importance of safety related maintenance in safely operating a nuclear plant _in that it:
1.
(Deleted) 2.
proposed a drastic cut in the maintenance budget; 3.
.(Deleted)
-4.
fails to keep accurate maintenance records related to safety items; u---
2 5.
has inadequata and understaffed QA/QC programs related to maintenance; 6.
extensively uses overtime in performing safety-related maintenance."
During presentation by TMIA of its affirmative case on its Contention 5, the presiding Atomic Safety and Licensing Board (Board) received in evidence certain TMIA Exhibits.
Licensee's prepared testimony, dated February 9,1981, " Maintenance at TMI-1", (following Tr. 13533) provides substantial information relevant to the current maintenance organization, management systems and practices.
That testimony includes descriptions of the preventive, corrective and shift maintenance organizations and activities, computer programs used for organizing and tracking of preventive and corrective maintenance, revised policies for overtime, maintenance training program improvements, and changes to and clarification of the priority system for identifying maintenance work.
The Licensee's testimony was reviewed by the NRC Staff and was determined to be an accurate' representation of the Licensee's current maintenance and QA/QC programs and practices, based on information independently obtained by IE during and in response to the Management Appraisal (MA)
Inspection 50-289/80-21-(described in NUREG 0680, Supplement 1, Appendix B).
3 In addition,-the Licensee's testimony also includes detailed explanations of the specific TMIA Exhibits (work requests), which had been received in evidence.
The NRC Region I Staff independently reviewed the work requests presented in the TMIA Exhibits during the period November 1980 - February 1981,.and essentially agrees with the Licensee's testimony.
This testimony in conjunction with our testimony on "Auditability of Maintenance Practices in the Sample Year 1976 and Currently," then, responds to TMIA Contention 5.
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4 Q.2 What evaluations were conducted by the NRC staff of TMIA Exhibits (Work Requests) and what are the general conclusions of those evaluations?
A.2 Table B lists those work requests received as TMIA exhibits.
Those work requests were considered representative of various contended inadequacies concerning the TMI-l maintenance program.
The specific evaluations of NRC staff review of those work requests, associated maintenance activities and their significance, are described in Table B.
The general conclusions of this review are described below:
The majority of the work requests entered as TMIA exhibits were for equipment or components which had little or no nuclear sa'ety signifi-cance in themselves.
Therefore, there were no NRC regulatory or
?icense requirements for maintaining the operability of those compo-nents or for administrative control of maintenance performed on those components.
Howev r, tha Licensee optionally applied the sare type of. administrative controls to maintenance activities performed on nonsafety-related systems / components as it did on safety-related.
I The few exaroples of maintinance which actually was deferred and the several examples of deferred testing, review or closeout of mainten-ante and documentation thereof, as described by evaluation comments in Table B, are not considered to have had any individual or collec-
-tive. adverse impact on safety.
There appears _to be no example of inappropriately deferred saft.ty-related maintenance work.
5 The examples of misuse of " blanket" work requests and cancellation of duplicate work requests, as described by the evaluation commer.ts in Table B, appear to have had no impact on sa.'ety.
The records of maintenance work activities were, in fact, auditable.
However, there were several examples of cancellation of work activities, particularly with respect to air handling filter replacement, with no formal documentation of the basis for not performing the work.
The maintenance apparently was re evaluated as unnecessary prior to initiating any work, and the work requests were initially held open for extended periods and later cancelled during purges of duplicate or inappropriate work requests.
This shortcoming of record cor.plete-ness was not a noncompliance with NRC requirements, but impeded the timely Licensee and NRC review of those work requests, ultimately requiring discussions with responsible maintenance personnel to determine the reasons for cancelling work.
Past practices regarding identification, scheduling, performance, testing, control, monitoring, quality review and documentation of maintenance activities have been considered by the Licensee.
Those practices found to be deficient _or marginally adequate have been improved by~ revising maintenance organization structure, procedures, and management and computerized information control systems.
f
6 i
Q.3 With regard to TMIA's Contention 5, which states, in part, ".... This course of conduct includes:
b.
disregarding the importance of safety-related maintenance in safely operating a nuclear plant in that it:
2.
proposed a drastic cut in t5e maintenance budget...", was the NRC aware the Operations and Maintenance (0&M) Budget was to be reduced for TMI-l?
A.3 Yes.
At a routine, programmatic IE Management meeting with Mr. J. G.
Herbein, then the Metropolitan Edison Company's Vice President - Generation and others, in the Region I office on February 9, 1979, Mr. Herbein indicated that the company recently had proposed budget reductions across the entire General Public Utilities system.
Mr. Herbein added that co.npany ' management was very sensitive to the operations and maintenance of its nuclear powered plants and that the budget reductions wou.ld not impact upon plant safety at TMI.
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7 Q.4 What, if_anything, did Region I do upon learning of this budget reduction?
A.4 IE normally is not concerned with the internal financial arrangements of a utility company as long as the company is able,to meet its commitments to-public health and safety while operating its nuclear plants.
Inasmuch as the company, in the_ person of Mr. Herbein, was totally above board in informing Region I of the proposed budget reductions and re-emphasized the company's sensitivity to plant safety, no specific actions were taken at that time.
However, regional management, having been alerted to tnis fact, would consider this circumstance while carrying out the inspection program at the TMI site.
If and when the results of any inspecti7n conducted at the site indicated that hudget reductions were in any way adversely affecting the safety of plant operations, appropriate NRC action would have been intitiated promptly.
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.s 8
Q.5 Was there any indication in early 1979 that the budget reductions could possibly lead to an impact upon the safety of plant operation?
A.5 To the best of ou'. personal knowledge and as a result of reviewing IE inspection reports for that period, there was no apparent basis to suspect that budget reductions were having adverse affects on plant safety.
It must be pointed out, however, that due to the accident at TMI-2, on March 28, 1979,- the' budget reduction program never was implemented fully.
Therefore, it is not possible to determine how those reductions proposed for TMI would have affected the plants.
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9 Q.6 As a result of this issue as contended by TMIA,.iid Region I perform any inspection to determine what the proposed inaintenace budget reductions included?
A.6 During the period of September 10-30, 1980, this issue, as well as other issues perceived by TMIA.to be of concern, was inspected oy an NRC Region I inspector.
(Ref. IR No. 50-289/80-27)
Thu inspector interviewed Metropolitan Edison Company (Met-Ed) personnel including the Superintendent of Maintenance and maintenance supervisors and foremen.
The inspector also reviewed the documented material on this issue which had been placed in the Discovery Reading Room by Met Ed.
The inspector found no discrepancies between the documented material and the verbal information given during interviews.
He did identify some reduction in contracted preventive maintenance support in early 1979 (prior to and during March 1979) but 'could not assess what impact on plant safety this reduction may have had if continued and expanded over an extended period, or what action, if any, the Licensee would have initiated if this reduction were observed by the Licensee to start impact'ng on plant safety.
The inspector could find no evidence that the maintenance budget reduction affected any-safety related corrective maintenance.
C
10 Q.7 What are your personal views on the budget cuts proposed by Met Ed in the area of maintenance?
A.7 Inasmuch as the budget cuts apparently were not being applied to the corrective maintenance work to be performed by the Licensee (eithet in the number of personnel assigned or the nature of work to be completed),
and since the effects of a proposed reduction in preventive maintenance are highly speculative and depend largely on the quality of the preventive maintenance program prior to the proposed reduction, and lacking any indication that the prior preventive maintenance program was less than adequate, we can find no basis to conclude that, as contended by TMIA, the Licensee disregarded the importance of safety-related maintenance in safely operating a nuclear plant by proposing cuts in the maintenance budget.
Additionally, we re-emphasize that had such a condition been indicated, we feel certain that it would have been identified at an early stage by the IE inspection program and that prompt action by the Licensee to correct the condition would have been required.
11 Q.8 With regard to TMIA's Contention 5, which states in part, "...This course of conduct includes:
b.
disregarding the importance of safety-related maintenance in safely operating a nuclear plant in that it:
6.
exten-sively uses' overtime in performing safety-related maintenance...," is there any indication that the extensive use of overtime impacted adversely on the quality of the maintenance performed at TMI?
A.8 In our review of inspection reports for our testimony on "Auditability of Maintenance Practices in the Sample Year 1978 and Currently" and other inspections which reviewed mai 'enance related activities at TMI, if extensive overtime was used in the performance of safety-related mainten-ance work, we found no apparent basis on which to conclude that it adversely affecteo the quality of the work.
It should be noted that prior to the accident at THI-2, the IE inspection program did not specifically require the inspection of the degree to which overtime was utilized to perform maintenance work.
However, during the course of IE inspections of maintenance activities in progress, informal (and formal) interviews are conducted with all levels of the maintenance staff. Questions asked during these interviews include the following:
are personnel familiar with the job procedure and any special requirements, are they following the procedure, are they qualified to do c
12 the work they are performing and so forth.
These interviews also provide an opportunity to observe the mental and physical attitudes of the workers.
If a worker is noted to be mentally or physically fatigued to the extent that his workmanship may be impaired, this observation would be brought immediately to management's attention with corrective action required.
Also, the quality of workmanship in performing maintenance is indicated by noting the maintenance history, i.e., down time vs. operating time on specific equipment.
Recurrent problems on equipment which require out of service time for maintenance could be indicative of poor workmanship caused by mental or physical fatigue.
Indicati M of abnormally repeti-tive maintenance are reviewed and followed by IE inspectors during routine inspections.
It is important to note that the quality of work and, in some cases, the immediate safety of plant operations is enhanced by the prudent use of overtime.
This is particularly true for prompt corrective repairs of safety-related equipment.
The maintenance work may be better if the same person or crew starts and completes the repair _because specific techniques are sometimes learned during the troubleshooting and disassembly of a component.
Also, the prudent use of' overtime may be particularly bcneficial where ertain specialized qualifications or talents are limited to only a few. individuals, such as would be the case for'certain welding operations or complex calibrations.
13 Our review of IE inspec' ion reports and Mr. Haverkamp's observations of work in progress while an inspector at TMI gave no indication that the quality of maintenance was affected by the extensive use f overtime.
These inspections included refueling outages when overtime, in fact, was used, with consideration given by plant management to the proper balance between productivity and safety of work activities as observed by the inspectors.
Subsequent to the TMI-2 Accident, the Licensee issued a memorandum in February 1980, concerning working hours in response to NRC IE Circular 80-02.
The memo establishes a new policy concerning working hours within the operations and maintenance departments; and requires Plant Manager (Director) Unit 1 approval, with documentation of the reason, for devia-tion from the guidelines.
The working hours guidelines apply to supervisors and union personnel.
Interviews during MA Inspection 50-289/80-21 revealed that the policy had been implemented.
The schedul-ing of maintenadce'(plan of the day and outage coordinatio?) and the provision of on-shift maintenance, coupled with an increased 'taff, have improved the maintenance department response to the outstanding work
[
items within. normal working hours.
L f
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Q.9 What ari;zour conclusions regarding TMIA Contenti<a 5?
A.9 Based on the NRC Staff reviews of the Licensee's safety-related maintenance program and practices, including independent Staff review of TMIA Exhibits (work requests), we conclude that the Licensee has not pursued a course of conduct that is in violation of 10 CFR 50.57, 10 CFR 50.40, 10 CFR 50.36, 10 CFR 50.71 and 10 CFR 50, Appendix B, such as would demonstrate that the Licensee is not " technically... qualified to" operate TMI Unit 1 "without endangering the health and safety of the public."
We conc *.ade that the Licensee did not pursue & course of conduct which (a) deferred safety-related maintenance ara repair beyond the point estab-lished by its own procedures (see e.g. AP-1407), or (b) disregarded the
'importance of safety-related maintenance in safely operating a nuclear plant by (1) proposing a drastic cut in the maintenance budget, (2) failing to keep accurate maintenance records related to safety items, (3) having inadequate.and understaffed QA/QC. programs related to maintenance; and,-(4) extensively using overtime in performing safety-related maintenance.
f IN I
E:
TAJllE B
SUMMARY
OF TMI-1 WORVdlEQUESTS ENTERED AS TMIA EXillBITS (Item 4)
(Item 16)
(Item 11)
(Item 10)
(Item 19)
(Item 20)
(Item 21)
(Item 72)
(Item 23)
Sup. of Shift fla in t.
Shift Shift QC Dept.
Sup. of Work Maint.
Foreman foreman foreman forem.in Peview luint.
Pnquest Origin-OC Dept.
Approval Approval Work Work Testing of Work /
uork Req.
WORK DCSCRipTIOff At 0 llumber/
ation Review To Work To Work Reviewed Complete Complete Testing Complete N C EVALUAT10ft 'GitEttIS Priority Date Date Date Date Date Date Date lute Date
Reference:
TMIA Exhibit 11 21910/ID 11/14/77 Blank Blank 11/14/77 Blank 11/27/78 11/27/78 12/1/78 12/4/78 Repacking of feedwater flow (4/12/78) control valve FW-V-17A.
'11/14/77) (11/14/77 i
Note 1 Note 1 Note 1 Note 1: Missing dates were obtained from valve packing traveler maintenance docu-ment, which is an official quality record. This was the only example of this type of administrative in-adequacy with respect to the TMIA Exhibits listed in this table. The maintenance work was for a secondary system problem and had no impact on nuclear safety.
Packing gland was initially adjusted, and valve was
, repacked during 1978 outage.
Observation of repair work continued for seven months after work was completed.
This is considered proper post repair practice, how-ever, in this instance it may have been overly extended Maintenance actions were appropriate for the problem.
_ TABLE B
SUMMARY
OF TMI-1 WORV, REQUESTS ENTERED AS Jf1IA EXillBI,TS (Item 4)
(Item 16)
(Item 17)
(Item 18)
(Item 19)
(Item 20)
(Itna 21)
(Item 27)
(item 23)
Sup. of Shift itaint.
Shift Shift QC (*pt.
Sup. of Work Maint.
Foreman Foreman Inreman foreman fiev ir w Maint.
Pequest Origin-OC Dept.
Approval Approval Work Uork Testinq of Unrk/
Mark Req.
WORK Il[SCRIPil0ft Af10
!!unber/
ation Review To Work To Work Reviewed Complete Crepicte lestirr)
Complete NRC EVALUAi!Ott CG#tltlTS rriority Date Date Date Date Date Date Date Date Date
Reference:
TMIA Exhibit 12 18471/2D 11/11/76 3/19/77 10/13/78 2/20/79 3/16/79 6/27/79 6/22/79 6/26/79 6/27/79 Modification to FW-V-5A/B operators, latch system and cables.
Modification was initiated by Met-Ed corporate engi-neering.
During 11/11/76-1/31/77 an engineering review was conducted including a review of the FSAR in the area of the feedwater system.
Work was scheduled for the May 77 refueling outage.
Due to design criteria re-evaluatlon, work was Jeferred and rescheduled to the 79 refueling outage.
Deferral of modification had
.no impact on safety and was acceptable.
Reference:
TMIA Exhibit 13 23310/lA 3/30/78 N/A 3/30/78 N/A 8/31/79 8/31/70 8/31/79 N/A 9/4/79 Insta11attoi. of drip shield under leaking (nonradioactive water) feedwater block valve FW-V-5A.
MJ"in
SUMMARY
O_F TMI-l WORK REQUE_ST.S EllTERED AS. Tijl A f!!! BITS _
(item 4) M em 16)
(Iten.17)
(! tem 18)
(Item 19)
(Item 70)
(Item 71)
(Item 72)
(Item 23)
Sup. of Shift Ita int.
Stilf t Shift QC Drpt.
Sup. of L'o r k Malnt.
Foreman foreman foreman foremin Review fialnt.
l'equest Origin-QC Dept.
Approval Apptr: val Work llork lestb.)
of l! ort /
Ucrk Feq.
WORK lt%CRIP110ft Afl0 thm tiar/
ation Review To Work To Work iteviewed complete romplete icsting Complete itRC EVALUAT10ft C(f VtEtt!S ritority Date Date Date Date Date Date Date D.i t o Date Tchiporary drip shield in-stalled 3/30/78. Permanent drip pan installed 8/31/79.
Deferral of permanent main-tenance for this secondary system problem bad no impact on nuclear safety.
Reference:
TMIA Exhibit 15 20856/2A 7/28/77 8/18/77 8/18/77 11/28/77 6/29/78 6/20/78 6/30/78 8/29/78 9/5/78 overhaul of various anubbers.
Rebuild.ig of snubbers was used as "f111 in" work.
Spaa snubbers were rebuilt when aufficlent snubbers accumu-lated or when replacement snubbers were needed.
Testis
,is required when the snubber is installed and set up to a certain specific arrange-ment.
Performing the above " fill la maintenance of spare snubberg on a deferred basis is an acceptable practice.
TABLE B
SUMMARY
OF TMI-1 WORK REQUESTS EllTERED AS TMIA EXHIBITS (item 4)
(Iten 16)
(Item 11)
(Item 18)
(Item 19)
(Item 20)
(1 tem 21)
(Item 22)
(Item 23)
Sup. of Shift
!!a in t.
Shift thlft QC Dept.
Sup. of Work Fisint.
Foreman foreman Foreman foreman Review fla int.
Pequest Origin.
QC Dept.
Approval Appr oval Unrk Hork Testinq of Ucrk/
Uurk Req.
HOOK DESCPIPTIOri Ar20 ihmhet /
ation Review To Hork To Work Reviewed Complete Complete Testing Complete NRC EVALUAT10fl C(fttEtifS triority Date Date Date Date Date Date Date Date Date
Reference:
TMIA Exhibit 16 15350/1A 5/11/76 5/11/76 5/11/76 5/11/76 2/4/78 2/4/78 2/4/78 2/13/78 2/15/78 Replacement of intermediate Note 2 cooling system filters IC-F-1-A/B.
Note 2: The work request was used twice to work on both filters.
The filters were changed first on 5/18/76 and later on 2/4/78. A change to Procedure 1407-1 in 1979 does not allow " blanket" work requests to stay active for longer than 1 yeat.
Use of this work request twice was a poor practice, but did not affect safety because the work was other-wise properly performed and
.affected systema were properly controlled and returned to service.
1 Allt.E U
SUMMARY
OF TMI-1 WORV, REQUESTS ENTERED AS IMIA EXillBITS (Item 4)
(Iton16)
(ltem 17)
(Item Ill)
(Item 19)
(Item 20)
(llem 21)
(Item 22)
- f. Item 23) top. of Shift 11a int.
shift Shift QC flapt.
Sup. of Work Hafnt.
Foreman Foreman foreman forem n Iteview Haint.
Acquest Origin-QC Dept.
Approval Approval Work llork Testing of llort/
Work Req.
EDK PCSCPipT10fl fJ30 laun t er/
atton Review To Work To Work Reviewed tomplete Complete Testing Complete NRC EVALUATIOff t0fE1Enis l'riority Date Date Date Date Date Date Date (h t e Date
Reference:
TMIA Exhibit 17A Repair shaft seal (non-
- - - - - - - - --------- -Canceled (Records Purged on 11/6/79)-
= = - - - - - -
23579/lA 4/22/78 Note 3 radiological) packing leaks on nuclear river booster pumps NR-P-2A and NR-P-2B.
Note 3:
Example of a work request written to perform maintenance work that was being done under another work request.
Cancelation of the duplicate work request was acceptable. Current com-puterized job tickets should preclude this problem from recurring.
Reference:
TMIA Exhibit 1 715
-Cancoled (Duplicat of WR #: 3579)----
Repair packing leaks on NR-P--
23858/lA 5/13/78 Note 3 IB.
=--__ _________________
Reference:
' INIA Exhibit I/C 24252/2A 6/17/78
-Canceled (Duplical e of Wit #: 3858)----
Repair packing leaks on NR-P-Note 3 IB.
e TAllLE B
SUMMARY
OF _TM_I_-1J10R,K REQUESTS ENTERED AS 1MIR EXillBITS
~ item 22)
(Item 23)
(Item 4)
(Item 16)
(Item 17)
(Item !!!)
(Item 19)
(Item 20)
(item 21)
(
Sup. of shift ita in t.
Shift Shift QC Dept.
Sup. of ttaint.
Foreman Foreman Foreman Inveman Review t1aint.
Park
()C Dept.
Approval Approval Work llork Testioq of ifork/
Llork Req.
WORK DESCRIPTIOrt ArsD Reyses t Origin-t;unter/
ation Review To Work To Work iteviewed Complete Complete Testing Complete NRC EVALUATIort tarttrats Priority Date Date Date Date Date Date Date Date Date f
Reference:
TMIA Exhibit 17D 25056/2A 8/28/7S
-Canceled (Duplicat e of WR #;'3858)-- -
Repair packing Icaks on NR-P=
Note 3 IB.
c
Reference:
TMIA Exhibit 17E 25124/2A 9/2/78
--Canc eled (Duplicat e o f WR # '5056)----
Repair packing leaks on NR-P-Note 3 IB.
Reference:
TMIA Exhibit 17F 25129/2A 9/4/78
--Ca nceler (Duplical e of WR#2 >0 5 6 ) --
=-
= - Repair packing leaks on NR-P-Note 3 IB.
Reference:
TMIA Exhibit 18 18626/2A 1/22/77 *~'5/78 12/5/18 12/5/78 1/10/79 1/10/79 1/10/79 1/12/79 1/31/79 Repair packing leaks on NR-P-IA/IB/IC and NR-P-2A/2B/2C.
Note:
Exhibits 17A-F descrit, similar repai,r work.
Delay i completing work due in part t<
material delivery problems.
Deferral of work did not affect safety.
TAJ!LE !!
SUMMARY
_OF TMI-1 WORK REQUESTS Et[T_ERED AS TMI A EXf!IBITS (Item 4)
(Item 16)
(Item 17)
(Item 18)
(Item 19)
(Item 20)
(Itra 21)
(Item ??)
(Item 23) !
Sup. of Shift flaint.
shift shift
(/: f ep t.
Sup. of Mcn k Maint.
Foreman Foreman foreman Foreman review tiaint.
Request Origin-QC Dept.
Approval Approval Work Unrk Testinq of !! ark /
thrk Req.
WOTM DESCRIPTIOrt At:0 therber/
ation Feview To Work To Work Reviewed Complete torplete Tes ting Complete "RC EVALUAll m CitttENIS Priority Date Date Date Date Date Date Date IM te Date
Reference:
THIA Exhibit 19_
19590/ID 4/7/77 9/16/77 9/17/77 9/17/77 9/18/77 1/16/79 1/16/79 2/1/79 2/2/79 Remove, relubricate and retorque hand hole, manway and aux nozzle nuts on OTSG "A" and "B".
Corrective maintenance initiated on 4/7/77 to be done after heatup and cool-down. kork deferred until unscheduled cooldown in Sep 77.
All work was completed except the bottom primary side manway of OTSG "B" due to high radiation. The work request (19590) should have been closed out, but
.was not.
Similar work was completed during the 1978 refueling outage under work l
request 22878.
Paperwork found still open during plan for 1979 outage was then closed out.
Delayed closeout of the work request was unusual, but the method of final closcout was acceptable.
l.A.C_L E.11 SilfftARY OF TMI-l WORK REQtJESTS EllT,ERED AS. TMIA_ EXHIJ1J_TS_
(Item 4)
(Item 16)
(Item 17)
(Item 18)
(Item 19)
(Item 70)
(Itrm 21)
(lica 72)
(Item 23) ~
Sup. of shift ita int.
shift Shift 4r trpt, s,,p, or Work Haint.
Foreman Foreman foreman foreman
!!cview thint.
Pequest Origin-QC Dept.
Approval Appioval Work Hork Icstivi of.!orlf Work Feq.
WODK IU CPIPTIO?l APID IM tier /
ation Review to Work To Work Reviewed templete torplete insting Complete irtC EVALUAIINI Urritt Is friority Date Date Date Date Date Date Date Date Date
Reference:
TMIA Exhibit _20 22181/2D 12/13/77 3/2/78 3/3/78 3/20/78 4/8/78 4/10/78 4/10/78 1/15/79 1/18/79 Inspection of reactor coolant system valve limit switch and torque switch.
Post-work QC Dept. rcview delay was reportedly due to backlog of other outane paperwork.
Maintenance activities were acceptab b.
Delayed QC revie of work request did not af fec the quality of work.
Reference:
TbilA Exhibit 21 22268/lA 12/27/77 12/27/77 12/27/77 12/27/77 Replace indicator on "11"
. makeup pump discharge isolation valve Mil-V-74n.
The valve operator work van completed except replacing the indicator pin on the valve. Operationally, the valve functioned properly.
The work requent was purged from the system on 11/5/19, instead of completing the paperwork.
TABLE B
SUMMARY
OF TMl-1 WORK RE, QUESTS ENTERED AS TMIA EXHIB1iS (Item 4 (Item 16)
(Item 17)
(Item 18)
(Item 19)
(Item 20)
(Item 21) ~
(Item 72)
(Item 23)
Sup. of Shift fla in t.
shtfL
%llt t10 Dept.
Sup. of Work Hafnt.
Foreman Foreman foreman forcuan review ttaint.
Pequest Origin.
QC Dept.
Approval Appr oval Work Unrk Testino of Unrt/
Ucr> Feq.
WOM RESCRIPT 10't AND thriber/
ation Review To Work To Work Reviewed Complete Complete lesting Complete NRC EVALUATIOff Cfff!ENTS Priority Date Date Date Date Date Date Date Date Date The inoperable position indicator for this. manually operated valve, which is either fully closed or fully open, has no opera-tional or safety significance
Reference:
TMIA Exhibit 22 25166/lA 9/6/78 Canceled (Records
' urged on i 1/2/ 79)--
- = - -
Attachment of chains to hammers and drift punches in the reactor building personnel access hatches.
Work request was never processed by engineering, due to different design change to be used to solve
, problem per work permits C 0372 and C 0371. Work request was purged from system during review of outstanding maintenance documentation.
Cancellation of this modification work request for the above reason was acceptable.
.T_A!!_L_E_ _.B.
SUMMARY
OF TMI-1 WORK RE, QUESTS ENTERED AS TMIA EXilIBITS (Item 4)
(Item 16)
(Item 17)
(Item 10)
(Item 19)
(Itt,n FC)
(Item 21)
(Item 72)
(Item 23)
Sup. of Shift fla in t.
shift shift 40 r>pt.
Sup. of Mar k Haint.
foreman foreman Torrman For enan Peviov Haint.
Re.rses t Drigin-OC Dept.
Approval Apprnval Work Work Testiriq of Unrt/
Work Req.
WORK IC%CRIrilott AND thm ber/
atton Review to Work To Work Reviewed trwnplete Complete Testing Crsrplete NRC CVALUATIO'l C(TFtENTS Priority Date Date Date Date Date Date Date flate Date
Reference:
DilA Exhibit 23 24246/2A 6/15/78 6/22/78 6/22/78 2/26/79 3/14/79 3/22/79 3/22/79 4/16/79 5/14/79 Reposition improperly mounted limit switch on reactor building access hatches.
Work determined to be necessary in June 1978, partc and material to do the work received.,nd released from 43 in February 1979.
Maintenance was done in an acceptable and timely manner for the nature of the work and minor significance of the problem.
_=_
Reference:
UlIA Exhibit 28 15349/lA 5/11/76 5/11/76 5/11/76 5/11/76 5/18/76 2/2/78 2/2/78 2/3/78 2/15/78 Replacement of makeup filter MU-F-1A/II.
Blanket" work recluest was issued and used to change out filters six different times from 5/11/76 to 9/28/77.
No apparent reason why it was not closed out until Feb 78 i
T A_BLE H_
SUMMARY
OF TMI-1_ WORK REQUESTS EllTERED AS TitIA EXilIBITS (Item 4)
(Item 16)
(Item 17)
(Item 18)
(Item 19)
(Item 20)
(Item 21)
(Item 22)
(item 2.1)
Sup, of Shlft Itaint.
Shlft Shift QC Dept.
Sup, of Work Halnt.
Foreman Foreman forciaan forem.m I?cview Haint.
Request Origin-QC Dept.
Approval Approval Woi-k Work Testing of !! ort /
Wrk Req.
WORK MSCRIPil0ff ArtD flumber/
atton Review To Work To Work Reviewed tomplete tneplete Testing Complete NtC EVALUATI0ra trsittrats priority Date Date Date Date Date Date Date Date Date This apparent oversight did not affect plant safety.
Current administrative pro-cedures should prevent recurrence of this type of problem.
Reference:
TMIA Exhibit _31_
C0178/l 1/7/79 1/9/79 1/9/79 1/9/79 1/9/79 Blank 8/3/79 8/8/79 8/10/79 Repair fuel handling door (Not 3 cal.
Required)
Work was promptly completed.
Work request held open for observation of repairs for unusually long period, but this had no safety impact.
Final documentation of post-work testing and review was
,acceptahle.
Reference:
TMIA Exhibit 33A 20000/2A 5/16/77 Canceled Replace air handling G.ot Note 4 machine shop exhaust) filters All-F-6A/ B.
Note 4: Work request to replace the filters was initiated based on high differenttal pressure across
.T_A_l:L_E__B_
SUMMARY
OF TMI-1 WO_R_K REQUESTS EllTERED AS TMIA EXillBITS (Item 4)
(Item 16)
(Item 17)
(Itea !!!)
(Item 19)
(Item 70)
(Item 21) 3 tem 22)
(Item 23)
Sup. of Shift fia int.
Shlit Shlft if Dept.
Sup. of Work Maint.
Foreman foreman foreman Foreman Review ttaint.
Request Origin-QC Dept.
Approval Approval Work Work Testir.o of Ucrk/
llork F.cq.
WORK rEstPirT!9ft Ar:0 thnber/
ation Review To Work To Work Reviewed Complete Cocplete lesting Complete NRC EVALUATI0rt Crners triority Date Date Date Date
'Date Date Date Date Date Note 4 continued:
the filters as found during operations surveillance. The work was not approved for accomplishment by plant management and the work request was canceled.
Similal work was later performed unde' another job ticket.
Although the ventilation system installation is regarded as QC, these f11ters are not within QC scope, and the work involved was not nucicar safety related.
Apparently, due to maintenanc.
backlog, changeout of ventilation filters was
, deemed a very low priority job. Cancellation of the work request had no safety impact.
Reference:
TtlIA Exhibit 33_n 20183/2A 5/29/77
-Canceled-Replace air handIing fiItern Note 4 All-F-6 A. (See W.R. #20000/2A)
.=.
TABLE _B_
SUMMARY
OF TMI-1 WORK _RE_ QUESTS ENTERED AS TMIA EXHIBITS (Itna d)
(Item 16)
(Item 17)
(Item 18)
(Itnn 19)
(Item 70)
(Item 21)
(Iton 72)
(Item 23)
Sup. of Shift fla int.
Shift
%IIL QI: Dept.
Sup of Unrk Maint.
Foreman Foreman l omnan forcu n Feview ifaint.
Request Origin-QC Dept.
Approval Approval Wnsk Work Testinq of 1: ort /
thrk Req.
WORK l'CSCRtritor: Mr0
!Lmber/
atton Review To Work To Work Reviewed Complete Cooplete Testing Crnplete tiRC EVALUAf tort Crrr:Ents l'riority Date Date Date Date Date Date Date Date Date
Reference:
TMIA Exhibit 33C 20332/2A 6/19/77
-Canceled-
=
Replace air handling filter Note 4 All-F-6 B.
Reference:
TMIA Exhibit 33D
-Canc eled-Replace air handling fi1ter 20974/2A 8/7/77 All-F-6 B.
Note 4 1
Reference:
TMIA Exhibit 33E 21165/2A 8/28/77 Canceled-Replace air handling filter Note 4 All-F-6 A.
Reference:
TMIA Exhibit.3_3F 21587/2A 10/7/77 Canceled Replace air handiing f11ter Note 4 All-F-6A.
Reference:
TMIA Exhibit 3_3G Replace air handling filter 21794/2A 10/30/77
- -Canceled Note 4 All-F-6A.
.T.A..l:1. E_ 11 StM4ARY 0f TMI-l WORK IEQllf,STS EllTERfD AS Till A__EXil! BITS _
(Item 4)
(Itcen 16)
(Itca 11)
(Iton 18)
(Itcia19)
(Iton 20)
(Item 21)
(Item 72)
(Itens23)
Sup, of Shift 11a int.
%lft Shift tjt Dept.
Sup, of Wor k Ftilnt.
foremal foreman fornnan foreman Revle.#
flaint.
Pequest Drfgin.
QC Dept.
Alproval Approval Work Hork Testinq of ifor>/
tlork Peq.
WORK DCstPirilDft AND biter /
atton Revicw lo Work To Work Reviewed Complete Complete lestlw; Complete imC EVAtuATlora Carrttttis l'rlori t y D.ite Date Date Date D.ste Date Date lu te Date
Reference:
THIA Exhibit 3 311 22043/2A i1/28/77 Replace air hand 1ing fiIter
- Canceled- --
Note 4 All-F-6 B.
- _ _ _ _ _ _ _ _ _ - - - - - - = _ _ _ _ _ _ _ _ _ _ _.
Reference:
TMIA Exhibit 33I 21769/2A 10/27/77 10/28/77-- Canceled-Replace Air handling f11 tern Note 4 All-F-5 and All-F-6A/6B.
- = - - - -
Reference:
'Ill!A Exhibit 3_3.1.
22905/2A 2/21/78 2/22/78-- Ca nc ol ed-- - - - - - - - - -
Replace air han<lling filter Note.
All-F-6A.
Reference:
'IllI A Exh t hi t 33K 23042/lA l/3/78 3/6/78 3/10/78 -
--Cancel. 4--------
Replace air handling filtern A ll-F-6A/ 611.
Work documented as completed,'
but work requent later ennceled.
Reference:
TMIA Exhthtt Yll.
25149 9/5/78 9/6/78 Replace a ir handlInn fIIt er
Can<' I cil----
Note 4
All-F-6 A.
TABLE B
SUMMARY
OF TMI-1 UODK_RE_ QUESTS ENTERED AS TMIA EXilIBITS (Item 4)
(Item 16)
(Item 17)
(Item 18)
(Item 19)
(Item 20)
(Item 21)
(Item 22)
(Item 23)
Sup. of Shift fla int.
shift Shift IT Dept.
Sun. of Unr k Maint.
Foreman Foreman foreman Foreman Review Maint.
Roquest Drigin-QC Dept.
Approval Approval Work Ucrk Testinq of 1:ork/
Work F0q.
WORK p[%CRipi!Gil /WD thm ber/
ation Review To Work To Work Reviewed Complete Complete Testing Complete NRC EVALUAiltri crit:ENIS priority 9 ate Date Date Date Date Date Date Date Date
Reference:
"I111A Exhibit 33y C1055 5/22/79 7/2/79 7/2/79 7/3/79 7/3/79 7/3/79 7/3/79 7/6/79 7/3/79 Replace air handling f11ters AH-F-6A/6B.
Maintenance work request was satisfactorily processed, indicating acceptable com-pletion of the filter replacement.
Reference:
7111 A Exhibi t 34A 20070/2A 5/22/77
-Canceled Replace air handl (control Note 4 tower emergency)
.e ers All-F-4 A/4 B.
Reference:
- 1111A Exhibit 3/g 20139/2A S/25/77
---Canceled----------
Replace air handling filters Note 4 All-F-4 A/4 B.
=-.
Refe;ence: 'l?!IA Exhibit 34C 20254/2A 6/3/77 6/6/77 -
- - = - - - - - -
---Cancel' d--------
f Replace air handling fiIters Note 4 All-F-4 A/ 4 B.
k
I.A.i!!.E.11
SUMMARY
OF TMf-1 WORK REQUI;STS. ENTERED AS JMI A EXJIJBITS_
(Item 4)
(Item 16)
(Item 17)
(Item 18)
(item 19)
(Iton 20)
(lte,n 21)
~htenn22)
(item 23)
Sup. of Stilf t ita in t.
Stilf t Stili t UC tw pt.
Sun. of Woi k Maint.
Foreman foreman forrman Foreman Review fla int.
Request Origin-()C Dept.
Approval Approval Work Work Testing of Unrk/
Wark Req.
WORK 0CSCPirT10rs A*r0 ILebe /
atton Review To Work To Work Reviewed Complete Corople te lesting Complete NRC EVALUATitra Cffrtthis referity Date Date Date Date Date Date Date (Lite Date
Reference:
TMIA Exhibit 34D 20545/2A 7/2/77 Signature
-Ca nc el e.l---------
- Replace air handling filters But No Note 4 All-4 A/4B.
Date
Reference:
TMIA Exhibit 34E 20673/2A 7/13/78 7/14/77
--Cancele t---------
Replace air handling filters Note 4 All-F-4A/4 B.
_-_-___c
Reference:
TMIA Exhibit 34F 21000/2A 8/10/77 8/10/77
Cancele 1 Replace air handling filter Note 4 All-F-4 B.
Reference:
TMIA Exhibit 34C 21534/2A 10/4/77 10/5/77
---Ca nc e l o 1 (Duplic.
te)--
Replace air handling filter Note 4 All-F-4 B.
Reference:
TMIA Exhibit 3411
(
21674/--
L--Canceli <l (Duplic.ite of WR #23897)-
Work description unknown.
Note 5 Note 5: Work rerguest lost.
Unable to assess signiff-cance of work.
TABLE B
SUMMARY
OF TMI-1 WORK R_EQU_ESTS EtiTERED AS TMIA EXIIIBITS (Item 4)
(Item 16)
(Item 17)
(Item 18)
(Item 19)
(Item 70)
(Item 21)
(Item 22)
(Item 23)
Sup. of Shift Ita int.
Shift shift QC Dept.
Sup. of Work Itaint.
Foreman Foreman foreman foreman Feview ltaint.
Request Origin-QC Dept.
Approval Approval Work Work Testinq of !!orff Work Req.
WORK OESCRIPTI0rt nio ihmber/
ation Review.
To Work To Work Revi a4 Complete Corrpicte Testing Complete f4RC EVAttlATI(rt Cffr:Er4rs triority Date Date Date Date cate Date Date Date Date
Reference:
TMIA Exhibit 34I 22064/2A 11/30/77 Cauceled-Replace air handling filter Note 4 All-F-4 B.
Reference:
TMIA Exhibit 34J
~ 21982/2A 11/12/77 11/21/77-Canceled- ---------
Replace air handling filter Note 4 All-F-4 B.
--e
Reference:
TMIA Exhibit 34K C-0689 3/12/79 6/22/79 6/22/79 Blank 6/22/79 Not Not 7/8/79 7/16/79 Replace air handlir.g filter Required Required All-F-43.
Maintenance wors request was satisfactorily processed
, indicating acceptable com-pletion of the filter replacement.
_____________c 4.
TABLL B
SUMMARY
OF TMI-1 WORK REQU_ES_TS_ EfjTERED AS TMIA_EXillBI.TS_
(Item 4)
(Item 16)
(Item 17)
(Item 10)
(Item l'))
(Itnn 2t))
(Item ?!)
litna72)
(l tem 23)
Sup. of Shift Itaint.
%Ift
%ilt fr Dept.
Sup. of Unrk Haint.
Foreman Foreman Inreman f on emn Imylew ttaint.
request Origin-QC Dept.
Approvkl Appr oval Work Hork icstin1 of Uni)/
thrk Req.
WOCK DE%CRIPTI0tt AND thritier/
ation Review To Work To Work Reviewed Coinplete Crm ple te lesting Complete NRC EVALUAil(rt Cartutis frlority Date Date Date Date Date Date Date Date Date
Reference:
DilA Exhibit 39 23635/lD 4/28/78 4/28/78 4/28/78 4/28/78 6/28/79 6/28/79 6/28/79 7/2/79 7/16/79 Repair four Control Rod Drive motor thermocouples.
Work was delayed due to lengthy delivery time for material and appropriate plant condition to perform the maintenance.
Deferral of work for these reasons is acceptable, and did not impact plant safety, since the CRD thermocouples were not essential for plant operation.
-____________________________c
Reference:
DilA Exhibit 40 20801/IA 7/22/77
=
+
-Ca n c e l ed--
. Repair reactor coolant pump
- 1 seal lenkoff recorder alarm switch and relay.
The initial high priority work request was can-celed and rer~.sced with new work re,uest #21061 (originati,n date 8/17/77).
More eny8.eering studies revealed the actual problem and another work request F25957 (priority 3/origina-tion date 11/6/78) was issued which canceled WR #21061.
~2
.TA_l:LI: 11
SUMMARY
OF TMI-1 WORK REQi[EST_S_ Ef[TERED _ftS. TMI A Ey._!11 BITS _
(Item 4)
(Item 16)
(Item 17)
(Itc, !!!)
(Item 19)
(Item 20)
(Item 21)
(Itee 22) 3t'em23)
Sup. of Shift fla int.
%If t 5tilf t (F: Dept.
Sup. of Work
- Maint, foreman foreman foreman foreman Review
- Maint, request Origin-QC Dept.
Approval Approval Work Unrk Testinq of Uort/
Work Req.
WORK PESCRIPTIOff MID
!!utber/
ation Review To Work To Work Reviewed Complete Complete Testing Complete NRC EVALUATI0tt CGtithis Priority Date Date Date Date Date Date Date Date Cete Caricellation of unrk request and replacement with a lower priority work request was appropriate for the problem.
Reference:
TMIA_ Exhibits 42 and 4},\\
13047/2A 12/19/75 1/8/76 1/12,
--Ca nc e l ed ---------- - - - - - - - - -
Repair oil reservoir leaks or3t miscellaneous waste transfer pump WDL-P-78.
The apparent oil leak was assessed by utaintenance personnel as a possibic spillage of oil during reservoir filling, and the work request was cancelled on 2/12/76.
Similar work was
,later completed under WR #24854.
Cancellation of the work request for the above reason appears acceptable.
TABLE B
SUMMARY
OF TMI-1 WORK _ REQUESTS EflTERED AS TMIA EXHIBITS litem 4)
(Item 16)
(Item 17)
(Item 10)
(Item 19)
(Item 70)
(I te:421)
(Item 72)
(item 73)
Sup. of shift 11aint.
Shlft Shift QC I+pt.
Sup, of
-Work Maint.
Foreman Foreman foreman forennn Review Maint.
Request Origin.
QC Dept.
Approval Approval Work Hork Testing of t!ork/
Work Req.
WORK DCtCRIPTI0tt t.r30
!!unber/
ation Feview To Work To Work Reviewed Complete Complete Testing Complete NRC EVAIDAT10tl (fifttrats Priority Date Date Date Date Date Date Date fla te Date
Reference:
TMIA Exhibit 43B 24854/2A 8/9/78 8/10/78 8/14/78 8/14/78 8/16/78 8/16/78 8/16/78 8/22/78 8/25/78 Repair / replace waste transfer pump WDL-P-7B casing gasket leaks.
No problem with this work request. Similar to work described for WR #13047, abov s
a 9
'em et UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of METROP.0LITAN EDISON COMPANY, ET AL.
Docket No. 50-289 (Restart)
(Three Mile Island Nuclear Station, Unit 1)
)
CERTIFICATE OF SERVICE I hereby certify that copies of:
1.
"f'RC Staff Testimony of Richard R. Keimig and Donald R. Haverkamo in Response to 7ne Board Questions Concerning Auditability of Maintenance P actices In The Sample Year, 1978, and Currently" dated March 17, 1981; 2.
"NRC Staff Testimony of Richard R. Keir and Donald R. Haverkamp In Response to TMIA Contention 5 - Maintenar.ce At TMI-1" dated March 17, 1981; and 3.
Memorandum from R.
P,. Keimig to D. T. Swanson dated March 13, 1981 regarding apparent concerns raised by TMIA.
in the above-captioned proceeding have been served on the following by deposit in the Uni.ed States mail, first class, or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commissien's internal mail system, this 18th day of March, 1981:
Ivan W. Smith, Esq., Chairman Walter W. Cohen, Consumer Advocate Administrative Judge Department of Justice Atcac Safety and Licensing Board Strawbe.ry Square,14th Floor 25 North Court S m et Harrie'ourg, PA 17127 Harrisburg, PA 17105 Dr. Linda W. Little Mr. Steven C. Sholly 3
Union of Concerned Scientists Acministrative Judge 172S I Street, N.W., Suite 601 Atamic Safety and Licensing Boa'd Washington, DC 20006
'5 ':crth Court Street farrisburg, PA 17105 l
Mr. Thomas Gerusky Bureau of Radiation Protection Dr. Walter H. Jordan Department of Environmental Administrative Judge Resources Atomic Safety and Licensing Board P.O. Box 2063 25 North Court ;:reet Harrisburg, PA 17120 Harrisburg, rA ;7105
' George F. Trowbridge, Esq.
Shaw, Pittman, Potts & Trowbridge Mr. Marvin I. Lewis 1800 M Street, N.W.
6504 Bradford Terrace Uashington, DC 20006 Philadephia, PA 19149 Karin W. Carter, Esq.
!!etropolitan Ed: son Company 505 Executive House ATTN:
J.G. Herbein, Vice P.O. Box 2357 President Harrisburg, PA 17120 P.O. Box 542 Reading, PA 19603
. Honorable liark Cohen 512 E-3 !!ain Capital Building Harrisburg, PA 17120
!'s. Jane Lee John Levin, Esq.
R.D. #3, Box 3521 FA Public Utilities Comission Etters, PA 17319 Box 3265 Harrisburg, PA 17120 1:5. Gail P. Bradford A'iGRY Jordan D. Cunningham, Esq.
245 West Philadelphia Street Fox, Farr and Cunningham York, PA 17404 2320 t; orth 2nd Street Harrisburg, PA 17110 John E. Minnich, Chaiman Dauphin Co. Board of Commissioners Ms. Louise Bradford Dauphin County Courthouse TMI ALERT Front and Market Streets 1011 Green Street Harrisb.rg, PA 17101 Harrisburg, PA 17102 Robert Q. Pollard Ms. Ellyn R. Weiss 609 Montpelier Street Sheldon, Harmon & Weiss Baltimore, MD 21218 1725 I Street, N.W.
Suite 506 Chauncey Repford Washington, DC 20006 Judith H. Johnsrud Environmental Coalition on Thomas J. Gennine. Deputy Nuclear Power Attorney General 433 Orlando Avenue Division of Law - Room 316 State College, PA 16801 1100 Raymond Boulevard Newark, N.J.
07102 Ms. Frieda Berryhill, Chaiman Coalition for Nuclear Power Plant Atomic Safety and Licensing Board Postponement Panel
- 2610 Grendon Drive U.S. Nuclear Regulatory Commission Wilmington, DE 19808 Washington, DC 20555
3-i Ms. Marjorie M. Aamodt Atomic Safety and Licensing Appeal j
R.D. #5 Panel (5),
Coatesville, PA 19320 U.S. Nuclear Regdatory Commission Senator Allen R. Carter, Chainnan Joint Legislative Committee on Docketing and Service Section (7)
- Energy Office of the Secretary Post Office Box 142 U.S. Nuclear Regulatory Commission Suite 513 Senate Gr.ssette Bldg.
Washington, DC 20555
- Columbia, SC 29202
,,e
,n,,.
/ - -
.;.r..-
Daniel T. Swanson Counsel for URC Staff 1.
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