ML20003D199
| ML20003D199 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 07/11/1980 |
| From: | Christopher R NRC |
| To: | Allan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML20003D189 | List: |
| References | |
| NUDOCS 8103190561 | |
| Download: ML20003D199 (11) | |
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!!E'.ORAhDuti FOR:
James Allan, Ceputy Cirector FRCM:
R. K. Christopher, Investigation Specialist
SUBJECT:
CONCERNS RAISED IN THE TMIA CEF0SITI0iiS In reviewing the T!!IA Cepositions there were seven (7) gancral arcas
'~ that appear to receive the greatest emphasis from the I!IA representatives.
These areas of concern are not cenerally accorpanied by specific allegations or su?;crted by facts.
The cuestioning of individuals about these araas us an attempt to obtain specific infcrmaticn that v.culd correterate tM se ccncsrns.
It is ry impressicn thet de follcuing seven areas will receive the Sreatest e p'csis.
r Concern "o.
1 R,2 philesophy guidelines and irplenentaticn of the Priority System used in Se Trocessing of I'aintcnanca ;:rk Ceders:
Cc ment:
752 2..phasis in questicning is in regards to the originator of a t.crk cr:'ar cnd who accually establishad ' hat priority it will hs.va and '.ho has the au:hority to change the priority of the wrk cedar.
The irplication here is that the Operations tecarvent, who has the final decision with re; arcs to what the priority is and what condition the plant is in is prcductica criented and therefore creates a tandency to delay or change the priority of a work order in the interest of heeping the plant on the l i r.e.
?!o specific allegation or fact appears in the deposition with regard to this alle5ation. Gees back to the producticn vs. safety issue.
Concarn ::o. 2 The backlog of work orders in the Maintenance Department:
Coment:
This refers to a backlog of work crders in both rechanical and electrical rai ntenar.ce. T'i!A cites uhat it believes to te instances where Priority I werk recuests are not done for up a year.- The depositions cite cne instance in which it took 4 years to cbtain 6 digital replace ::nt on the Ccusole Indicatcrs.
The time pericJ involved is related to the ensintering d: cision to inplement using the digitals.
The backlog of ecrk ceders is also used as an example cf ir. sufficient and inexperienced r.anpower at T :!.
The T"IA inplies the shcrtar.e of nann.1er furt' er a ;ravates the clant's ability to naintain ;.reventiv2 nai'.L;.:ance schenlas.
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P_00R ORIGINAL
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Concern tio. 3 Extensive cvertir.e for plant maintenance personnel is a safety risk.
T;41A cites extensive instances of double shif ts,12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> days, and weeks without tire off during scheduled and unscheduled outages.
Coment:
Tnis is a heavily discussed itan in the depcsitions and relates to wrk ceder backlogs, r.anscuer shcrtages and inability to raintain day-to-day s:hadules.
It is tited as a safety concstn in t' rat plant parscrr.el are so tired ' hey cannot perform thei:- f:ts effsetively.
se;eral of the fer-er plant e:coloyees ;oint to what they feel is forced ar.d c.anda: cry ovartime during unscNduled outag:s.
'O nCern EC. 4 Tasting Frccaduros on plant cc: 7.an.s are sic;py with ccr.tr:ry results being igncres and tossible falsificatica of test records (; _raulic
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2: rant:
D.is co., carn is based en an *pril 16, 1973 r.e<: sparer article in the Philadelphia Ir.quirar in which a for:.er ::aintaranca ?: reman (::2chanical) icentified as oichard Blakaran alleged that the hydraulic snubbers '.:ere not being croperly tested. Fe allegas that in " arch 1978 all but a few snubtors (Unit 1) were signed off as testad in two days by an engineer.
The dispositicas providad nothing c:ncreta on this issue but the THIA effort in this area is extensive.
D. P.averkamp feels this shculd be looked into further.
Concern i;o. 5 The practice of making te::porary repairs on plant cocconents and systems in order to s'ay on the line is causing a safety concern.
P00R ORIGINAL M'II".
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Corrent:
This concern is from the Philadelphia Inquirer article on April 16, 1979.
A formar employee alleges that pump leakaces were being temporarily ~ fixed with packing rather than techanical seals because seals are rcre expensive and often it requires cutting back on power operations to :.ske rapairs.
An example en the disposition indicate that tetporary packing is still in place after 2 years on
' the Driv-1 valve in the heat remval systen.
This line of questioning tainly leads to the producticn vs. safety issue.
C:ncern ::o. 6 Rad Masta Cparaticns as a radicic]ical safety issue.
Corrent:
- o allegattens or ccncarr.s are cluriy expressed en the subject of r:d 5.cs:2.
OvcVer, there is a keen intarast in the day-tc-day crerations in that dpa: t en-as relatad to Balth Physics involvement, radiaticn : rotectica, and Mr.inis trative renitoring of individual e:y'osure data.
Also extensiva int 2 rest in Jin Snith's activities in rad waste.
Ccacarn ::c. 7 Narcotics and alcohol abuse by employees and contracters en the island.
Co. rent:
!!o sup::ortive information in any of the dispositions en this issue.
Crinking proble.:s are probably cost prevalent while contract personnel are on site and during the second and third shift lunch breaks.
The drinking problem is ecstly centered in the parking lot out of an ice box rather than at local tars and restaurants. Possibly including in inspection criteria the presence and enforecr.ent of drinking and drug use prohibitions during work hours by the licensee including avenues for local agency referrals on narcotics tatters.
R. Ys. Christopher Investigation Specialist cc:
P00R ORIGINAL
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- .n.s.; The following items:are concerns that became evident en a lesser scale in the
-:#.: THIA depositions and may also becone issues at a' hearing procedure:
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- Quality of work'done by contractor pers'onnel (no specifics).
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Operators deactivating audible alarrs in the control recm b:-cause of t5 e noise.
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- 4.. Cancellation of safety cuttings during outages.
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Eeron accu 21ations in drains and c7 the floor in reactor building.
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Testing of Unit VI safety valves' by letting super heated steam rush out of
' them into a standpipe; caused thb sleeves on the valves to blow throwing retal into the air and blowing the alurinum eff the side of the building.
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Eudget cutbacks in the W.intenance Dzpartment.
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Inadequate Quality Control Surveillance because of insufficient tanpower.
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Inconsistent instrumentation calibration because of a lack of canpower in
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Vibrations in valves, handwheels, pipes etc.
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. 11. Various valves being permitted,to leak until an outage..
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.12. - Hotwell level indicator problems..
- 13. Delaying certain maintenance work orders and allowing a problem (i.e.
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Statement of R. R. Keimio Relative +o Additional Concerns No.1, No. 2, flo. 6 and f;o. 9 Additional Concern No. 1
, Perceived Concern: The use of contract personnel in high radiation areas rather than company employees to keep company employees from being " burned out".
The use of contractors to perform maintenance in radiation areas is not an unusual practice in the nuclear po.<er industry.
In some cases, the individual contractor has a highly specialized skill which enables him to perform a particular job more rapidly and efficiently, thereby resulting in a lower total ran-rem exposure for the job than would be possible using less specialized, licensee employees.
Certain skills are only needed on occasion so it is economically r.cre advantageous to contract for that skill than to maintain a full-time employee who only occasionally uses that skill.
In general, use of contractors during hot maintenance assures that upon return to power or during unscheduled shutdowns or emergencies the plant staff has a sufficiently low accumulated radiation exposure to permit the use of plant staff during these exigencies.
If they were to approach permissible exposure limits curing a planned outage, their use during operation may be severely restricted with greater percentages of the plant staff close to exposure limits at a time when exposure may have to be taken to assure safe operation.
It should be noted also that the use of contracted personnel, or personnel from specialized groups within a company's organizational structure, to perform certain activities is not common only in the nuclear industry.
It is prevalent in most industrial operations since economic plant operation staffing levels, in many cases, do not warrant the numbers of personnel, or personnel with specialized skills, necessary during outages to be included as permanent plant staff.
The only different aspect relative to -he nuclear industry is the additional consideration of 'the plant staff's exposure to radiation as discussed previously.
In summary, the Staff does not consider it improper for a utility to use contract personnel rather than company employees in high radiation areas.
P00R ORIGINAL.
Additional Concern No. 2 Perceived Concern: Quality of work done by contractor personnel (no specifics).
This concern, on the part of TMIA, was probed'by their counsel during the deposition program but no specifics on which to base an inspection were apparent.
It is believed that the concern may have been misconstruad by TMIA in that there may have been some animosity on the part of Metropolitan Edison employees who considered that they were being deprived of overtime work by contractors performing work on the plant.
This may have led to adverse comments regarding quality of work by contractors.
However, a sampling review of IE Inspection Reports for the year of 1978 was conducted as well as informal inquiries of Region I inspectors who perform inspections of contractor activities.
There was nothing noted which would raise concerns about the quality of work perfomed by contractors.
Additional Concern No. 6 Ferceived Concern: Testing of Unit VI (sic) safety valves by letting super heated steam rush out of them into a standpipe; caused the sleeves on the valves to blow throwing netal into the air and blowing the aluminum off the side of the building.
The discussion of this event in a deposition taken by IMIA counsel (and also in a Philadelphia Inquirer newspcoer article of April 16, 1979 and attributed to the witness, Normal C. Reismiller) actually addresses two separate events relating to the steam generator's safety valves.
One occurred in September 1977 during pre-operational testing of the plant, and the second occurred in April 1978 during power ascens-ion testing.. It should be noted that steam generator safety valves, whether in nuclear or conventional power plants, are tested with live steam as a matter of routine.
The September 1977 event resulted in pieces of metal siding coming away from the turbine building wall. This was due to the safety valves' exhaust piping outside of the building not being of sufficient height to discharge the steam being relieved to the atmosphere without impinging on nearby structures.
Installation of the exhaust piping had not been completed at the time of testing.
The problem was corrected by completing the installation.
The April 1978 event occurred due to an inadvertent reactor trip from 30% power which caused the steam generator safety valves to lift (as required). However,
.due to a design error in the safety valves' exhaust piping attached to the discharge port of the valves, several thermal expansion bellows liners (sleeves) broke free from their weldments and were ejected through the exhaust piping to the atomsphere.
Other problems associated with the safety valves themselves resulted in the licensee replacing the steam generator safety valves with those of another manufacturer.
This required extensive piping modifications and caused the unit to be shutdown for a period of about 41/2 months.
After retesting of the new safety valves, the unit was returned to operation in September 1978.
P00R ORlGlML
t;either of these two events posed a radiological hazard to either plant persor.nel or the public. The April 1978 event (and the reactor trip which initiated the event) was reported to the NRC by the licensee in accordance with the requirement of the Technical Specifications (LER 78-34-1T).
During the September 1977 event, NRC inspectors were on site and the event is discussed in IR No. 50-320/77-34. The licensee had no formal requirement to report that event.
Additional Concern No. 9 4 erceived Concern:
Inconsistent instrumentation calibration because of a lack
'of manpower in instrumentation.
This concern, on the part of TMIA, apparently steraned from a docunent entitled
" Review of Health Physics and Monitoring Procedures in Use at TMI at the Time of the Accident" which stated that over half of the health physics monitoring instruments were not functional at the time of the accident.
_(Note _: The title of the doc 9nent appeared in the transcript of the deposition but was not other ise identHied. The docunent could not be located by this reviewer.)
This fact was also docurented in several reports of ir.vestigations of the accident as well as a report of an NRC inspection con &cted prior to the accident (ref.1.1 No. 50-320/79-04).
These reports addressed portable radiation nonitoring instruments rather than fixed in-plant radiation instrumentation or en.ergency response radiation monitoring equipment.
The non-functicnal condition of the portable radiation monitoring instruments apparently was due to their use during the just completed outage at Unit I prior to the Unit 2 accident.
It M probable that as Unit 1 instruments became inoperative or cut-of-calibration through use during the Unit 1 outage, Unit 2 instruments were borrowed to replace thec rather than to stop outage work in progress to effect repairs and/or re-calibration. This is not an unconmon practice at multi-unit sites. After the outage at the affected unit is completed, time is more readily available to repair and re-calibrate portable instruments which are otherwise rarely needed except during heavy work peaks such as outages.
It should be noted that the three Unit 2 emergency radiation monitoring kits required by NRC in accordance with the licensee's Emergency Plan were available for response to the emergency. A fourth kit which the licensee used as a spare was out-of-service for routine checking and re-calibration.
One piece of equipment in one of the three available kits malfunctioned while being used in response to the emergency. This piece of equipment was replaced with equipment from another kit and did not imoede the licensee's emergency response.
P00R 0RIGINAI.
Althcugh the issue of lack of nanponer in the area of instremitation calibration s.as probed by TMIA counsel with several witnesses during the deposition progra.,
responses to questions in this area did n3t establish that this was the case c.or was this fact considered by the TMC as an it' pediment to '.ne licensee's resper.se to the accident.
The concern was not pursued by 1E since it was apparently misdirected and could not be substantiated.
9 P00R OR GINAL
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