ML20033B520
| ML20033B520 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/29/1981 |
| From: | Blumberg N, Caphton D, Caphton O, Ebneter S, Haverkamp D, Koltay P, Napuda G, Petrone C, Thomas Scarbrough, Simmons L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20033B508 | List: |
| References | |
| 50-289-81-22, NUDOCS 8112010489 | |
| Download: ML20033B520 (34) | |
See also: IR 05000289/1981022
Text
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9
U. S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
REGION I
Report No.
50-289/81-22
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Docket ~No.
50-289
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License No. DPR-50
Priority
-
Category
C
Licensee:
Metropolitan Edison Company
P. C. Box 480
Middletown, Pennsylvania 17057
Facility Name:
Three Mile Island Nuclear Station, 'Init 1
- Inspection At:
Middletown, Pennsylvania and Parsippany, New Jersey
Inspection Conducted:
August 17-21, 24-28 and 31 and September 1-2, 1981
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Inspectors:
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G Napuda, Rea tor Inspet or--
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N. J. Bluaib' erg, Reactor Insg6ctor-
date
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G /ba
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P. S. Koltay,Sbictor Inspector
date'
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C. D. Petrone, Reactor Inspector
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D. Rg/Haverkamp, Resident Inspector
date
b.G.Scarbrough, Engineer,NRR-Standards
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date
b.Simmons, Instructor-IETrainingStaff
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date
S. D. Ebneter, Acting Chief, Engineering
'date '
Inspection Branch, RI
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Approved by:
/
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D~. 'L'. Eiphton, Chief, Management Programs
date
- Section, DE&TI-
8112010489 811112
PDR ADOCK 05000289
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Inspection Summary:
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Inspection on August 17-21, 24-28 and 31, and September 1-2, 1981
(Inspection Report No. 50-289/81-22)
Areas Inspected: Special announced inspection by:
four region-based
inspectors, one resident inspector, one NRC supervisor,.and two participants-
representing NRC Standards (QA) and IE Headquarters, of: QA Program
implementation-including annual raview of QA Program changes; QA/QC
administration; committee' activities; QA surveillance (monitoring); QC
inspection; maintenance; document control; records; and, licensee action on
previously identified inspection findings. The inspection involved 488 onsite
ins.oector-hours and 70-inspector-hours at the corporate offices.
Results: No items of noncompliance were identified in eleven areas and two
items of noncompliance were identified in one area (Violation-failure to
control documents and engineering drawings, Paragraph 3.c; Violation-failure
to properly review and approve a plant document / drawing control procedure,
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Paragraph.3.c).
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DETAILS
1.
Persons Contacted
a.
General Public Utilities Nuclear (GPUN)-
B. E. Ballard, Manager, Quality Assurance (QA) Modification /
Operations, TMI-1
R. Chisolm, Manager of Electrical Power and Instrumentation
- J. J. Colitz, Plant Engineering Director
G. L. Derk, Supervisor, Quality Control (QC) Inspection Support
- E. C. Donovan, GPU Nuclear Manager, Design and Drafting
- T. Faulkner, TMI-1, Maintenance and Construction Planning Manager
- R. F. Fenti, TMI Site Audit Manager
I. R. Finfrock, Jr., Chairman, General Office Review Boards
J. C. Fornicola, Operations Quality Assurance Manager
- J. F. Fritzen, Technical Functions, TMI-l Site Supervisor
F. Glickman, GPU Nuclear, Vice President / Director Administratien
- J. K. Gulati, TMI-1 Engineering Projects Supervisor
J. Harris, Supervisor, Maintenance Training
- J. G. Herbein, Vice President, Nuclear Assurance
- D. Hosking, Supervisor, Quality Assurance Mainten nce/ Modification
Support Monitoring
N. C. Kazaras, Director, Quality Assurance
P. B. Magitz, GPU Nuclear Quality Assurance Supervisor
C. A. Mascari, Manager, Engineering Services
- P. Omaggio, GPU Nuclear Maintenance and Construction Engineer
- J. J. Potter, TMI Site Quality Assurance Systems
R. N. Prabhaker, TMI Quality Assurance Engineering Manager
W. Sayers, Administrative Services Supervisor
W. F. Schmauss, Chairman, General Review Committee, TMI 1 & 2
D. M. Shovlin, Manager Plant Maintenance, TMI-l
- D. G. Slear, TMI-1, Project Engineering Manager
M. G. Snyder, Manager Preventive Maintenance, TMI-1
- M. J. Stromberg, Manager, Quality Assurance Methods / Programs
Audits
J. Thorpe, GPU Nuclear, Director, Licensing and Regulatory Affairs
R. Toole, Operations and Maintenance, Director, TMI Unit 1
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R. Wayne, Manager, Design and Procurement Quality Assurance
F. Weinzimmer, Director, Engineering Projects
R. Whitesel, Vice Chairman-General Office Review Boards
R. F. Wilson, Vice President, Technical Functions
- J. E. Wright, TMI Site Quality Control Manager
b.
R. Conte, Senior Resident Inspector, TMI-2
A. N. Fasano, Chief, TMI Resident Section
- G. Meyer, Reactor Inspector
- F. Young, TMI-1, Resident Inspector
- denotes those present at the exit interview conducted on.
September 2, 1981.
The inspectors also interviewed other licensec and contractor
employees including staff engineers, administrative support
personnel and technicians.
2.
Licensee Action on Previous Inspection Findings
(Closed) Deficiency (289/77-35-01):
Records storage facility did not
meet ANSI 45.2.9 requirements.
The inspector reviewed the completed records storage facility, located.in
the Unit 2 administrative building, and found the construction of the
facility to be in compliance with the Operations Quality Assurance Plan,
Revision 9, and ANSI 45.2.9.
This item is closed.
(Closed) Inspector Follow Item (289/79-IR-25):
Inadequate QA inspection-
of operations surveillance testing.
The inspector reviewed QA monitoring (surveillance) schedules and
applicable reports of surveillance activity (see Detail 8) and verified-
that the subject activity was addressed in both and that the amount of QA
overview appeared appropriate for the present operating mode of the
plant.
(Closed) Infraction (289/79-10-01):
Inadequate corrective action by QA
in relation to ISI activities.
The licensee outlined corrective actions in letters to the NRC dated
October 4,1979 and February 20, 1980. The following corrective actions
have been taken.
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The ISI function has been assigned to the Material Technology
Section-Quality Assurance Department (QAD) which is staffed with
-three full-time NDE Level IIIs.
ISI procedures were developed and
approved by Level III's.
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QA surveillance (monitoring) of ISI activities is the responsibility
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of the Maintenance Modification Support Monitoring group.
Surveillance of ISI were scheduled and performed consistent with the
ISI-NDE activities.
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Corrective actions related to the findings of Audit V-79-01 were
documented. These were reviewed by the inspector and found to be
acceptable.
This item is closed.
(Closed) Unresolved Item (289/80-05-02):
The Operational Quality
Assurance Plan (0QAP) distribution list requires review and revision to
assure that all designated copy holders possess up-to-date copies. The
inspector determined that the OQAP distribution list has been revised and
the sampling of 0QAPs reviewed were up to date.
This item is closed.
(Closed) Unresolved Items (289/80-05-04 and 81-04-01): Classification
conflict concerning safety systems between licensee's documents and NRC
status report of 8/9/80 and short term lessons learned.
The referenced items address the licensee's failure to classify equipment
purchased and installed as part of restart modification RM-10, PORV
Position Indication, as important to safety and required to meet environ-
mental and seismic requirements of IEEE 323.
NUREG-0680, Supplement 3 (Section 2.1.3.a) recognizes that modification
RM-10 is not entirely safety grade and evaluated the licensee's proposed
methods for determining valve position and safety classification as
acceptable.
This item is closed.
(Closed) Unresolved Item (80-16-01):
Establish computer based
document / drawing control system for control and distribution of drawings;
distribution of as-built documents (recent modifications); and, the
control / distribution of documents. This system was expected to be
operational by January, 1981. The inspector observed that the computer
is operational but, through discussions with a licensee representative,
determined that not all anticipated data bases have been programmed into
the computer. The licensee representative also informed the inspector
that it was not intended to use the computer specifically for document
control or distribution.
It was intended that the computer be used only
for information retrieval, records retention, and procedure and drawing
status information. Document distribution control and records would be
maintained manually.
Based on this and observations made during this
inspection, this item is considered closed.
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(Closed) Noncompliance (289/80-21-04): ' Failure of Gener 1 Office Review
Board (G0RB) to review certain violations of internal procedures and the
Technical Specifications. During the period April 1,.1979, to June 30,.
1980,.they did not review violations of Technical Specifications or-
Operating License DPR-50 identified in Quality Assurance audit reports.
The GORB QA Audit Subcommittee did review audit reports; however, their
report on audits for the above period was only a statistical summary of
open audit findings.
It did not address the subject of any individual
audit report or audit findings, which described violations of Technical
Specifications.
In response to this item, the licensee stated in a
lettee to NRC Region I, dated November 26, 1980, that:
(1) The Mct-Ed
QA/QC Department has been reorganized and integrated into the GPU Nuclear
QA organization; (2) The QA organization is currently issuing a status of
open audit findings on a monthly basis; and, (3) The GORB QA Subcommittee
is reviewing these status reports and the associated audits and is
issuing a summary report, including violations of Technical
Specifications, to the GORB periodically. The inspector discussed the
corrective actions with the GORB Chairman and reviewed the OA
Subcommittee May-June 1981 audit of QA audit program / audit findings. The.
GORB Chairman receives all audit reports and concerns for GORB review.
The inspector determined that the corrective measures appeared adequate
to prevent recurrence and had no further questions concerning this item.
This item is closed.
(Closed) Inspector Followup Item (289/80-21-10): GORB review
responsibilities not completely included in the charter and
administrative procedure. This weakness concerned the potential for
overlooking the specific GORB responsibility to review the adequacy of
PORC and licensee staff determinations regarding unreviewed safety
questions. A change to Section 6 of the Technical Specifications was
included in Technical Specification Change Request No. 100 that will
delete specific review requirements for the GORB. That change request is
currently under review by the NRC staff. During the interim period, the
GORB charter and administrative procedure have been revised to assure
compatibility with existing Technical Specifications.
PORC and
Generation Review Committee (GRC) minutes are reviewed by the GORB
Chairman, and oral presentations are made at GORB meetings by the PORC
and GRC Chairmen. The inspector determined that the above measures are
adequate to assure proper GORB overview of determinations regarding
unreviewed safety questions. This item is closed.
(Closed)
Inspector Followup Item (289/80-21-11): No written means to
ensure review of required material. This weakness concerned the finding
that GRC relied extensively on the distribution lists of other
organizations to provide their review material and on the PORC meeting
minutes to provide them with information on proposed changes to
procedures or-to the facility, problem areas and deficient conditions.
In. reply to this item, the licensee stated in a letter to NRC Region I,
dated January 15, 1981, that a procedure would be prepared incorporating
the specific independent review responsibilities contained in the TMI-1
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Technical Specifications, and the GRC review record would assure that
appropriate documents for review are received and accounted for by GRC.
The inspector discussed these corrective actions with the GRC Chairman
and reviewed Technical Functions Division Procedure EMP-009, " Nuclear
Power Station' Generation Review Committee," Revision 2, dated June 1,
1981. The inspector determined that there are adequate written means to
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ensure GRC review of required material. This item is closed.
(Closed) Inspector Followup Item (289/80-21-19):
Failure to follow
Procedure EMP-009 concerning GRC requirements. This item concerned the
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apparent inadequacy of GRC reviews related to (1) safety evaluations for
changes to procedures, equipment and systems; (2) violations of codes,
regulations, orders, Technical Specifications, etc.; (3) proposed changes
to the Technical Specifications; and, (4) significant operating
abnormalities or deviations from normal.and expected performance of unit
equipment. Additionally, GRC alternates were not appointed in writing
and the GRC Secretary was not designated in writing,- as required by
EMP-009. Although the above weaknesses existed in July 1980, the TMI-1
Technical Specifications contained no specific provisions for the GRC.
The review responsibilities were assigned to the Met-Ed Corporate
Technical Support Staff. That staff was essentially disbanded following
the TMI-2 accident. Technical Specification Amendment No. 58 reassigned
the independent review functions to the GPU Nuclear Group Corporate
Staff, which includes the GRC. The inspector reviewed EMP-009, Revision
2, dated June 1,1981 ano determined that the procedure adequately
incorporates existing TMI-1 Technical Specification requirements.
Additional details concerning the inspector's review of recent GRC
activities are contained in Paragraph 11 of this report. The inspector
had no further questions concerning this item. This item is closed.
3.
Document Control
a.
References
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Operational QA Plan, the Metropolitan Edison Company GPU
Nuclear Corporation, Three Mile Island, Revision 9, May 28,
1981, Section 3.0, Control of Documents and Records
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Procedure 1001, TMI Document Control, Revision 31, September
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21, 1979
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Procedure 1001, Enclosure 11, Drawings and Aperture Card
Control, Revision 9, July 5, 1979
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Procedure 1033, Operating Memo's and Standing Orders, Revision
2, November 11, 1980
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QA Department Procedure 7-5-01, Control of QA Plans,
Procedures, Forms, and Checklists, Revision 4, December,1980
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QA Section Procedure 7-5-DP-001, Document Control Within TMI
Design and Procurement Section, Revision 0, May 1980
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QA Section Procedure 7-6-M0-002, Quality Assurance
Modifications / Operations Section Procedure, Section Document
. Control, P.evision 0, April 30,.1980
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Information Management Department (IMD) Procedure IMD-151,
Drawing Distribution Control - Unit 1, Revision 0, June 5,
1981;
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IMD-181, Dis.tribution of Controlled Copies of Procedures,
Revision-0, January 1, 1981
b.
Area Reviewed
An inspection was conducted of the drawing and procedure control
program and its implementation to determine conformance to the
requirements of 10 CFR 50, Appendix B, " Quality Assurance Criteria
for Nuclear Power Plants..."
Technical Specification 6.8, ANSI
N18.7 - 1976Property "ANSI code" (as page type) with input value "ANSI</br></br>N18.7 - 1976" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., " Administrative Controls and Quality Assurance-for...
Nuclear Power Plants" and the procedures referenced in paragraph 3.a
above.
The inspector verified that administrative controls were established
and implemented to assure the following:
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Up to date drawings and procedures are distributed to specified
locations in a timely manner;
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Obsolete drawings are properly controlled;
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Drawings, procedures, and information excerpted from drawings
and procedures that are in use at work locations are controlled
and up to date;
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Responsibilities are c< signed for proper control of drawings
and procedures; and,
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Procedures are periodically reviewed.
c.
Findings
(1) The inspector observed on August 19, 1981, that an
environmental barrier was being constructed in the Fuel
Handling Building to isolate Unit 1 from Unit 2.
Erection and
assembly drawings located at the job site for this work were -
not marked as controlled copies.
Further investigation
determined that a contractor was performing this work and had
established its own document control procedure, TMI-4, which--
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had been approved by the licensee's Quality Assurance
Department. This procedure requires that the contractor
control its own drawing distribution to assure that drawings
used in the' field are the latest revision.
The inspector compared the drawings at the job site against.the
latest drawing list for this job and determined that 3 of 6
erection drawings and 3 of 17 assembly drawings were not the
latest revision.
The licensee was then informed of the
apparent discrepancy and conducted its own investigation of the
problem. Additionally, the inspector determined that the
latest revision of 4 of the 6 drawings in question had been
forwarded to the contractor field superintendent but had not
been distributed to the job site.
The licensee's investigation determined that for two of the
erection drawings, the contractor issued drawing list was in
error and the other revisions were the result of field changes.
An inspection by the licensee determined that work affected by
these changes had been performed correctly. Subsequently the
correct drawings were placed at the job site and contractor
personnel were re-instructed on the need for proper drawing
control and adherence to procedures.
This is one example of an item of noncompliance discussed in
subparagraph (10) below.
(2) To assure that the latest drawing information is used, plant
procedures require that controlled drawings and drawing
aperture cards be annotated to reflect the latest applicable
design change which affects that drawing.
Since final
revisions to drawings may not be issued until some time after
system modifications have been accomplished, personnel must
refer to the latest issued revision of the drawing plus
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applicable design change information to determine current
system "as-built" status. However, design change information
is maintained at the Site Drawing Control Center in Unit 2
Administration Building and is not readily available to Control
Room operators and other plant personnel who use the drawings
for tagouts.
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This problem was recognized by the plant and a system has been
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in effect since November 1980 to distribute and attach interim
"As-Installed" drawings to controlled copies of drawings which
reflect drawing changes resulting from design changes.
However,'this system was not made retroactive to previous
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design changes that affected numerous' controlled drawings in
the Control Room and all other Controlled Drawing locations.-
Therefore, there are numerous controlled drawings which are
affected by design changes which do not have updated interim
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drawings attached.
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On August 19, 1981 the inspector observed a Control Room
operator verify a proposed system tagout Drawing C-302-203,
" Screen Wash and Fluid System - River Water Pumps Lubricating
System".
This drawing was annotated as having Design Change
Notices (DCN's) 0057, 0110, and 0112 applicable to it.
Since
these DCN's were available only at the Unit 2 Administrative
Building, he could not determine from the information
immediately available to him whether or not these DCN's
affected the valve lineup he was verifying. The inspector
discussed the verification with the operator who stated he
could only use what was provided to him.
The inspector later
verified that two of the three design changes did affect the
drawing but did not affect the valve lineup being verified.
Licensee representatives later produced for the inspector
Drawing Standard (DS) - 001. Appendix A to DS-001 lists all
drawing series that the licensee cor.siders to be " baseline
drawings" (important to plant operation or safety). The
licensee representatives stated that controlled copies of all
baseline drawings maintained in the control room would be
revised or interim drawings would be attached to the baseline
drawings to reflect current plant systems status prior to Unit
1 criticality.
Failure to maintain up-to-date controlled draw;ngs at the work
location is considered another example of the item of
noncompliance.
(3) While in the Control Building one level below the Control Room,
on August 25, 1981, the inspector observed numerous drawings of
the Integrated Control Systems (ICS) and Non-Nuclear
Instruments (NNI) marked "For Information Only" in the
immediate vicinity of control panels for these instruments.
Many of these drawings were torn or illegible. The licensee
representatives stated that these drawings were not controlled
but were used for performing maintenance.
They had been
updated by I&C technicians on an "as you go" basis and ware
considered by I&C personnel to be the most up-to-date drawings
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available to them.
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This problem was recognized by the licensee about one year ago
and some drawings were updated and under review for accuracy
but these represented only a small percentage of the drawings
at this location. A licensee representative stated that all
the ICS and NNI drawings would be controlled and updated by
initial criticality.
Use of uncontrolled drawings to perform plant maintenance is
considered to be another example of the item of noncompliance.
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(4) On August 25, 1981, the inspector observed four system drawings
posted on a wall by the radwaste panel in'the Auxiliary-
Building. These drawings were marked as controlled drawings
but the inspector later determined that two of the drawings,
were one revision out of date. Also located at the radwaste
panel was a set of controlled drawings which was current.
Copies of the four drawings posted on the wall were among this
set.
In addition, there was a notebook.of uncontrolled and
out-of-date drawings located on a stand adjacent to the
radwaste panel and the controlled drawings. During a
discussion with the inspector, a radwaste panel operator stated
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~that the controlled and uncontrolled drawings observed at the
work location were used interchangeably.
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A licensee representative stated that the uncontrolled drawings
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on the wall would be removed. However, he stated that the
uncontrolled drawing notebooks presented another problem, as
there was no intent to control them or maintain them
up-to-date. They were to be used by individuals for self
training and information only.
The inspector informed the licensee that the drawing notebooks
were acceptable for information purposes but that they should
not be maintained at work locations or used for making
decisions concerning system operation, tagout, maintenance, or
modification.
Use of uncontrolled drawings to perform work is considered
another example of the item of noncompliance.
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(5) On August 25, 1981, the inspector observed sketches of sampling
valve lineups posted to Radiation Monitors RM-A4, RM-A8, and
RM-A9 located in the Auxiliary Building. These sketches were
excerpted from procedure 1105-8, " Radiation Monitoring System",
Revision 0, November, 1973.
These sketches were uncontrolled
and the ' current procedure is Revision 8, April 1981.
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When informed of the problem, a licensee representative posted
Revision 8 at RM-A4; however, he failed to post the current
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revision to RM-A8 and RM-A9.
This failed to correct the
problem as the sketches still remained uncontrolled.
Failure to control copies of portions of approved procedures
used at work location constitutes another example of the item
of noncompliance.
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(6) A laminated chart was posted to the side of Control Panel PLF
on August 19, 1981. This chart contained Emergency Plan plant
set points and action statements which were summary information
contained in Emergency Plant Procedures 1004.3 and 1004.4.
This chart, previously used as a training aid, was
uncontrolled.
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A licensee representative stated that this chart was for
information only and would not be used in case of an emergency.
The inspector informed the licensee that locating this chart in
the control room created the potential for its being used in an
emergency situation.
Further, since it was uncontrolled it
could become out of date if the procedures on which it is based
were changed. The licensee removed the chart pending
evaluation of whether or not to' control it.
The posting of uncontrolled procedural information at a work
location is considered another example of the item of
noncompliance.
(7) On August 20, 1981, four engraved placards were observed
permanently mounted on the four respective breaker panels for
the reactor makeup pumps. These placards repeat the caution
from Technical Specification 3.1.12.3 which states "[if] Tavg.
is 5 275'F, High Pressure Injection Pump breakers shall not be
racked in unless a. MU-Vlb A/B/C/D and Mu-V217 are closed, and
b. pressurizer level is 5 220 inches." Additionally, an
engraved placard is permanently mounted to Control Room Panel
PLF which- summarizes the thermal discharge limits given in
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Technical Specifications Appendix B.
In each instance, the information posted on the placards was
correct but the placards were uncontrolled.
Should the above
Technical Specifications requirements be changed there is no
assurance that the placards would also be revised.
Posting of uncontrolled information.from the Technical
Specification at work locations is another example of the item
of noncompliance.
(8) During inspection between August 19 and 29, 1981, of controlled
drawings located in the Control Room and the Technical Support
Center (located in the Control Building) and aperture cards
located in the Document Control Center and the Unit 1
Engineering Office, the inspector observed thirteen errors in
the posting and distribution of controlled drawings and
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aperture cards. The following are examples of such errors.
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Drawing C-302-Oll, " Main Steam System", located.in the
Control Room is annotated that DC 099 is applicable to
this drawing.
The inspector determined that DC 099 does
not apply to C-302-011.
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Drawing 2601, " Flow Diagram Reactor Coolant Pump Seal
Recirc and Cooling Water", has Revision.10 posted in the
Control Room although Revision 11 is the latest revision.
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Drawing C-302-640, " Decay Heat Removal", did not have
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interim drawing MCG-32 posted to the copy located in the
Control Room although MCG-32 is applicable.
Interim
drawing MCG-32 was incorrectly posted to Drawing
C-302-645, " Decay Heat Closed Cooling".
Aperture card for Drawing C-302-231, " Fire Service Water",
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located in the Drawtqg Control Center was not annotated to
indicate that interin drawing MCG-57 was applicable.
Aperture card for Drawing C-302610, located in the Unit 1
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Engineering Office, was not annotated to indicate that DC0
116 was applicable.
The above and other errors were made known to licensee
representatives during the course of the inspection. The
inspector informed the licensee that the high number of errors
indicated a lack of control in the implementation of. drawing
distribution.
A licensee representative subsequently informed the inspector
that an inventory of Control Room drawings had been completed
and all errors were corrected. He further stated that all
errors noted in other areas during the inspection would be
corrected and that inventory of all controlled drawings and
aperture cards would be accomplished.
Failure to properly distribute, post and annotate controlled
drawings is another example of the item of noncompliance.
(9) During July, -1981, new Technical Functions Procedures (a
manual) were issued to replace the existing Engineering
Procedures. A transition period was required since there was a
period of time when both sets of ,orocedures would be in effect.
The Technical Functions Procedures were issued without clear
instructions to al' user personnel as to how this transition
would take place. Some of the Technical Functions Procedures
did d.scuss the transition but these procedures were issued to
a limited distribution list.
The inspector observed between August 19 and 28, 1981, that
some offices had only the Technical Functions Procedures, some
offices had only the Engineering Procedures, and some offices
had both sets of procedures. Discussions with certain
management, quality assurance, and Technical Functions
personnel onsite indicated they were aware of the transition
and how to implement it.
However, based on discussions with
many user personnel the inspector determined that they were
unaware of the transition and that the old or the new
procedures may apply depending on the circumstances. Users
with one set of procedures were often unaware of the existence
of the other set.
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A licensee representative stated that the mixed distribution-
was intentional depending on the needs of individual offices.
However, the licensee representative concurred that. sufficient
explanation of .the transition may not have been made to all
offices and persons on distribution causing some confusion at
the user level. He further stated that actions would be taken
to correct this situation.
Failure to adequately control the use of new and old procedures
during a transition period constitutes another example of the
item of noncompliance.
(10) The use of uncontrolled or out-of-date documents at work
'ocations; errors in-distribution of documents; and failure to
properly control transition on the issuance of new Technical
Functions procedures as identified in the examples of
noncompliance in subparagraphs (1)-(9) above are contrary' to 10 CFR 50, Appendix B, Criterion VI and the TMI Operational
Quality Assurance Plan, paragraphs 3.2.1, 3.2.2.5, and 3.2.2.6
and collectively constitute an item of noncompliance
(289/81-22-01).
Further, the scope of this item of noncompliance indicates an
increased need for management attention in the area of document
control.
(11) Procedure 1001, Appendix ll, " Drawing Control", is the current
-
approved procedure for the distribution and control of Unit I
drawings and aperture cards. The inspector determined that
this procedure was out of date since much of what was being
done in drawing control was not reflected in the procedure. A
licensee representative informed the inspector that this had
bee.. recognized by the licensee and that a new procedu e,
1001C, had been written to reflect the changes in drawing
i
control.
The licensee representative stated that 1001C had
been written in February, 1981 but PORC review and Unit Super-
intendent approval had not yet been obtained for various
'
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reasons.
As result of a QA audit finding (S-TMI-80-11-17), the
Information Management Department issued 1001C as Information
Management Department Procedure (IMO) - 151, " Drawing
i
Distribution Control - Unit
I", on June 5,1981. However,
IMD's require only approval of the IMD Manager'and do not
require PORC review and Unit Superintendent-Approval.
Because of further changes in drawing control, a new draft of
procedure 1001C was prepared and submitted for PORC review per
an internal memorandum dated August 19, 1981. There are now
three drawing control procedures:
1001, Appendix II, which had
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been approved by th2 Unit Superintendent but which was now
out-of-date; a draft of new procedure 1001C, issued as IMD-151,
which was also partially out-of-date; and a more recent draft
of 1001C not yet issued as an IMO or as a unit administrative
procedure. On August 20, 1981, the inspector determined that
the latest draft was actually the procedure being used by
drawing control personnel.
A. licensee representative informed
the inspector that procedure 1001C would be PORC reviewed and
approved by the Unit Superintendent by September 4, 1981.
Implementation of a procedure prior to review by the PORC and
approval by the Unit Superintendent is contrary to Technical Specifications 6.8.1 and 6.8.3 and constitutes an item of
noncompliance (289/81-22-02).
(12) Paragraph 3.c(ll) noted an item of noncompliance in which a
second draft of Procedure 1001C was being implemented although
the procedure had not yet been formally approved. The
inspector reviewed the later draft of this procedure and
determined the .following portions had not yet been implemented.
--
Paragraph 4.1 requires the use of a special form for
requesting controlled copies of drawings. This form is
not being used. A licensee representative. stated this
form would be put into effect upon final approval of
1001C.
--
Paragraph 4.2 requires a drawing distribution list which
is to be periodically approved by the Manager - TMI
Information Management Department. A drawing distribution
list is in preparation but has not yet been finalized. A
licensee representative stated that the drawing
distribution list would be issued by September 27, 1981
and that the frequency of Manager approval-would be
specified in an Information Department procedure.
--
Paragraphs 4.6 and 4.7 require periodic inventories of
drawings and aperture cards but does not specify the
frequency. A licensee representative stated that this
frequency would be specified in an Information Department
,
.
I
procedure.
--
Paragraph 4.8 requires a drawing / aperture card log / record
!
of distribution.
The log currently in use reflects only
l
DCN's and MCG interim drawings. A licensee representative
stated that the log would be revised by September.27, 1981
to reflect the distribution of all drawings received.
l
l
This item is unresolved pending licensee action and subse-
quent NRC:RI review (289-81-22-03).
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(13) Design Change Notices (DCN's) are issued listing drawings
which may be affected by the DCN. The site Drawing
Control Center (DCC) then annotates each controlled copy
of applicable drawings with the DCN number so that
personnel using that drawing can reference the DCN package
for drawing changes.
As the DCN package is revised, or when it is closed, the
DCN drawing applicability list is reissued.
In some.
instances, it may delete some of the previously identified
drawings since they were not affected by the DCN. Drawing
Control _ Center personnel must compare the previous list (s)
with the revised or close out list to determine which
drawings have been deleted; then they must remove the
applicable DCN numbers from controlled copies of
previously annotated drawings. DCC personnel had no-
instructions as how to handle these deletions or ascertain
if the drawing deletions were deliberate or inadvertent.
A licensee representative acknowledged the inspector's
concerns in this area and stated that instructions would
be provided to DCC personnel which better describe when
DCN's no longer apply to previously identified drawings.
This item is unresolved pending licensee action and subse-
quent NRC:RI review (289/81-22-04).
(1?) The Architect Engineer (A/E) has established a new
Integrated Drawing List (IDL) for the licensee. This IDL
lists all as-built drawings (except vendor drawings which
are in'a separate listing) and their latest revision;-
associated design changes for each drawing; interim
-
drawings for projected or in progress modifications and
their latest revision; and, design changes to interim
drawings.
The inspector reviewed the IDL and determined that it was
not up-to-date, contained inaccurracies, and had
limitations as to its usefulness to licensee personnel.
The licensee acknowledged the inspector's comments'but
stated that this was the first issue of the IDL and
improvements would be made to future issues. A licensee
representative stated that a users instruction would'be
written and provided to offices which have the IDL on its
usage and limitations. Additionally, a licensee
i.
representative stated that they would evaluate whether or
not MCG interim drawings (see paragraph 3.1.(15)) should
"
be' listed on the IDL. Currently, such drawings are not
listed on the IDL.
This item is unresolved pending licensee action and subse-
quent NRC:RI review (289/81-22-05).
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(15).After a modification is completed the latest drawing
changes are provided by the Modification Control Group and
are attached to each controlled copy of the applicable
drawing. This " interim drawing" may show only the changed
area.
It must be used in conjunction with the existing
"as built" controlled drawing until a drawing ~ revision is
actually issued.
The interim drawing is given a
Modification Control Group (MCG) Number which is
referenced on each controlled copy of the existing
"as-built" drawing. This system has been in effect since
November, 1980.
The controlled copies of system drawings which are used
regularly in the Control Room have been. laminated-to
withstand constant use and to allow temporary markup. MCG
interim drawings are photo copy reproductions which cannot
withstand constant use. The inspector noted five
instances of MCG interim drawings that were unusable since
they were torn or were illegible because of poor
reproduction or extensive use. The inspector informed the
licensee that these conditions were unsatisfactory and
that the MCG system could not be considered functional if
the end product was not usable.
The licensee acknowledged the inspector's comments and
stated that action would be taken to repair or replace MCG
interim drawings and.to assure that future MCG interim
drawings are maintained in a usuable condition. This
action is to be completed prior to criticality of Unit 1.
This item is unresolved pending licensee action and
subsequent NRC:RI review (289/81-22-06).
4.
Maintenance
a.
Quality Assurance / Maintenance Interface
,
"
Section 6 of the Operational Quality Assurance Plan (0QAP) defines
!
the relationship and interface between QA and Maintenance.
Section
!-
6.2.1.10, Control of Construction, Maintenance
(Preventive / Corrective) and Modifications, specifically addresses
maintenance activities.
The QA program is essentially based on a
tri-level program of inspection (level I), surveillance (level II),
and audits (level III) as defined in the QA program. The inspector
verified that the QA program as applied to' maintenance had been
implemented. To determine that the.QA program had been implemented,
.
the inspector reviewed procedures, objective evidence of
implementation such as records, and interviewed QA and Maintenance
managers.
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b.
Plant Maintenance
~
The new GPUN organization has placed significant emphasis on the
.
maintenance function and the TMI-I station orgrnization includes
organizational elements dedicated to both corrective maintenance and
preventive maintenance. The maintenance staff presently'is at-
i
approximately 145 persons with an authorized staff level of approxi-
'
mately 155. An increase in authorized staff level has been approved
for the next fiscal year.
'
The maintenance programs are primarily defined by:
--
AP 1027
Preventive Maintenance-
--
AP 1026
Corrective Maintenance and Machinery History
--
AP 1054
Control of Environmentally Qualified Safety Related
Electrical Equipment
.
There are interfacing procedures which impact the maintenance
-
program such as:
-
--
AP 1010
Technical Specification Surveillance
'
AP 1022
Control of M&TE
---
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AP 1023
Test Equipment Recall
The QA/ Maintenance interface is defined in AP 1026, and requires
that QC review maintenance procedures anc identify hold points ~ which
must be complied with.
In interviews with maintenance and QA/QC'
management-both stated that observance of hold points has been
complied with and this was substantiated by a review of QA/QC
records.
4 .
liscrepancy.
,
c.
Level I (Inspection)
The level I activities are essentially inspection or quality control
in nature and involve a direct inspection of activities.
The QA
organizational element responsible for accomplishing this function
!
is the Quality Control Section under the QA Modification / Operations
Department.
'
The inspector verified that this group is fully staffed. The group
is composed of permanent GPUN staff personnel and supplemented by-
contractor personnel. The latter aspect provides flexibility of
_ _ _ _ _ _ _ _ _ _ _ -
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19
operations in a- fluctuating workload environment. The 0QAP provides
for a graded approach to QA/QC and, therefore, allows for-sampling
inspections.
The' inspector verified that level I inspections were being conducted
. on preventive maintenance activities by review of inspection
schedules and records. The records provided objective evidence that
QC reviews maintenance requests and identifies hold points as
required by AP 1026 and AP 1027.
Records of inspection of
preventive maintenance activities were reviewed and it was verified
that schedules of followup or re-scheduling (if deferred) were
consistent with maintenance activities.
Training / certification
records for the licensee and contractor were complete and provided
objective evidence of inspector qualifications.
d.
Level II (Surveillance / Monitoring)
The Maintenance Modifications Support Monitoring (MMSM) sub-section
has the responsiblity for monitoring maintenance activities. The
group is presently staffed at the authorized level with 5 fully
certified monitors. The group has requested additional staff for
the next budget cycle.
Scheduling and planning requirements for the MMSM organization are
defined in procedure 7-14-MO-001. The inspector verified that
schedules are being submitted monthly and are being followed. QA
Schedules are based on maintenance activities which are reactive in
nature and this causes frequent cancellations or deferrals of
scheduled monitor functions. Cancelled monitor activities are
justified and approved by management.
Deferred monitor activities
are scheduled for accomplishment in succeeding months.
The inspector reviewed monitor documentation QAMRs HRH-1051-81 and
HRH-1060-81. The former QAMR identified several cable tray
installation practices which deviated from the manufacturer's
instructions. These were identified, recorded in the QAMR log as
requiring followup, and a resolution obtained from engineering by
MMMS. The system provides for followup until adequate resolution is
obtained. The inspector verified that an adequate resolution had
been obtained for QAMRs 1051A and 1051B.
Procedure 7-10-MO-003, Indoctrination and Certification of QA
Mod / Ops Section Monitors, Rev. 1 establishes the requirements for
'
training and certification of QA monitor personnel.
Personnel
training records for tFe QA monitor (s) that performed the monitor
functions documented on QAMRs 1051-81 and 1060-81 were verified.
The training records were in accordance with the above procedures
and provided objective evidence of the monitor's capability to
perform monitoring of maintenance functions.
The requirement for
retraining was being complied with and was being scheduled on a
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three month basis.
It was noted that retraining had included two
technical courses conducted primarily~for maintenance department
personnel. This develops technical expertise of the individual and
provides interaction between QA and maintenance personnel in other
than formal QA functions.
In a July 1981 memorandum, the MMSM subsection documented an
overview of the TMI station preventive maintenance program.
It
identified several problems including the following:
(1) need for an expanded maintenance staff
(2) desirablity of additional administrative controls
The inspector reviewed the MMSM recommendations and discussed the
proposed solutions with the preventive maintenance Manager.
Additional staff has been authorized for the P-M function and
additional administrative controls are being implemented. The
backlog of P-Ms is still relatively high but has stabilized. The
. backlog has been influenced by a re-definition of- safety related
(ES-011 and EP-011) equipment and some problems in determining what
exactly'is important-to-safety (ITS) at the component level are
being experienced (The problems concerning identifying -ITS items at
the component level will be further addressed during inspection
289/81-27). The maintenance organization expressed a favorable
opinion of the QC/QA functions, noted that there is a good rapport-
between the organizations and that QA/QC personnel have demonstrated
a willingness to participate in solving problems.
,
e.
Level III (Audits)
Section 9 of the Operational Quality Assurance Plan delineates the
TMI-1 audit requirements.
Section 9.2.1 requires an audit schedule,
pre-established procedures and written reports of results.
It
,
specifies that uuditors be qualified in accordance with AN51
N45.2.23.
The QA audit organization for TMI-1 is located on-site but, to
l
assure' independence, functionally reports to the Manager, Program
i
Development and. Audits at corporate headquarters. The on-site
l~
organization is fully staffed with five permanent and fully
qualified auditors. A significant factor related to auditor
qualifications is that two auditors were previously licensed control
room operators. The audit staff is qualified per ANSI N45.2.23 and
has received formal QA audit training. The qualification records of
two selected site auditors were verified during the corporate office
records review.
'
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Audit schedules are based on the status and importance to safety of
activities being performed. QA implementing procedure 7-18-M0A-002,
j
" Audit Scheduling", provides the basic scheduling requirements.
(
The inspector: verified that the audit program includes provisions to
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21
audit station maintenance activities annually. The most recent
audit schedule, dated July 22, 1981 scheduled maintenanca audits for
October 1981 and September 1982.
The audit frequency was'
established by an in-depth analysis of Technical Specification
requirements and QA program commitments. .The. scope of audits are
graded such that the applicable 10 CFR 50 Appendix B-criteria
pertinent to maintenance activities are substantially encompassed
over the 24 month QA audit cycle established for the maintenance
program.
In addition to specific maintenance audits, maintenance
activities that interface with other station operations are also
audited during audits of these other functional areas.
The inspector reviewed the past performance of the audit
organization in relation to maintenance activities. Audit'
S-TMI-80-11 which included Unit 1 Maintenance was conducted in
September-October 1980. The audit was conducted by two certified
audit team leaders (ANSI N45.2.23) and two auditors in training.
The audit was performed in accordance with a detailed audit plan.
Twenty (20) findings were documented in the audit report. The
inspector reviewed the documentation and noted that an effective
system for tracking corrective actions was in place and positive
means were established for notifying management of findings and when
corrective action commitments were not met. The audit findings were
significant and reflected the in-depth planning and technical
qualifications of the auditors.
f.
Quality Assurance Effectiveness Reports
The Manager, TMI QA Modifications / Operations organization prepares a
monthly report titled " Assessment of the. Implementation and
Effectiveness of the Site Quality Assurance Program" that is widely
distributed to upper management including the vice presidents of
major organizational functions. The report includes a statistical
analysis of the level I (inspection) and level II (monitoring)
function, but more importantly, it contains a narrative section
which discusses the QA/QC perspective of station activities. These
reports have identified major station problem areas which are
brought to the attention of senior management.
Interviews with QA
managers revealed that the TMI-1 Vice President has been receptive
to QA findings and seeks the advice of QA on problem areas.
>
QA effectiveness is further reviewed by an independent audit
'
conducted by the Joint Utility Audit Group. The inspector reviewed
the most recent audit report dated January 9, 1981 which concluded
that substantial progress had been achieved since the 1979 audit and
that there were no major procedural deficiencies. The audit
identified nine " findings" and thirteen observations which had been
or were being corrected.
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g.
Maintenance Training
IE Inspection Report IR 80-21 noted a weakness in TMI-1 maintenance
training. The inspector reviewed the maintenance training program
and interviewed supervisory personnel to determine what corrective
actions had been implemented. The maintenance training organization
is fully staffed with four full time instructors who have extensive
background in plant maintenance. The staff experience is
supplemented by attendance at contractor courses (e.g., Multi-amp
breaker maintenance) and original equipment manufacturers
maintenance courses (e.g. , Foxboro). All members of the
instructional staff have attended a one week instructor course.
The maintenance training program is structured into four basic areas
which correspond to the maintenance technical functions -
electrical,_ instrumentation and control, mechanical, and utility.
One primary instructor is assigned full time to each instructional
area. The program incorporates training in technical areas and
interfacing areas such as fire brigade and emergency response
procedures. This desirable feature assures a large pool of trained
plant personnel in fire fighting and emergancy response. Another
desirable feature is the incorporation of NRC
bulletins / circulars /information notices, LERs, and INP0 information.
For example, Cycle 5 included NRC Information Notice 81-08 as part
of the instructional program.
The program is primarily an in-house one controlled by the Training
Department.
It makes good use of persons such as the Vice President
of TMI-1 (who frequently presents a lecture on station
organization), the Manager of Radiological Controls and Maintenance
Supervisors. The in-house program is supplemented by specialized
contractor courses such as the Multi-amp course on electrical.
breaker maintenance during Cycle 2 and a short course conducted by
Marshall Institute on The National Electric Code.
Course size is limited to approximately 15 students per area per
cycle.
It was noted during the review of class records that QA
personnel have attended some of the maintenance courses which is a
postive aspect of the program since it fosters interchange between
QA and maintenance personnel as well as strengthening the technical
background of QA personnel.
The training facility is a recently completed structure of approxi-
,
i
mately 20,000 square feet.
Four classrooms (approximately 600
square feet) are dedicated to the maintenance training function.
The classrooms are satisfactorily equipped with training materials
and aids. Hands-on training utilizes actual plant equipment to
increase training effectiveness.
It is recognized by the licensee
that additional training aids are.desirat,le and this has been
budgeted for the next fiscal year.
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23
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All plant personnel also receive General Employee Training (GET) as
part of the indoctrination and badging process. A lecture on the
QA/QC department, its functions and importance, is presented.
In
addition, the employee's responsiblity for following proced9res and
how to. recognize QA/QC procedure hold points are discussed.
5.
Design Changes / Modifications
-
a.
References
--
AP 1021A, Plant Modificatiot.s, Rev. 7, 11/18/79
,
AP 1043, Engineering Change Modifications, Rev. 1, 2/10/81
--
--
AP 1047, Startup and Test Manual, Rev. 0, 3/"i/80
EMP-008, Engineering Change Memorandum, Rev. 8, 2/13/81
--
--
QA Section Procedure No. 70-10-M0-002, QA
Modification / Operations Section - Inspection Program; Sections
5.2, Hold Point and 5.3, QC Witness Point
--
ES-011, Methodology and Content of TMI 1 Quality Clessification
List, Rev. 1, 2/13/81
-- '
EP-011, Quality Classification List, Rev. O, 6/1/81
--
MCG-1, Turnover of a Plant Modification, Maintenance and Con-
struction - Instructions, Rev. O, 2/23/81
b.
Review
'
The inspectors selected and reviewed the design changes listed below
to verify, as applicable, that:
they were accomplished in
accordance with 10 CFR 50.59 and the licensee's QA Program
requirements; code requirements and specifications were included;
acceptance tasts including acceptance values and standards were
included; records of equipment performance were reviewed and
accepted; and, prints / drawings and operating procedures were
revised.
The following modifications and associated documents were reviewed-
and the as-installed configuration of the designated
components / systems was examined.
--
RM-8, Relocation of OTSG Level Instrumentation, SECM-010; SCEM
029-1 and SECM 159
kM-10, " Monitoring of PORV and' Safety Valves", SECM-57, which
--
included; Field Questionaire (FQ) R138; FQ R162; Purchase
Requisitions 86016, 86017, 86023, 86027, 86034, 86046, 86092
and 86093
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RM-12, " Leak Rate Test Manifold Relocation", ECM085 and-
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" Hydrogen Recombiner" ECM 72 (a walkdown of some portions of
the-system was performed)
--
RM-13C, " Modify EFV-30A- and B, TO FAIL OPEN ON L0d AIR
,-
2
PRESSURE", ECM-005, Revs. O, 1, and 2 (a walkdown of the
installed system was also performed)
--
RM-130, " Manual Load of Emergency Feedwater Valves", SECM-077,
Rev. 2, 12/24/80; T.P. 250/1.1 MTX 85.5.4.1; FQ R212, FQ R189,
and FQ R234, Purchase Requisitions 86149 and 86151
4
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RM-17, " Modification of Power Supply to ICS/NNI System"
SECM-123, Rev. O, 1, 2, dated 7/6/81; Field' Questionnaires
(F.Q.) R426 and R698; Design Change Notice (DCN)-DT0211 and
,
'
DT0411
c.
Findings-
,
i
The inspectors' review of the design change / modification
documentation, and a walkdown of installed systems, did not identify
4
any unacceptable conditions.
-
6.
Record Storage
,
a.
References
--
AP 1307, Control of Records, Rev. 4, July 14, 1978
-
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AP-1024, Control of TMI Q.C. Records, Rev. 1, December 16, 1977
--
Operational Quality Assurance Plan, Rev. 9
t
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ANSI /ASME NQA-1-1979,-Supplement 17S-1, Supplementary
Requirements for Quality Assurance Records
.
b.
Review
The inspectors selected representative samples of records to verify
licer.see compliance with regard to storage, control and retrieval of.
records.
c.
Conclusions and Findings
The inspector verified that the design and construction of the
record storage facility meets the requirements of Section 4.4.1 of
ANSI /ASME NQA-1-1979 Supplement 17S-1.
No unacceptable conditions were identified.
.
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7.
QC Inspection
a.
References
--
Operational Quality Assurance Plan, Rev. 9 (Section 6.2.1.1)
--
7-2-01, Indoctrination and Training, Rev. ?
--
7-2-03, Qualification for Inspection and Surveillance Duties
Other than NDE in Accordance with ANSI N45.2.6, Rev. 2
--
7-9-01, Nondestructive Examination Personnel Qualification and
Certification, Rev. 0
--
7-10-MO-002, QA Mod / Ops Section-Inspection Program, Rev. 1
--
7-10-MO-004, Indoctrination & Certification of QA Mod / Ops
Section Inspectors, Rev. 0
--
7-14-MO-001, Inspection / Examination / Monitoring Scheduling and
Planning, Rev. 1
b.
Organization
The Quality Control Section is comprised of a QC Manager; a QC
Modifications / Construction Inspection Supervisor, a Welding
inspecto
a Civil / Structural inspector, and an NDE/ Piping
inspecto , a QC Inspection Support Supervisor, two Electrical
inspectors, two Mechanical inspectors, two I&C inspectors, and a QC
Maintenance Coordinator; a Lead Receipt Inspector and two Receipt
inspectors, a System / Modifications Turnover Coordinator; and,
administrative / clerical personnel.
Each inspector is certified as
qualified in his particular discipline and those performing NDE are
certified in accordance with SNT-TC-1A.
The inspector reviewed a number of individuals' qualifications and
noted all had experience and a few had extensive backgrounds in
their assigned discipline (s).
Interviews with a number of
individuals verified they were knowledgeable of governing procedures
and their discipline.
No unacceptable conditions were identified.
c.
Implementation
The inspector reviewed QC inspection activities in order to
determine that they were accomplished in accordance with established
requirements. The inspector's review included but was not limited
to the following mera important aspects of the overall
implementation of this portion of the QA Program.
.
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26
Each inspector developed a monthly Projected Schedule / Summary, and
maintained and used it as a working document. The QC Manager stated
that experience has indicated that it is very difficult to project
QC activities a month in advance and the schedules were revised
constantly.
Because of this, the plant is revising Procedure
1407-1, Maintenance, which will then require that a weel.ly
maintenance schedule be provided to QC. The plant wili then be
notified of selected hold / witness points by QC. An inspector is
assigned, on a weekly basis, to perform inspections / observations
during three backshifts during the week which must include a weekend
and one midnight to eight shift.
The inspector reviewed various inspection reports generated since
January,1981 to verify the above.
The inspector noted that a full
time inspector had been assigned to second shift (four to midnight)
hanger / restraint activities effective August 31, 1981.
The QC
Manager stated that this coverage would continue until such work is
completed, and plans are to assign an inspector to the second shift
for mechanical type activities beginning September 14, 1981.
The
inspector noted that hanger inspections constituted a large portion
of the workload since July,1981, and that identified deficiencies
appeared to be corrected promptly.
The inspector stated that the level of inspection appeared adequate
for current activities.
The inspector also stated that the common
practice of engineering groups selecting what inspections of modifi-
cation work are performed by QC did not seem to impair the QC
function at this tima.
The licensee acknowledged tha inspector's
comment.
No unacceptable conditions were identified.
8.
QA Surveillance (Monitoring)
a.
References
i
!
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Operational Quality Assurance Plan, Rev. 9, 5/21/81 (Section
l
6.2.1.2)
l
l
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7-2-01, Indoctrination and Training, Rev. 2
--
7-2-03, Qualif' cation for Inspection and Surveillance Duties
Other than NDE in Accordance with ANSI N45.2.6, Rev. 2
l
--
7-1-MO-001, QA Mod / Ops Section Fi>eedure Organization and
!
Responsibility, Rev. 1
--
7-10-M0-001, QA Mod / Ops Section Monitoring Program, Rev. 1
'
7-10-M0-003, Indoctrination and Certification of QA Mod / Ops
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Section Monitors, Rev.1 (PCN No.1)
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f
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7-11-MO-001, QA Mod / Ops Test Verification Personnel for
Startup, Functional and Power Escalation Testing, Rev. 0 (PCN
No. 1)
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Applicable procedures listed in paragraph 10.a
b.
Organization
The Operations Section is composed of a QA Manager, a-Maintenance /
Modification Support Monitoring Supervisor, an Operations / Radiation
-Controls Monitorir Supervisor, nine Monitors, and administrative /
clerical personn. . Mechanical, Electrical /I&C, NDE/ Piping,_ Fire
Protection / Security, and Administration / Training are defined as
t
functional disciplines and each is assigned a Monitor.
Additionally, an. individual is assigned to surveillance of Unit 1
operations activities (a discipline) and another is assigned this
area at Unit 2.
Two other individuals are similarly assigned in the
Radiation Control discipline. Monitors, including both supervisors,
are certified in accordance with licensee program requirements. An
exception is the Administrative / Training Monitor who is still in the
qualification process.
The inspector reviewed Monitor qualifications and noted that all had
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extensive education and or experience in their assigned
discipline (s).
Interviews with a number of individuals verified
they were knowledgeable of governing procedures and their
discipline (s).
No unacceptable conditions were identified.
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c.
Implementation
The inspector reviewed QA surveillance (monitoring) activities in
order to determine that they were accomplished in accordance with
established requirements.
The inspector's review included but was
not limited to the following more important aspects of the overall
'
implementation of this portion of the QA Program.
A listing was developed that identified the Monitor who would
conduct surveillance of activities controlled by given procedures.
Each Monitor is to observe, over a two year period, those activity
areas assigned him. A section representative is present at various
meetings such as Plan-of-the-Day and Radiation Controls. Monitors
develop their individual monthly " Monitoring Schedule" by utilizing
the information from these meetings; reviewing preventive
maintenance, plant surveillance and other schedules; and, reviewing
previous monitoring reports. This schedule is approved by a
supervisor and is used to document work status and completion.
The
schedule is subsequently used as a summary report of QA surveillance
activities that is forwarded to QAD management.
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A manual Monitoring Log is also maintained that shows what QA
Program elements are monitored (e.g. T.S. surveillance, fire
protection, electrical / mechanical maintenance, I&C, and ISI). The
log is reviewed by the supervisors to assure that elements are
addressed consistent with their activity level.
A Monitor is assigned to observe activities during portions of three
backshifts weekly which must include a weekend and midnight to eight
shift. The Unit 2 Operations Monitor is currently assigned to the
second shift (four to midnight) and observes ongoing activities at
both units.
The inspector reviewed various surveillance records generated since
January, 1981 to verify the above. A review of the monthly
schedules January through August, 1981 indicated that T.S.
surveillances are being monitored. Additionally, the Monitoring Log
showed that an average of six plant T.S. Surveillance Procedures per
month were monitored between January and August, 1981.
The
inspector noted that a number of Surveillance Reports identified
some of the deficiencies discussed in Paragraph 3.
Various Monitors were accompanied during their monitoring of ongoing
activities such as plant T.S. surveillances and expended resin
processing. Observations of and discussions with the Monitors and
review of applicable procedures verified that the individuals were
knowledgeable of and well prepared to observe the particular
activity.
The inspector stated that the level of QA Surveillance appeared
adequate for the current operating mode of the plant, but
reallocation of resources may be necessary when back shift
activities increase. The licensee acknowledged the inspector's
comment.
No unacceptable o.rditions were identified.
9.
Audits
a.
References
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Operational Quality Assurance Plan, Rev. 9 (Section 9)
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7-7-01, Surveillance of Vendors and Suppliers, Rev. 4
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7-7-03, Supplier Classification List, Rev. 5
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7-7-04, Evaluation and Selaction of Suppliers (QA), Rev. 4
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7-18-01, Quality Assurance Audits, Rev. 6
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.7-18-01, Attachment A, Generic Audit Checklist, Rev. 0
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7-18-01 Attachment B, Technical Audit Checklist, Rev. 0
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7-18-02, Quality Assurance Auditor Qualifications, Rev. 3
7-18-02, Appendix B, Documentation-of Quality Assurance Auditor
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Indoctrination and Auditor Continuing Education, Rev. I
b.
Onsite QA Audit Section
The inspector reviewed selected onsite auditing activities in order
to determine if they were accomplished in accordance with
established requirements.
The licensee has developed an Audit Matrix TMI Nuclear Station that
is a refinement of the previous Audit Schedule Matrix. The audit
section had identified 32 discrete elements within the Quality
Assurance Program and 27 functional areas onsite in which some or
all of these quality elements are performed. This information,
along with the required audit frequency, is depicted in chart form
on the audit matrix which is then used as a management tool to
assure that the overall scope of the onsite quality program is
addressed by audits and is performed within the required time frame.
The licensee has also developed Audit Scope Documents.
Each Audit
Scope Document addresses a given functional area and identifies the
standar/., procedures, manuals, committments, etc. that apply to the
cuality program activities within that area. These documents are
used as guidance by the auditors to develop specific checklists.
The inspector verified the qualifications of two lead auditors
certified in accordance with ANSI N45.2.23-1978, Qualification of
Quality Assurance Program Audit Personnel for Nuclear Power Plants.
The inspector also verified that all onsite auditors were certified
as lead auditors to the standard. The onsite audit staff and an
in-depth review of an audit is discussed further in Paragraph 4.e.
No unacceptable conditions were identified.
c.
Corrorate Audit Section
The inspector reviewed selected corporate audit activities in order
to determine that they were accomplished in accordance with
established requirements.
The licensee has developed an Audit Matrix Corporate Office similar
in content to the onsite matrix.
This matrix identifies 19 quality
elements in the corporate offices functional area and 35 specific
groups involved in these activities such as engineering, licensing,
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architect-engineer, nuclear system supplier, and vendor services.
The QA Audit Schedule (8/21/81) reflects the new audit matrix and is
maintained manually. The licensee stated that a computer based
scheduling system is in trial use and a computer program for audit
findings and corrective action trending is being developed.
The inspector reviewed the following audits in-depth to ascertain
that the checksheets adequately addressed the audited area;
technical expertise-of the auditor was evident; the audit was
carefully planned; and, other established audit requirements were
met.
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Q-TMI-80-1, TMI Plant Engineer.ng' Department
Q-TMI-80-06, Technical Function estart Report
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The effectiveness of the quality program and audits are discussed
further in Paragraph 4.f.
No unacceptable ccnditions were identified.
d.
Procurement 0A'
The inspector reviewed selected supplier / vendor control activities
in order to determine that they were accomplished in accordance with
established requirements.
Evaluation (record reviews), surveys and surveillance of
suppliers / vendors are conducted by this section located at the
corporate offices.
Each vendor is evaluated annually and resurveyed
every five years. A resurvey is conducted sooner should an annual
evaluation indicate the need. The licansee has recently assimilated
the Oyster Creek QA Department and its functions including an
approved vendor list. These previously approved vendors are being
re-evaluated, and re-surveyed where necessary. The licensee
representative stated that when this effort is completed the routine
scheJule will be approximately 80 surveys annually.
The Contractor Classification List is in a computer program. The
print out is by vendor, product / service, evaluators, last
evaluation, contractor classification, type of evaluation,
performance classification, and includes remarks. This list is
distributed as a controlled document by the section Technical
Analyst.
No unacceptable conditions were identified.
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10. QA Program
a.
References
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-7-2-M0-002, Quality Assurance Audit / Monitor / Inspect System-
(QAMIS) Data Acquisition Procedure, Rev. 2
7-2-M0-003, Job Request / Submittal of Quality Assurance Audit /
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Monitor / Inspect QAMIS, Rev. 0
7-10-MO-001, QA Mod / Ops Section Monitoring Program, Rev. 1
--
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7-10-MO-003, Indoctrination and Certification of QA Mod / Ops
Section Monitors, Rev. 1
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7-14-MO-001, Inspection / Examination / Monitoring Scheduling and-
Planning, Rev. 1
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7-18-01, Quality Assurance Audits, Rev. 6
7-18-02, Quality Assurance Auditor Qualifications, Rev. 3
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7-18-M0A-001, QA Audit Plan, Rev. 0
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7-18-MOA-002, Audit Scheduling, Rev. 0
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7-18-M0A-003, Audit Checklists, Rev. 0
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7-18-MOA-004, Audit Report Filing, Rev. 0
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7-18-MOA-005, Quality Assurance Audit Reports, Rev. 0
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7-18-MOA-006, Management Rep rting, Rev. 0
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Nuclear Assurance Division Organization, Rev. 4
b.
Program Review
,
1
The inspectors reviewed the changes made to the organization and the
referenced implementing nrocedures in order to ascertain that they
were consistent with th- QA Program as described in the Opurational
i
QA Plan (0QAP), Rev. 9, that was approved by the NRC.
A number of minor discrepancies such as incorrect references, lack
of clarity and slight differences in instructions were noted. These
were discussed with the licensee representative who stated
corrections would be made.
The inspectors noted that the current revision of the 0QAP indicates
that the licensee intends to comply with the provisions of ANSI /ASME
NQA-1-1979, Supplement 175-1.and Appendix 17A-1, with respect to
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records (implementation is discussed in paragraph 6). -The
acceptability of this commitment will be discussed and resolved by
-NRR-QAB and RES-HFB.
No enacceptable conditions were identified.
c.
QA/QC Administration
The inspectors reviewed the referenced documents to verify that:
--
The scope and applicability of the QA Program were defined
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Appropriate guidance was provided by the procedures for the
intended area
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Adequate implementation of the procedures would fullfill QA
Program requirements
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Management controls and overview were addressed
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Authority and responsibility for each QA position was specified
The Nuclear Assurance Division Organization manual described
organizational responsibilities and major functions, and provided
organization graphs-and charts. -The licensee also recently
developed a GPU Job Description and Specifications Manual that
detailed individual job responsibilities, position requirements,
capabilities, etc. Additionally the GpU Organization Plan, signed
by the President, is the senior management policy description.
Management awareness and involvement in the QA Program is
demonstrated by the Nuclear Assurance Division Goals and Objectives
index that delineates specific goals and task completion dates. A
report has been issued to senior management on the acheivements-of
the"1981 goals and objectives, and an index has already been
prepared for 1982. The Program Development and Audit Program
Summary Report, February 2,-1981, that was distributed to management
assessed and examined the results of the audit program and the QA
Training Program.
The QA Department has developed a QAMIS tracking
system by computer and a User Procedure Manual has been issued.
Certain portions of the tracking system are on line.
!
The inspectors determined that the licensee has established an
effective QA Department program and was implementing it
i
satisfactorily.
,
No unacceptable conditions were identified.
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11. Offsite Review Committees
The inspector conducted interviews with the- former' and current General'
Office Review Board (GORB) Chairman, the_GORB Vice Chairman and the
Generation Review Committee (GRC) Chairman and reviewed the following
_
committee implementing procedures, meeting minutes and records.
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Three Mile. Island Nuclear Generating Station Unit 1, General Office
Review Board Responsibility, Authority,-Organization and Resources
Document dated April 1981
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Procedure No. GORB-1, General Office Review Board Administrative
Procedures, Revision No. 1, April 1, 1981
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Procedure No. EMP-009, Nuclear Power Station Generation Review
Committee, Revision 2, June 1, 1981
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Minutes of GORB Meetings #39 (October 15, 1980), #40 (December
15-16,1980), #41 (February 10-11, 1981), #42 (April 7-8, 1981), #43
(June 16-17, 1981), and #44 (August 4-5,1981)
Minutes of GRC Meetings #4 (September 9, 1980), #5 (October 21,
--
1980), #6 (December 11,1980), #7 (January 28, 1981), #8 (March 24,
1981), #9 (May 27,1981) and #10 (July '22,1981)
Committee member resumes
--
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Committee correspondence
The objective of the above discussions and reviews was to ascertain
whether the offsite review functions were conducted ~in accordance with
Technical Specifications and other regulatory requirements by verifying
the following.
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Changes since the previous inspection (50-289/80-21 completed August
1, 1980) fn the charter and/or administrative procedure governing
GORB and GRC activities were consistent with Technical
Specifications and ANSI 18.7-1976
f
GORB and GRC membership and qu'lifications were as required by
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Technical Specificatiores an..i ANSI 18.7-1976
2Property "ANSI code" (as page type) with input value "ANSI 18.7-1976</br></br>2" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process.
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GORB and GRC meetings convenet during the previous year ware held at
the frequency required by Technical Specifications
b
GORB and GRC members who participated in committee reviews of
--
selected items included persons who constituted a quorum and
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possessed expertise in the areas reviewed
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GORB and GRC reviewed appropriate activities as required by
Technical Specifications (e.g., safety evaluations completed per 10 CFR 50.59, proposed _changs which involve ar. unreviewed safety
question, noncompliance items, etc.)
--
Use of consultants by GORB and GRC was in conformance with Technical
-ifications
'
The inspector's findings concerning GORB and GRC activities were
acceptable. The GORB composition, including number of members and
collective competence, substantially exceeds Technical Specification
requirements. GORB meetings were conducted every two monthc vice every
six months as required by Technical Specifications. The performance of
both committees has improved since the last inspection (50-289/80-21) in.
this area which was the management appraisal by the NRC Performance
Assessment Branch. The weaknesses and noncompliance regarding committee
review activities identified during that inspection have been corrected,
as described in Paragraph 2 of this report.
No unacceptable conditions were identified.
12. Unresclved Items
Unresolved items are matters about which more information is required in
order to ascertain whether they are acceptable, deviaticns or items of
noncompliance.
Four unresolved items were identified during this inspection and are
detailed in paragraphs 3.c(12), (13), (14) and (15).
13. Management Meetings
Licensee management was informed of the scope and purpose of the
inspection at entrance interviews conducted at the Three Mile Island
-Nuclear Station on August 17, 1981 and General Public Utilities offices
on August 24, 1981.
The findings of the inspection were discussed with
licensee management at the Three Mile Island Nuclear Station on August
21, 1981 and General Public Utilities offices on August 26, 1981, and
periodically during the inspection with licensee representatives.
An exit interview was conducted at the Three Mile Island Nuclear Station
on September 2, 1981, at which time the findings of the inspection were
presented (see paragraph 1 for attendees). During this interview
licensee management confirmed the specific times contained within this
report as applicable to the specific actions.
,