ML20039B640
| ML20039B640 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/17/1981 |
| From: | Blumberg N, Caphton D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20039B637 | List: |
| References | |
| 50-289-81-27, NUDOCS 8112230336 | |
| Download: ML20039B640 (12) | |
See also: IR 05000289/1981027
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U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
Region I
Repbrt No.
50-289/81-27
Docket No.
50-289
License No.
OPR-50
Priority
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Category
C
Licensee: Metropolitan Edison Company
P.O. Box 480
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Middletown, Pennsylvania 17057
Facility Name: Three Mile Island, Unit 1
- Inspection at: Middletown, Pennsylvania
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Inspection con'cucted:
October 4-7 and 9, 1981
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II /d
Inspectors:
Blum er ,
eac}or y pector
date signed
Approved by:
fl
8/
/[!/7/8/
0.~ L. Chptfton, Chief,
dat4 signed
Management Programs Section,
Engineering Inspection Branch
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Inspection Summary:
Inspection on October 4-7 and 9, 1981 (Report No. 50-289/81-27)
Areas Inspected:
Routine, unannounced inspection by one region-based
inspector of licensee action on previous inspection findings; admin-
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istrative controls for safety related maintenance; implementation
of safety related maintenance; and licensee resolution of ASLB concerns
regarding-maintenance activities.
The inspection involved 27 inspector-
hours onsite by one region-based inspector.
Results: Noncompliance:
None in three areas and one in one area
(Violation - Inadequate documentation of maintenance and test activities
in maintenance records
paragraph 4. c. (2).
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.G112230336'811204"
.PDR ADOCK 05000289
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DETAILS
1.
Persons Contacted
General Public Utilities Nuclear (GPUN)
B. Ballard
Manager-TMI Quality Assurance (QA) Modifi-
cation / Operations
J. Colitz
Plant Engineering Director
G. Derk
Quality Control (QC) Inspection Support
Supervisor
D.-Dyckman
Lead Shift Maintenance Supervisor - TMI-1
R. Fenti
R. Harper
Corrective Maintenance Manager
W. Heusek
Supervisor Site Audits
W.rMiller
TMI-1
Licensing Engineer
D.'Shovlin
Manager. Plant Maintenance - TMI-1
P. Sinegar
Administrator - TMI-1 Maintenance
C. Smythe
Supervisor Licensing Operations and Maintenance
M. Snyder
Preventive Maintenance Manager - TMI-1
R..Toole
Manager - TMI-1
R. Troutman
Supervisor of Maintenance Management Control -
TMI-1
H. Wilson
Instrument and Control (I&C) Foreman - TMI-1
R. Conte
Senior Resident Inspector - TMI-2
.D. Haverkamp
Senior Resident Inspector --TMI-1
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F. Young
Resident Inspector - TMI-1
The' inspector also interviewed other licensee employees' including
clerical and maintenance personnel.
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Denotes those present at exit interview.
2.
Licensee Action On Previous Inspection Findings
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(Closed) Unresolved Items (289/80-04-01 and 80-13-01):
Method for identification of safety related systems and components
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needs to be provided. These items addressed the -lack of identi-
fication of safety-related systems and components and the classi-
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fication of related engineering change memorandums (ECM'S) as
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unresolved items.
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Inspection 289/81-17 noted that procedures 1021 A/B, 1001, 1001A
(to be issued), 1026, and 1407-1 refer to procedure GP-1008 for a
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listing of components which require quality control.
Further,
Inspection 289/81-17 determined that GP-1008, Quality Assurance
Systems List, Revision 2, dated September 25, 1978 had not been
revised in three years and no longer accurately reflected the
design of TMI Unit No. 1.
During inspection 289/81-17, which was conducted June, 1981, a
licensee represeitative stated that.another engineering procedure
had been issued which superseded GP-1008 and more accurately
reflected the status of TMI Unit 1.
He further stated that a
memorandum had been issued !nforming personnel of the change and
that procedures would be revised as they came due for their
periodic review.
NUREG-0680, Supplement No. 3, "TMI-l Restart Evaluation of
Licensees Compliance with the...NRC Order dated August 9, 1979...",
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Order Item 6 (Short Term), Management Capability and Resources,
states, in part, the following:
I"0PERATIONAL QUALITY ASSURANCE _ PROGRAM
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In NUREG-0680 (p. C6-9), we noted that the licensee had not
yet provided a list of the structures, systems, and components.
to which their QA program will apply (Q-list).
The licensee submitted this list in March 1981. We have
reviewed the document and find that it identifies safety-
related systems, structures, and. components, and that it
represents a significant improvement relative to the
acceptable Q-list in effect prior to the TMI-2 accident and to
that of other operating reactors. On the basis of our review,
we conclude that the Q-list is acceptable for restart,.and
that the licensee is in full compliance with this part of the
Order."
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The above "Q" list was officially issued as Engineering Procedure
EP-Oll, " Quality Classification List", Revision 0, June 1,1981;
and Engineering Standard ES-Oll, " Methodology and Content of TMI-l
Quality Classification List", Revision 1, February 13, 1981.
Although not referenced in Inspection Report 289/81-22, EP-Oli and
ES-011 were reviewed during inspection 289/81-22. During inspection
289/81-22, the inspectors verified that, based on their impact on
safety, the licensee had provided an adequate classification of
equipment, systems and structures. Based on the above determinations,
unresolved items 289/80-0401 and 80-13-01 are closed.
However, during this inspection, the inspector determined that GP-
1008 is still referenced by procedure 1407-1, [" Unit No.1 Corrective
Maintenance Procedura", as well as other procedures and was still
in use by maintenance planners. A licensee representativa stated
that GP-1008 was still in use because it provided a "Q" listing on
.a component basis and ES-011 did not.
Further, the inspector
observed the following instruction in Enclosure 2 to proposed
revision 8 to procedure 1407-1 for filling out a Job ticket:
"18, Is this work on a component on the Quality Control List
(QCL)...Use the Quality Control List per GPU Nuclear Procedure ES-
Oll .(In the interin, until ES-Oli is defined to the component
level, utilize GP-1008 to define-QC components)."
Discussions with licensee representatives during inspection 289/81-
17 indicated that the licensee intended to develop ES-Oli "Q List"
to the component ~1evel.
Proposed Revision 8 to 1407-1 also indicates-
this intent. However, during this inspection, various licensee
representatives stated that there was no intent to revise ES-011.to
the component level as it was satisfactory for engineering use and
that the updating of GP-1008 had r. very low priority.
In summary, during this inspection, the inspector determined that:
GP-1008 is still in use by Maintenance planners, although it has
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not been revised since 1978 and is no longer an "efficially"
existing controlled procedure.
ES-Oll, while useful to engineers, cannot be used at the shop level
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since it does not provide a component "Q" list.
There are no plans to revise ES-Oli to the component level nor'to
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update and control GP-1008.
The inspector informed the licensee that GP-1008 is unsatisfactory-
.in its present form and that an acceptable "Q" list is needed prior
to criticality. This item is unresolved pending licensee action
and subsequent NRC:RI review (289/81-27-03).
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3.
Administrative Controls For Implementation of Safety - Related
Maintenance
a.
Administrative controls were inspected to determine the
licensees program for compliance to the implementing requirements
associated with the conduct of safety-related maintenance as
specified in Technical Specification Section 6; Regulatory
Guide 1.33-1978, Quality Assurance Program Requirements (Operation);
and ANSI N18.7-1976, Administrative Controls and Quality
Assurance Requirements for Nuclear Power Plants,
b.
The folicwing procedures were reviewed:
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1026, Corrective Maintenance and Machinery History, Revision 12,
September 22, 1981;
1027, Preventive Maintenance, Revision 10, July 24,1981;
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1020, Cleanliness Requirements, Revision 6, November 17, 1978;
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1008, Good Housekeeping, Revision 8, June 22, 1981;
1036, Instrument Out of Service Control, Revision 3, October 23,
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1980;
1042, Control of Welding, Revision 0, July 10, 1981;
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1030, Control of Access to Primary System Openings, Revision
3, July 13,1980;
1035, Contro of Transient Combustible Materials, Revision 6,
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August 11, 1981;
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1024, Control of TMI Q.C. Records, Revision 1, December 16,
1977;
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1407-1, Unit #1 Corrective Maintenance Procedure, Revision 7,
October 22, 1980; and,
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Operational QA Plan, The Metropolitan Edison Company, GPU
Nuclear Corporation, Three Mile Island, Revision 9, May 28,
1981, Section 6.2.1.10, Control of Construction, Maintenance
(Preventive / Corrective) and Modifications.
c.
Findings
th) items of noncompliance were identified. However, one
unresolved item was identified and is detailed below:
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The inspector observed that maintenance housekeeping clean-
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liness zones as defined in ANSI N45.2.3 were established by
procedure 1008, " Good Housekeeping". However, this procedure
does not provide a means for implementation or documentation
of what zones are to be used for specific maintenance jobs.
A licensee representative stated that housekeeping cleanliness
zone requirements would be moved from procedure 1008 to pro-
cedure 1030, " Control of Access to Primary System Openings",
and that methods of implementation and record keeping, when
required, would be established.
Currently, procedure 1030 requires that records associated
with primary system openings be maintained by Operations
Department. The licensee will evaluate whether or not these
records should be maintained as permenent records in the job
package.
This item is unresolved pending licensee action and subsequent
NRC:RI review (289/81-27-02).
4.
Review of Implementation of Safety Related Maintenance Activities
and Resolution of ASLB Concerns
a.
A sampling of safety-related maintenance performed by the
licensee was inspected to determine that:
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Technical Specification requirements were satisfied while
equipment was out of service;
Maintenance activities had been conducted in accordance with
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administrative procedures detailed in paragraph 2;
An approved procedure was used for those maintenance acti-
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vities which could be considered beyond the skills normally
possessed by qualified maintenance personnel;
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Inspections of maintenance activities were performed as re-
quired by administrative procedures;
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Post maintenance testing was accomplished, when required;
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Records to substantiate quality of work and parts used were
available; and,
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Licensee resolution of concerns by the ASLB in its Partial
. Initial Decision, dated August 27, 1981, regarding the area of
maintenance.
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-The inspection included a review of job tickets issued within
six months of this inspection as detailed in Paragraph 4.b and
associated maintenance procedures (when used).
b.
Documentation of the following Unit 1 maintenance activities
were inspected:
Job Ticket (JT) C6004, Disassemble and Inspect Reactor. Building
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Spray Valve, BSV-558, Completed June 17, 1981. Procedure 1410-
V-10, Disassemble, Inspect, Clean,-Repair and Assemble Gate
and Globe Valves, Revision 6, October 2, 1980;
JT C6034, Adjust and Checkout Emergency Diesel Fuel Oil Level
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Switch, LS 1728, Completed July 13, 1981.
Procedure 1430-Y-
25, Repair / Calibration of Various Instrumentation Leve.
Switches, Revision 1, July 30, 1980;
JT C6054, Adjust and Test Hydraulic Snubber in Nuclear Services
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Closed Cycle Cooling System, Completed June 23, 1981.
Procedure
1410-Y-34, Repair of Hydraulic Snubber, Revision 2, May 10,
1978;
JT C6118, Reset Fire Service Pump 2 Relief Valve, Completed
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June 12, 1981.
Procedure 1410-V-3, Test, Repair,, Inspect
and/or Reset Relief Valves, Revision 3, October 7, 1980;
JT C6195, Replace Temperature Gage for Fire Service Diesel
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Circulating Water, Completed August 5, 1981. Procedure 1430-
Y-7, Temperature Indicator Repair / Calibration, Revision 2,
April 15, 1981;
JT C6212, Repair Penetration Pressurization System Flow
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Indicator Ball, Completed July 13, 1981.
No procedure;
-- .JT C6334, Repair Emergency Diesel Generator Injector Oil
Leaks, Completed July 19, 1981.
Procedure 1410-Y-4, Tighten-
ing and/or Replacing Tubing and Fittings, Revision 2, May 20,
1980;
JT C6349, Modify. Snubber To Decay Heat Removal System Cooler
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DH-C1A, Completed August 8, 1981.
Procedure PE-213-6, ITT
Grinnel Corporation Field Procedure, Alteration of Fig. 201
and Fig. 307 Snubber Extension Pieces NF Nuclear' Power Generation
Stations Procedure No. PE-213-6, Revision 2, September 9,
1980;.
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JT C6394, Repair Decay Heat Removal River Water Pumps In-
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- dicating -Lights, Completed July 28, 1981.
Procedure 1420-Y-
13,-Troubleshoot and Repair of Control or Indication Circuits,
Revision 2, March 9,.1981;
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JT C6423, Reset Reactor Coolant Drain Tanker Level Alarm
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Setpoints, Completed August 25, 1981.
Procedure 1430-Y-25,
Repair / Calibration of Various Instrumentation Level Switches,
Revision 1, July 30, 1980;
JT C6456, Reset "0" Battery Charger Output Voltage, Completed
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August 23, 1981.
Procedure 1420-EL-1, Trouble Shooting Unit
1 Battery Charger, Revision 1, May 21, 1980;
JT C6473, Replaced Instrument Air Suction Filter, Completed
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August 21, 1981.
Procedure 1410-F-1, Filter Elements Replacement
1410-F-1, Revision 2, July 4, 1981;
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JT C6528, Reorient Reactor Building Spray Snubber BS-25,
Completed August 19, 1981. Procedure 1410-Y-34, Repair of
Hydraulic Snubbers, Revision 2, Ma i 10,1978;
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JT C6550, Repair Limit Switch on Makeup System Valve, MU-V-12,
Completed August 20, 1981.
Procedure 1420-LTQ-1, Troubleshooting
Limit-Torque Valve Operators and Control Circuits, Revision 3,
May 22, 1980;
JT C6554, Replace Torque Switch on Chemical Addition Valve,
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CA-V-13, Completed August 28, 1981.
Procedure 1420-LTQ-3
Limitorque Torque Switch Adjustment, Revision 3, July 17,
1981;
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JT C6580, Replace Mechanical Seal on Makeup System Pump 1A,
Completed August 27, 1981.
Procedure 1410-P-11, Repairing and
Installing Mechanical Seals, Revision 3, April 6, 1981;
c.
Findings
(1) The Atomic Safety and Licensings Board (ASLB) Partial
Initial Decision resolution to TMI Alert (TMIA) Con-
tention No. 5 noted a concern in paragraph 315 of the
decision which states, in part, the following:
"...We therefore note the Commissions dependence in the
future on the Staff's routine inspection program. Given
the Staff's ongoing inspections, and in light of the fact
i, hat the Licensee is implementing a radically different
system, we expect the staff inspections will focus in
part on the ability of the Licensee routinely to keep
track of its maintenance records and manage the scheduling
and prioritiz_ing of its maintenance, and on the continuing
auditability by Licensee itself and by the Staff of
safety-related maintenance records . . .L"
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During this inspection, the tracking of maintenance
records, management of maintenance scheduling, priori-
tizing of maintenance, and the auditability of maintenance
records were inspected. The inspector determined that
.there appeared to be good control in all of the above
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areas with the exception of records regarding auditability.
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A deficiency was identified concerning the completeness
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and auditability of some maintenance records and is
further detailed in paragraph 4.c.(2) below.
Inspection of additional ASLB concerns regarding resolution
of.TMIA Contention No. 5 are discussed in paragraphs
4.c.(3), (4), and (5) below.
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(2) Most maintenance-records contain as a minimum the job
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ticket (work permit) for the job and an attached maintenance
procedure. This procedure is usually attached to the job
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ticket by a planner based cn'the projected nature of the
described problem. While some procedures are job specific,
most are generic in nature.
Based on the exact nature of the repair, all, some, or
none of the attached maintenance procedure may be used.
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This includes the post maintenance testing which may be-
prescribed in the procedure.
During review of main-
tenance records, the inspector, in some cases,'could not
determine the exact. maintenance. accomplished, what
portions of the attached maintenance procedure was_used,
or what post maintenance testing was actually accomplished
because the procedure attached to the job ticket was
unmarked and the job summary listed on the job ticket
was too limited. The following are examples of job
tickets which contain such deficiencies:
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C6550, Repair of Makeup Valve MU-V-12;
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C6456, Reset "D" Battery Charger Output Voltage;
C6473, Replace Instrument Air _ Suction Filter;
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C-6004, Disassemble and Inspect Reactor Bu'ilding Spray
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Valve; BSV-55B; and,
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C6195, Replace Temperature Gage for Fire Service Diesel
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Circulating Water.
In'each instance, above, during the inspection,.in' order
to ascertain the exact maintenance and post maintenance
testing that had been done, a maintenance supervisor had-
to make additional inquiries regarding the actual maintenance
and testing accomplished.
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The inspector informed the licensee that maintenance
records must adequately reflect maintenance performed,
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inspections accomplished, and post maintenance testing
performed. Additionally, as.noted in paragraph 1 above,
the Atomic Safety and Licensing Boards (ASLB) Partial
Initial Decision, item 315, expressed a concern on the
continuing auditability of maintenance records. Based on
the above inspection, the inspector determined that the
maintenance records, in some instances, were not adequate
to provide for auditability.
Failure to maintain adequate _ records of corrective
maintenance actitities is contrary _to 10 CFR 50 Criterion
XVII _and ANS1 N18.7-1976, paragraph 5.2.7, and consti-
tutes an item of noncompliance (289/81-27-01).
(3) ASLB Partial Initial Decisions paragraph 317 stated the
following concern:
"As we note below in the QA/QC section in connection with
TMIA Ex. 12, the auditability of records would be improved
if QC observation hold points were signed off by QC at
each such point ~, instead of just the final QC approval
being noted after completion of the work. The acceptance
or rejection of this change by Licensee should be documented
and reviewed by the staff as part of its future inspection
maintenance and QA/QC records."
The inspector verified that QA Modification / Operations
Section Procedure 7-10-M0-002, "QA Modifications / Opera-
tions Section - Inspection Program", Revision 1, July 10,
1981, now requires that QC hold _and witness points must
be signed.
Specific managerial approvals must be obtained
for QC not to ob' serve a hold o'r witness points. Additionally,
a special QC log is maintained which documents when QC
hold and witness points are_not observed and states the
reasons.
The inspector observed that QC hold and witness points,
which were in the procedures reviewed during this inspection
had been signed by the QC inspector.
Based on the above, this concern appears to be satis-
factorily resolved.
(4)' ASLB Partial _ Initial Decision paragraph 318 stated the
following concern:
"As we also note in the QA/AC section in connection with
TMIA Ex. 20 and 31, there were long delays in the QC
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approval being obtained and noted after completion of the
work. At best, this is a poor record keeping practice.
The performance of licensee in this regard should be
reviewed in future staff inspections of maintenance and
QA/QC records."
The inspector determined, from a sampling of job tickets,
that there was no significant delay between work com-
pletion and final QC review. Also, as noted in paragraph
4.c.(3) above, QC inspection and hold points are now
being signed.
Proposed Revision 8 to Procedure 1407-1, " Unit No.1
Corrective Maintenance Procedure", which is in process of
review and concurrence, eliminates the final QC review of
job tickets. A licensee representative stated that'this
was being done because the licensee felt that the final
responsibility for the adequacy of job completion should
be with the Maintenance Department. Also, post QC
reviews rarely found inadequacies in the completed job
package. However, the licensee representative stated
that QC would randomly audit completed job packages for
completeness.
Based on the above, this item appears to be satisfactorily
resolved.
(5) ASLB Partial Initial Decisions paragraph-319 stated, in
part, the following concern:
"...Our concern is whether the potential for actual work
on a non-QC component to have an effect on nuclear
safety (e.g. , because the work must be done in the
proximity to safety related systems) is properly evaluated
by Licensee before the work is done...To put it in the
format of the new job ticket, we do not understand why.
(job ticket) itcm 4 (agreement that approved procedure is
not required because work has no effect on nuclear safety)
does not apply regardless of whether the work is on a QC
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component... Licensee should expressly consider whether or
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not to make such a change,-and the staff should furnish
its agreement or disagreement and the reasons therefore
with licensees decision to the Commission prior.to any
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restart."
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The TMI Licensing Section issued a memorandum to certain
licensee managers on September 22, 1981 requesting-
comments by October 15, 1981 on proposed resolutions of
the above issue.' Hence, this item is still under evaluation
by the licensee and remains open.
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4.
Unresolved Items
Unresolved items are matters about which more information is required
in order to ascertain whether they are acceptable, deviations, or
items of noncompliance.
Two unresolved items were identified
during this inspection and are detailed in naragraphs 2 and 3.
5.
Management Meetings
Licensee management was informed of the, scope and purpose of the
inspection at the entrance interview conducted on October 5, 1981.
The findings of the inspection were periodically discussed with
licensee representatives during the course of.the inspection. An
exit interview was conducted on October 9,1981, (see paragraph I
for attendees), at which time the findings of the inspection were
presented.
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