ML20044A953

Forwards Util Response to Weaknesses Identified in Maint Team Insp Rept 50-289/89-82.Corrective Actions:Engineering Personnel Reminded to Assure Documented Approval Obtained Prior to Proceeding W/Work

ML20044A953
Person / Time
Site:	Three Mile Island
Issue date:	07/09/1990
From:	Hukill H GENERAL PUBLIC UTILITIES CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
C311-90-2094, NUDOCS 9007170061
Download: ML20044A953 (5)

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OPU Nuclest Corporation

• , . h' Post Office Box 480 Route 441 South -

Middletown, Pennsylvan!a 17057 0191-717 944 7021

, TELEX 84 2386 Writer's Direct Dial Number:

C311-90-2094 a

1' I U. s. Nuclear Regulatory Conunission

• Document Control Desk Washington, D.C. 20555 Dear Sir Three Mile Island Nuclear station Unit 1, (TMI-1) operating License No. DPR-50 Docket No. 50-289 CPUN Response to Weaknesses Identified in Inspection Report 89-82 NRC Kaintenance Team Inspection This letter transmits CPUN's responses to the weaknesses identified in the <

Maintenance Team Inspection report (IR) 09-82. The report requested notifica-tion of the actions taken or planned in order to enhance the maintenance activitiee pertaining to the weaknceses described therein. In the came of each of the six identified weaknesses, actions taken or plannkd to enhance the Maintent.nce Program by their resolution are provided.

Sincerely, i

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H D. Hu ill Vice President & Director, THI-l HDH/WCH Attachment cca R. Hernan T. Martin J. Stola >

F. Young Q '7th61 g PDC g9 e;

GPU Nuc! ear Corporation is a subsidiary of General Public Utilities Corporation  ! g m

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Attachment 1

' Weakness 1 identified three specific problems with the use of engineering evaluation requests (EERs) by Plant Engineering as addressed below:

l' An' inspector was unable to locate several EERs from the 1986 time

' frame. . These EERs were hand carried and not properly routed and con-trolled as required by procedure. As noted by the Inspection Report the EERs wore located in the work package. The problem occurred when EERs were hand carried through the approval chain by the end user. The end user was unaware or the need to go through the Engineering Clerk to

, close out log entries and make formal distribution.

Response To prevent recurrence, the EER number will.be assigned by Plant Engineering, thus ensuring Plant Engineering knows the EER is-active and is engaged in addressing it. The QA Engineers have been "Jtructed to provide a copy of the signed EER to the end user and return the original to the Engineering Clerk for administration and distribution.

2 A quality deficiency report (QDR) noted by an inspector identified that the EER procedure was not properly implemented in that work was com-pleted prior to the completion of the EER routing and disposition.

Responset Both Plant Mai.clel and Plant Engineering personnel have

.beentreminded to assure that documented approval is obtained prior to proceeding with the work. The QDR has been closed.

3 The inspector noted that the EER backlog was almost double the goal established and that the on site engineering staff is somewhat over-loaded with work in this area.

Response The number of EERs in Plant Engineering is excessive.

Actions are underway to 1) reduce that portion of the EER total which is " backlog" (chronologically late items) and 2) to work off the new, incoming EERs on'a schedule which keeps Plant Engineering current.

Our plan of attack for backlog work reduction is 1) to schedule the backlog items for work' execution by appropriate engineers so that between July and December 1990 the backlog' items are appropriately addressed and 2) by December those items remaining as " outstanding backlog" are acceptable both in number and content and are also accept-able with regard to future completion dates.

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[ Our_ plan of attack for new, incoming EERs is to assign to them pre-established work execution spans (60 cays) and-to manage them in earnest according to those spans. .

Further, we plan.to change the procedure which governs Plant Engineer-ing's effort on EERs to ensure front-end agreement is reached between  !

the requestor and engineer on the priority, due date (if other-than 60 -'

days) and technical content of the requested evaluation.

In the' interim, sufficient controls are in place to prevent adverse impact on safety. The sources of most EERs are Materials Management (Purchasing / Stores), Plant Operations or Plant Materiel. Those EERs determined to be more significant to safe operation of the unit are from Operations and Plant Materiel. Priority items are identified'at 1 the daily and monthly planning meetings. In addition, periodic meet-  !

ings are held with Operations and Plant Materiel Departments to review -i their open requests.

Weakness 2 states that " Generic procedures are frequently used in work [

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packages without indication as to which portions of the generic procedure are applicable to the work to be performed".  !

Responset GPUN believes that the use of generic procedures fulfills the <

objectives of its maintenance philosophy. The objectives in the use of

• generic procedures are s

e to maintain a reasonable number of procedures vice an extremely large 6 number which would result from providing an unnecessary level of detail for qualified workers and e provide good quality generic procedures which provide the user with 7 options for many conditions and contingencies that may be encountered. c The technicians are qualified through a formal process to perform the work identified in the procedures; this includes understanding when to follow an alternative path because the conditions dictate.

We agree that work packages can be improved by making it clearer which  ;

portions of generic procedures apply to a specific job. Guidelines will be developed for work package preparation to reference, extract or identify in some approprJ (e way the portions of the generic procedures which are applica-ble, when thia can bo determined during the planning process.

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Weakness 3 centered on three issues identified in the area of Vendor Document l, 2 control. The inspector addressed lost manuals,. preventing use of lost

" . replaced manuals and-manuals that are not entered into the control system.

Response The responses to these issues follow in respective order:

1 There are about 45 unique distribution points for the approximately 10,000 manuals issued. An audit of the manuals was performed in 1989, I three years-after the control program was implemented. Thirty-six manuals were identified as missing by the' audit. Although this is a relatively small percentage of missing manuals over the three year period,-it is expected-that the number can be further reduced. In that'

-vein, a memo has been issued to all major distribution point department heads stresslag the importance of proper sign out of manuals and overall document control.

2 Cognizant department heads must request, in writing on a proprinted form, a replacement manual once a manual is determined to be lost.

This form requires the department to destroy the lost' manual if found.

This form was in place at the time of the inspection and was reviewed by the inspector. 'These controls are currently more stringent than the controls on procedures. They are viewed to be adequate and no further action will be taken.

.3 A' number of " personal copies" of. vendor manuals do exist..These docu-ments are considered training materials and as euch, may be used as references for understanding equipment operation. The documents may be annotated by their owners and are not controlled ca updated. Direction has been given to all Maintenance personnel to destroy uncontrolled manuals which are no longer useful and to stress the importance of compliance to the administrative procedure prohibiting use of any+.hing but controlled manuals for work on safety related equipment.

Weakness 4 identified the need to improve the storage of some material in the warehouse.

Response The Nuclear Warehouse Manager has/will take the following actions to improve the conditions of stored material as addressed belows e A meeting was held with Warehouse Supervisors / Administrators to discuss the conditions identified by IR 89-82. These personnel were directed to increase their awareness and identification of storage conditions that require improvement during regular and informal inspections / tours 3

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and during'the normal course of work. They were also' directed to be .l responsive to conditions identified by employees or visitors that may-need attention.  :)

. A training program was developed specifically to address storage condi-tions as established by GPUN procedures and' ANSI standards. Training of most warehouse personnel has been completed and will be scheduled in i the near future for those who have not yet attended. The material will L j

be included as a training subject for warehouse personnel biennially.

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• The Warehouse willalso be scheduling personnel to conduct a row by row physica1' inspection / corrective action activity. This hands on activity is intended to correct not only the items specifically addressed,_ valve j.

caps and snubbers, but also any additional items that might be identi-fled. It is. intended to complete this activity by October 31, 1990.

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L Weakness 5 identified inadequate corrective action for quality assurance findings associated with in-plant storage of equipment in shop areas and the control of test equipment, i

Response Though corrective actions-specified in response to our internal GPUN Quality Deficiency Report (QDR) 027-89 have had a positive effect, they did not meet all of the program requirements. Plant Materiel Department management recognizes the inadequacy of that action and has developed rarrec-tive actions which will address this weakness. These actions were described

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.I as part of the response +3 the Notice of Violation 89-82-01 items B and C, and

. include increasing the c; ope and frequency of checks on in-plant stored materials and measuring-and test equipment, providing training to responsible persons on procedural requirements and purging uncontrolled / unneeded materi- j als. 3 Weakness 6 identified the failure of periodic procedure reviews to identify -

f significant deficiencies in the procedures associated with slings and hoisting j equipment' control. ,

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Response The quality of the procedure reviews is a recognized weakness. As )

a result, in March 1989, as part of a significant effort to upgrade mainte-nance procedures, a staff position was created to produce a. procedure writer's guide, provide training on its use and finally provide input on procedure

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revisions. The procedures cited were biennially reviewed prior to the new review program's implementation and the inspection. The procedures are currently in the review cycle having had improvements made to them. The upgrade process is on- going with the initici review cycle improvements to all maintenance procedures to be completed by November 1991.

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