IR 05000289/1987026

Insp Rept 50-289/87-26 on 871214-18.No Violations Noted. Major Areas Inspected:Licensee Action on Previously Identified Concerns,Document Control Program,Program Implementation & Qa/Qc Interfaces

ML20149M950
Person / Time
Site:	Three Mile Island
Issue date:	02/19/1988
From:	Blumberg N, Dev M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20149M943	List: IR 05000289/1987026 ML20149M942
References
50-289-87-26, NUDOCS 8802290308
Download: ML20149M950 (9)

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U.S'. NUCLEAR REGULATORY COMMISSION

REGION I

' Report No. -50-289/87-26 Docket N License No. OPR-50 Licensee: GPU-Nuclear Corporation P. O. Box 480 Middletown, Pennsylvania 17057 Facility Name: Three Mile Island Nuclear-Station, Unit 1 Inspection At: Middletown, Pennsylvania Inspection Cor ted: December L4-18,1987

Inspector: / a 2 4 B8 M. Dev, P. = E. , Reactor Engineer dite '

-Approved by: 7 /7 N.Blumberg, Chief,Operat/ionalPrograms date Section, DRS /

Inspection Summary: Routine, Unannounced Inspection on December 14-18, 1987 (Inspection Report 50-289/87-26)

Areas Inspected: Review of the licensee's action on previously NRC identified concerns, document control program, and program implementation, and QA/QC interface Results: No violations were identifie PDR ADOCK 050 G

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1.0 Persons Contacted General Public Utilities (GPU) - Nuclear Corporation-

• W. County, QA Lead Auditor C. Incorvati, TMI Audit Manager

• M. Knight, TMI-1 Licensing Engineer D. Langan, TMI-1 Operation QA Engineer

• T. Noble, Senior Licensing Engineer

• Pilsitz, Drawing Center Assistant R. Schaible, Senior Designer, TMI-1 C. Shorts, Manager, Technical Functions, TMI-1

• S. DiVitto, Supervisor, Design & Drawings, TMI-1 The inspector also contacted licensee's other technical and administrative personnel during this inspectio U.S. Nuclear Regulatory Commission (NRC)

• R. Conte, Senior Resident Inspector A. Sidpara, Resident Inspector, TMI-1

• Indicate those person who were present at the exit meeting, on December 18, 198 .0 Licensee's Actions on Previously NRC Identified Concerns (Closed) Unresolved Item (50-289/86-14-03): This item pertains to the licensee's inadequate control of the Three Mile Island Unit I drawing document The licensee's licensing action item (LAI) No. 86-9303 addressed the underlying conc?rns and formulatad procedure and assigned additional resources to properly centrol the drawings update and its distribution in a timely manner. Accordingly, any relear,ed drawings have the associated micro aperture card (MAC) distributed to the cognizant departments within three weeks. The licensee has emphasized awareness of the user community regarding the existence of an updated drawing based on the configuration control listing. Copies of the new drawings are distributed by the docu-ment distribution and control center (DD&CC) at site while the MACS are being produce The inspector Jiscussed with the licensee's site technical function staffs and reviewed the licensee's design and drafting update activitie The inspector verified that the most important drawings for use by the control room and the maintenance department are included in a "controlled

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. 3 copy" list maintained by the licensee's Information Management Department (IMD). The key locations have a hard copy set of all drawings that are used in performing any safety-related activitie The notification that a new change document affects either a control room drawing or a maintenance drawing occurs immediately upon receipt of the change document by IMD. For control room drawings, the revised drawing is usually provided simultaneously to the issuance of the change documen The site design and drafting section incorporates the changes and issues the revised approved drawings for use by the control room staff in a expeditious manner. When a revision is complex, the change document identification is stamped on the drawing in the control _ room, until the revised drawing is issued. For maintenance department, the hard copy drawing is stamped with the change document identification until it is revise ,

In order to facilitate expeditious handling of the plant document release forms (DRFs) and change documents, the licensee's ED&CC department issued memorandum 5140-87-005 dated February 2, 1987. Accordingly, a special

"technical function priority mail" bag has been established. The tech-nical function site office transmits all approved original change documents and DRFs, for the same day turn around basis, to the ED&CC department for processing and updating the configuration control lis In addition, the ED&CC department also issued memorandum 5140-87-011, dated February 26, 1987 which provided guidance to resolve any deficiencies encountered with DRF packages and avoid excessive dela Based on the above, the licensee's action is considered adequate. This item is close .0 Document Control Program Inspection Criteria / References The scope of this inspection ascertains whether the licensee is implementing a quality assurance program relating to document control in conformance with the requirements established in the documents listed in Attachment .2 Program Review The licensee's drawing / document control program (see Attachment 1)

was reviewed to verify that the licensee has established:

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Administrative controls and responsibilities to prepare review, and distribute 'as-built' to the plant site in a timely manne Administrative controls for obsolete drawing ;

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Administrative control to ensure that discrepancies found between 'as-built' drawings and the 'as-constructed' facjlity, are handled as design change "

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Master indexes for drawing, manuals, Technical Specifications, FSAR and Procedures to provide mechanism -for issuing and distributing current revision of drawings / document Requirements for periodic review of the master list to verif that changes have been incorporated into appropriate procedures, instructions, and drawing .3 Implementation Review and Findings 3. Technical Functions The licensee Technical Function Procedure EP-025 delineates method for preparation, review and approval of 'as-built'

drawing The 'as-built' condition of the plant is documented by the combination of drawings with a release status of 'as-built'

or 'as-installed' on the Configuration Contro! List -

Computer Assisted Records and Information Retrieval System (ARIRS) plus the outstanding change documents. These change documents comprised of Field Change Notices / Field Change Requests (FCN/FCR) or Design Change Notices (DCN).

Currently, the licensee is revising and updating all

'as-built' drawings at the site which have operational

constraint, and seek higher priority attention. Other

'as-built' drawings are updated by the licensee's A-E, the ,

Gilbert Associates, In The design and document control center transmits the updated drawings, in accordance with the approved distribution list, to the cognizant plant departments for us The obsolete drawings are destroyed to avoid inadvertent us The inspector reviewed the control and distribution of selected plant drawing documents under the control of the station engineering, site technical function section, control room, I&C, Electrical and mechanical maintenance shops. These documents are listed in Attachment 1. The inspector noted that the site technical function had an obsolete revision (P3) of elementary drawing 209-736, instead of the current revision 2. The print was voide In actuality the associated field change notice (C-034275)

was voided after completion of the wor Consequently, the elementary drawing should have been updated. The licensee representative acknowledged that the updated drawing was

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.: 5 not redistributed. However, the correct and revised aperture card was available. The inspector determined that this was an isolated cas . Document Control The DD&CC assistant periodically conducts an-inventory check of the drawings and micro aperture cards (MACS) at all cognizant locations, in~accordance with the administrative procedure 1001C. Any document deficiencies observed are. simultaneously corrected and the inventory updated. The inspector reviewed the recent inventory check record and found it effectiv . Plant Engineering The plant engineering department is responsible to review and update changes to the plant Technical Specifications through amendment in accordance with licensing procedure LP-006_(Attachment 1). The inspector discussed with the licensee representative the distribution control of the amended documentation. Currently, Amendment 135 to the TMI-1 Technical Specifications has been implemented. The inspector verified the availability of the control. led, amended Technical Specification at key locations such as control room, ' licensing department, and the site QA library, and found them satisfactor . Licensing Department The licensee's FSAR coordination corporate staffs are responsible for review and update of the TMI-1 FSA The document is updated annually following each refueling outag Currently, Revision 6 to the facility FSAR is in use. The inspector verified the control and distribution of the updated FSAR at key locations, such as control room, licensing department and the site QA library, and found them satisfactor .4 Conclusions The licensee's control and distribution of updated plant drawings and documents including the Technical Specifications and FSAR with cognizant holders were found adequate and effective. The DD&CC assistant personally carries the revised drawings to the recipients and updates their drawing files, including MACS. A periodic drawing inventory check is also conducted at these locations and any discrepancies observed are simultaneously correcte .. .

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- 6 The licensee has established a special "technical functions priority mail" bag which transmits the approved drawings and documents, on the same day turn around basis, from the site to the offsite ED&CC staff for document processing and update. The licensee's control of assuring quality of the station design and drawing was found adequat The inspector noted that site QA audit of the licensee's drawings control program was thorough, and the audit findings were meaningfu The operational QA monitoring of the station drawings control appeared to be effective. They identified some hardware oriented deficiencies in the plant system drawings and initiated quality deficiency reports for the station engineering department's resolution of stet. The concerns were resolved through followup meetings with the meetings with the management. This indicated that the station QA action to verify the licensee's compliance to the procedural requirements for the station drawing control has been on going, and is effectiv Based on the above, the inspector concluded that the licensee's drawing control program is adequate and effective. No violations were identifie .0 QA/QC Interfaces The licensee's operational quality assurance (0QA) plan, 1000-PLN-7200-01, (Attachment-1) paragraph 3.2.2 requires a written drawing document control procedure. Accordingly, the Director-Administration is responsible to develop, maintain and administer GPUN policies, procedures, and plans including procedure for the control of documents and to establish and implement the GPUN document control program. The Director-Of-Nuclear Assurance is responsible for the review and approval of GPUN document control program procedures, and to evaluate the overall document control system effectiveness through review and audit The inspector noted that the licensee's site QA audit staff conducted audit S-TMI-86-15 to verify the effectiveness of the licensee's drawing document control program. The engineering services staffs have reviewed l the result of this audit and implemented corrective action in a timely manner.

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The licensee operational QA (00A) staff conducts monitoring and surveillance of the station quality control activities requiring use of approved, updated system or process drawing Any nonconformances identified are documented in the quality deficiency reports (QDRs) and forwarded to the responsible department for resolution. As a result of such a monitoring, the OQA initiated 00R DLL-066-87 which identified that 18 out of 218 drawings being utilized to develop the seventh refueling outage inservice inspection were found discrepant. The discrepancies ranged from incorrect support location, incorrect support type, to non-existent supports in the field. The inspector discussed this issue with the cognizant 0QA engineer

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who acknowledged that during his recent meeting with the Engineering Director, the discrepancies were resolved and no further action was warrante The inspector also reviewed the following 0QA monitoring report The attributes were found to have adequately verified tha licensee's procedural complianc CDB-0336-87, Drawing Utilization (Administrative)

CDB-0782-87, Drawing /FCN Control (Administrative)

SRB-0798-87, Drawing Utilization (Operations)

5.0 Management Meetings The licensee management was informed of the scope and purpose of this inspection at an entrance meeting conducted on December 14, 1984. The findings of the inspection were discussed with the licensee representatives during the course of this inspection. An exit meeting was conducted on December 18, 1987 at the conclusion of this inspection to provide the findings of this inspection to the licensee management (see paragraph 1.0 for attendees).

At no time during this inspection was written material provided to the licensee. The licensee indicated that no proprietary information was involved within the scope of this inspectio .,

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Attachment 1 Documents Reviewed 1. Desig'n/ Drawings .

203-001, Unit Trip Logic Diagram, Revision 3 203-002, Electrical / Mechanical Draft Cooling Tower Digital Logic, Revision 2 208-203, Electrical Elementary Diagram 4160V switchgear, Revision 8 208-492, Powdex Vessel outlet valve, Revision 3 208-573, Electrical Elementary Diagram 480V Motor Control Center,

~ Revision 4 209-615, Reactor Building Isolation and Cooling Engineered Safeguard Panel Indication, Revision 5 209-736, Electrical Elementary Diagram DC and Miscellaneous Equipment-Revision 2 302-272, Piping and Flow Diagram-Backup Instrument Air, Revision 6 302-640, Piping and Flow Diagram-Decay Heat Removal System, Revision 43 302-720, Piping and Flow Diagram-Nitrogen and Hydrogen Supply System, Revision 20 307-132, Sheet A, Piping Valve list, Revision 11 307-170, Secondary System Cooling Closed Cycle, Revision 6 307-327, Page 1, Decay Heat Removal System, Revision 13 307-352, Makeup and Pu-11* cation System, Revision 10 307-372, Reactor Coolant System, Revision 7 308-535, Low Pressure Extraction Steam Pressure Transmitter, Revision 2 308-550, Control Turbine PC-647, and FSV-6, Revision 3 308-572, Instrument Air Pressure Diagram, Kevision 4 308-324, Steam Generator and Steem Pressure Transmitter, Revision 9

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317-507, SH 1, Structural Support Design MX-NSH-375, Revision IA00 317-556, SH 1, Structural Support Design MK-C0H-332, Revision IA01 317-810, SH 1, Structural Support Design MK-MVH-325, Revision IA00 317-822, SH 1, Structural Support Design-Circulating Water Pump House, Revision 2. Licensing Document and Procedures Three Mile Island Unit 1 Final Safety Analysis Report (FSAR) Updated Version, Revision 6

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Three Mile Island Unit 1 Technical Specifications, Amendment 135.

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TMI-1, Operational Quality Assurance Plan Administrative Procedure 1001C, Drawing Distribution Control, Revision 5, July 18, 1985 Administrative Procedure 1001H, Drawing Utilization, Revision 3, January

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• ' 2 Attachment 1

~ Technical Functions Division Procedure,' EP-025 ~As-Built Drawings, Revision 2, April 7, 198 Technical Functions Division Procedure, EP-027, Plant Procedure Review,

-Revision 2, May:15, 198 Technical Functions Division Procedure, EMP-015, Field Questionaires, Change

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Notices, and Change Requests, Revision 3, May 15, 1987 Licensing Procedure, LP-004, Licensing Basis Document Change Control, Revision 1, January 30, 198 Licensing Procedure, LP-006, Plant Technical Specifications / Operating License-Change Control, Revision 0, December 20, 198 GPUN Audit Report S-TMI-86-15, Information Management, August 29 - October 8, 1986.