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/ytec4''o, UNITED STATES'j NUCLEAR REGULATORY COMMISSION7 ' '

3p(ti ( .n C REGION 1't , [ s 631 PARK AVENUE

% .' .% #,o KING OF PRUSSIA, PENNSYLVANI A 19406

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Docket Nos. 50-289 gp g 7 g350-320

Metropolitan Edison CompanyATTN: Mr. J. G. Herbein

Vice President - GenerationP. O. Box 542Reading, Pennsylvania 19603

Gentlemen:

Subject: Combined Inspection 50-289/79-16; 50-320/79-20

This refers to the inspection corducted by Mr. G. Napuda of this office onJuly 17-31, and August 1-2, 1979 at Three Mile Island Nuclear Power Station,Units 1 and 2, Middletown, Pennsylvania, at General Public Utilities ServiceCorporation offices at Parsippany, New Jersey, and your Reading, Pennsylvaniacorporate offices of activities authorized by NRC License Nos. DPR-50 andDPR-73 and to the discussions of our findings held by Mr. Napuda with Messrs.W. E. Potts and G. Troffer of your staff at the conclusion of the inspection,and to a subsequent telephone discussion between Mr. Napuda and Mr. G. Trofferand Mr. N. Kazanus on August 15, 1979.

Areas examined during this inspection are described in the Office of Inspectionand Enforcemen'. Inspection Report which is enclosed with this letter. Withinthese areas, the inspection consisted of selective examinations of proceduresand representative records, interviews with personnel, and observations by theinspector.

Based on the results of this inspection, it appears that certain of youractivities were not conducted in full compliance with NRC requirements, as setforth in the Notice of Violation, enclosed herewith as Appendix A. Theseitems of noncompliance have been categorized into the levels as described inour correspondence to you dated December 31, 1974. This notice is sent to youpursuant to the provisions of Section 2.201 of the NRC's " Rules of Practice,"Part 2, Title 10, Code of Federal Regulations. Section 2.201 requires you tosubmit to this office, within twenty (20) days of your receipt of this notice,a written statement or explanation in reply including: (1) corrective stepswhich have been taken by you and the results achieved; (2) corrective stepswhich will be taken to avoid further items of noncompliance; and (3) the datewhen fuli compliance will be achieved. In addition to the need for correctiveaction reg 1rding these specific items of noncompliance, we are concerned aboutthe implemeitation of your quality assurance program that permitted them tooccur. Consequently, in your reply, you should describe in particular, thoseactions taken or planned to improve the effectiveness of your quality assuranceprogram.

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RESDOWSE'TO IRFRACTIOR H:

Corrective Action Taken:

On August 28, 1979 a memo was issued to cognizant managers , identifyingall open findings in a detailed matrix, identifying priorities , andsoliciting prompt corrective action. On July 30, 1979, a reorganizationof major functional areas at TMI was announced. Hence, the responsibilityfor implementation of corrective action of the outstanding audit findingsis ,in many cases , being re-assigned. In addition, TMI Generation Group'sQA Department has established a full-time QA Auditing Staff at the Sitewhose responsibilities include programmatic auditing, close-out andfollow-up of corrective action for timeliness and effectiveness. Withrespect to current outstanding audit findings - the site audit staff villcoordinate the establishment of a schedule for milestone dates with theappropriate managers for resolution of all significant outstanding auditfindings. This schedule is expected to be complete by December 15, 1979

Corrective Action to Prevent Recurrence:

A Site QA Audit Staff has been established to better coordinate andmanage audit activities and provide management with increased awarenessof the adequacy and implementation of the QA Program. Specifically,the following actions are anticipated by the dates indicated:

(10/30/79) A) Revise the current auditing procedure to better defineresponsibilities, provide simplified audit reportingand better follow up of problem areas.

(10/30/79) 3) Revise the current scheduling practices / procedures to -

assure adequate and complete coverage of activitiesaffecting safety. Provide a managed approach to assureadequate follow up.

(10/30/79) C) Review the current corrective action procedure for QAAudits to provide better guidance so that correctiveactions address measures to preclude recurrence.

( 4/01/80) D) To establish a computerized audit status system to providebetter management visibility of problem areas and todetermine trends.

(.10/01/791 E) A conserted effort to establish priorities of audit findingsand to commit the appropriate level of management , via thepost audit conference, to provide corrective actions that ensurethe cc=mitment of sufficient resources.

In addition to the above actions, the Vice President-Nuclear Operations willissue a memo by October 15, 1979 to reinforce and amplify managementscommitment to 10 CFR 50 Appendix B, Criteria XVI for prompt corrective action.

Date Full Compliance vill be achieved:

Full compliance vill be achieved by April 1,1980. Interim implementationdates are as identified above.

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Infraction H (Units 1 and 2):

10 CFR 50, Appendix B, Criterion XVI, states that, " Measures shall beestablished to assure that conditions adverse to quality...are prtruptlyidentified and corrected..."

The Three Mile Island Nuclear Station Unit 2 FSAR*, Section 17.2.23states in part, that, "It is the responsibility of the cognizant manager...to review the audit report and to ensure that corrective action is acca plishedin a timely manner..."

Contrary to the above, as of August 2,1979, corrective action has notbeen performed in a timely manner subsequent to the conduct of the internalaudits listed below:

- 76-13, Requalification/ Training Program; performed August,1976

- 77-02, Design Control; performed January, 1977

- 77-19, Major Modifications; performed June,1977

- 77-21, Fire Protection; performed June,1977 (corrective action ccm-pleted July,1979)

78-05, Control of Purchased Material, Equignent and Services (Nuclear) ;-

performed February, 1978.

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Response to Deficiency G:

The respcnses to each of t'te three examples of the apparent failure to performspecific requirenents of unplementing procedures are as follows:

EXAMPLE I - The NRC's finding states in part "...the licensee did not havean approved surveil].ince procedure for warehouse storage areas nor was heperforming periodic, surveillances of said arew."

Response - Procedure GP 4014 defines the necessary steps to perform anysurveillance deemed necessary by the Supervisor-Quality Control. SurveillanceReport 78-13 was issued in June 1978 covering storage of nuclear safety relatedmaterial, and was conducted in accordanm with GP 4014. This surveillance metthe requirenent of performing a periodic surveillance as required in AP 1018.

i Action - In addition, to avoid future misunderstandings regarding the require-ment of periodic surveillances, a change to AP 1018 will be subnitted torequire a surveillance quarterly.

EXAMPIE II - The NPC's finding states that " Regularly scheduled inspections ofmaterials, compcnents, and equipment in storage shall be performed byGDUSC/QA... Results of these inspections shall be documented.

Response - Prior to the NPC's inspection, no Unit I Restart bbdificationmaterial, ccmponents and equipment had been stored in the warehouse; therefore,an inspection of the area was deemed unnecessary. Upon receipt of materialthat is stored in the warehouse, regularly scheduled inspections will beconducted.

EXAMPIE III - The NPC's finding states in part, " Surveillance of storage areaswhich contain nuclear safety related material shall be conducted mor_hty ...all inspections shall be documented...no @,wmted inspections oI these Unit II_

storage areas had been performed."

Pesponse - During the accellerated nodifications activity period, GPUSC assignedthree (3) qualified receipt inspectors to the Unit II warehouse for the purposeof ccrrpletely nonitoring receipt activities in acmrdance with the approvedplan. Daily observations of storage conditions were made by these inspectors.Only limited anounts of nuclear safety related materials were received duringthis period. Except for filters, these materials were prcrnptly released toinstallation as their need was great.

Corrective hbasures

On August 6, 1979, a surveillance was performed at Unit II warehouse andelectrical storage. Appropriate checklists were enployed. On August 21, 1979a followup surveillance was performed and appropriate checklists were enployed.These lists are on file at site. On Septenber 26, 1979 a surveillance wasperformed at Unit II warehouse employing appropriate checklists.

'Ihe storage control procedure QCP-M-002 (for Unit II nodifications) will berevised to require surveillance of storage areas on a quarterly basis or nerefrequently as directed by the site QC hhnager.

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Deficienc? G (Units 1 and 2) :

10 CFR 50, Appendix B, Criterion ZII, states in part that, " Measuresshall be est ahl khed to control the. . . storage. . .of material and equignent. . .in accordance with work and inspection instructions to prevent damage ordeterioration."

The Three Mile Island Nuclear Station Unit 2 FSAR*, Section 17.2.18,states in part that, "The perfonnance of activities. . .shall emply withANSI N45.2.2-1972."

ANSI N45.2.2-1972, Section 6.2, states that " periodic inspections shall,

be performed to assure that storage areas are being maintained..." i

Section 6.4.1 states that, " Inspections and examinations shall be performedand documented on a periodic basis to assure that the integrity of theitem...is being maintained."

Listed below are three examples of failure to perform specific requirenentsof implenenting procedures.

The Operation QA plan for Three Mile Island Nuclear Station, Section-

XIII, states that, " Supervisor-QC is responsible for... surveillanceof... storage...of material..." AP 1018, Section 13.3.5 states that"the QC Department shall conduct periodic surveillances...to assurecmpliance with established warehouse procedures." GP 4014, ChangeMeno 1, states that "surveillances shall be perfonned with an approvedchecklist."

Contrary to the above, as of August 1,1979, the licensee did nothave an approved surveillance procedure for warehouse storage areasnor was he performing periodic surveillances of said areas.

- The QA Plan for Restart Modifications to Lhit 1, Section 13.3,states that, " Regularly scheduled inspections of materials, cx2nponentsand equignent in storage shall be performed by GPUSC/QA... Resultsof these inspections shall be documented..."

Contrary to the above, as of August 1,1979, inspection pursuant tothis requirement had Int been performed.

- Procedure QCP-M-002, Storage Control (For Unit 2 bbdifications)states in part, that " Surveillance of storage areas which containnuclear related materials shall be conducted monthly... All inspec-tions shall be documented..."

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Contrary to the above, as of August 1,1979, no documented inspectionsof these Unit 2 storage areas had been performed.

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Pesponse to Deficiency F:

Corrective Steps Taken

The field purchasing procedure issued by the Iogistics Manager to provideinstruction to the buyers for preparing and placing purchase orders wasreviewed for interface control and distribution requirments on August 10,1979.

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A revision to that procedure (revision 2), incorporating resolution tothe QA cm ments generated was issued September 26, 1979. Final approvalof this procedure is anticipated by October 5, 1979.

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Corrective Steps Taken to Preclude Recurrence

The Ingistics Manager has been notified that all interface procedureswhich affect quality should be reviewed and concurred with by the inter-facing departments prior to issuance.

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It should be noted that this procedure is not intended to be a controllingprocedure on quality, but merely instructions and a listing of constraintsto buyers on what they can and cannot do. It also provides distribution

,lists for purchase orders.

All quality and engineering requirments for products to be purchased areincluded on the controlled purchase requisition which is not controlledby this procedure.

No additional actions are planned on this item.

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0 / 19 79Metropolitan Edison Company 2

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Item nur.cer D, shown in the Notice of Violation enclosed with this letter, is )a recurrent or uncorrected item. In your response please give this matter 1

your particular attention.

In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2,Title 10, Code of Federal Regulations, a copy of this letter and the enclosureswill be placed in the NRC's Public Document Room. If this report contains anyinformation that you (or your contractor) believe to be proprietary, it is lnecessary that you make a written application within 20 days to this office to |withhold such information from public disclosure. Any such application must !

be accompanied by an affidavit executed by the owner of the information, whichidentifies the document or part sought to be withheld, and which contains astatement of reasons which addresses with specificity the items which will beconsidered by the Commission as listed in subparagraph (b)(4) of Section

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2.790. The information sought to be withheld shall be incorporated as far as jpossible into a separate part of the affidavit. If we do not hear from you in 1

this regard within the specified period, the report will be placed in the ,

Public Document Room. |

Should you have any questions concerning this inspection, we will be pleasedto discuss them with you.

Sincerely,

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Bo ce H. GrierDirector

Enclosures:1. Appendix A, Notice of Violation2. Office of Inspection and Enforcement Inspection

Report Numbers 50-289/79-16; 50-320/79-20

cc w/encls:E. G. Wallace, Licensing ManagerJ. 1 Barton, Project Manager.R. C. Arnold, Vice President - GenerationL. L. Lawyer, Manager - Generation OperationsG. P. Miller, Manager - Generating Station ~ NuclearJ. L. Seelinger, Unit 1 SuperintendentJ. B. Logan, Unit 2 SuperintendentW. E. Potts, Unit 1 Superintendent - Technical SupportG. A. Kunder, Unit 2 Superictendent - Technical SupportI. R. Finfrock, Jr.Mr. R. ConradG. F. Trowbridge, EsquireJ. Lieberman, EsquireMiss Mary V. Southard, Chairman, Citizens for a Safe Environment (Without Report)Chief, Resident Office TMINS

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