IR 05000289/1972014
| ML19206B037 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/12/1972 |
| From: | Heishman R, Howard E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19206B026 | List: |
| References | |
| 50-289-72-14, 50-320-72-05, 50-320-72-5, NUDOCS 7904210732 | |
| Download: ML19206B037 (33) | |
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3ERGY CCS!ISSION
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CPPR-40
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License No. CPPR-66
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Priority Unit 1-B Category _ Uni t 2-A h :- -
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SECTION I Enforec=cnt Action A.
The 2T inspection perfor=ed on the borated water storage tank was accomplished without use of an RT technique procedure as requi ed by the PDM QA Manual.
(Section II, paragraph 4)
B.
Material receiving inspection report indicated no protection used between carbon steel holddowns and stainless steel plate.
No cor-rective action was docu=ented.
(Section II, paragraph 5)
C.
PDM cleaning procedure No. CP-1 allows the use of acetone which is contrary to site procedure No. MFC-3.
(Section II, paragra,h 7)
D.
Evidence of approval of the cleaning procedure and use during the inspection was not available on site at the start of the inspec-tion. However, this procedure had been approved and the documen-
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tation indicating approval was later presented by PDM.
(Section II, paragraph 8)
E.
The e.cternal surf ace of the barated water storage tank contained weld splatter and are strikes, which was contrary to PDM cleaning procedure.
(Section II, paragraph 9)
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F.
The specifications for construction of the borated water storage tank is /SME Section VIII, partially.
The FSAR indicates the tank is built P.o AWWA D-100.
(Section II, paragraph 10)
G.
Resolution of corrective actions required by site audits were not co=pleted "within a reasonable period of tt=a" as required by the Metropolitan Edison QA plan.
(Section II, paragraph 11) and (Section IV, paragraph 9)
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H.
UE&C procedure Qd-8 " Pipe welding control" does not include all the quality requirements of the Gilbert Associates Specification S'ction IV, paragraph 2)
No. 5550, paragraph 2.7.3.
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I.
Detailed fabrication records and material certificates covering reactor coolant pipe spools supplied by B&W are not on site and have been missing since this material was received in July of 1970.
(Section IV, paragraph 3)
J.. B&W f abrication records for the pressurizer surge piping contain
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weld material certificates, which indicate the =aterial does not meet either the ASTM chemical requirements or the ferrite require-
=ents of the B&W specification CS-3-37.
(Section IV, paragraph 4)
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for viewing radiographic film is incapable of re-Cona: equipment a violation of ASSI K.
vealing rejectable defects in "co:posite" film,(Section IV, paragraph 5)
3-37.1, Appendix B, paragraph 1-110.6.
to the side of 18" pipe spool No. DC-57 shows L.
Welding of a sockolet the toe of the weld deep undercuts to the base piping caterial at the dimensional requireuents of 331.7.
(Sec-which does no
=eet tion IV, paragraph 6)
CF-1 show Shop welds in the Grinnell stainless steel pipe spool Mo.
weave welds in excess of the B&W Specification UESC Procedure QC-8 M.
li=itations.
(Section IV, paragraph 7)
Mill test reports for E308 electrodes from Grinnell show they do M.
the Ferrite requirc ents of the B&W or UELC specifications.
not meet (Section IV, paragraph 8)
Lack of installation procedures or instructions for safety related
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valves.
(Section V, paragraph 4)
Deficiency reports not being issued for nonconfor=ing conditions.
P.
(Section V, paragraph 5) and (Section III, Paragraph 9)
Omr inspectors did not find drawings, nor instructions relative to Q.
=ethod of closure of the opening in the Engineered Safeguards actu-ating benchboards.
(Section III, paragraph 16)
The two battery rooms appear to share a co==on ventilation systen.
R.
(Section III, paragraph 17)
(Section QA check lists are not used by inspector while inspecting.
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III, paragraph 2)
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Records relative to audit of measuring and test equipment were rot T.
(Section III, paragraph 3)
in accordance with requirements.
Engineered safeguards motor shaf ts were not rotated as required.
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(Section III, paragraph 4)
Engineered safeguards motors were not being ecggered as required.
V.
(Section III, paragraph 5)
W.
Ihe E?I pump motor heaters were not energized as required.
(Section III,
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paragraph 6)
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Instruments, panels and contro1 boards were not inspected during I.
storage as required.
(Section III, paragraph 7)
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Notification of the field supervisor, quality control by the crafts prior to installation of safety related equipment is not being ac-co=plished.
(Section III, paragraph 8)
Z.
Engineered saf eguards actuating cabinets located in the control room do not have separation as required.
(Section III, paragraph 10)
AA.
Reactor pressure sensing actuators (RK-13) were not receipt inspec-ted.
(Section III, paragraph 11)
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BB.
Instructions, procedures and drawings were not prepared for instal-lation of instrumentatior calibration and testing of instru=enta-tien, and vertical cabletray covers.
(Section,III, paragraphs 12, 13, and 14)
CC.
Instructions, procedures and drawings do not require that cabletray loading be verified.
(Section III, paragraph 15)
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Licensee Action on Previously Identified Enforcement Matters None
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Unresolved Items A.
An 18" Atwood-Morrill check valve in the core flooding system con-tains a sharp =achined notch at the base of the flange on both weld ends.
(Section IV, paragraph 10)
3.
Grinnell mill certificate and test report for welding electrode E-7018, No. 65CX290, reports Charpy test values of 240 pounds when tested at minus 20*F.
(Section IV, paragraph 11)
C.
The UE&C field welds for nuclear piping in general do not meet the visual and/or merge smoothly requirements of ANSI B31.7.
(Section IV, paragraph 13)
D.
Weld No. RCP-2 attaching the reactor coolant piping to the lower
nozzle of the steam generator has been severely overground leaving.
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flat thin spots in local areas.
(Section IV, paragraph 12)
E.
Reactor coolant pu=p supports.
(Section V, paragraph 6)
Safety Items
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A.
Lack of closure between engineered saf eguards actuating benchboards and cable spreading room.
(Section III, paragraph 16)
B.
Lack of redundancy in battery room co==on ventilation system.
(Sec-I tion III, paragraph 17)
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-4-Status of Previously Identified Unresolved Itc=s Not inspected.
Unusual Occurret.ces None Design Changes None Persens Contacted CPU / Met Ed Mr. R. Heward, Proj ect Manager Mr. M. Strceberg, Field QA Supervisor Mr. C. Kupp, QA Engineer Mr. B. Avers, QA Manager
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MPR Associates Mr. J. Co r=an Mr. Larry Lunstros, Site QA Specialist, (Piping)
Babcock and Wilcox Mr. Jack Uhl, Site Erection Supervisor Gilbert Associates, Inc.
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Mr. R. Fleming, QA Site Manager United Engineers and Constructors
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Mr. R. Moyer, Site QC Supervisor
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Mr. Harold Fin'.-, Senior ?C Site Engineer, (Welding)
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Mr. R. Thomas, Site QC Engineer
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l't. Dave Wells, QC Engineer (Records Coordinator)
Mr. William Carney, Site QC Engineer, (Piping)
Mr. D. C. La=bert, UELC QC Engineer,. Mechanical Mr. E. K. Ferguson Mr. F. L. Reed Mr. R. LeFever, QA' Coordinator Mr. Mike Stiger, NLr Technician
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-5-Cona: Inspection Acency Mr. R. Williamson, East Coast Regional Manager Mr. John Luksic, Three Mile Island Site Supervisor Royal Globe Insurance Company (Code Inspector)
Mr. L. Cuttschall, Site Resident Representative Manacenent Interview A management interview war held at the site on August 17, 1972, and on October 5, 1972 a telephone conversation was held between J. G. Miller
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and J. P. O'Reilly during which the generic issues were discussed. The interview:
f ollowing subj ects were discussed during the site canage=ent A.
The inepector stated that the RT performed on the borated water storage tank was stated by PDM to have been accomplished in accor-
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dance with RT-1 specification in the QA Manual without a technical procedure sheet cs required by the manual. The licensee stated this item would be reviewed.
(Section II, paragraph 4)
B.
The inspector stated that a material receiving inspection report
. dated May 18, 1972, by ELW indicates that no protection was used between carbon steel hold downs and stainless steel plate during shipment. No corrective action reports were found in PDM, B&W, or UE&C files.
This is contrary to the material specification MS-1.3.
The licensee stated this item would be reviewed.
(Sec-tion II, paragraph 5)
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C.
Welder qualification records for welder mark "D" (Macmillan) were not available upon request of the inspector, but were later pre-sented before the end of the inspection. The licen'see offered no co= ment.
(Section II, paragraph 6)
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D.
PDM cleaning procedure C2-1 allows the use of acetone; however, site procedure MCP-3, revision 4, statas that acetone is prohibited from use en the site. The licensee stated that this item would be invez-tigated.
(Section II, paragraph 7)
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E.
Cleaning procedure CP-1 was in use and no evidence was available on site of approval of this procedure by the A-E as required by the spe-cification. The approval letter was later presented upon obtaining
. the letter from the CAI home office.
(Section II, paragraph 8)
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The barated water storage tank was found to contain weld splatter and slag on the exterior surfaces.
The cleaning procedure does not allow weld splatter or slag to be on any surface of the borated water storage tank, prior to the start of cleaning.
The licensee stated this item would be corrected.
(Section II, paragraph 9)
G.
The FSAR states that the barated water storage tank will be built in accordance with AWWA D-100 Code; however, the procurement spe-cification indicates actual construction to be done in accordance with ASME,Section VIII, partially.
The licensee stated that this had been a chaage in the contract to increase the requirements and that this ite: would be investigated and the FSAR changed as re-quired.
(Section II, paragraph 10)
H.
The inspector stated that corrective action on items identified as deficient during audit of site construction activities had not been corrected as required by the Met Ed QA plan, Appendix B, Revision 3.
The licensee stated that the corrective action report would be
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reviewed and would be expedited.
(Section II, paragraph 11)
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The inspector stated that the Unit 2 Construction Deficiency Re-port No. 088, indicated that the stop work authority of the qual-ity control organization was not effective. The licensee stated that the authority had been given to the quality organization; how-ever, complete i=ple=entation was not always effective, but would be corrected.
(Section II, paragraph 12)
J.
The failure of the UEC procedure QC-8 " Welding Control" to meet the requirements of the Gilbert Specification No. 5550, paragraph 2.7.3.
(Section IV, paragraph 2)
There was no rebuttal or co= ment by the attende.es on this item.
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K.
B&W supplied reactor coolant piping spools on site and installed in IInit 1 without documentation covering =aterial certificates and fabrication records.
(Section IV, paragraph _3)
There was no co==ent by the attendees on this item.
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L.
The B&W fabrication records and material certificates for pressuri-zer surge piping spools contain certificates for electrode material which does not meet ASTM chemical requirements and the 5% mini =un f errite requirements of the B&W specification.
(Section IV, para-
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-7-There were co ec=ments or rebuttal by the attendees on this item.
The Conam equipment for reviewing radiographs do not meet the re-M.
(Sec-quirements of ANSI B31.7, Appendix B, paragraph 1-110.6.
tion IV, paragraph 5)
s There were no ce==ents by the attendees on this ite=.
Veld No. RC-55A0 in the pressurizer surge line had not been ground N.
to an acceptable surf ace finish for final radiography in violation of ANSI B31.7, Appendix B, paragraph 1-120.1.
(Section IV, para-graph 5)
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There was no rebuttal or co==ent by the attendees on this item.
A sockolet veld to the 18" pipe spool No. DC-57 showed deep under-O.
cuts of approxt:ately 3/32 of an inch.
It does not appear to meet the fillet veld dimensions of B31.7 figure 2-727.4.
(Section IV, paragraph 6)
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There was no co==ent by the attendees on this item.
An 18" Walworth check valve in the. core flooding system contains a P.
sharp =achine notch at the base of the flange on both weld prepara-tion ends.
(Section IV, paragraph 10)
There was no co==ent by the attendees on this item.
An 18" stainless steel pipe spool in the core flooding system No.
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CF-1 shows Grinnell shop welds with transweld weave of approxt=ately 1 1/4 to 1 1/2 inches wide in violation of the B&W and UE&C specifi-cations.
(Section IV, paragraph 7)
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There was no cocsent or rebuttal by the attendees on this item.
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The Grinnell Mill Test report for E-308 electrodes, Heat No. 9 H63B R.
shows f errite content less than the 5% minimum requirements of the B&W' and the Gilbert Associates Specifications. -(Section IV, para-
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graph 8)
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There were no comments or rebuttals fro = the attendees on this item.
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Failure of :he site QA orgar.ization to resolve and provide correc-tive action for deficiency reports dated 1969 and 1970 covering in-correct stainless steel sheet stock for use in the fuel pool stor-age well.
(Section IV, paragraph 9)
There were no co==ents by the attendees on this iten.
T.
Mill certificates and test reports for welding electrode, Heat No.
650X290 report Charpy values of 240 pounds at - 20*F.
This was probably a typographical error but it never was identified until audited by the inspector.
(Section IV, paragraph 11)
It was stated that the UE&C QC organization had now prepared a de-ficiency report covering this itc=.
The UE&C field welds for nuclear piping, in general, do not sect the visual and merge s cothly require =ents of ANSI B31.7, paragraph 1-727.4.2 nor the surface finish requirements for reliable non-de-
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structive testing.
There were no cc==ents or statements of rebuttal concerning this ite during the meeting.
U.
Field Weld No. RCP-2 appears to have been severely overground cre-ating flat spots. This is a violation of B&W Specification No.
CS-37-2 and the UE&C Specification MC?-6A.
(Section IV, paragraph 12)
It was stated that a deficiency report was "in process" covering this ite: and that continued work on this joint had been stopped until a' resolution was received.
V.
Procedures for the installation of the decay heat removal outlet valves and core flooding check valves were not available to direct
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the activities relative to quality for these ce=ponents, this is contrary to the requirements of Appendix B to 10 CFR 50, Criterion V, " Instructions, Procedures, and Drawings."
(Section V, para-graph 4)
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The licensee stated this ite: would be reviewed for appropriate action.
W.
The inspector was informed that the reactor coolant pumps wili
,t be supported by any means other than the piping from the stea gen-erator and to the reactor pressure. vessel plus restrait. attached to the
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pu=p and motor.
(Section V, pardgraph 6)
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X.
The UE&C 'Jeld History Reports are confusing.
They define all NDT require =ent on one line and permit "Conam", acceptance signoff, on the same line. This is not a true acceptance of all NDT, since Cona: is not authorized by the UELC procedure to accept radiography.
The inspector stated that the record, should reflect a true accep-tance and should not depend on supporting documents to determine the cc=ponent quality.
This is not a violation, but the report
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fors should be revised to present a cceplete and accurate quality his to ry.
The licensee's response to the above ites, was that they will be re-viewed for appropriate action.
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Y.
The incpector stated there are no instructions, procedures, or draw-ings delineating the quality aspects of the installation of the in-dividual sensors or instruments used in the detection of system ab-normalities.
(Section III, paragraph 12)
The licensee concurred with this finding.
Z.
The inspector stated that there were no instructions, procedures, or drawings which describe the testing and/or calibration requirements for the sensors or instruments used in the detection of system abnor-malities.
(Section IV, paragraph 13)
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The licensee concurred with this finding.
AA.
The inspector stated that there were no instructions, procedures or drawings, relative to paragraph 8.2.2.ll(d) of the FSAR, which re-quires that vertical trays have calid covers to six feet above their
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floor penetration.
(Section III, paragraph 14)
The GAI representative stated that this was, in fact, included on drawings; however, the license.e supported the inspector's findings, str-ing that general notes on drawings and details on drawings had be; eviewed and no requirement for solid covers of vertical trays,
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as c cribed in the FSAR, could be identified.
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BB.
The inspector stated that the quality control inspectors were not provided with checklists at the ti=e that the inspection was being perfor=ed, but rather that the dates on the checklists do not agree with the dates with the supplied by the craf t performing the func-tion.
(Section III, paragraph 2)
The licensee concurred with this finding.
CC.
The inspector stated that the quarterly field audits of =casuring and test equipment to assure that they were properly controlled, calibrated and adjusted had not been perforced in accordance with
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the applicable procedure, QC-13.
It was recognized that this pro-cedure was amended on July 6,1972, changing this requirement and re-assigning responsibility; however, only three audits could be identified as having been perf or=ed prior to the July 6,1972 date.
(Section III, paragraph 3)
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The licensee concurred with this finding.
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DD.
Thz inspector stated that approxi=ately four =onths had lapsed since the last rotation of the motor shaf ts, which was contrary to the UELC procedure ECP-6, which requires conthly rotation of the engin-eered safeguards cotor' shafts.
(Section III, parcgraph 4)
The licensee concurred with~this finding.
EE.
The ir;pector stated that approximately four =onths had lapsed since the last = egger of the engineered safeguards =otors, which was con-trary to UE&C Procedure ECP-6 which required that engineered safe-guards motors be =eggered monthly.
(Section III, paragraph 5)
The licensee concurred with this finding.
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FF.
The inspector stated that the high pressure injection pu=ps designa-ted MUP-1A, 1B, and 1C, which, vere selected for review, did not ap-pear on the heater checklist and the prescribed red indicating lamp had been re=oved from MUP-1A and 1B, which is contrary to UE&C pro-
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cedure ECP-6, which requires that space heaters be energized or sup-plementary heat provided within two working days af ter placement in storage and that docu=entation be provided. The procedure also r2-quires that a red indicating la=p be installed to show the circuit is energized.
(Section III, paragraph 6)
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The licensee concurred with this finding.
CG.
The inspector stated there is no documentary evidence that required surveillance of instru=ents, panels, control boards and related i
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ecuipment to assure that controlled conditions are maintained, had been perfo;=ed.
(Section Ill, paragraph 7)
The licensee concurred with this finding.
HH.
The inspector stated that there is no evidence that the field super-visor, quality control, is notified prior to the installation of engineered safe 5uards equipment except for safeguards cable instal-lation, nor was their evidence that QC had witnessed installation of other equip =ent, which is contrary to UE&C Procedures ECP-6 and ECP-10, which both require that the field superviser, quality con-trol, be notified prior to the installation of engineered saf eguards equipment.
(Section III, paragraph 8)
The licensee stated that he felt that this was being done; however, there was no documentation indicating that notification had been ac-co=plished prior to the installation, except for safeguards cable installation and several cases for electrical equipment installation.
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He further stated that, in many cases, this was handled infor= ally.
II.
The inspector stated that deficiency reports required by QC-17 had not been prepared for each instance of violation of the separations criteria described in UE&C Procedure ECP-8.
(Section III, paragraph 9, and Section V, Paragraph 5)
The licensee concurred with this finding.
JJ.
The inspector stated that the separations criteria described in the FSAR, Paragraph 8.2.2.12(c) had not been met in the engineered safe-guards actuating cabinets located in the control roo=.
The inspec-tor also stated that there was a lack of barriers and that nu=crous rolls of cable, which had been terminated at both ends, was suspen-ded under the cabinets and that there was no docu=entation indicat-
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ing that this practice was unacceptable.
(Section III, paragraph 10)
The licensee concurred with this finding.
KK.
The inspector stated that the reactor pressure sensing actuators,
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identified as RK-18 were not receipt inspected and that the per-maaent file for these devices indicated that they had not been re-ceived, elthough further investigation revealed that they were re-ceived in Dece=ber 1971.
UE&C Procedure QC-2 requires that all items identified as being associated with reactor safety shall be inspec-
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ted on receipt for conformance with the applicable specification re-
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quir ements.
(Section III, paragraph 11)
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The licensee stated that this was an unusual circumstance in that the components were shipped installed in B&W furnished equipment.
I which is not subject to their QC-2 procedure. The ensee stated
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inspection of the inspector's findings relative to the receipt that these co=ponents and violation of their procedures was correct.
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The licensee concurred with this finding.
LL.
The inspector stated that there are no instructions, procedures, or drawings waich require the cable tray loading which is specified 8.2.2.2.1.13.4 of the FSAR be la 'JE&C procedure ECP-3 and paragraph verified.
(Section III, paragraph 15)
The licensee concurred with this finding.
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the Engineered Safeguards actuating The inspector stated that benchboards, Channels A, B, C, and D are open to the cable spread-IM.
ing room and that no drawings or specifications relative to clo-(Section sure of this opening could be found.
this space would be
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The licensee's A-E representative stated that closed, however, the licensee was unaware of any plans to eff ect closure.
the battery rooms appear to share a com-The inspector stated that NN.
non ventilation systen, separated by da=pers, which do not appear to have the redundancy afforded other circuits which are vital to reactor safety.
(Section III, paragraph 17)
this had been previously reviewed and found The licensee stated that to be adequate by licensing.
The inspector stated the use of da=pers for the coe=en ventilation system had been reviewed, not the adequacy of the danpers.
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SECTION II
Prepared by:
R. F. Heishnan Additional Items Inspected. Not Identified in Section I. Where No Deficiencies or Unresolved Items Were Found 1.
General This portion of the report is directed to the results of the inspec-tion relating co the Borated Water Storage Tank, site sodits by var-
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ious organizations, and Construction Deficiency Reports for Unit 1 and 2.
2.
Borated Water Storage Tank
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i Procedures, specifications and records were inspected in the follow-ing areas to verify conf ormance to construction requirements:
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c.
Qualification of NDT technicians b.
Identification of Weld location, welder, weld procedures, NDT technician and technique, NDT results and evaluation of weld quality.
c.
Welding nr.terial issue control and disposition of unused mater-ial, d.
Mr.terial ce= position and physical characteristics.
3.
Site Audit Reports Audit reports of GPU, UE&C, GAI and E&W were inspected for Unit 1
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for the period 1970 - to June 1972.
Details of Subjects Discussed in Section I 4.
RT Inspection Procedure
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Paragraph 2.4, B&W Specification 1132/0369, states in part, "The vendor shall have written procedures for control of inspection pro-grams. These procedures shall cover such items as, all nondestruc-
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tive inspections.
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The PDM QA Manual, Paragraph ll.14;4,'"RT-1 Specification, 1-14-70",
sta?.es in part, "RT technique procedure will be used with this spe-cification."
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Contrary to the above, the inspector found that no RT technique procedure was used by PDM during the radiography conduc ed on the borated water storage tank.
The inspector was informed by PDM that on Section Vill welding that was acce=plished, the PDM QA Manual referring to the RT technique procedure was not required by co=pany policy.
5.
Material Receiving Recorts MS-1.3 states in part, " Carbon The B&W Material Specification No.
steel tie-downs shall not be used f or stainless steel material."
dated 5/18/72, was reviewed by the inspec-A B&W receiving report, tor which indicated that no protection was used between carbon steel
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hold-down clips and stainless steel plate for the borated water storage tank received on 5/9/72.
The inspector could find no cor-rective action reports or other documentation to indicate that cor-rective action had been taken to resolve this matter in the B&W, PDM, UE&C or GPU records on site.
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6.
Welder Oualification Records Welding Procedure Specification No. WPS-48 for borated water stor-age tank (SS) under PDM Steel Company Contract No. 10139, states in paragraph 5.1 that veld procedure qualifications and welder
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edition qualifications are required in accordance with the latest of ASME Code,Section IX.
The inspector found, while reviewing the welder qualifications and welding electrode issue forms that welder mark "D" (MacMillan) was listed as receiving stainless stael elec-trodes; however, no qualification record was available for this welder. During the last day of the inspection, the PDM QC inspector presented a welder qualification form f or the above individual.
No
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explanation could be found for the delay in presentation of the qual-
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ification record.
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7.
Cleanine Materials Site procedure No. MCP-3, Revision 4, Paragraph 3.60, states in part,
" Acetone is prohibited for use."
PDM Cleaning Procedure No. cpl
" Visible oil and grease spots should be removed from
-
states in part, plates or nozzles by hand-wiping with acetone. prior to welding the plate or nozzle into the tank."
The inspector was informed by PDM quality control personnel that acetone was used during the fabrica-tion and cleaning in accordance with the cleaning procedure.
.
Approval of. Procedure Used for Testine and Cleaning of Borated Water
_
8.
Storace Tank Paragraph 2.3, " Control of Special Processes", B&W Specification No.
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1132/0369, states in part, "The vendor shall have written procedures s
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and instructions for control of all special processes used for the items such as
. cleaning processes
." Metropolitan Edison
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specification Sheet No. 620-0005-36-A-o, dated 8/28/70, states in part, " Procedures for control of special processes such as welding NDT.
. cleaning..
.shall be approved by the engineer prior to
.
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use."
The inspector observed the cleaning of the borated water storcge tank in progress and records indicating testing had been accceplished; however, no approved procedures for these operations were available on the site at the tt e of this inspection.
The in-
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spector was provided at the exit interview with an approved copy of
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the procedure dated 7/7/71 by Gilbert Associates, Inc., the Engineer.
9.
Cleaning Procedure PDM Cleaning Procedure CP-1, Revision 1, dated 6/25/71, states in paragraph 2.1, "It is understood that prior to cc=mencing with the
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cleaning of the tank, all fabrication, welding, inspecting, and testing has been completed and approved by the authorized persons."
In paragraph 4.2, which states: "All weld splatter and/or. lag should be rc=oved f rem all tank surf aces per veld procedure specification
.WPS-48."
Contrary to the above, the inspector observed the external surfaces of the borated water storage tank to contain veld splatter and are strikes which was contrary to the above procedure.
In addition, the inspector was informed by the PDM quality control inspector that the final inspection and hydrostatic testing had been completed on this item prior to the start of the final cleaning.
10.
Code Requirements
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The Final Saf ety Analysis Report, Page 6-24, Table 6.2, "Su==ary of Requiremente for Borated Water Storage Tank", states in part, "In-spection requirements for welds, the acceptance standard is AURA-D-100.
The additional requirements and all girth and seam welds are full penetration velds."
The welding procedure specification No. WPS-48
-
for borated water storage tank PDM Steel Co=pany Contract 10139, Re-vision C, dated 10/12/71, in paragraph 6.1, states that " Weld pro-
.cedure and welder qualifications are required in accordance with the latest edition of ASME Code,Section IX," and further states, "ASME Section VIII will be used for acceptance standards on NDT."
In ad-
' dition, the specification states that NDT require =ents will be 20%
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radiography' and the require =ents listed in the FSAR and the procure-
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ment documents do not agree.
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11.
Corrective _ Actions The Metropt.i n Edison QA Plan for Three Mile Unit 1.in Appendix B, Revision 3, Paragraph VI.A, states in part, "The audit team leader should check to make sure that such response is received within a reasonable period of tice (one scnth)."
Contrary to the above, the inspector found that the following audit
_
reports which recuired corrective action had the status as indicated below:
Audit No.
Date of Audit
_
Outstandine Items
~
72-8 June 8-9, 1972 Answer had been received and was currently being evaluated by GPU.
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72-5 April 12, 1972 Four findings outstanding.
72-4 March 7-8, 1972 Answer being evaluated by GPU 72-3 February 15, 1972 No answer 72-2 January 26, 1972 Answer being evaluated 72-1 Dece=ber 28-29/71 23 findings.
Two outstanding The above information indicates that corrective actions are not being completed in accordance with the requirements of the Three Mile Island Quality Assurance Plan.
12.
_ Quality Control Stoo-Work Authority
_
The inspector reviewed Unit 2 Deficiency Report No.
the reactor containment wall concrete pour.
088, relative to The deficiency report indicated that the QC inspector identified that the construction per-
_
sonnel were noe following the procedure due to the concrete pump be-coming clogged.
ii.e inspector requested that til the procedure cou13 be followed; however, the work be stopped un-the work continued and an engineering deviation request was submitted by the construction forces which was later approvm3 by the engineer.
tion specified on the deficiency report The corrective ac-
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all construction supervisors would be held to stress the importanceindica
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of following~ procedures and that work being done which was not in ac-
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cordance with approved procedures must be stopped at once.
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SECTION III Prepared by:
E. M. Howard Additional Subjects Inspected Not Identified In Section I. b'herc No lieficiencies cr Unresolved Itc=s k'ere Ycund 1.
Cencral This inspection was directeu at the i=ple=entation of the Quality Progra= which has been previcusty approved and found to be satis-
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f actory.
Considerable difficulty with the i=ple=entatien of the progra= has been noted previously, particularly in the area of concrete place =ent.
Details of Subj ects Dise'. sed in Section I 2.
C.ble Installation UE&C Procedure ECP-3, Addendu A, states, "The quality control in-spector will co=plete the attached check list as applicable while inspecting the installation of the equip =ent."
A detailed inspec-tion of the dates on the check list against the dates when the cable
,
was actually pulled revealed a several days lapse between the ti=e that the check list was filled out and the date that the cable was actually pulled. Discussions with the QC personnel revealed that the forms were not supplied to the inspector at the time that he was witnessing a pull. The electrical QC supervisor for UESC stated that he expected his inspector to be knowledgable as to what the in-spection~ points were.
It was also stated that there had been a con-siderable number of pulls =ade which were not witnessed at the tbne
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of the actual pulling of the cable. The UE&C QC supervisor also
_
stated that the individual inspecters recorded the infor=ation in a notebook which they transcribed at some later date.
3.
Measurine and Test Ecuic=ent Calibration
_
UE&C Procedure QC- ', which was changed on July 6,1972, required prior to that date, that a quarterly field audit be perfor=ed to determine that measuring and test equipment throughout the site were properly controlled, calibrated, and adjusted. A review of the records indicated that only three such audits had been made -
the first on August 5,1970 and the last on November 18, 1971.
_
The UE&C site quality assurance supervisor concurred that the audits had not been made.
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Rotation of Engineered Safeguards Motor Shafts 4.
the engineered UELC Procedure ECP-5, Paragraph 5.1.4 requires thatA review of the records safeguards motor shaf ts be rotated =onthly. rotation of the =otor shaf ts was perf indicate that the last The UELC quality control supervisor stated on February 28, 1972.
how-these tests had actually been perfor=ed since this date; rotation of the cotor shafts was performed approx-that ever, the last i=ately four conths prior to the date of this inspection.
Mecgerine of the Engineered Saf eguards Motors 5.
__
all engineered UE&C Procedure ECP-6, paragraph 5.1.4 requires thatA review of the records in-safeguards motors be =eggered monthly.approxicately four conths has
,
dicates that megger of the motors.
6.
Heating for Motors in Storage _
UE&C Procedure ECP-6, paragraph 5.1.3 requires that space heaters be energized or supplementary heat provided within two working days Docu=entation is to be after the placement of motors in storage.UE&C Procedure ECP-6 also requires,
a provided on Form ECP-6-1.
is en-red indicating la=p shall be installed to show the circuit ergized.
The high pressure injection pu=ps designated MUP-1A,1B, and 1C did There was no documentation in-not appear on the heater check list.these pu=ps had been checked for sup dicating that Since these pumps were in place, an inspection was made to see if, in f act, heat was on the cotors and if the red indicating lamps were
_
Pumps MUP-1A and 1B did not have the red indicating la:ps installed as required by the procedures, precluding immediate and in place.
ready verification that heat was being supplied to the motor wind-ings.
Surveillance of Instruments, Panels, and Control Boards
_
7.
_
UE&C Procedure ECP-10, requires that a surveillance be performed and related equip =ent to on instruments, panels, control boards, assure that controlled storage conditions are maintained.
surveillance as re-
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No records could be produced indicating that quired per the procedure, had been perforced.
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8.
Installation of Encineered Safecuards Eauirment UE&C Procedures ECP-6 and ECP-10 both require that the field super-visor, quality control, be notified prior to the installation of en-gineered safeguards equipment.
A =echanis: had been established for notification of impending safe-guards cable installation.
There was no evidence that the field
.
supervisor, quality control, had or is being notified prior to the installation of other eng;ncered safeguards equipment, either orally or in writing.
.
9.
Identification of Nonconfor=ances UE&C Procedure QC-17, paragraph II B1, states in part, "Nonconform-
_
ance includes activities, materials and equipment whose condition does not ec= ply with the' applicable.
. specification." Deficien-
.
cy reports had not been prepared for each instance where the separa-
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tions criteria described in UESC Procedure ECP-8, paragraph 4.4.4 had not been net.
In some instances, field prepared sketches were submitted to the A-E, however, this method of identifying a defi-ciency is not procedurally covered nor is there assurance that each instance of a violation is ulti=ately corrected, since there is no procedural review of this type of documentation nor will there be evidence that an evaluation has been made.
10.
Separation of Redundant Circuits The FSAR, paragraph 8.2.2.12C states in part, "In a very few cases, the separation is sount 12 inches and in these cases a barrier is installed between the trays."
The engin2ered safeguards actuating cabinets, located in the control
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room, do not have the separation specified as the minimum for cable trays, nor barriers separating the channels.
There are numerous rolls of cable suspended under the cabinets,' which were ter=inated at both ends. The work on these cabinets was approaching comple-tion, however, there was no documentation indicating that these
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practices, both lack of separation and coiled rolls of cable, were found unacceptable. Attachments A, B and C are photographs show-ing the congestion underneath the safeguards actuating cabinets.
11.
Receipt Inspection
_
UE&C Procedure QC-2 requires that all items identified as being as-sociated with the reactor safety, including engineered safeguards equipment and co=ponents, be inspected on receipt for conformance
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with the applicable specification requirements.
The reactor pressure sensing actuators, identified as RK-18, were randemly selected for inspection.
The per=anent file for these devices indicated that they had not been received, although fur-ther investigation revealed that they were in f act received in De-cember 1971. There were no records indicating that these devices had been receipt inspected as required by UELC Procedure QC-2.
12.
Installation of Individual Sensors and/or Instruments Used In The Detection of Syste= Abnor:alities There are no instructions, procedures, or drawings which delineate
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the quality aspects of the installation of the individual sensors and/or instru=ents used in the detection of system abnormalities.
13.
Instrument Calibration There are no instructions, procedures, or, drawings which describe
_
the testing and/or calibration required for the sensors or instru-
=ents used in the detection of system abnornalities.
14.
Protection of Vertical Trays Paragraph 8.2.2.11D of the FSAR states in part, ".
all vertical
..
trays have solid covers to six f eet above their floor penetrations."
A review of the general notes on the drawings and. of several vertical tray drawings fail to show the application of solid covers on the vertical trays. There are no instruction or procedures which iden-tify this requirenent.
15.
Cable Tray Loadinc
_
UE&C Procedure ECP-3 and Paragraph 8.2.2.1.13.4 of the FSAR specify
_
that cable tray loading, the former in terms of physical fill and the latter in terms of cross sectional area. There are no instruc-tions, procedures or drawings which require that the cable tray load-ing be verified in the field.
_
16.
Enzineered Safeguards Actuating Benchboards, Channels, A, B, C, and D The bottom of the engineered safeguards actuating benchboards, chan-nels A, B, C, and D, are open to the cable spreading room which is located directly beneath the control room.
There were no drawings
_
which indicated that a barrier was to be placed between these two
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An eff ective fire barrier appears to be impossible due to rooms.
the congestion under these benchbocrds.
Failure to effect adequate closure of this base could result in the required evacuation of the control roo= if a fire occurred in the cable spec'ading roo=.
17.
Battery Roc The two battery roo=s share a co==cn ventilation system.
A fire in one battery root could conceivably transmit to the second battery room by the way of the ventilation system.
The A-E stated that the ventilation syste= f or one bcttery rec = could be isolated from the second battery room in the event of a fire.
There was no indication that a means of isolation between the two battery roc =s was treated as an engineered safeguards system.
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SECTION IV
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Prepared by:
J. H. Tillou Additional Subjects Insoected, Not Identified in Section I. Where No Deficiencies or Unresolved Items Were Found
_
1.
General The Three Mile Island 1 Plant is reported to be 85% co=plete.
The repairs to the defective containment ring girder for Unit No. 1 are now esticated for ce=pletion in February 1973.
.
Details of Subjects Discussed in Section I 2.
Weldine Defects Re=cval Verification During a review of the Gilbert Associates Specification No. 5550, in
~
paragraph 2.7.3, it states that def ect removal should be verified by either a liquid penetrant examination or by a reinspection in accor-dance with the same procedure which identified the defect.
During a comparisen of the requirements of UESC Procedure QC-8 " Pipe Welding Control", it was noted that this procedrue ccatains no requirement for defect re= oval verification. In pursuing this subj ect, the in-spector also found that the " weld history sheet", which is the con-trolling QC document for each weld in the plant piping, also has no provision for verification of removal of defects.
This failure of UE&C to reflect the Gilbert Associates Specification requirements on their veld history sheet and in their procedure for pipe welding control is a violation of Criterion IX, which states in part, " Mea-sures shall be established to assure that special processes, such as welding, are controlled and acco=plished in accordance with the applicable specification."
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3.
Inconclete Fabrication Records for B&W Reactor Coolant Pine Snools During a review of the fabrication records for a randomly selected reactor coolant piping pipe spool, No. A-33, it was found that the
_
only record on site was the MP-1 Data Report for Nuclear Piping, signed b'y the code inspector at Babcock and Wilcox.
It was fur-ther noted that when this section of pipe was received on site in January of 1970, the receiving records showed a deficiency "docu-mentation required" and that a deficiency report was written.
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There was, however, no evidence that this deficiency report had
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ever been resolved and there is, to date, still no documentation on
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site for this critical material.
This is a violatien of Criterion VII, Appendix B, 10 CFR 50.
4.
Weldine Electrodes Used on the Pressurizer Surge Piqdng Snools at Babcock and Wilcox During a review of the documentation records from Babcock and Wil-cox covering the fabrication, non-destructive testing, etc., of the pressuriaer surge piping spools, it was noted that Hear No. 65063 and 65065 f or 1/8 inch li=e coated electrodes did not =cet the chemical analysis require =ents for either chromium or molybdenum.
It was fur-ther noted that li=e coated electrode Heat No. 50311 did not meet the requirements for either chrome, nickel or molyodenum and the mill
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certificate had been marked " retest."
There was no retest record nor deficiency report to indicate this item had ever been identified or recognized by either the B&W or the site UE&C quality control
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group.
Another mill certificate was observed covering Heats No. 7/53809,
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53812, and 54583, which indicated the ferrite content was 1.5 to 2.5%.
This deficiency also was not identified nor had a deficien-cy report ever been written although B&W Specification No. CS-37-3, in paragraph 5.1.7, requires that stainless steel electrodes contain a 5% minimum of delta ferrite.
5.
Inadeauate Viewing for Radiograohic Film During a review of randomly selected radiographic film, representing welds in the reactor coolant and pressurizer surge line piping, it was found that the Conam inspection agency did not have on site, high-intensity film viewing equipment to meet the requirements of B31.7, paragraph B-1-110.6, which states that: "the equipment used to review films for radiographic interpretation shall provide a high intensity light source."
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It was obvious that the medical-type viewing equipment available on site was completely incapable of revealing ' rejectable defects, particularly, in composite fil=s (double films).
It was further noted, during the review of the radiographic film representing the
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pressurizer surge line weld No. RC-55AQ, that the veld area was characterized by alternating bands of light and dark areas, since the radiographer had failed to require the weld surface to be ground smooth prior to conducting his radiographic inspection. This is also a violation of Code B31.7 which in paragraph 1-727.4.2(d) states the finished surf ace of the weld shall be ground to be suitable for the
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proper interpretation of non-destructive examinations.
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6.
Fillet Welds in the Decay Heat Cooling System During an inspection of UE&C installed and welded piping, it was a sockolet which was welded to the side of an 18" pipe noted that No. DC-57, in the decay heat cooling system had fillet veld contours the di=ensienal requirements of 331.7, Figure which did not meet this weld had been everely overground 1-7 27. 4. 4 (a).
In addition, at the toe to a degree that the undercut had seriously reduced the piping wall thickness in local areas throughout the circumference that There was no evidence on the weld history sheet of the weld.
conditions had been identified prior to the inspec-
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these deficient tor's observations.
Core Flooding System Shio Welds With 1 1/4 to 1 1/2 inch Weave 7.
During a shop inspection the inspector observed an LIS" stainless steel pipe spool, No. CF-1 (core flooding system), which contains
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Grinnell shop welds with a transweld weave pattern f rom 1 1/4 to This is a violation or both B&W. Specification 1 1/2 inches long.
CS-37-3, and UE&C Welding Procedure No. QC-8, both of which state any transweld weaving shall have a maximum dimen-specifically that sion not to exceed 21/2 diameters of the electrode being used.
The inspector further observed that the transweld aeave pattern had
,
produced deep notches and an irregular surface across the weld with the end of the weave where it contacted the severe undercutting at piping base metal.
--- It was further apparent that these velds did not meet the " blend smoothly" and " surface smoothness" require-cents of B31.7, paragraph 1-7 27.42. 2 (d).
E-308 Electrodes (Grinnell) Violation of the B&W Specification No.
8.
CS-37-3
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During a review of the Grinnell Mill test reports covering the veld-
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ing electrodes on the pressurizer surge line pipe spools, it was noted that electrode E-308, Heat No. 9H63B chemical analysis indicated that less than 5% f errite was present.
Another mill certificate for stain-the ASTM chemical
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less steel electrodes Heat No. 50311 did not meet This mill test require ents for either chrome, nickel, or mol; bdenus.
report had clearly marked across the f ace " retest".
There were no this defi-retest records available nor was there any evidence that ciency had ever been identified either prior to or af ter the pipe UE&C QC records representatives admitted spools arrived on site.
they had not noted this particular item and that no deficiency
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that report had ever been written. -
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electrodes, Heat Nos. 53809, 53812, and 54583, were tested and r2-
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ported that the f errite content was 1.5 to 2.5% (specification re-quires minimum of 5%).
This also had never been identified by either
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-25-the Grinnell or the UELC receiving inspection and QC sections.
file it be-9.
During a review of the chronological deficiency report ca=e evident that there is no concentrated effort to dispose of open deficiency reports on a timely basis.
The inspector noted deficien-So. 56 dated May 1969, where the disposition had been made cy report in October 1970 but the work is not yet accc plished or signed off.
125 was written in October 1969, disposed of in Octo-Another DR So.the work is still not accomplished or signed off.
These ber 1970 but items are rather significant because they cover the use of the wrong stainless steel plate caterial f or the reactor and f uel handling pool,
_
which is a Class 1 structure.
Other delinquent DR's dating f rom June through December of 1970 were identified, together with seven items the work has written during 1971 where dispositions had been cade but In almost every case these deficiency not yet been acco:plished.
reports cover raterial, work =anship or other def ective and deficient activities in connection with Class 1 items, safeguard systems, safety related components, or Class 1 structures such as the containment
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ten-deficient mater-This failure to promptly identify and correct dons.
ial or def ective work =anship is a documented example of the serious in the Site QC System and their follow-up of this type of weakness discrepancy.
During a walk through the plant on observation of installation prac-t 10.
tices it sas noted that at elevation 287 there was an 18" Walworth check valve in the core flooding system which contains a sharp cir-cu=f erential machine notch at the base of the flange cast on each end of the weld ends.
It was stated,that this flange is cast on the ends of the valve and machine to a close R&M finish in order to provide a sealing surface during hydrostatic testing of the valves according to Both the GPU and the UE&C representatives agreed Specification B16.5.
the machining had created a "no radius" notch extending for the full circumference around the veld end.
This was a mo.st undesirable condi-
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tion since it became a stress riser during operation and it was be-lieved that this would be investigated and some sort of corrective ection taken.
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Charpy Test values of 240 uounds at minus 20* Fahrenheit
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11.
During a review of the veld history record and supporting mill cert docurentation covering field weld A-33 in a reactor coolant pressure system it was noted that electrode E-7018 Heat No. 650X290, was doc-u=ented by test reports which indicated that the Charpy test values
'were 240 at minus 20* Fahrenheit.
The GPU, CAI, and UE&C QC person-
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nel all agreed that this was co=pletely out of line and that it was probably a typographical error. The inspector pointed out that this
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the f act that this document had was a likely explanation; however, been reviewed by Cona=, UE&O, and the UE&C receiving inspection in-dicated that reviews of material records were completely inef f ective since this deficiency had not been identified until the RO inspectorThe conducted his randem auaudit.
d and the cor-there would inmediately be a deficiency report prepare the rective action would be available for the inspector's review at next inspection.
einine to the Overcrindinc of RCP-2 weld attaching reactor coolant 12.
steam cenerator noccle
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to the The inspector observed that a 30" reactor coolant piping joint that stern generator veld No. RCP-2, had been overground to the extent l
the crown of the weld had been almost completely removed in severaIn addition a deep local areas of approximately two square inches.
grinding gouge approximately 3/16 of an inch deep was observed running l
axially along the edge of the safe end where the grinder had apparent y
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It slipped and gouged into the base =aterial of the safe end itself.a deficiency re was stated by the UE6C welding engineer that been prepared covering this item, although there was no identification
.
It was apparent however, that on the joint proper to indicate this.
all grinding had been stopped on this particular joint.
The Weld Surf ace and Merce Scoothlv Recuirements of B31.7 13.
the RO inspector observed that, in general, the Throughout the plantUE&C field welds in the main steam, reactor coolant pipi safety related systems do not meet the merge smoothly requirements of nor the surf ace finish requirements of B31.
B31.7, paragraph 1-727.4.2 7, Appendix B-1-120.1 which states weld ripples and weld surface ir-regularities on both the inside and the outside of the pipe shall be removed so that the resulting radiographic contrast due to irregular-ities will not mask or be confused with the i= age of any objectionable
_
defect. --- This violation of the surf ace finish was observed parti-cularly during a review of randomly selected radiographic film rep-resenting the velds in the pressurizer surge line where the veld sur-face irregularities did indeed cc pletely =ask local areas so that it would be dif ficult or impossible to identify rejectable defects
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SECTION V Prepared by:
R. L. Brown Additional Subjects Inspected, Not Identified in Sectio _n 1, Where No Deficiencies or Unresolved Items Were Found 1.
Reactor Pressure Vessel Inspection of those records pertaining to installation.
a.
in storage, b.
Storage and protection of component c.
Observation of installation to assure protection and maintenance
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of cleanliness of the installed vessel.
_
d.
Records of cleanliness inspection.
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2.
Reactor Coolant Pu=n Review of installation procedures and instructions to assure the a.
following requirements are defined:
(1) Handling (2) Froof testing of handling equipment (3) Cla aing (4) Place =ent
.
(5) Level
_
(6) Hook-up (7) Use of technical personnel (8)
Inspection of completed installation
_
Inspection of manufacturing records to assure presence of:
b.
(1) Material identification
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(2) Material certification
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(3) Confor=ance to construction require =cnt c.
Receipt inspection records.
d.
Records pertaining to installtica of pu=p casing and te=porary installation of pump internals, and observation of work in pro-gress.
Quarantine of nonconfer=iag =aterial c.
.
f.
Storage and protection of cc=ponents in storage 3.
Decay Heat Re= oval Outlet Valves and Core Floodine Check Valves Review of QC program to determine if requirements had been estab-a.
lished.for the following areas:
(1) Receipt inspection
,
(2) Special handling and storage precautions (3) Quarantine of nonconforming co=ponents Inspection of =anufacturing records tc assure presence of:
b.
(1) Material identification (2) Material certification (3) Confor=ance to specification requirements Receipt inspection records c.
.
d.
Storage and protection of co=ponents in storage Records pertaining to installation of val'ves and_ observations e.
of work in progress.
_
Details of Ite=s Discussed in Section I 4.
The Lack of Installation Procedures or Instructions for Saf ety Related Valves Procedures for the installation of the decay heat removal outlet
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valves and core flooding check valves were not available to direct the activity relative to the quality for these cc=ponents, this is
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contrary to the requirements of Appendix B,10 CFR 50, Criterion V, (
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G4-136
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- 29 -
" Instructions, Procedures, and Drawings", which states in part,
"Ac-tivities aff ecting quality shall be prescribed by documented instruc-tions, procedures, or drawings, of a type appropriate to the circu=-
stances shall be accomplished in accordance with these instructions, procedures, or drawings.
Instructions, procedures or drawings shall include appropriate quantitative or qualitative acceptance criteria for deter =ining that i=portant activities have been satisfactorily accceplished."
5.
Deficiency Reoorts Not Being Issued f or Senconf or=inc Conditiens A Cona= inspection report dated May 23, 1972, states in part: --
" Magnetic particle rej ectable indications on the Unit 1 reactor head flange."
A deficiency report (DR) for this condition has not been issued.
This is contrary to the ULLC procedure QC-17, " Control of Nonconform-ing Conditions", Paragraph IV-3, that states, in part, --- "QC shall
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caintain a = aster log of inspection reports to indicate their status",
and Paragraph C states in part, --- "Ite=s that are re-inspected and are found to be unacceptable, --- shall be tagged with a rej ect tag."
The nonconforcing condition and the ref erenced inspection report nu=-
ber shall be identified on a deficiency report processed as specified in Section IV.A.
The rejected status and a ref erenced DR number shall be docu=ented on the applicable inspection report for cross reference.
6.
Reactor Coolant Pu=o Supports The inspector was infor=ed, that the design does not require the re-actor coolant pumps to be supported by any =eans other than the suction pipe from the steam generator, and discharge pipe to the reactor pres-sure vessel, plus restraint attached to the pu=p e..d =otor.
This ap-pears to be a tremendous load (approxi=ately 210,000 pounds) to be
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carried by the stea= generator and reactor pressure vessel nozzles and connecting pipes.
This condition has been referred to RO headquarters (Mr. W. Rein =uth)
for a review and disposition.
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