IR 05000289/1973002
| ML19256E651 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/06/1973 |
| From: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | John Miller METROPOLITAN EDISON CO. |
| Shared Package | |
| ML19256E649 | List: |
| References | |
| NUDOCS 7911130533 | |
| Download: ML19256E651 (2) | |
Text
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m, AUG 61973
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Metropolitan Edison Company Docket Nos. 50-289 Attention:
Mr. John G. Miller 50-320 Vice President P.O. Box 542 Reading Pennsylvania 19603 Gentlemen:
Enclosed is a copy of Inspection Report 50-289/73-02 and 50-320/73-02 which documents the results of our inspection which were discussed in the letter to Metropolitan Edison from the Director of Regulatory Operations dated June 21, 1973.
This report was reviewed by your staff for prc,prietary informaticn as stated'in your letter dated July 20, 1973.
No reply to this letter is required, however, should you have any questions
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concerning this matter, we will be pleas 6d to discuss them with you.
Sincerely, James P. O'Reilly
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Director
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Enclosure
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RO Insp Report No.
50-289/
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50-320/
bec: W/O Enci RO Chief, Field Support & Enforcement Branch RO: HQ (4)
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Central Mail & Files Unit Directorate of Licensing (4)
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TIC State of Pennsylvania 1647 308 omcg>
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ie_iS,h.,,I,[p,db,lT oWard SURNAME >
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MEMO POUTE SLIP 5'******"'"'-
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T11REE MILE ISLAND UNITS 1 AND 2 RO Files p
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central Mail 6. Files Unit RO INSPECTION REPORT NOS. 50-289/73-02
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50-320/7J-02 i o (N...aa.ac.,
w n4Ls i atmums Regulatory Stat.Jards '3)
Directorate of Licensing (13)
PDR mn The subject inspection report is forwarded Local PDR NSTC for information.
TO (Name na unst)
NTIALs RimAAA3 TIC
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i State of Pennsylvani a
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Iloward, RO:I I
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N MIE X278 7/26/73 USE OTHEA sic 4 FOR ADC470suAL REMARKS cn3 3,13 o. 445-es,
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U.S. ATOMIC EUERGY CO. FISSION T
DIRECTORATE OF REGULATORY OPERATIONS
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REGION I
50-289 RO Inspection Report No.:
50-289/73-02 and 50-320/73-02 Docket No.: 50-320
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CPPR-40 Licensee:
- trenolitan Edison Company License No.: CPPR-66
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P. O. Box 542 Priority:
Unit 1-B Reading, Pennsylvania 19603 Category:
Unit 2 - A
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I Location: Middletown, Pennsylvania (Three Mile Island 1 & 2)
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Type of Licensee: WR 831 IMe (BE10
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Type of Inspection: Routine, Unannounced I
March 26.- 28, 1973 (]DatesofInspection:
Dates of Previous Inspection:
January 9-11, 1973
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Reporting Inspector:
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Seth A. Folsom, Re,ctor Inspector
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AdX b g.27 73 Accompanying Inspectors:
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E. M. Howard, Chief, Facility Ccnstruc-Date
l Etid~ dngi cering Support Branch f/.a/.o w
/ ate R. F. Heishman, Sr. Incpector, Facility
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Construction-ft Engineering Support Branch
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J. H. Tillou, Senior Insp ec tor, Facility Date Construction & Engineering Support Branch
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Other Accompanying Personnel:
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Date b.s ma.c cl I-27 73 Reviewed by:
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E. M. Howard, Chief, Facility Construction & Engineer-i ing Supoort Branch 7y{ggm
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SUMMARY OF FINDINGS Enforcement Action A.
Delta-Ferrite Welding Electrodes
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The Babcock-Wilcox material certifications for E-304 weld!.g electrodes Heats #32167 and #50311 do not contain evidence of 5-10% delta-ferrite as required by the Babcock-Wilcox Specification No. CS-37-3.
(De tails,
Paragraph 4)
B.
Engineered Safecuards Motors, Shaf t Rotation
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Several engineered safeguards motor shaf ts were identified which had
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not been rotated in accordance with applicable procedures.
(Details, i
Paragraph 5)
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l C.
Surveillance of Instrument Panels, Control Boards, and Related Ecuincent
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The surveillance of instrument panels, control boards, and related equip-ment does not identify equipment inspected, provide quantitative or ()
qualitative evidence relative to the equipment nor is surveillance
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of installed, but not energized, equipment conducted.
(Details, Para-
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graph 6)
D.
Installation of Engineered Safecuards Pumns Without Prior Documented j
Notification of Ouality Control Four engineered safeguards pumps were installed without evidence of notification of the Field Quality Control Engineer contray to pro-cedures.
(Details, Paragraph 7)
E.
Quarterly Audits of Measurine and Test Eauinment The quarterly audits of measuring and test equipment do not meet
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the requirements of Criterion KVIII.
(Details, Paragraph 8)
F.
Separation of Redundant Circuits Engineered safeguards control consoles (CC and CR) do not have the specified separation of redundant channels.
(Details, Paragraph 9)
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Sensors Inst rumen ts and Associated Lines
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The design objective separ lines has not been providedation for process instrum or qualitative acceptance crit
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n sensing
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eria in procedures.
e Construction Deficiency Re (Details, Paragraph H.
ncrts flood, on or about June 23 Damage to four engin a eguards motors which occurred d 10 CFR 50.55(e).
, 1972, was Licensin (Details, Paragraph 11)not reported in accordanc uring the Action on Previous 1v Identifi
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A.
Borated Water Storace Tank RT ed Enforcement Matters An RT Ins,cctions on the borated water storage ttechnique sheet has be provided for the RT inspections surance Manual.
ank graph 12)
This item is cons,idered reas required by the PDM performed solved.
s-B.
Borated Water Stora (Details, Para-e Tank (3 Deviation Report No.
Carbon to Stainless Steel H l
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stainless steel material. resolved relative to the carbo o d-Down Clios 26, 1972 j
This item is considered res lsteel tie-tails, Paragraph 13)
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Borated Water Storage Tank o ved.
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Cleanin The prohibition relative t With Prohibited Solution was invoked by U o the use technical reason. ESC because of Acetone All contractors and subcontof the indu
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on advised of the prohibition tails, Paragraph 14)
This item is considered res lractors ha er thari a
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o ved.
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Lack of Procedures Prior to Start of Work A UE&C construction memo, dated October 11, 1972, was issued to the that for-UE6C purchasing organization, reaffirming the requirement mally approved procedures must be available on site prior to start of work. This item is considered resolved.
(Details, Paragraph 15)
E.
Borated Water Storace Tank Inspection A review of the final inspection performed by PDM indicated that the borated water storage tank had been cleaned in accordance with applicable UE&C records also indicate that the tank had been inspected procedures.
to verify conformance with the specifications. This item is considered
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resolved.
(Details, Paragraph 16)
F.
Borated Water Storace Tank, Construction Code
Amendment No. 36 to the FSAR, dated February 9, 1973, pages 6 through i (3 34, state that the borated water storage tank had been constructed in
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accordance with Section VIII of the ASME Boiler and Pressure Vessel
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Code, rather than ANWA D-108.
This item is considered resolved.
(De-tails, Paragraph 17)
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G.
Corrective Action Audit findings which were previously identified as being unresolved for a period of time inconsistent with the QA plan, were found to be re-solved.
This item is considered resolved.
(Details, Paragraph 18)
H.
Pipe Welding Defect History UE&C Field Change, QC-33, dated October 3, 1972, which is a revision of the UE&C procedure QC-8, requiles documentation of defect removal.
It includes a revised history record form and conforms to Gilbert Associates Specification No. 5550, paragraph 2.7.3.
This item is
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(Details, Paragraph 19)
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Materials Certification for B&W Sunnlied Pine Records and material certifications were on site for B&W supplied pipe.
This item is considered resolved.
(Details, Paragraph 20)
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Use of Lime-Coated Electrodes
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A review of welding material test reports by the UE&C site welding j
engineer and QC records clerk revealed a transcription error from one l
welding material test certificate to a second which resulted in E-16-8-2 being incorrectly identified as E-308.
This item is considered re-solved.
(Details, Paragraph 21)
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K.
Radiocranh Examination Eouipment
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The Conam Testing Agency now has a completely equipped radiographic inspection laboratory, including a hi-intensity viewer.
This item is considered resolved.
(Details, Paragraph 22)
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Sockolet Fillet Welds The fillet welds attaching a sockolet to the side of pipe No. DC-57 have been repaired. This item is considered resolved.
(Details, Para-graph 23)
M.
Transweld Weave on Pine Snool CF-1 The transweld weave on pipe spool CF-1 has been ground to a smooth finish, and hardness tests performed to verify that overheating during the trans-weld weaving had not adversely affected the material.
This item is considered resolved.
(Details, Paragraph 24)
e N.
Delta-Ferrite Content - Grinnell Shen Welds Inspection records show that a 100% f errite scope inspection was con-ducted on the. surface of each shop weld cade by Grinnell and the results evaluated by the A-E.
All welds were verified to have delta-ferrite of at least 6%.
This item is considered resolved.
(De tails,
Paragraph 25)
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Elec*rical Nonconformine Condition Deficiency Renorts Deficiency reports and/or engineering deviation notices for noncon-forning conditions in the electrical, control, and instrumentation, relative to the design obj ective separation, are now being prepared.
This item is considered resolved.
0 Details, Paragraph 26)
P.
Closure of Openine Between Control Room and Cable Soreadine Room
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Drawings are being developed for closure of the opening in the engineered safeguards actuating control consoles. This item is considered unre-solved.
(De tails,
Paragraph 27)
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Common Ventilation Svstem for Batterv Rooms t
The common ventilation systen shared by the two battery rooms will be
i carried as an unresolved item until such time as the FSAR, Paragraph 8.2.2.10.e is accepted and approved by the Directorate of Licensing.
(Details, Paragraph 28)
R.
Use of Electrical OC Checklists h
The procedure pertaining to the use of QC checklists while inspecting has been changed.
The present system recuires that the inspector I
carry a copy of the applicable procedure while inspecting and/or
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witnessing the receiving, storing, an,d/or installation of the eouip-ment.
This item is considered resolved.
(Details, Paragraph 29)
S.
Quarterly Audits of Measurine and Test Ecuinment Quarterly audits of measuring and test ecuipment were performed, which resolves the original violation; however, the procedure used in per-forming the audit does not meet the intent of Criterion V, Appendix B, 10 CFR 50.
This item will be carried as a new violation.
(De tails,
Paragraph 8)
T.
Engineered Safecuards Motors, Shaf t Rotation Several instances were identified where engineered safeguards motor shaf ts were not rotcted as required.
This item will be carried as a repeat violation.
(Details, Paragraph 5)
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Supplenentary Heat for Hich Pressure Iniection Pumo Motors The high pressure injection pump notors had been turned over to the startup unit and were in a controlled environment.
Quality control procedures state that motors in a controlled environment do not reauire supplementary heat. This item is considered resolved.
(Details, Para-graph 30)
V.
Surveillance of Instrument Panels, Control Boards, and Related Equipment There is fragmented documentation that instruments, panels, and control boards had been inspected during storage for Three Mile Island Unit 1.
The documentation is considered inadequate since inspection records re-viewed, with one exception, do not list the equipment which was in-
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spected, nor could the quality control organization identify equipment l
under their scope or its physical location.
This item will be carried
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cs a repeat violation.
(Details, Paragraph 6)
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Installation of Engineered Safeauards Pumps Without Prior Documented
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Notification of Ouality Control Notification of the field supervisor, quality control, by the. crafts prior to installation of safety related equipment is not being accom-plished.
This will be carried as a repeat violation.
(Details, Para-graph 7)
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X.
Separation of Redundant Circuits The engineered safeguards control console (CC and CR panels) located in'
the control room do not have separation as required.
This will be carried as a repeat violation.
(Details, Paragraph 9)
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Y.
Receipt Insoection Documentation was reviewed indicating that the reactor pressure sensing actuators (RK-18) were an integral part of B&W equipment and as such, did not require individual unit inspection.
This item is considered resolved.
(Details, Paragraph 34)
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Sensors, Instruments, and Associated Lines Procedures have been prepared for use in verifying that instrumenta-tion has been installed in accordance with the engineering drawings.
The design separation objective for process control systems used in the reactor protection system could not be identified.
This will be carried as a new violation.
(Details, Paragraph 10)
AA. Calibration and Testine of Instrumentation i
Procedures have been prepared for the calibt'ation and testing of in-
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strumentation.
This item is considered resolved.
(Details, Para-
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graph 31)
,BB. Vertical Cable Trav Covers
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Vertical cable tray covers have been described in a general note on the electrical drawings.
Procedures requiring verification of this installation have been prepared.
This will be carried as an unresolved
item, pending completion and verification of the installation.
OD e-T tails, Paragraph 32)
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CC, Cable Trav Loading Procedures have been p epared requiring verification that the design objective cable tray losding has not been exceeded. This will be carried as an unresolve: item, pending installation of the remaining cables and velification that the design loading objective has not been exceeded.
0 Details, Paragraph 33)
Design Chances None
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U nusual Occurrences None
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Other Significant Findines
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A.
Current Findines 1.
Subsequent to the final inspection and acceptance of the borated water storage tank, this tank was splattered by welding being per-for=ed on an adjacent structure.
(Details, Paragraph 16)
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2.
Drawings and details of the method of effecting closure of opening between the engineered safegua;ds actuating consoles and cable i
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spreading room were not available for review.
(Details, Paragraph
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3.
Vertical cable tray covers have been described in general no::
on electrical drawings. This will be carried as an unresolved item
pending completion of verification of the installation.
0 Details, j
Paragraph 32)
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4.
Design objective cable tray loading has now been established as a QC check point.
This will be carried as an unresolved item pending
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I verification of cable tray leading.
(Details, Paragraph 33)
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5.
UE&C internal audits required by QC-15 have not been implemen- ';
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however, the schedule shows that such audits would be conducted during the period April-December 1973.
This will be carried as an unresolved item.
(Details, Paragraph 35.c)
l 6.
The NP-1, Partial Data Sheets for the core spray and the pressurizer surge lines do not include evidence of conformance to the Pennsylvania i
i Special Standard No. WC-1891, as required by the FSAR.
(Details,
Paragraph 3)
B.
Status of Previous 1v Reported Unresolved Items Not reviewed during this inspection.
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Manacement Interview The management interview was held at the site on March 28, 1973.
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Personnel Attending General Public Utilities Service Company Mr. W. A. Verrochi, Vice President, Design and Construction Mr.
B. G. Avers, Manager, Quality Assurance Mr. M. J. Stromberg, Site QA Auditor
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- 10-i Mr. J. E. Wright, Site Quality Assurance Manager
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Mr. J. A. Renshaw, Quality Assurance Specialist Mr. W. T. Gunn, Project Site Manager L*nited Engineers and Constructors Mr. V. E. Cichocki, Construction Superintendent Mr. C. F. Rabenold, Vice President Mr. E. C. Nagle, Construction Manager
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Mr. E. K. Ferguson, Project Superintendent Mr. R. N. Moyer, Quality Control Supervisor Gilbert Associates, Inc.
' Mr. R. H. Fleming, Quality Assurance Site Cocrdinator
l Burns and Roe, Inc.
Mr. R. S. Groseclose, Lead Site Quality Assurance Engineer s
'tJ The following items were discussed:
A.
Indoctrination and Trainine Programs for OC and Construction Personnel The inspector stated that the indoctrination and training programs for UE&C site quality control personne~l and appropriate UE&C con-struction personnel, as well as the incorporation of training re-quirements in appropriate construction and quality control procedures, conformed to the co=mitment contained in the licensee's letter of December 14, 1972.
The licensee did not cocaent.
B.
Stop-Work Authority The inspector stated that the UE&C site procedures hac been reviewed for the inclu.sion of emphasis on stopping of nonconforming work as stated in the licensee's letter of December 14, 1972.
The licensee did not comment.
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C.
Reorganization of Ouality Orcanization The inspector stated that the organization described in the December 14, 1972 letter differs from the organizational structure as it presently exists.
The licensee stated that the organization did differ from their intended structuring; however, the present structure is the result of assumption by GPUSC of the site QA manager responsibilities, and felt that the l
intent of the commitment had been met.
The inspector concurred.
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D.
Redefinition of GPUSC Site OA Grouo's Responsibilities
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The inspector stated that the function to be performed by the GPUSC site QA group appeared to be well underway; however, the assumption of the
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administrative QA responsibilities by the site quality assurance mana-ger had not yet been fully accomplished.
The licensee concurred and requested that future inspections be co-
- f ordinated through the GPUSC site QA auditor rather than the site quality j ()
assurance manager until a smooth and orderly full transition is accom-plished.
i E.
Core Sprav and Pressurizer Surze Lines
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The inspector stated that the NP-1, Partial Data Sheets, for the core spray and pressurizer surge lines do not include evidence of conformance to the Pennsylvania Special Standard No. WC-1891, as required by the FSAR.
The inspector stated that this item is unresolved.
(De tails,
P ;agraph 3)
F.
Delta-Ferrite Weldine Electrodes The inspector stated that the Babcock-Wilcox material certification for E-304 welding electrodes, Heats #32167 and #50311, did not contain
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evidence of 5-10% delta-ferrite as required by E&W Specification No.
CS-37-3.
The inspector stated that this item is a violation.
CDe-tails, Paragraph 4)
G.
Electrical Encineered Safecuards Motors, Shaft Rotation The inspector stated that the electrical quality control organization 1647 320
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did not have a list of equipme.'t in their assigned area of responsi-bility, but must search several documents to establish the quality level classification.
On Unit No. 1, the inspector found that six motors were identified which had not had their shaf ts rotated in ac-cordance with the procedures, and six other motors for which no dis-position existed from date of receipt on site.
These latter six motors failed to appear on the construction list.
There was no audit at any level which identified this deficiency. Approximately 15 motors were received for Unit No. 2, of which five are engineered safeguards; how-ever, no required preventive maintenance has been performed since re-ceipt.
The inspector further stated that this is the second similar violation identified on consecutive inspections in this area.
(D e-tails, Paragraph 5)
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H.
Surveillance of Instrument Panels, Control Boards, and Related Equionent The inspector stated that the surveillance of instrument panels, con-
trol boards, and related equipment did not list the equipment subjected i
to such surveillance, nor its location.
The inspector stated that
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audit or surveillance reports addressed general cleanliness of the
storage area; however,.there were no reports indicating surveillance of installed,but not energized, equipment as described in the Metropolitan I
Edison letter of November 3,1972.
The inspector also stated that the electrical quality control organization was not aware of the November 3, 1972 commitment, nor did an equipment list with equipment locations and status exist within this organization.
The inspector further stated that this is the second similar violation identified on consecutive inspections in this area.
(Details, Paragraph 6)
I.
Installation of Encineered Safeguards Pumns Without Prior Documented Notification of Ouality Control
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The inspector stated that four engineered safeguards pumps were installed with no evidence of prior notification of the Field Super-visor, Quality Control, and without notification by " speed letter" as described in Metropolitan Edison's letter of November 3,1972.
The inspector furt'her stated that this is the second similar violation identified on consecutive inspections in this area.
(Details, Para-graph 7)
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Quarterly Audits of Measurine and Test Eculpment
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The inspector stated that the quarterly field audit for tools, gauges, and instruments was reinstated on October 27, 1972, and that an audit report was prepared on January 26, 1973; however, the audit report did not identify the equipment inspected and, in one instance, answered i
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the question, "How?" with "Yes".
The inspector stated that this was a violation of Criterion V and/or Criterion XVIII, in t at the pro-cedures do not contain quantitative or qualitative acceptance criteria
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and there is no means of identifying all equipment audited or assuring that all such equipment is accounted in the documentation of the audit.
(Details, Paragraph 8)
q K.
Separation of Redundant Circuits
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The inspector stated that separation of the different engineered safe-
guards channels beneath the engineered safeguards control consoles (CC and CR panels) erroneously identified as "saf eguard actuation cabinets"
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in our previous report, had less than two inches air separation in two ()
instances which is in violation of the design criteria.
This lack of The
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separation had not been identified by any quality organization.
inspector also stated that the present arrangement of cables in these l
consoles made verification of channel separation impracticable if not impossible. The inspector fu.rther stated that this was a second viola-
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tion on consecutive inspections of lack of separation and of failure of the quality organizations to identify and document the lack of separa-
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tion.
(Details, Paragraph 2)
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Sensors, Instruments, and Associated Lines The inspector stated that the procedure for inspection of instrument /
sensors and associated lines had been prepared, but the AEC was con-cerned with the maintenance of separation and precluding the introduction of a common mode of failure.
It was further stated that " quality as-
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spects", addressed in the previous noncompliance, was concerned with the failure to address the minimu= acceptable separation of redundant instruments / sensors and associated lines. The present procedure did not contain quant'itative or qualitative acceptance criteria, nor was there guidance available concerning the stated, sign objective separation or other criteria.
The inspector stated
.a t this would be listed as a violation.
(Details, Paragraph 10)
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Construction Deficiency Reports Subsequent to the inspection, the licensee was informed that a viola-
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tion of 10 CFR 50.55(e) had been identified associated with water l
damage to four engineered safeguards pump motors which were damaged
during the flood on or about June 23, 1972.
Two reports, one oral and one in writing, failed to identify this flood damage.
(De tails,
Paragraph 11)
N.
Borated Water Storace Tank RT Insoection
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The inspector stated that an RT technique sheet has been provided for
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the RT inspections performed on the borated water storage tank as required by the PDM Quality Assurance Manual.
The inspector stated that this item is considered resolved.
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The licensee did not comment.
(Details, Paragraph 12)
O.
Borated Water Storace Tank, Carbon to Stainless Steel Hold-Down Clips
?)
The inspector stated that Deviation Report No. 72, dated September 26,
'"
1972, was issued and resolved, relative to the carbon steel tie-downs, which were used for stainless steel material. The inspector stated that this iten is considered resolved.
The licensee did not comment.
(Details, Paragraph 13)
P.
Borated Water Storace Tank Cleaning with Prohibited Solution l
The inspector stated that he found documentation indicating that the prohibition relative to the use of acetone on stainless steel
'
was invoked by UESC because of the industrial hazard rather than far a technical reason.
All contractors and subcontractors had not been
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advised of the prohibition.
The inspector stated that this item is considered resolved.
The licensee,did not comment.
(Details, Paragraph 14)
Q.
Lack of Procedures Prior to Start of Work The inspector stated that a UE&C construction me=o, dated October 11, 1972, was issued to the UE&C purchasing organization, reaf firming ( _
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the requirement that formally approved procedures must be available on site prior to start of work.
The inspector stated that this item is considered resolved.
The licensee did not comment.
(Details, Paragraph 15)
R.
Borated Water Storace Tank Inspection
The inspector stated that a review of the final inspection performed by PDM indicated that the borated water storage tank had been cleaned in accordance with applicable procedures, and UE&C records also indicated that the tank had been inspected to verify conformance with the specifi-The inspector stated that this item is considered resolved; cations.
however, subsequent to the inspection and acceptance of this tank, welding on an adjacent structure resulted in additional external weld splatter,
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which had been identified and documented'by the licensee.
!
The licensee acknowledged the issuance of the nonconformance report.
j l
ODetails, Paragraph 16)
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S.
Borated Water Storace Tank Construction Code
'
i The inspector stated that Amendment No. 36 to the FSAR, which he re-viewed, dated February 9,1973, pages 6 through 34, state that the
!
borated water storage tank had been constructed in accordance with
.
Section VIII of the ASME Boiler and Pressure Vessel Code, rather than AWWA D-108.
The inspector stated that this item is considered resolved.
The licensee did not comment.
(Details, Paragraph 17)
T.
Corrective Action The inspector stated that audit findings which were previously identified as being unresolved for a period of time inconsistent with the QA plan
'
were found to be resolved. The inspector stated that this item is con-sidered resolved.
The licensee did not comment.
(Details, Paragraph 18)
U.
Pipe Weldine Defect History The inspector stated that he found UE&C Field Change, QC-33, dated October 3, 1972, which was a revision of the UE&C procedure QC-8, requires documentatien of def ect removal and included a revised history i647 524
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record form, which conformed to Gilbert Associates Specification No. 5550, Paragraph 2.7.3.
The inspector stated that this item was considered resolved.
The licensee did not co= ment.
(Details, Paragraph 10)
V.
Materials Certification for B&W Suonlied Pipe The inspector stated that he had reviewed the detailed fabrication records and material certifications which were on site for B&W sup-
plied pipe. The inspector stated that this item was considered re-solved.
l The licensee did not comment.
(Details, Paragraph 20)
W.
Use of Lime-Coated Electrodes
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The inspector stated that a review of welding material test reports by
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the UE&C site welding engineer and QC records clerk revealed a trans-l cription error from one welding material test certificate to a second which resulted in E-16-8-2 being incorrectly identified as E-308.
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/
The licensee did not comment.
(Details, Paragraph 21)
X.
Radiograph Examination Eauipment The inspector stated that the Conam Testing Agency now has a completely equipped radiographic inspection laboratory, including a hi-intensity viewer.
The inspector stated that this item is considered resolved.
The licensee did not comment.
(Details, Paragraph 22)
Y.
Sockolet Fillet Weld to Ploe No. DC-57
.
The inspector stated that the fillet welds attaching a sockolet to the side of pipe No. DC-57 have been repaired and that this item is considered resolved.
'
The licensee did not comment.
(Details, Paragraph 23)
Z.
Transweld Weave on Pioe Scool CF-1 The inspector stated that the transweld weave on pipe spool CF-1 has been ground to a smooth finish, and hardness tests performed to verify
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E that overheating during the trans-weld weaving had not adversely af-fected the material.
The inspector stated that this item was con-sidered resolved.
The licensee did not co= ment.
(Details, Paragraph 24)
AA. Delta-Ferrite Content - Grinnell Shop Welds
,
The inspector stated that the inspection records show that a 100% ferrite scope inspection was conducted on the surface of each shop weld made All welds were veri-by Grinnell and the results evaluated by the A-E.
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fied to have delta-ferrite of at least 6%, but not in excess of 10%.
,
The inspector stated that this item was considered resolved.
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The licensee did not comment.
(Details,. Paragraph 25)
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I BB, Electrical Nonconformine Condition Deficiency Reports i
i The inspector stated that Deficiency Reports and/or Engineering
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Deviation Notices were now being prepared for nonconforming conditions in the electrical control instrumentation installation where the design objective separation of cable trays and conduits has been vio-I lated.
The inspector stated that this item was considered resolved.
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The licensee did not comment.
(Details, Paragraph 26)
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CC. Closure of Openine Between Control Room and Cable Spreading Room The inspector stated that he had been informed that drawings are being developed for closure of the opening in the engineered safeguards
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actuating control consoles. This would be carried as an unresolved item pending review of the intended method of closure.
The licensee asked if he would be required to respond to this item.
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The inspector stated that the use of the term " unresolved item" implied that the item would be re-inspected, but was not a violation and there-fore would no.t appear in the letter discussing the inspection find-ings and would not require a reply.
(Details, Paragraph 27)
DD. Common Ventilation System for Batterv Rooms The inspector stated that the common ventilation system shared by the two battery rooms is considered resolved, subject to further action by the Directorate of Licensing.
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(Details, Paragraph 28)
The licensee did not comment.
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EE. Use of Electrical OC Checklists The inspector stated that the procedure pertaining to the use of QA checklists while inspecting has been changed. The present system re-quired that the inspector carry a copy of the applicable procedure l
while inspecting and/or witnessing the receiving, storing, and/or
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Field notes were prepared for later
installation of the equipment.
The in-The notes were found to be comprehensive.
f transcription.
spector stated that this item was considered resolved.
!
l (Details, Paragraph 29)
f The licensee did not comment.
for High Pressure Iniection Pump Motors
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FF. Jupplementary Heat The inspector stated that the high pressure injection pump motors had been turned over to the startup unit and were in a controlled environ-Quality control procedures stated that motors in a controlled ment.
therefore, this item environment did not require supplementary heat; I()
was considered resolved.
(Details, Paragraph 30)
The licensee did not comment.
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GG. Receint Inspection of Reactor Pressure Sensine Acutators
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I The inspector stated that he had reviewed documentation which indi-(RK-18) were treated l
cated that the reactor pressure sensing actuators as an integral part of the B&W equipment in which they were installed.
,
The inspector stated that this item was considered resolved.
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The licensee did not comment.
(Details, Paragraph 34)
r HH. Calibration and Testing of Instrumentation
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The inspector stated that procedures had been prepared for the calibra-tion and testing of instrumentation prior to installation, and that this item was considered resolved.
(Details, Paragraph 31)
The licensee did not consent.
16A7
$27
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II. Vertical Cable Trav Covers The inspector stated that the vertical cable tray covers had been described in a general note on the electrical drawings, and that
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procedures requiring verification of this installation had been pre-pared; however, this will be carried as an unresolved item, pending completion and verification of the installation.
The licensee stated that fire barriers throughout were also pro-cedurally covered.
(Details, Paragraph 32)
t JJ. Cable Trav Loading
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The inspector stated that procedures had been prepared requiring veri-fication that the design objective cable tray loading had not been
,
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j exceeded; however, this would be carried'as an unresolved item, pending installation of the remaining cables and verification that the design i
i loading objective had not been exceeded.
The licensee did not comment.
0 Details, Paragraph 33)
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KK. UE&C Internal Audits
!
The inspector stated that the UESC internal audits required by QC-15 had not been implemented; however, the schedule showed that such
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audits would be conducted during the period April - December,1973.
This would be carried as an unresolved item.
The licensee did not comment.
(Details, Paragraph 35.c)
LL. Loes and Records The inspector stated that an examination of typical construction legs
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and records revealed a number of instances where unsuitable informa-tion was included, and where deficiencies identified a year or more ago remained uncorrected in the record.
This item remains unresolved.
The licensee did not ccm=ent.
MM. Containment Rine Girder Repair Documentation The licensee stated that, per the inspector's request, all documentation and history on the containment ring girder repair had been assembled fol-lowing completion of the repair work. An audit by QA had been conducted
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and the documentation package was now available for examination.
The inspector stated that this documentation would be examined during a later inspection.
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DETAILS
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Persons Contacted General Public Utilities Service Company Mr. W. A. Verrochi, Vice President, Design and Construction Mr. B. G. Avers, Manager, Quality Assurance Mr. J. E. Wright, Site Quality Assurance Manager Mr. M. J. Stromberg, Site Quality Assurance Auditor Mr. J. A. Renshaw, Quality Assurance Specialist Mr. G. Kopp, Quality Assurance Engineer Mr. P. Levine, Quality Assurance Engineer Mr. P. Gemmingen, U. S. Testing Quality Assurance Engineer Mr. C. Talbott, Conan Inspection Agency, Contract Level III Radio-graphic Inspector United Encineers and Constructors Mr. C. F. Rabenold, Vice President.
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Mr. E. C. Nagle, Construction Manager
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Mr. V. E. Cichocki, Construction Superintendent Mr. E. K. Ferguson, Project Superintendent Mr. R. N. Moyer, Quality Control Supervisor
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I Mr. H. Finlan, Site Welding Engineer s
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Mr. J. A. Schmidt, Records Coordinator Mr. J. Fleming, Electrical Startup Engineer Mr. R. W. Liscoa, Electrical QC Engineer Mr.
N.. A. Vitale, Documentation Engineer Gilbert Associates, Inc.
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Mr. R. H. Fleming, Quality Assurance Site Coordinator Mr. N. R. Barker, Quality Assurance Project Engineer Burns and Roe, Inc.
Mr. R. S. Groseclose, Lead Site Quality Assurance Engineer
,
Babcock and Wilcox Mr. N. Norman, Associate Project Engineer Mr. J. Uhl, Site Manager Roval Globe Insurance Comnanv
\\b Mr. L. Gottshall, National Board, Site Code Examiner 2.
Status of Construction The licensee reported that there was no change in the projected ccm-pletion dates.
Construction was 85% complete, with hot functional test November 30, 1973; fuel loading February 1, 1974; and 100?'.
power June 15, 1974.
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l 3.
Core Sorav and Pressurizer Surce Line, Not Certified in Accordance with FSAR The NP-1 Partial Data Sheets for the 2 " core spray and the 10"
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pressurizer surge line piping were signed off by a State of Ohio inspector as conforming to the ANSI B31.7 piping code but contained no evidence that they were also in conformance with the Pennsylvania Special Standard WC-1891 as required by the FSAR.
4.
Improper Delta-Ferrite and Improcer Certification - Welding Electrodes It was found during a review of the records for B&W supplied equipment that the materials certificates covering the B&W welding electrodes l
classification E-304, heat #32167 contained 1.5 to 2.5% Delta-ferrite which is below the minimum requirement in the B&W specification CS-37-3
>
which requires 5 to 107. Delta-ferrite in all welding electrodes.
It was also found that welding electrode class E-304 heat #50311 showed no chemical analysis of ferrite at all on the records.
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5.
Engineered Safecuards Motors, Shaft Rotation
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UE&C Procedure ECP-6, paragraph 5.1.4 requires that the engineered
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safeguards motor shaf ts be rotated monthly.
The quality control
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organization responsible for the electrical aspects of the job did not
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have a list of the equip. nt under the scope of the quality assurance organization. The construction organization who has a responsibility i
for rotation of motor shafts had an equipment list which was inspected in detail. Fifteen motors associated with the engineered safeguards were found to be improperly accounted for. The quality control organi-zation had not identified these deficiencies.
The particular defi-ciencies are as follows:
Pump NS-P-1c (Nuclear Service Cooling) inadvertently shown as a.
being turned over to startup by construction.
Rotation of the shaf t was not accomplished between September,1972 and the date of the inspection.
.
b.
Motors AH-E-15a and 15b were shown on the construction log having been turned over to the Startup Unit in September, 1972.
The Startup log shows that this unit assumed responsibility on Decenber 8,1972.
There is no record of rotation between September, 1972 and December, 1972.
c.
Motors AH-E-19b and AH-E-29a were shown on the construction log as having been turned over to the startup unit on October 3,1972, however, the startup unit has no records indicating the assumption and responsibility of these motors.
There is no record of rota-tion between October 3,1972 and March 29, 1973.
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Motor AH-E-18a was shown on the construction log as having been turned over to Startup in October, 1972, however, the Startup log indicates assumption of responsibility on January 8, 1973.
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There is no record of rotation between October 3,1972 and January 8, 1973.
The makeup pump main oil pumps (MUP-3a, 3b, and 3c) do not appear e.
on the construction list.
There is no record indicating inspec-tion and/or rotation, if required, since the initial receipt of these pumps and motors.
i f.
Makeup pump auxiliary oil pumps (MUP-2a, 2b, and 2c) do not appear
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on the construction list.
There is no evidence that these pumps i
have been inspected and/or rotated since initial receipt.
6.
Surveillance of Instruments, Panels, and Control Boards
.
UE&C Procedure ECP-10 requires that a surveillance be performed on all
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instrument panels, control boards and related equipment to assure that l
controlled storage conditions are maintained.
Paragraph 3 of this proce-dure states:
" Documentation will be performed in accordance with
quality control check list for storage of instrument control centers, cabinets, consoles and instruments racks..."
There is fragmented docu-l]
mentation which indicates that a cursory inspection of this equipment has been made.
The quality control office does not have a list of equipment under their scope nor the location of this equipment.
One audit of this equipment performed approximately one year prior to this inspection listed that equipment which was inspected, however, subsequent inspections address the general cleanliness of the area
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and appears to be concerned primarily with equipment that is stored
'
l in the warehouse.
In answer to our initial violation, Metropolitan Edison stated that such surveillance included installed, but not
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energized equipment.
7.
Installation of Engineered Safeguards Ecuiement UE&C Procedures ECP-6 and ECP-10 both require that the field super-
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visor Quality Control be notified prior to the installation of engineered safeguards equipment.
Metropolitan Edison's letter in answer to our violations states in part:
"...Further, starting in Septembe,r, 1972, UE&C construction. crafts notify QC by speed letter...".
It was found that the four engineered safeguards pumps, BSPIA, IB, and DHPIA and IB, were installed without written communication.
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i 8.
Measurine and Test Ecuionent Calibration UE6C Procedure QC-13 was revised on October 27, 1972 to reinstate the requirement for quarterly field audit which had been deleted by a change to this procedure dated Jul" 6, 1972. An internal audit for tools, gauges, and instruments was performed on January 26, 1973; however, the audit does not state what equipment was inspected.
Instructions for the check list states in part:
"...The applicability of a given check list or item is Icft to the discretion of the person conducting
'
the audit."
It is not possible to determine if all tools, gauges, and instruments were audited or what portion if not all.
The audit check
list procedure does not contain qualitative cr quantitative evidence.
t 9.
Separation of Redundant Circuits i
The FSAR, paragraph 8.2.2.12c states in part:
"In a very few cases,
'
l the separation is about 12" and in these cases a barrier is installed j
between the trays," A change to the FSAR to permit the 6" air separa-
,
tion criteria between channels in the area immediately under the
.
l engineered safeguards control console (CC and CR panels) was stated to be in the submission process; however, this proposed change was
{
not available for review.
T'
Several instances were identified where the 6" separation criteria i
which has been applied to these cabinets had been violated without
l identification by the quality control organization. Again, it was found.that coils of wire, one or two coils, for each indicating and/or actucting device were suspended under the consoles and in some i
instances constituting a confused mass of wiring making the verification of separation impractical, if not impossible.
There is no method, without removing the cable terminations at both ends, to verify that there
,
is not channel mixing. There is no code or standard that we are aware
'
of that addresses equipment internal wiring, however, the coiling of wiring as described above precludes a valid determination relative to separation between channels.
10.
Sensors, Instruments, and Associated Lines The UE&C Construction Procedure MCP-14 has been prepared and is in use.
This procedure, however, requires verification that the sensors and/or instruments used in the detection of system abnormalities be verified for conformance with drawings.
There is no guidance relative to the design objective separation of redundant sensing line and sensors.
Consider-able effort is expended in assuring that the power, control, and in-strument wiring maintains a minimum separation. The design objective separation of the cables is described in the FSAR and in the Architect-Engineers Specifications, however, no reference to sensors and sensing lines could be identified. There is no means of establishing a quan-
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titative or qualitative criteria for inspection.
1647 533
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11.
Construction Deficiency Recorts Subsequent to the inspection it was found that the four engineered safeguards pumps, BSPIA, IB, DHPIA, and IB, which were installed without notification of the quality control organizations, were damaged during the flood on or about June 23, 1972.
There was no reported flood damage during our inspection of June 21-22, 24-25, 1972, ("O Report 50-289/72-11) and a negative reply to our letter of June 27, 1972, requesting information relative to flood damage.
12.
Borated Water Storace Tank RT Inspections The inspector reviewed the PDM radiograp?^s technique procedure No.1 for contract 10146 dated September 6, 1972. The technique l
procedure was signed by the PDM QA Manager and included the re-In addition, records quirements of the above referenced contract.
were reviewed to indicate that UE&C QC had reviewed all radiographs
!
for the borated water storage tank and found them to be of satis-l
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factory quality. This item is considered resolved.
t Borated Water Storace Tank, Carbon to Stainless Steel Hold-down i
13.
,
Clips i
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The inspector reviewed a B&R deviation report No. 72 dated September 26, 1972 relative to the use of carbon steel hold-down
'
clips on stainless steel plate for the borated water storage tank received on site May 9, 1972.
The deviation report indicated that i
PDM had removed the carbon steel traces by buffing and cleaning the affected plates.
This action is documented in a PDM report dated September 26, 1972.
In addition, records were reviewed to indicate that B&N had reviewed other B&W site receipt inspection reports to determine if similar unresolved problems were indicated.
e
'
This review did not reveal any other open items.
This matter is'
considered resolved.
14.
Borated Water Stora2e Tank Cleanine with Prohibited Solutions
.
The PDM Cleaning Procedure No. CP-1 allowed the use of acetone as a cleaning material on the borated water storage tank.
UE6C Site Procedure No. MCP-3 prohibited the use of acetone on the Three Mile Island' site.
The licensee stated that from an engineering se'nd-point acetone is allowable as a cleaning agent, however, UE6C alected to prohibit its use as a safety precaution.
Documeatation was reviewed to indicate that all site subcontractors had oeca in-formed of the prohibition of use of acetone as a cleaning agent.
This item is considered resolved.
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15.
Lack of Procedures Prior to Start of Work The inspector verified that UEEC Construction Memo dated October 11,
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1972 reminded UE&C Purchasing that they should make sure that con-tractors understand, that formerly approved procedures must be available prior to start of work governed by these procedures.
The
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inspector reviewed several QC check lists which indicated that the field QC personnel munt assure that formal approval of procedures has been obtained prior to start of work.
This item is considered resolved.
16. Borated Water Storage Tank Inspection The inspector reviewed final inspection records performed by PDM
'
l to indicate that the outside and inside of the tank had been cleaned in accordance with PDM cleaning procedure CP-1 and welding specifica-tion WPS-48.
In addition, UE&C QC records were reviewed to indicate verification that the tank had been inspected and found to be in
'
j accordance with the above specifications.
Records were reviewed to indicate that subsequent to this inspection, however, welding in the vicinity of the borated water storage tank had caused additional I
weld splatter and a nonconformance report (NCR) had been issued for this item.
RO:I will review the resolution of this NCR during sub-l{T
/
sequent inspections.
17.
Borated Water Storace Tank, construction code
.
The ' inspector reviewed FSAR Amendment No. 36, dated February 9,1973, page 6-24 which indicates that the field erection welding require-ments were in accordance with Section VIII of the ASFE Boiler and Pressure Vessel Code.
This item is considered resolved.
.
18.
Corrective Action The inspector reviewed records to indicate corrective actions had
,
been completed per the following table:
Audit No.
Date of Audit Date of Resolution 72-1 12/28-29/71 Cleared 8/29/72 72-3 *
2/15/72 Cleared 9/19/72 72-5 4/12/72 Cleared 8/29/72 The inspector also reviewed a nonconformance report relative to incorrect alloy of steel plate for the fuel storage liner.
The specification called for ASI}t A240 material and the =aterial re-ceived was ASTM A167 material.
The specification was changed by the designer and the NCR was closed on December 27, 1972.
The l
above items are considered resolved.
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f 19.
Pioe Weldinn Defect History The UELC welding engineer produced field change #QC-33 dated October 3,1972 which is a revisien of the US&C Procedure QC-8, revision 6, " Pipe Welding Control." This now contains a require-
,
ment for the documentation of defect removal verification and in-j cludes a revised history record form which provides for the docu-
l mentation for this information.
20.
Materials certification for B&W Supolied Pipe t
j During this inspection, the UEEC quality control records clerk was i
able to produce the complete B&W Met Ed Three Mile Island piping fabrication report #620-0005-50 which covers all records, quality i
j control and fabrication documentation for the 28" and 36" piping.
The record package covering the 2 " core spray piping and the 10" l
pressuri::er surge line piping was also made available for review.
This included the following: Cert.ification of conformance to the
,
B&W specification and ANSI B31.7 piping code.
Complete stress re-ports in accordance with the requirements of ANSI B31.7 piping code, The B&W attested by a professional engineer for the State of Ohio.
The B&W QA Department Final quality assurance release for shipment.
.
Quality upgrading and document review for non-destructive testing ('
and Class C cleanliness as well as final release for shipment.
Welding material records by welders No., heat, lot, type, including
"
ferrite control information. Welding control records covering each welding operator, each wld, each material joined, each weld method, including qualification documents for each welding procedure and A full package of "as-built" dimensional drawings welding operator.
covering each pipe spool utilized in the reactor coolant pressure i
The NP-1, Partial Data Sheet for each pipe spool boundary systems.
A listing of all i
signed off by the Hartford Steam Boiler inspector.
contract deviations, their disposition and approval by the material
,
review boards. Complete material certificates covering tests for chemical and physical characteristics for all material used as well
,
as the test for bonds on DETA (Dupont Corporation Exposure Bonded cladding) including dye penetrant, ultrasonic inspection for bonding
.
in accordance with B31.7 code case 1338-3. Welding procedure, re-pair procedures, including records and re-inspection techniques.
B&W non-destructive testing shop specifications and procedures.
During'the review of the NP-1 Partial Data Sheets signed by the Hartford Steam Boiler Inspectors, it was noted that the forms covering the 28" and 36" reactor coolant piping, included not only a statement of compliance to ANSI B31.7 but also a confor.ance to the Pennsylvania Special Standard WC-1891.
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l 21.
Use of Lime Coated Electrodes
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l This item is considered closed since the UE&C site welding engineer and QC records clerk pointed out an error in transcription from
,
one welding material test certificate to another showing that welding rod identified as E-308 were actually welding rod E-16-8-2 which accounts for the lower and acceptable chromium and nickel content in this heat of electrodes.
During a further research of the records it was verified that the heat of electrodes which shwed i
i a lower chromium and nickel chemical content was identified as E-308 when it should have been E-16-8-2.
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22.
Radiograph Examination Ecuipment
'
a During this inspection the RO:I inspector observed that the Conam Testing Agency now have a completely equipped radiographic inspec-tion laboratory, including a HI-intensity viewer and a densitometer l
for measuring and comparing film density to the requirements of
'
B31.7 piping code.
.
23.
Sockolet Fillet Welds These fillet welds attaching a sockolet to a downcomer header in
]
the decay heat system did not meet the requirement of ANSI B31.7, paragraph 1-727.4.4.
Since identification of this item by the RO:I inspector, these welds have been repaired by grinding the observed undercutting to properly blend this weld into the contours des-
!
cribed in the above paragraph of B31.7.
In addition, the UE&C l
welding engineer produced a manufacturers specification from the j
supplier to the sockolets which advised that particular care must be exercised in installing ::hese sockolets to large diameter piping,
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in order to avoid undercutting and notch effects.
This information i
had not been previously available to the welding foreman who has a
copy in his possession for guidance in future welding in this type i
of joint.
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24.
Transweld Weave on Pipe Socol CF-1 The inspector observed during his inspection that this weld No. CF-1 has now been ground to a mirror-like surface finish in order to provide a suitable surface for the automated in-service inspection of the reactor coolant system.
The UE&C welding engineer produced records showing that ferrite-scope readings indicated that there was
to 7/. delta-ferrite in the weld.
Hardness tests using portable equipment verified that probable overheating of the weld by this trans-weld weave pattern had not produced a surface hardness in excess of that normally found in stainless steel welding.
The data provided by these investigations was evaluated by the UE&C welding engineers who concluded that this weld had sustained no
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detrimental effects from the probable overheating.
1647 337
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21.
Use of Lime Coated Electrodes This item is considered closed since the UE&C site welding engineer and QC records clerk pointed out an error in cranscription from one welding material test certificate to anocher showing that welding rod identified as E-308 were actually welding rod E-16-8-2 which accounts for the lower and acceptable chromium and nickel content in this heat of electrodes.
During a further research of the records it was verified that the heat of electrodes which showed a lower chromium and nickel chemical content was identified as E-308 when it should have been E-16-8-2.
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22.
Radiocraoh Examination Eculement During this inspection the RO:I inspector observed that the Conam Testing Agency now have a completely equipped radiographic inspec-tion laboratory, including a HI-intensity viewer and a densitometer for measuring and comparing film dencity to the requirements of
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B31.7 piping code.
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23.
Sockolet Fillet Welds These fillet welds attaching a sockolet to a downcomer header in
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the decay heat system did not meet the requirement of ANSI B31.7,
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paragraph 1-727.4.4.
Since identification of this item by the R0:1 inspector, these welds have been repaired by grinding the observed undercutting to properly blend this weld into the contours des-cribed in the above paragraph of E31.7.
In addition, the UE&C welding engineer produced a manufacturers specification from the supplier to the sockolets which advised that particular care must be exercised in installing these sockolets to large diameter piping, in order to avoid undercutting and notch effects.
This information had not been previously available to the welding foreman who has a copy in his possession for guidance in future welding in this type of joint.
24.
Transweld Weave on Pipe Spool CF-1 The inspector observed during his inspection that this weld No. CF-1 has now been ground to a mirror-like surface finish in order to provide a suitable surface for the automated in-service inspection of the reactor coolant system.
The UE&C welding engineer produced records showing that ferrite-scope readings indicated that there was 6 to 7% delta-ferrite in the weld.
Hardness tests using portable equipment verified that probable overheating of the weld by this trans-weld weave pattern had not produced a surface hardness in excess of that normally found in stainless steel welding.
The data provided by these investigations was evaluated by the UE&C
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welding engineers who concluded that this weld had sustained no
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detrimental effects from the probabic overheating.
1647 338
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Since the Grinnell piping and weld procedures limit weld weave
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patterns to a dimension equal to four times the electrode diameter, this nonconformance to their own procedures is being reviewed by UE&C with the Grinnell Corporation.
The licensee representatives have stated that as soon as this problem is resolved with Grinnell they will advise the RO:1 inspector so he can review the documentation f
which resolves this problem.
l 25.
Delta-Ferrite Content - Grinnell Shop Welds
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l The answer which was received from Grinnell Corporation concerning i
this deficiency was vague. A 1007. Ferrite-scope inspection was
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conducted on the surface of each shop weld made by Grinnell on i
stainless steel piping provided by that supplier. The UE&C welding
engineer produced records of this inspection which verified that in no case was the delta-ferrite content of the deposited metal less than
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6%.
In addition, Gilbert Associates conducted an engineering evalu-ation of this material which res.ulted in a conclusion that based on
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the Schaeffler diagram, each of the Grinnell shop welds contained l
from 6 to 8% Delta-ferrite.
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26.
Electrical Nonconformine Condition Deficiencv Reports
f(s)
UE&C Procedure QC-17, paragraph II, B1, states in part, "Noncon-
formance includes activities, materials and equipment whose con-i
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dition does not comply with the applicable... specification".
It was found that deficiency reports and/or engineering deviation re-quests had been prepared for.approximately 100 instances where the
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separation criteria had been v'iolated.
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27.
Closure of Opening Between Control Room and Cable Spreadine Room
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Drawings are presently in preparation describing the technique and method to be used to provide a fire barrier between the opening and the bottom of these panels and the cable spreading room below.
This i
will be carried as an outstanding item.
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28.
Common Ventilation System for Batterv Rooms Further inspection of the ccamon ventilation system for the two battery rooms will be deferred until such tima as it is determired that the description in the FSAR is acceptable to the Directorate of Licensing.
29.
Use of Electrical OC Check Lists UE&C Procedure ECP-3, Addendum A, dated March 2, 1973 states in part:
"While performing inspections, the inspector will carry a ( ',
copy of ECP-3.
While inspecting and/or witnessing the receiving, 1647 339
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storing. and/or installation of the equipments, notes will be made as required...".
It was found that the inspectors do have copies of Procedure ECP-3 which have been reduced to pocket size.
While field notes are not maintained after preparation of the i
check list, it was found that field notes not yet transcribed were comprehensive.
In order to verify the adequacy of the in-spection program, cable tray 148 which contains 139 circuits
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were inspected to assure that all cables in this tray were either engineered safeguards designation "a" or non-engineered safe-guards cables.
In addition, all non-engineered safeguards cir-cuits and engineered safeguards circuits in this tray were veri-fied on the computer run to assure that they were not routed in an engineered safeguard designation, other than "a".
Engineered safeguards cable designated CG-202, which appeared on the computer run for cable tray 148, was electronically verified throughout its entire run.
Field run conduit, system "WG", safeguards channel "a"
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which contained cable designations 1CQ421a, 1CQ521a, RP493a, RP541a, was inspected and all cable in this conduit were identified in the cable schedule as engineered safeguards designation "a".
System
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"WL" field run conduit was also ' verified and found correct.
No
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deficiencies were found.
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30.
Supplementarv Heat for High Pressure Iniection Pumn Motors I
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All motors were now found to be in a controlled environment which i '
does not require supplementary-heat as defined by the UEEC
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Procedure ECP-6.
i 31.
Calibration and Testine of Instrumentation Precedure MCP-13 was reviewed and was fcund to require four calibration points except where modules, control valves, and posi-tion switches are calibrated to vendor requirements. The elec-trical quality control does not have a list of such equipment nor is there any quality control task assigned to the calibration of instruments.
32.
Vertical Cable Trav Covers
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A general note has been added to the electrical drawings indicating that all vertical trays shall have solid covers to 6 feet above their. floor penetrations.
This item has been added to the check list under UELC Procedure ECP-8.
This item will be carried as an outstanding item pending verification that barriers, as described in paragraph 8.2.2.11b of the FSAR, has been verified.
33.
Cable Trav Loadine The UESC Procedure ECP-3 requires tray loading verification.
This will be carried as an outstanding item to assure that all e
engineered safeguards trays have been evaluated.
Tray 149 shows 1647 340
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approximately 507. fill o n the cable run schedule while the physical fill is in excess of 807., however, this tray had not yet been evalu-
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ated by the quality control organization.
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i 34.
Receipt Inspection
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Reactor Pressure Sensing Actuators, identified as RK-18 which were selected for random inspection during the preceding inspection were found to constitute a part of the larger device in which they are contained.
Receipt inspection on the individual sensors will not be performed but rather the receipt inspection for the cabinet and
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all associated equipment in the cabinet was performed as a single i
unit.
35.
Internal Audits
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a.
GPU and 1TR Audits
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The inspector reviewed the fo'110 wing audit reports to verify compliance with the requirements of the ihree Mile Island Quality Assurance Plan.
No deficiencies were identified.
Audit Date Subject Findings Resolution
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11/27 - 12/1/72 Drawing Control
Satisfactory; Verified 12/18/72
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l'/1-4/72 (72-15)
QA Records
Satisfactory; Verified 1/3/72
11/24 & 12/11/72 UE&C QC Files
Satisfactory; (72-16)
Verified 1/15/72 12/13-14/72 (72-17)
Drawing Control
Satisfactory; Verified 12/9/72
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(72-18)
UEEC Documentation
Satisfactory; Status Verified 2/9/73
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1/2-5/73 Cable Tracing
Not yet resolved
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(73-1)
Resolution: 3/28/73 b.
Gilbert Associates. Inc. (GAI) Audits The inspector reviewed the GAI audits No. 41 and No. 81 relative to Engineering Change Request (ECR) conducted on August 12-27, 1971 and November 27, 1972, respectively.
The results of Audit
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l No. 41 were not satisfactory and records of resolution were re-i647 34I
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viewed for the period September 12, 1971 to August 29, 1972 at which time satisfactory resolution of the problems was documented. Audit No. 81 was conducted during the period October-November, 1972. The results of this audit were con-sidered unsatisfactory but were satisfactorily resolved on February 20, 1973.
This area is the subject of a reaudit scheduled for April 1, 1973.
No deficiencies to QA program requirements were identified, c.
United Eneineers and Constructors (UE&C) Audits The inspector requested information relative to internal audits
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conducted by UE&C in accordance with Procedure QC-15.
The
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portionsof QC-15 relative to the " Response to Owner's Audits and A/E Surveillance Reports" were reviewed as part of the audits described in paragraphs 35a and b above. The portions relative to internal audits were stated by site personnel to
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have not been implemented; however, a schedule was produced to indicate the requirements would be implemented during the period April-December,1973 which, if accomplished, will
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satisfy the requirements of QC-15 requiring annual audits in
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the areas of field purchase control, field QC group activities, field engineering office activities, craft construction opera-j tions and subcontractor activities.
Some of the above areas are included in QC audits performed of construction activities and have been performed.
Procedure QC-15 was recently revised to include the internal audit function and that portion has not yet been implemented. This. matter will be reviewed during sub-sequent inspections and is considered unresolved.
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1647 342
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