ML19210B563

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Responds to AEC Re Violations Noted in Insp Repts.Corrective Actions:Began Revision W/United Engineers & Constructors,Inc of Site Drawing Control Sys & Revision Completed of Applicable Storage Procedure
ML19210B563
Person / Time
Site: Crane  Constellation icon.png
Issue date: 09/28/1972
From: John Miller
Metropolitan Edison Co
To: O'Reilly J
NRC Office of Inspection & Enforcement (IE Region II)
Shared Package
ML19210B558 List:
References
NUDOCS 7911110007
Download: ML19210B563 (3)


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. Mu (ROPOLITAN EDISON COMPANY SUS $10MRY OFGENERAUUBUCUNUDESCORPORAHON 3ST OFFICE BOX 542 READING. PENNSYLVANIA 19603 TELEPHONE 215 - 929 3601 g

September 28, 1972 I

I Mr. J. P. O.'Reilly Director, Region 1 Directorate of Regulatory Operations U. S. Atomic Energy Commission 970 Broad Street Newark, New Jersey 07102

Subject:

Three Mile Island Nuclear Station Resolution of AEC Findings Regarding Document Control and Storage of Non-conforming Material

Dear Mr. O'Reilly:

1

'v Your letter of August 29, 1972, refers to inspections performed by AEC-DRO personnel at the TMI site during July 11 to 14, 1972.

Your letter indicates that there were two areas noted where activities at the TMI site were in apparent nonconformance with the AEC quality assurance criteria in Appendix B to 10 CFR 50.

These apparent nonconformances, and our resolu-tion of them, are as follows:

1.

Finding A randem check of drawings in the field indicated that 31% of

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i the drawings were superseded and 26% were illegible as to title, revision number, or drawing number, and their status could not be determined.

Resolution Earlier this Spring, our own quality assurance surveillance system had alerted us to the need to upgrade the site drawing centrol system, and we had initiated corrective action with United Engineers and Constructors (UE&C). Our review of drawings in the field has indicated that many of the out-of-date or illegible drawings were being retained for informational purposes rather than for control work. We recognize that this should have been indicated on the 1566 203 7911110CO7

v 2-drawings. We have essentially completed a thorough upgrading of the drawing control system at the TMI site to ensure that all drawings used to control work are up-to-date and all informational drawings are clearly identified as not being for construction.

This upgrading included:

Detailed auditing of documentation control at the TMI site a.

was performed to identify the areas requiring correction.

b.

Revisions and clarifications have been issued to the UE&C procedures for drawing control and for control of QC procedures.

I The Gilbert Associates and Burns & Roe master drawing lists c.

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are being clarified to-facilitate drawing centrol.

d.

Each UE&C construction organization has thoroughly reviewed their drawings to assure that only up-to-date drawings are 1

in use.

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UE&C has re-emphasized to their construction supervision e.

the need to follow document control procedures. In this regard, the responsibilities for keeping documents up-to-date in each construction department have been clarified and documented in the applicable UE&C procedures. Addi-tional document control personnel have been assigned to h

.this work.

f.

Re-audits have been and will again be performed to assure that the upgraded document control system is effective.

2.

Finding The designated quarantine storage area at the site contained items which were not in a' hold status. In addition, it was noted that tagged nonconforming items were in storage outside of the quarantine area.

Resolution The applicable UE&C storage procedure has been revised to emphasize that only " Reject" items shall be stored in the " Reject" storage The procedure has also been revised to emphasize that, while area.

items on " Hold" are not given se*regated storage, their storage g

locations are logged and they may not be released frem storage ex-cept on a waiver basis as permitted by the procedure for control of nonconforming material.

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(,'i In regard to storing all reject items in a segregated " Reject"

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storage area, this is sometimes not practical, e.g., for large vessels. The applicable UE&C procedure requires use of segre-gated sto' rage when practicable.

We consider that the above actions satisfactorily resolve the findings in your letter of August 29,.1972.

Very truly yours, i

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. G. Miller V ce President l

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