ML19220A684
| ML19220A684 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/16/1977 |
| From: | Arnold R Metropolitan Edison Co |
| To: | O'Reilly J NRC Office of Inspection & Enforcement (IE Region I) |
| References | |
| NUDOCS 7904240106 | |
| Download: ML19220A684 (5) | |
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METP.OPOLITAN EDISON COMPANY sues iov o= ce.sent puetic uritiries cosranariou POST OF flCE 00X 542 READING, PENNSYLVANI A 19603 TELEPHONE 215 - 929-3601 March 16, 1977 f m GQL 03h0 C'
G Regulatory Docket File oj Y
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Mr. J. P. O'Reilly hg'
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U. S. Nuclear Regulatory Con =ission p
Office of Inspection & Enforcement
- -jC Region I 7
631 Park Avenue
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it" King of Prussia, PA 19406 w
Dear Sir:
Three Mile Island Nuclear Station Unit 2 (TIE-2)
License No. CPPR-66 Docket No. 50-320 Inspection Report No. 50-320/T7-02 This letter is in response to the subject inspection report resulting from Mr.
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Narrov's inspection of January 10 through 13, 1977 and the findings thereof.
Response is given below to the infractions identified in the report.
Aprarent Infraction 77-02-01:
Ronconforming conditions in Energency Feedvater and Main Steam Lines.
" Contrary to 10CFR50, Appendix B, Criterion I, Sections of the emergency feedvater and =ain steam lines which had been accepted by Field QC did not confor= to the drawings and specifications."
Respense to Antarent Infraction (Energency Feedvater):
The energency feedvater line had been inspected for phase I turnover and accepted. The NRC inspector found that hanger EFH-h5S did not have the clearance specified on Bergen-Paterson Drawing No. 1691-1. Eanger EFH-h55 had been previously inspected during QC phase I inspection and was found to have been installed in accordance with the require =ents of Bergen-Paterson Draving No.
1691-1. However, at the time of phase I inspecticn, the piping was not complete in that certain spool pieces were missing (as documented on the phase I punch list). Subsequent to the QC phase I inspection, but prior to the NRC inspection,-
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the piping department installed =issing spool piece 2-EF-33 It is concluded that during this installation the clearance on hanger ETH kSS was changed.
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g Mr. J. P. O'Reilly March 16, 1977 GQL 03ho Corrective Action Taken:
Ranger EF-45S has been re=cved and vill be reinstalled and reinspected to meet the drawing requirements.
Restonse to Arearent Infraction (Main Stea=):
The QC phase I inspection of the main stea= line had not been co=pleted at the ti=e of the NBC inspector's review; therefore, this item is not considered to be an infraction.
While condition noted by the NRC inspector did exist, neither the piping construction iL;pector nor the QC piping inspector had completed their inspection or accepted the syste=.
Corrective Action Taken:
No specific corrective action is required.
Corrective Stecs to Avoid Further Items of Nonec=nliance (Energency Feedvater):
An evaluation vill be =ade during QC phase I inspection to deter =ine specific ite=s which could be changed when inco=plete work ite=s are acco=plished.
These ite=s vill be noted on the phase I punch list for reverification after co=pletion of the unfinished work by construction.
Date When Dull Co=cliance Will be Achieved (Energency Feedvater):
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Co=pliance vill b; achieved on April 15, 1977 Apuarent Infraction 77-02-02 Nonconfor=ing Cable Installation
" Contrary to 10CFR50, Appendix B, Criterion I, certain cable runs which had been accepted by Field QC did not confor= to specification requirements and installation of some cables had been accepted.vithout approved dravings or specification requirements."
Resconse to Accarent Infraction (Part 1):
UE&C Electrical Construction had installed rods across the open side of the vertical cable tray as te=porary tie points so that additional cable could be added to the trays. The QC inspector had not noted these rods and ties on the inspecticn report as te=porary.
Corrective Action Taken:
A reinspection has been =ade of all engineered safety feature vertical cable ~ -
trays to document where te=porary tie rods vere used and Deviation Report 068h hn been issued to identify the nonconforming conditions.
The disposition of Ieviation Report 068h requires that, upon ec=pletion of cable tray fill for cach of the listed trays, the te=porary rods shall be rencved and the cables
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tied to the tray rungs according to Engineer-Approved crecifications.
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- March 16, 1977 Mr. J. P. O'Reilly GQL 03h0 Besconse to Acrarent Infraction (Part 2):
UE&C Electrical Construction had secured some cables to the inside of a cabinet using taped metal supports bolted to the cabinet. These supports were not shown on the Burns & Roe drawings and Burns & Roe approval had not.been obtained.
Corrective Action Taken:
The UE&C Electrical Construction Department vill request Engineer review and approval to e= ploy the supports as built.
Corrective Stens to Avoid Further Items of Nonce =nliance 1.
UE&C Electrical Construction is revising Procedure ECP-3-2 to permit the use of te=porary tie down rods until all cables are pulled in these trays.
2.
QC Electrical Inspection personnel have been instructed to be especially observant of conditions not in accordance with engineering drawings and specifications and to document any such conditions identified.
The in-spectors have also been instructed to report proble=s noted to the QC Engineer or to the Supervisor-Quality Centrol so that required action is initiated in a timely e ner.
Date Full Co=cliance Will be Achieved Compliance vill be achieved on March 30, 1977 Antarent Infraction 77-02-03 Electrical Construction Procedures not in Confor=ance with Specifications.
"Contran to 10CFR50, Appendix B, Criterion V, Procedures ECP-3-2 and ECP-8-2 do not.onform to specification 2555-T0 and a cable termination accepted by field QC did not =eet specification requirements."
Restense to Annarent Infraction:
We do not concur that the conditions observed by the NRC inspector constitute an infraction of 10CFR50, Appendix B, Criterion V.
Paragraph Sa of the inspectors detailed report concerning fire barrier caterials states the QC checkoff list of Procedure ECP-8-2 does not conform to Burns & Roe specification 2555-70.
ECP-8-2 and the associated QC checklist was initially written to conform to the original issue of Burns & Roe specification 2555-T0.
In May 1975 Eurns &
Roe changed the require =ents for the fire barrier material and issued ECM 2671. Using establishe 1 procedures for acting on ECM's, the revised material vas purchased, QC receipt inspected and QC released for construction. It is TMI-2 site practice to revise construction procedures when the specification is revised.
In Nove=ber, 19T6, Barns & Roe issued a revision to specification 2555-T0 which incorporated ECM 2671.
ECP-8-2 had not been revised at the time Q
of the NRC inspection; however, this 6h day delay is not. considered to be seriously delinquent since installation had not started. The pro,cedure has subsequently been revised.
l'.r. J. P. O ' Reilly k-
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- March 16,1977
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GQL 03hD Paragraph Sb of the inspectors detailed report describes the inspector's observation that ECP-3-2 did not confor= to Burn's & Roe specifica^iun 2555-70 and that cables in circuit hH30P had been accepted by the QC inspector vithout heat shrink irsulation.
In March, 1976, Burns & Roe issued ECM 3L16 which established the require =ent for the heat shrink insulation. Burns & Roe specification 2555-70 was not revised to incorporate this ECM until Nove=ber,1976.
The ECP was not revised when the ECM vas issued as explained above.
However, a normal part of the QC phase I inspection is a separate reviev =ade to ensure that appropriate inspections are performed to deter =ine cespliance with outstanding ECM's.
At the phase I Inspection of circuit EH30P this was done and the QC inspector had in fact rejected the circuit for lack of heat shrink insulation.
Action Taken:
ECP-8-2 has nov been revised to comply with Burns & Roe specification 1.
2555-70.
2.
ECP-3-2 vill be revised to comply with Burns & Roe specification 2555-70 by Ma: ch 30, 1977 3
An inspection for heat shrink insulation has been added to the phase I QC checklist for electrical inspections.
Stens Taken to Avoid Future Recurrence None required.
As construction activities focus more on tasks leading directly to fuel loading and eventually to ro ercial operation, we are as concerned as the NRC that these schedule pressures not result in any degradation in the Quality Assurance program at TMI-2.
Both Quality Assurance and Project Management personnel are cdtted to see that degradation does not happen.
Since Dece=ber 1976 ve have taken the following specific steps:
1.
A total of 15 first level inspection personnel have been added to the TMI-2 Quality Control staff.
This increase has been predominently in the electrical / instrumentation area (9).
2.
One additional Quality Assurance Engineer has been assigned to the phase I documentation review and turnover activity.
3 Overti=e has been authorized for Quality Assurance Engineers to insure thoroughness of review and nini=u= quality risk from schedule pressures.
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Specific policy guidance has teen reiterated to QC inspection, and site construction and manage =ent functions, concerning proper interfac.ing of- - -
construction ~ and test schedules with site quality control. This policy
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attempts to =inimize schedule pressure on first level inspection personnel.
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- March 16, 1977 M:. J. P. O ' Reilly GQL 03ho 5
The activity of the third level Site Quality Auditing group has been increased and the staff au6:ented. Dedicated auditing in the electrical area has been initiated.
We vill continue to review critically the activities at TMI-2 and to increase managenent attention to this important area as va.rranted.
Very truly yours, Signed - R. C. Arnold R. C. Arnold Vice President RCA:JRS:kl cc:
Dr. Ernst Volgenau, Director Office of Inspection is Enforcement U. S. Nuclear Regulato:/ Cc-4ssion Washington, D. C.
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