ML19220A813

Responds to NRC Re Reporting Reuqirements of 10CFR50.55(e).Util Believes Deficiency Reporting Procedure Met Both Ltr & Intent of 10CFR50.55(e)

ML19220A813
Person / Time
Site:	Crane
Issue date:	11/12/1975
From:	Arnold R Metropolitan Edison Co
To:	Robert Carlson NRC Office of Inspection & Enforcement (IE Region I)
References
GQL-1698, NUDOCS 7904240638
Download: ML19220A813 (4)

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r CFFICE EOX 542 REACING. PENNSYLVANIA 106:3 TE LEPHCNE 215 - 973-:601 November 12, 1975 GG 1698 Mr. Rober: T. Carlson, Chief Facility Constrac:icn and Engineering Support 3 ranch Office of Inspecticn and Inforcemen U.S. Nuclear Regulatory Cen=ission Region I 631 Park Avenue King of Prussia, Pennsylvania 19406

SUBJECT:

TEREE 1CLE ISI.AND NUCI. EAR STATION CNIT 2 DOCKET ND'3ER 50-300 REPORTING DEFIC'ENCIES IN ACCCRDid*CE WITH 10 CFR 50.55(e)

This is in respense to ycur letter of August 21, 1975, which excressed views en the intent of the reporting recuirenents of 10 CFR 50.55(e) and cur co=cliance.with the of a Notice of Viola:icn to Me:-Ed in July of this year. intent of these require:

In that let:er you stated that while adequate procedures exist at DE-2 to respond to the requirements of 10 C7R 50.55(e),

this instance dces not appear to meet 1 plementatien of our precedures "in discussed iu =cre detail belcw, we interpre:the inten of the Regulatiens."

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and do not agree that our reporting actions which werese._ien 50.55(e) differently l

the subject of the noticed violation were inconsistent with either the intent or,

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letter of sec tion 50.55(e).

indeed, the l

J, TMI-2 currently is under construction.

t Durin, the constructicn of this plant, as is :he case with all nuclear f acilities, discovered numerous deficiencies, suspected deficiencies, or potential there have been i

deficiencies in design and construe:1cn.

l incensequential to significant in nature and are recorded, evaluatedThese deficienc resolved and reported accordingly.

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Mr. Robert T. Carlsen f hief

'. Facility Cons tructien and Page 2 Engineering Support 3 ranch There are two basic =ethods by which NRC keeps abreast or construction activities and their attendant proble=s.

First, and principally, NRC on a periodic but f requent basis, conducts en-site inspections of the facility and its records. Every f acet of a licensee's operaticas and records, including documentation related to inconsequential and significant deficiencies alike, is subject to an NRC inspector's rev_ew.

Mcwever, not every activity nor every docu=ent is actually reviewed and while probably every ccustruction proble= of consequence is reviewed ul:i=ately by NRC inspectors, there =ay be sc=e ti=e lag between such problem's actual occurrence and its resolution, and NRC's initial awareness and review of the probles.

In order to ec=ple=ent dependence on the inspection syste= alene to ensure NRC pru=pt recognition of significant deficiencies uncovered in the cotrse of construe:1cn of a plant, NRC e= ploys through 1:s regulatory require =ents of licenseas a second basic =ethod for staying infor=ed --

the require =ent set cut in 50.55(e) that holders of construction pe:=its promptly notify NRC of certain specified significant deficiencies.

The Cc==ission, however, carefully circu= scribed in 50.55(e) those occasions which trigger the prc=pt notifica:icn require =ents.

Thus, this reporting is 11=ited to a deficiency:

"... which, were it to have re=2ined uncorrected, could have affected adversely the safety of operations of the nui. ear power plant at any ti=e throughout the expected lifetime of the plant, and which represents:

(i) A sf rnificant breakdown in any portion of the quality assurance progra conducted in accordance with the require-rents of Appendix 3; or (ii) A sienificant deficiency in final design as approved and released for censtruction such that the design does not conform to the criteria and bases stated in the safety analysis report or construction per=it; or (iii) A sienificant deficiency in construction of or significant damage ta a structure, syste=, or ce=ponen: which will require extensive evaluation, extensive redesign, or extensive repair to meet the criteria and bases stated in the safety analysis report or construction per=it or to c:herwise establish the adequacy of the s:ructure, system, or cc=ponent to perfor= its intended safety function; or (iv) A sienificant deviation frem perfor=ance specifications which will require extensive evaluation, ex:ensive redesien, or extensive repair to establish the adequacy of a structure, system, or ccmponent to meet the criteria and bases stated in the safety analysis report or construction per :i:

g gg or to otherwise establish the adequacy of the s:ruc:ure, syste=, or co=ponent to perform its intended safety function."

10 CFR 550.55(e) (e:phasis added).

Mr. Robert T. Carls Chie f Facility Cocscructi.

3rau-n Engineering Suppor:, nd a

Page 3 There are in effect at TMI-2 procedures we believe co= port co=pl: <

y with the require =ents of 50.5f(e) and, if cc= plied with, assure pro =;

notification to NRC of repot table deficiencies.

In your letter of August 21, you concurred that our procedures are adequate.

It is our view that our i=ple=entatica ei these precedures, too, is consistent with 50.55(e) and the intent of that regulation. You have indicated that "i=ple=entation of these procedures in this instance does not appear to =eet the intent of the Re gula tions."

While the facts surrounding the July 9 Notice of Violation have been spelled out in several exchanges of correspendence and there does not appear to l e any substan:ial difference of cpinion as to the=, we wish to reitera:e here the principal relevant events which have occurred since May.

During the baseline in-service inspection of reactor coolant pu=p fasteners in late May,1975, linear axial indications greater than one inch in length on sc=e nuts and studs were detected by =agnetic particle inspection.

This apparen: noncenfor=ity with inspection acceptance standards was docu=ented by a si:e deviation report and called to the attention of the pu=p supplier, who was requested to verify the results of the tests. I: was anticipatad that the indicatiens veuld not prove to be relevant but confir=2:icn was necessary.

In nugust, 1975, the pu=p suppliet, on the basis of a repea: exa= int ' ion using the original =agnetic particle test irecedure and a subsequen: liquid penetrant inspection of the surfaces of se4.eral nuts and studa, concluded tha: the initial indications were irrelevant and that the studs and nuts =eet applicable code require =ents.

During the interi=, hcwever, en June 24, 1975, the project =anager at TMI-2 notified your office by telephone, of the eniscence of the indicatiens and that engineering verifica:10n was unders r'.

This notification resulted in Met-Ed's being cited for its failure to ce= ply with see:1cn 50.55(e),

specifically, for its failure r rotify NRC =cre pr:=p tly of the axial linear indications ini:iale "Jererved in May.

The project =arager's notification of your office on June 24 was not

=ade because the indications were significant, repertable ite=s under 50.55(e). We maintain that they were not 50.55(e) deficiencies in May when they were first detected and, in fact, never =atured into reportable deficiencies. The indications did not constitute:

(1) a significant breakdcun in any portien of the quality assurance progra=; (ii) a signifi-cant deficiency in final design as appreved and released for construction; or (iii) a significant deficiency in construction of or signif f cant da= age to a structure, syste=, or ce=ponent.

In our view, they were indications of a persible proble= which was subject to engineering verification and would caly have constitu:ed deficiencies reportable under 50.55(e)(iv) had the subsequent tests confir=ed that the s tuds and belts had significant deviaticas fro: perfor=ance specifica:icas - ich sculd have required extensive evaluation, extensive redesign, c: extensive repair to establish their adecuacy to =ce: the cri: aria and bases stated in rhe safety analysis report or construction permit or to otherwise establish their adecuacy to perfor= their intended safety function.

The indications al: e did not W 056

Mr. Robert T. Carlson 'thie'

, ' Iacility Cons truction and Page 4 Engineering Support 3 ranch constitute a significar.t deviatica from performance specifications and our request of the pu=p supplier to perfors con ##-~4ag or verifying tests on the studs and bolts did not a=ount to a request for extensive evaluation, extensive redesign, or extensive repair to establish their adequacy.

Had those tests confir=ed the relevance of the initial indications and extensive engineering evaluation, extensive redesign, or extensive repair been necessary then to establish the adequacy of the nuts and studs to perfor=

their intended safety f unction, they =ay well have constituted a reportable ites under 50.55(e). This, however, never proved to be the case.

The June 24 telephone call was intended to keep NRC co=pletely informed not only of =atters required to be reported, but other =atters as well.

The call was consistent with our project =anager's open policies regarding such =atters, which includes reporting ite=s whose analysis to deter =ine their significance have not been co:pleted.

The result of our having notified you of a = attar which we did not

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at the ti=e, and still do not. regard as reportable under 10 CFR 50.55(e), is unfortunate.

The notice of violation, if let stand, not only serve d as an unwarranted blemish on our record, but canceivably could affect the dis-position of any si=ilarly viewed deficiencies in our reporting procedures in the future.

For these reasons, we ask that you review your current position, as we understand it, with regard to 50.55(e) reporting requirements and reconsider whether in this instance i=ple=entation of our ceficiency reporting procedures did not, in fact, meet both the letter and the intent of 10 CFR 50.55(e).

Very truly yours, 4

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. C. Arnold Vice President asb File: 20.1.1/7 7.3.6.2 70--057

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