ML19220B612
| ML19220B612 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/11/1977 |
| From: | Arnold R Metropolitan Edison Co |
| To: | O'Reilly J NRC Office of Inspection & Enforcement (IE Region II) |
| Shared Package | |
| ML19220B610 | List: |
| References | |
| GQL 483, GQL-0483, NUDOCS 7904270103 | |
| Download: ML19220B612 (3) | |
Text
'
s'~~.
METROPOLITAN EDISON COMPANY
~
'oST office BOX 542 REAclNC. PEP:NSYt.VANIA 19503 April 11,1977 GQL ch83 BL;C: TMI-2/3262 lir. J. P. O'Reilly, Director U.S.
- uclear Regu'.c. tory Cc--issica Office of Inspection i S.forec=ent Region I 631 Park Avenue King of Prussia, PA 19406 De e Sir
Three Mile Island I:uclear Station Unit 2 (CII-2)
License No. CPp3-66 Docket Co. 50- 320 Report no. 50-320/77-06 In accordance with our telephone conversatien with Mr. Robert T. Carlson, this letter is sub.itted 3 days late.
This letter is in response to the subject inspection report resulting frc= Mr. L. Harrov's inspection of February T through February 10, 19TT, and the findings thereof. Below is the response
(
to the infractions referenced in the subject inspection.
A.'
Attarent Infraction
~
10CFR50,' Appendix B, Criterion VII states, in part, "Docu=entary evidence that naterial and equi;=ent confor= to the procure =ent require =ents s%1'_
be available at the nucicar plant site prior to installation or use of such..."; and Chapter 17.1.7.h of the FSAR states, in part, '"All equipnent and naterial delivered to the site... is subject to receiving inspection...
Receiving inspection is perfomed in accordance with vritten checklists.
and the results documented."
^
Contrary to the above, on February 9,1977, it was observeil t' hat inspection.
checklists had not been prepared for receiving inspection of certain purchese orders placed under Specification 2555-999 As exanples; Valve Kc. v83A/3 and No. US-VShA/B vhich had been converted frc= =anual operation to air operation and electric =otor operation vere received on site and released for construction although chceklists for perfor=ance of receiving inspection had not been provided; evidence of the seis=ic qualification of these valves was not provided despite the fact that they are classified as Seis.:ic Class I in the F.ngineer's Valve List and in Specification in " Station Butterfly Wolves."
2555-103 O
Prior to the conclusion of the inspecticn, infomation was received which indicated that the identified valves are considered to be seis=ically qualifici T 90427 0 N3. 80 N
~
Resoonse To Accrent Infraction We do not concur that the itcs deceribed above constitutes an The purchase orders, C-0193 and C-019k were 10:ued to add :: tori:cd raction.
~
operator:
Since si=ilar valve, valve-operator conoination:to Gei:nic Class I valv had been seis=ically qualifici, no requirecents for seis=ic design verification vere includ d in the purchase orders.
e The Quality A::urance enginee- "*
evieved these purchase order deter =ined that the orders did not require any quality document ti s and this basic, checklists for these two orders were not required a
on.
On prepared.
The ori inal order for the valves, without operators E
and none vere quality dec=c:.tation requirenents, including seisnic enalysis
, contained had been prepared and required documentation was received prio Q/. checklicts of the valves.
r to release Since an engineering decision had been =ade during the preparati C-0193 a.d C-019h that sei:=ie qualification'docu=entation w on of P.O.s it is concl~uded that and no violation occurred,the proper action was taken during receiving inspection as not needed, t
B.
Arearent Infraction 10CFR50, Appendix 3, Criterien V states, in part, shall be accc=plished in accordance with these instruc
... and
, procedures..."
Weldi g procedure 9WP-lCOU/C-6, paragraph 8.3 states surfaces to be velded =bn11 be cleaned to bright clean =etal, " Prior to velding, t assure co=plete re= oval of defects."shn11 be exa=ined by the =a The cavity o
Contrary-to the above, on February 10,197T, it was observed '
identified as 2-?G-55, 2-ts-92, 2 4s-94, 2-m-9hg and 2 Ms 804
, on velds magnetic particle or liquid penetrant exa=ination was perfor=ed on th that no cavities prior to revelding.
e Corrective Action Taken Failure to perfor= =agnetic or liquid penetrant e m inations procedure 9WP-1002/C-6 by the 3?N Construction C of the e
noted that failure to perfor= these non-destructive er:-.' ations did It should be in our opinion, constitute a violation or code require =
b
- not, be repaired as provided in Parag aph 1-72h.l.T a ents.
USAS 331 7, ects shall and 2-72h.7."
ons 1-727.T 80 296
^
9 Subdivisien 1-727 7 applies to the repair of defects in Class II nuclear piping field veld joints.
I'on-destructive examination of the esvity prior to veld repair is not a require===..
la the case of ' repair of the subject = sin stes= syste= vel:1 joi=ts, difficulty had been exp-:rienced i= precisely locating the area of the veld circu=ference to be excavated for defect re= oval.
For this reason, it was decided to verify defect rc= oval by =eans of radic;raphy prior to veld repair. Failure to revisc the applicable 3'IJ velding procelure to incorporate this option resulted in the subject procedu-e violations.
Defect re= oval vas verified by radiograph prior to veld repair of each cavity. Subdivisics 1-727 7 states, "The types, extent, and =ethod of examinatica and 1Nts of i= perfections of repair velds shall be sa=e as for the original veld."
The subject 13 systes piping veld joints have been accepted based upon the above criteris.
(
Steps Taken to Avoid Futu e Recurrence The scope of work of the EFJ Construction Cenpany at CII-2 has been ec=pleted and the subcontract ter=inated. As such, B&W velding procedure 9WP-100H/C-6 is no longer in use and therefore requires no revision.
Date That Cc=tliance Will be Achieved Co=pliance has been achieved.
Very truly yours, Sw.e4 - R. C. 5 mwd R. C.' Arnold Vice President RCA:JES:ll Dr. Ernst Volgenau, Directo$-
cc:
Office of Inspection & Enfereenent U.S. Nuclear Regulatory Cc==ission
{
Washington, D. C.
20555 l
g.
l~