ML19220B667
| ML19220B667 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/06/1972 |
| From: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19220B659 | List: |
| References | |
| NUDOCS 7904270193 | |
| Download: ML19220B667 (9) | |
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ENCLOEURT. 1 l
Deccrintion of Zioncornliance Itces Metropolitan Edisen Co:pany
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Docket 1:es. 50-2S9 and 50-320 l
License bos. CIPR-40 cnd CFPK-66 l
l Certcin itets appccr to be in ncncorpliance with 10 CFR 50, Appendix b, cs identified belev:
1.
Criterion V, " Instructions, Procedures, and Drawings", ctates in part,
"Activitics cff ecting quality shall be prescribed by docurented in-structicas, procedurcs, or drawines, of a type appropriate to the circumstances and chall be accomplished in accorcance with these instructions, procedures, or drzwin.cs.
Instructions, procedures, or drneings chall include appropriate quantitative or qualitative acceptance c:1teria for deterrining that icportant activitics have been satisfnetorily accomplished."
Contrary to che above:
There are no instructiens, procedures, or drawings delineating the a.
quality scpects of the installation of the individual sensors or instru= tats used in the detection of system abnormalitics.
b.
There are no instructions, procedures, or drawings which describe the testing and/or calibration required for the sensors er instru-cents used in the detection of system abnorcalities, There are no instructions, procedures, or drawings relative to the c.
Paragraph a.2.lld of the FSAR requirerents, vhich states in part,
"... All vertical trays have solid covers to six feet above their floor penetrations."
d.
Instructiens, procedures, or drawings do not require that the cable tray loading specified in the UE&C Procedure ECP-3 and paragraph a.2.2.1.13.4 of the FSAR be verified.
Procedures for the installation of the decay heat reroval outlet a.
valves and care flooding check valves were rot available to direct the quality related activities for these corpenents.
2.
Criterien VII, " Control of Purchased Yaterial, Iquiprent and Services",
states in part, "... Docu=entary evidence tha r caterial and equiprent conf orm to the procurc=ent require =ents shall bt available at the nuclear power plant site prior to installation or use of such material or cquip-c.cnt..." Criterion XVI, " Corrective Action", states in part, ".
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7904 70133 81 080 1
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-2_
Mcasures chall be established to accure that conditions adverse to
. are prceptly identified and corrected.
quality.
Contrary to the above, the inspector found that tbe only raterial and
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fabricatica records available on site f or the Esbcock & Wilcox cupplied reactor coolant piping, spctis were the veldier records. This ince.plete i
dccuncntatica was noted as a deficiency against the piping spools and the receiving recordo dated July 1970.
Tne deficicney had not been corrected at the tine of the incpection.
3.
Criterien IX, " Control of Special Tracesses", states in part, ' Measures shall be established to acsure that specici processes such as veldine
.. are accenplished.
. in accordance with applicable codes, oten-
.dards, cpecifications, and other special requirenents."
Centrary to the abavn:
The inspectors found that UE&C Trocedure QC-8, " Pipe Velding Control",
a.
contains no requirencut nor provision on the veld history sheet for defect rcroval verification which is specifically imposed on the Three Mile Island 1 pipe velding by the Gilbert Associates Specificatien No. 550.
b.
E6W Specification No. CS 37-3, Paragraph 5.1.7, requires that cicetrodes for velding stainicss steel shall contain a minirura of 5% delte ferrite.
Contrary to the above, the incpector found, during a review of a Crinnell test report for E-308 electrode, heat f9H63E, that cher.-
ical analysis indicated less then 5% ferrite. This deficiency had not been identified by Crinnell or UE&C QC record personnel.
The inspector also found that the Esbcock. & Wilcox documentation records covering the pressurizer surge piping spools contained material records for lino coated electrodes which do not meet the AS'IM chemical requirements.
(81-081 i
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a ESCLOSURE 2
- Descrintien of Nonconferrnnce Itern 4
Metrepolitan Edison Cc=pany Locket Nos. 50-289 and 50-320 Lictnse Mos. CPP.'.-40 cod CFTE-66 Certain itens appet; to be in nonconf orrance with staterents in your Final Esfcty Analysis Ecport (TSAR) and/or site procedures and instruc-l tiens, as identified below:
i l.
The FSAR, Paragraph 4.1.3.2, " Piping", states in part, "The design, l
fabricatien, inspecticn and testing of the reactor coolcnt piping including the precauriser surge line is in accordance with A"SI 331.7."
ANSI B31.7, "Mucicar Fover Piping", Paragraph E-1-110.6, states
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l a.
in part, ".
. Equipment used to view fil= for radiographic interpretatica shall provide a high intensity light source such that the penetra eter and hole f or the specified quality level shall be readily visible for the specified intensity range."
Paragraph 3-1-120.1 states in part, ' '... the veld ripples or i
veld surface irregularitics on both the inside and outside shall be rencved by any suitable ecchanical process to such a degree that the resulting radiographic contrast due to irregularities cannot cask or be confused with the inage of any objectionable defect Centrary to the above, the inspector observed that the CC"Ali in-spection agency did not have high intensity radiographic vieving equip =ent on site and that the available equiprent appeared to be incapable of revealing rejectable defects in conposite films.
During a review of the radiographic film representing pressurirer surge line veld No. EC-55AQ, the veld area was characterized by alternating bcnds of light and dark areas due to improper prepara-tion of the veld surface prior to conducting radiography.
b.
USASI 331.7, Paragraph 1-727.4.4 states bn part, ".
. Fillet
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velds r.ay vary fron convex to concave. The size and contour determined as shcun in figure 1-727.4.4(a)... The exenination requirements shall be es specified in sub-paragraph 1-727.4.2(e)3,
"... which states in part, "I= perfections that are unacceptable and shall be repaired are... any undercutting... "
Contrary to the above, the inspector observed a cock-o-let velded to the side of the 18 inch spo'ol' piece Uo. DC-57 in the decay heat cooling systes which contained a deep, ground undercut at the toa of the fillet veld.
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81'082
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2.
United Engineers and Ccnstructors Procedure Eo. QC-17, Paragraph IV-E
Control of nonconforming Conditiens", states in part, ".
. Quality centrol chall caintcin a = aster log of inspection reports to indicate their status" and, Paragraph IV-C, states in part, "... Itc=s that are reinspected and are found to be unacceptable
. shall be tanged with a reject tab.
. The noncenferring ecnditica and the ref erenced f
incpection report nur3cr chnll be identified on a deficiency report.
The rejected status and a ref erenced ER n.ber shall be docurcntec cn the cpplicable inspection report f or cresc-reference."
Centrary to the above, a deficiency report has not been issued f or a ncnconforning conditien that was identified in a COU/.M inspectica report dated l' y 23, 1972, which relates to rejectable ragnetic particle 2
indications en the Unit 1 reactor closure head flange.
Furtherr. ore, there was no evidence thet the conditice had been corrected at the time of the inspectics.
3.
UE&C procedure ECP-3, Addendum A, states in part, "The quality centrol inspector vill ec=plete the attached check list as applicable while inspecting... installation of the equipcent.
Contrary to the above, the check lists are not given to the QC in-spector for use while inspecting.
Dates on the check list do not agree with the date supplied by the craf t perforning the function.
4.
UE&C procedure QC-13, prior to July 6,1972, required that a quarterly field audit be performed to determine that ceasuring and test equipnent were properly controlled, calibrated and inapected.
Contrary to the abeve, the records indicated that only three such audits have been r.ade, the.first on August 5,1970, and the last on Nove=ber 18, 1971.
5.
UE&C procedure ECP-6, paragraph 5.1.4, requires conthly rotatica. of the engineered safeguards motor shaf ts and that engineered safeguatue motors be scggered monthly.
Contrary to the above, approri=ately four conths have elapsed since the last rotation of the motor shaf ts and performance of the re-quired meggering.
6.
UE&C procedure ECP-6, paragraph 5.1.3, requires that cpace heaters be energized or supplementary heat provided on engineered safeg~ards motors within two working days af ter placement in storage. Locuren-tation is required to be provided on forn ECP-6-1.
UE&C procedure ICP-6 t_
81'083 4
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m "A red indicating lamp shall be installed to show niso requires that the circuit is energ:. zed."
that the high nrcscure saf ety injection pu=ps, desig-Contrery to the above,
nated IET-1A, it, and 1C, which were nc1ceted for review, did not appear on the heater check list, and the prescribed red indicating lamps had been rencved fren ET-1A, and 13.
surveillance be perforned on instru-CELC procedure ICP-10, requires that to assure that 7.
ncnts, panels, control boards, and related equipecnt controlled storare conditions are raintained.
the required Contrary to the above. there is no docurentary evidence that surveillance has been conducted.
UE&C procedure ECP-6 and ECP-10 both require that the field supervisor, qual 3ty control, be notified prior to the installatica of electrical 8.
engineered safeguard equip =cnt.
Contrary to the abc<e, there is no evidence that the field superviser, quality control, is notified prior to installation of engineered safe-guards equipcent, nor evidence that quality control person el had vitnessed installation except f or caf eguards cabic' installation.
UESC procedure QC-17, paragraph II.E.1, states in p,rt. "Nonconferrance
. includes activitics, raterials and equiprent whose condition does 9.
not comply with the applicable... specification."
Contrary to tbc above, deficiency reports were not pecpared for each instance where the cable separation criteria descrf'oed in paragraph 4.4.4 I-of UELC Procedure ECP-8 vere not cet.
The. Final Safety Analysis Ecport, Paragraph 8.2.2.12.c, states in part,
i in reference to cable separation,... "In a very f ew ccses, the eep-i 10.
and, in these cases, a barrier is installed aration is about 12 inches between the trays."
Contrary to the separations criteria described above, the engineered safeguards actuating cabineta Icented in the control room, do not have the separation cpec4 fied as the minisuc for cable trays, nor barriers In additien, there vere nuncrous rolls of ceparating the cha vels.the cabinets, which were terminated at both ends cabic suspended undet with no documentation indicating that tnia practice was unacceptable.
all itens identified as being UE&C procedure QC-2, requires that 11.
associated with the reactor asfety, including engineered safeguards equiptent and corponents, be inspected upon receipt for conformance,
vith the applicable specification requirements.
81 084 l
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Contrary to the above, reactor preseure ncnsinr trenducers, identified by nurLer, RE-IS. vere not inopccted en receipt at the nite and the te rr anent file for these devicco indicated that they had not been re-l ceived, although further investigation revealed that they were received l
on the site in Dece=ber,1971.
12.
ELW specification 1132/0309, paraprnph 2.4, states in part, The ven-der shall have written precedures for centrol of inspection prerrara.
These procedures shnll cover r.uch ittr: cs ccn-den t ructive tes ting inspecticns
." The ICM OA Manunl, pcragraph 11.14.4, "nT-1 Speci-fiention, 1-14-70," o tates in part, "ET technique procedure vill be uced with this specificatien."
Centrary to the above, the inspceter found that no ET technic,uc pro-cedurca vere used by FDM during the radiography conducted on the Ecrated Water StoraEe Tank.
13.
L5W lbterial Specificatien,13-1.3, staten in part, "Carben steel tie derns chall not be used for stainless steel natcrial."
Contrary to the above, the E&U receiving report, dated ISy 18, 1972, reviewed by the inspector, indicated that no protection was used between carbon steel holddevn clips and stainless plate iur the Ecrated Uater Storage Tank 1.aterialc rcccived on }by 9, 1972.
In addition, the inspector eculd find no corrective actien reperto or other docenentation indicsting that corrective action had been taken to resolve this natter in the ELW, PDM, UEEC, or GPU records on cite.
14.
Site procedure Mo. ):CP-3, revisien 4, paragraph 3.60, states in part.
"Acetene is prohibited for use on site."
Contrary to the above, PUM cleaning, procedure Ho. cpl states in part.
'Tisible oil and grease spots should be renoved frea plates or nor:les by handviping with acetene prior to velding the plate or nozzle into the tank."
The inspector van infor=ed by FD'! Quality Control persennel that acetone was used during the fabrication and sning of the tank.
15. B&W specification 16. 1132/0369, paragraph 2.3, " Control of Special Processes" staten in part, ' Vendors shall have vritten procedures and instructions for the perforcance of all special processes used for the ite=s such as.
. cleaning processes.
." Metropolitan Edicen specificatien sheet No. 620-0005-36-A-0, dated August 28, 1970, staten in part, 'Trocedures for control of special procccees such as velding, NUT,.
. cleaning.
shall be approved by the engineer prict to use."
Contrary to the above, the inspector observed the cleaning of the barated water storage tank in progress and reviewed records indicating that I
testing had been corpleted.
The testing was perforced without an cppreted l
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available en site, although an approved procedure was in I
procedure cxistence.
is understocd PCI cleaning procedure CP-1, staten in paragraph 2.1, "It i
that prior to the ce=rencing with the c1 caning of the tank, all fabricatien, 16.
he velding, inspectinr., and testing has been corpleted and approved by t In codition, parcereph 4.2 etates, "All veld spatter cutherized persenc. "
and/or olag cheuld be rencved frc= all tank curf aces per veld procedure I
specification VPS-4S."
the incpector observed the external curf aces of Contrary to the sbove, ikes.
the borated water stcrate tank to centnin veld splatter and are str
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The internal surf aces could not be cr.nrined, due to work in propress.
The Final Safety Analysis Report, page 6-24, Table 6.2, "Sutrary of Requirements for Torated Vater Storage Tank" states under inspectica 17.
the acceptance standard is AUVA-D-LOC. The requirencats for velds that FSAR also requires that all girth and scam velds shall be full penetrs.tien In addition, the velding procedure specification No. WTS-48, for velds.
the borated water storage tank, PDM Steel Ceepany contract 10139 dated October 12, 1971, paragraph 6.1, states that "Ucid procedure and velder qualifications are required in accordance with the latest editien of ASME Ccde Section VIII," and further states, "/.EME Section VIII will be used for acceptance standards on NDT."
The specification also states that NDT requirceents vill consist of 20% radiopraphy.
Contrary to the above, the requircrenta listed in the FSAR and the work perforced in accordance with procurenent docunents do not anrce, nor had this deviation fron the FSAR been identified or docurented.
Metropolitan Edicon QA Plan for Three Mile Island Unit 1 Appendix B, 13.
revision 3, paragraph VI. A, relative to audita and corrective action
'The audit team leadcr should check to make sure that states in part, euch response is received within a reasonable period of time (1 month)."
Centrary to the above, the inepector found that audit reports dated April 12, 1972, February 15, 1972, January 26, 1972, and December 28, 1971, did not contain documentary evidence that corrective action had In addition, the use of an incorrect been taken on these findings.
alloy of stainless steel plate for the fuci storare liner, identified by site personnel in 1969, had not been resolved at the tice of the inspection.
UL&C Procedure No. QC-8 restricts trans-weld weaving to a dirensien 19.
AUSI equal to two and on-half diarcters of the electrode being uned.
1-727.4.2(d), states in pert, The finiphed ourf ace of E31.7, Paragraph
. the surface the veld shall cerge cmoothly into the coaponent surf ace...
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i secothness of the finirhed mid chall be nuitable for the proper inter-pretatica cf ncndectructive x =inations of the velds Contrary to the above, the inspector observed that en 18 inch stainicss l
j eteci pipe opool, Mo. CF-1, choved chop velds with a trans-weld weave pattern fre: 1-1/4 to 1-1/2 inches vide.
In addition, the weave patterns 1.ad produced deep notches neross tl.c weld, with severe undercutting at the end of the weeve where it centceted the piping bcse retal, which i
j does not ncet the 'llend c oothly" cnd "curf ace ancothness" requirerents.
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(81-087 l
D;CirSURT. 3 i
Description of Safety Items i
lietropolitan Edison Ccepany Docket I;oo. 50-239 and 50-320 i
Licence lies. CTPR-40 and CFTR-56 Certain ite a appear to raise cuestions concerning the adequacy of cen-struction as identified belev:
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1.
Incinected saf er,uards Actuating bench Boards, Channels A, E, C, and D The betteu of the ecpincered safeguards actuating bench boards, channels A. E, C, cnd D, are open to the cable spreading rocs, which is located i
below the control reo=.
Failure to effect adequate clonure of these openings could result in the required evacuatien of the control rocn if a fire occurred in the cable spreading roc =.
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Our inspectors did not find drawings nor instructions relative to the ccthod of closure of this opening.
2.
B:stterv Roc s I
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' Die two battcries appear to share a cct;nen ventilation systen, which could result in a co=ron rode _f failure should a fire occur in one l
battery room cnd be tranc=itted to the second room by way of the ven-tilation syster..
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81-088
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