ML19220C412
| ML19220C412 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/12/1975 |
| From: | Arnold R Metropolitan Edison Co |
| To: | Robert Carlson NRC Office of Inspection & Enforcement (IE Region I) |
| Shared Package | |
| ML19220C411 | List: |
| References | |
| NUDOCS 7905010187 | |
| Download: ML19220C412 (5) | |
Text
.
l.
.?
A W I],~27/J nv.y::^.-
~..., -...,,
/
METROPOL\\ TAN EDl5CN COMPANY z ::mw:r or cuicut rut.uc ununts conrc,. :1 TELEPHCf 2E 215 - 97) 3:01 POST OFFICE DOX 542 READif.G,FEf?;SYLVAf4f A 10C03 February 12, 1975 Mr. Robert T. Carlson, Chief Reactor Construction and Support Branch U.S.1:uclear Regulatory Co=ission
~
Of fice of Inspection and Enforcenent - Region 1 631 Park Avenue King of Prussia, Pennsylvania 19406
Dear !!r. Carlson:
Subject:
Docket flo. 50-320 Construction Permit CPPR-66 Inspection No. 50-320/74'-09 This letter and the enclosure with this letter are in response to your inspection report of January 8,1975, concerning 11r. Folsom's December 18-20, 1974, inspection of our Three Mile Island fluclear Station, Unit 2 and the findings thereof.
Sincerely,
,0 1 '}
h tQ C. Arnold Vice President RCA/RSB/cas Encl. - Response to Description of Apparent Vlolations d
(.
g,(.
V
/
kN<S05010/g7
l'etropolitan Edinon Company Ihree lule Island Nuclear Station Unit 2 (TMI-2)
Docket No. 50-320 Const1 action Permit CPpR-66 Inspection No. 50-320/74-09 RESPOSSE TO DESCRIPTION OF APPAPI.NT VIOLATIONS Apparent Violation 1 "Activitics Criterien V of 10 CFR50, Ippendix 3, states in part aff ecting quality shall be prescribed by documented instructions,
procedures, or drawings...and shall be acco=plished in accordance with these instructions, procedures or drawings." The constructor's procedure touch each other, nor ECP-4-2, Paragraph 5.2.1 states " Cells should not should any cell touch cetal supports of the rack," and the constructor's
"...bar ends shall be heated above procedure QC-1-2 which states in part, 2120F, but no core than 3000F and the bar ends then wire brushed..."
Contrary to the above, the inspector found that :
the storage battery cells were in direct contact with the a.
racks.
uninsulated side rails of the battery support Containment structure reinforcing steel was heated to an b.
unknown temperature with an oxy-acetylene cutting torch prior to wire brushing.
Corrective Action Taken An invcstigation of the condition established that plastic cc11
~
a.
strips, intended to be installed between the =etal rack supports and the battery cells, were installed between the bottom rails and the battery cells, but were not,' installed between the side rails and the battery cells.
Ic=cdiate corrective action consisted of issuance of Deviation Report f0385, ordering and scheduling the installation of plastic side strips, and inspection of the ba;teries and racks.to insure no da= age hau occurred to either item.
Deviation Report f 0385 has been appropriately acted upon. The plastic strips have been ordered, and no damage was discovered by inspection.
An investigation of the referenced condition established that b.
the fl8 reinforcing bars were being heated for the purpose of c1 caning and were not bei6g checked with tempil sticks to insure that 300 F would not 5
be exceeded in accordance with procedural requirements.
immediate. corrective action consisted of stopping the work, issuance I
of tempil sticks to the workers (with proper instruction) to allow continuance of cleaning other reinforcing bars according9to :thc7
/ L-U i' construction procedure.
.' f 0J86 was writ ten and "lloid Tagr," placed on the Deviation neport temperature checks.
twelve bars that had been heated without The f 0386 has been appropriately acted upon.
Deviation Report of f, with the Quality Control inspector witnessing twelve bars have been cut their rc= oval.
Stens Taken to Avoid Further Violations the cognicant construction superviser To avoid violations of this type, during his final inspection of a.
has been directed to be core vigilant completed work.
thorough in his The cognizant QC Engineer has been directed to be l
d co=parison of drawings, specifications, and procedures with the comp ete work for conformance, prior to acceptance.
craf t Superintendent, Supervisor, Foreman, and b.
The cognizant l
workers have been instructed to check for ingiacentation of all procedura requirements, particularly to insure the 300 F caximu= allowable te=perature is not exceeded.
The Quality Centrol Engineer has increased the frequency of surveillance of operations preparatory to and during cadwelding.
the Architect-Supplemental to the above, GPUSC will request Engineer study the f easibility of deleting this temperature raquirement.
the that when the reinforcing bar is torch cut, In view of the fact te=perature of the ends of reinforcing bar exceeds 1000 F. and when the cadweld is made, te:perature of the cadwelding caterial in contact with the reinforcing bar exceeds 1000 F.
"Date That Compliance Will Be Achieved The plastic side strips will be installed on the side rails and batteries re-aligned within thirty days af ter receipt of plastic side a.
strips.
Compliance has been achieved. The supplccental feasibility b.
study will be completed within two conths.
Apparent Violation 2 "1basures
~
Criterion VI of 10 CFR, Appendix B, states in part, shall be established to control the issuance of documents, such as instructions, procedurcs, and drawings, including changes thereto, which The constructor's document prescribe all activities affecting quality." control procedures p drawings, and superseded drawings removed.
(
current with the latest Contrary to the above, the inspector found that 9.3% of the construction drawings in a representative selection has been superseded.
~
f C7
[1,8 /
This is a recurrent violation.
7 e L.
v *c N-M
Corrective Action Taken The stick files exacined by the inspector were maintained by a supervising model maker, who is a part of a sub-con tracted vendor's organization, and distribution of drawings to this individual is acco=plished by our Architect-Engineer.
Of the four drawings (out of 43 examined) found to be out of revisica, three were in areas cr addressed details which are not being nodelled.
These drawings were out of date because it was determined that caintenance of these drawings in the model taker's stick files was an unnecessary and administrative burden, since they could contribute in no way cost to the accuracy or use of the model.
These drawings should have been re=oved fro the codel maker's stick file at that tice.
The fourth drawing (3170 sheet 7) was not out of revision.
Revision 4 was found on the drawing holder, clearly marked "VOLD SEE REVISION 5."
Revision 5 was being used by a codel =aker to construct on the model base to which it applied (Se rvice Bldg., elev. 880 '-6", base 7).
Immediate corrective action consisted of the following steps:
1.
All drawings which do not apply o areas or details being modelled have been re=aved f rom the superv.: sing =odel maker's stick files.
2.
All drawings in the supervising model taker's stick files have been cicarly stamped with the notation in red "E&R MODEL SHOP PRINT."
3.
All drawings retained for reference only have been cicarly sta= ped with the notation in red " RECORDS INFO ONLY - NOT FOR CONSTRUCTION."
The use of the =arking " VOID - SEE REVISION
" has been discontinued.
4.
A complete inventory of all drawings required by the model effort was completed by January 10, 1975.
5.
We have had our Architect-Engineer's Corporate QA Department conduct an in-depth audit during the week of January 13, 1975, to uncover all deficiencies in the area of drawing control within the Architect-Engineer's site organization.
Corrective action required as a result of this audit will be completed by February 14, 1975.
Corrective Steps Taken to Avoid Further Violations It is recognized that the drawing control is not limited to any specific area or group on site but that it is a generic issue. To help alleviate potential proble=s, the control of drawings is being reviewed and evaluated with the purpose of simplifying the issuance of drawings g
to the construction disciplines. Areas of evaluation include:
1.
Establishment cf measures to restrict the number of sources l
supplying to the site and methods to approve the control over their usage.
c, et :
1 L.
U * ~'
p 2.
Quality Assurance direction of internal drawing control audit:
conducted by United Engineers and Constructors Quality Cont rol Inspection and review of the data for proper corrective action, when required.
3.
Sinplification and clarification of procedures to reduce drawing control errors, including reducing the nu=ber of drawings required by each discipline.
4.
Additional re-education of supervision and clerks to the required procedures fot-drawing and documcat control.
5.
Proj ect Manage::ent evaluation of the control audits to identify generic problets or trends.results of previous dra Date That Ccepliance ' Jill Be Achieved Since various changes to sicplify drawing control are contenplated revisions to the drawing control procedures as a result of =anagement evaluation will be available for on-site inspection within one nonth Cc=pliance, therefore, will be achieved within one acnth.
~
9 1
l GO D /. '
I
/ L.
v +
_