ML19276H429
| ML19276H429 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/03/1972 |
| From: | John Miller Metropolitan Edison Co |
| To: | O'Reilly J NRC Office of Inspection & Enforcement (IE Region I) |
| References | |
| NUDOCS 7911080586 | |
| Download: ML19276H429 (18) | |
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METROPOLITAN EDISON COMPANY
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POST OFFICE BCX 542 READING PENNSYLVANI A 19603 TELEPHONE 215 - 929 4601 November 3, 1972 Mr. J. P. O' Reilly, Director Directorate of Regulatory Operations, Region 1 United States Atomic Energy Coccission 970 Broad Street Newark, New Jersey 07102
SUBJECT:
T11REE MILE ISLAND NUCLEAR STATION U'iITS 1 NO 2 DOCKET NOS. 50-289 rid 50-320 RESPONSE TO AEC/DRO AUDIT OF AUGUST 14 THROUGH 17, 1972
Dear Mr. O'Reilly:
Your letter of October 6,1972 reported the results of the AEC/DRO audit of the Three Mile Island construction site which was conducted on August 14 through 17, 1972. Enclosures 1, 2, and 3 of your letter described items which AEC/DRO considered to appear (1) to be in non-coupliance with the quality assurance criteria of Appendix B to 10 CFR 50, (2) to be in non-conformance with the FSAR, site procedures or instructions, or (3) to raise questions concerning construrrion adequacy. Our resolution for most of these items is indicated in Enclosures 1, 2, and 3 to this letter. A few of these items are still under review so that our answer on these items is not yet complete. We will advise you as soon as we have their final resolution.
As indicated in our letter to you of September 11, 1972, a number of steps have already been taken to improve the compliance of UELC construc-tion and QC groups with TifI quality requirements. Additionally, GPU has taken over respcnsibility for the mana:;ement direction of the UELC Quality Organization for the T>E P roj e c t.
Very truly yours,
'~ Y.,n
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J. G. Miller Vice President l ?932 0 80 $'~~6 f' o
Enclosures cc:
Mr. W. G. Kuhns Mr. W. A. Verrochi
ENCLOSURE 1 RESOLb7IO:I 0F ENCLOSUFI 1 TO AEC-DRO LETTER DATED OCTOLER 6,1972 1.
AEC FINDl:!G This general finding includes findings listed in 1.a through 1.c below, which cover areas where the AEC-DRO inspectors censidered that centrary to Criterion V of Appendi:< B to 10 CFR 50, appropriate p ro ce dure s, instructions, or drawings were not available.
RESOLUTION lt has been GPU's intent from the early stages of construction tc perform i portant activities in accordance with written procedures and GPU has taken action to have such procedures prepared and used.
Subsequent to the AEC audit, CPU canage:.:ent has again crcinasized to cognizant C"U personnel and UESC canaget2nt that all activities affecting the quality of nuclear and safety related parts of the plant ~.ust be covered by appropriate written procedures, instructicus or drawings. Our resolution of the specific AEC findings is given belou.
1.a AEC TII:DI:iG "a.
There are n_o instructions, procedures, or drnwings delineating the quality aspects of the installatica of the individual sensors or instruments used in the detection of system abnornalities."
RESC'LUTIC:!
Requirements for installation of instru.ent sensors are delineated en CAI drawings,*:hich indicate desired locations and typical installation details.
To further clarify the recuirer.:nts appliccble to ins tallation o f instru:..cnt sensors, a ULCC construction procedures ( CP-14) cill be issued by :;overber 15, 1972, and will include qur.lity centrol check points.
In addition, all nuclear and safe t:. rel.ted sensor installatiens will be cheched as part of UELC's finci QC inspection (Procedu~ QC--16) of construction vork prior to turnov2r for ins t ruc.cn t locp calibr:3 tion and systen testing.
1.b AEC FI::DI';G "b. There are no instructione, procedures, or d: wings which describe the testian cad /or calibr.Lica required for the a r.ncers or inctr uments used in the 'detectir cf v. uan abnornalities."
l-]
ENCT.0SURE 1 RESOLLTION Testing and calibration of sensors and instruments have been performed using nanuf acturer's instructions and have been recorded on Instrument Calibration Data Sheets. This practice will be formalized by the issue of a construction procedure (MCP-13) with a QC check list, which will be issued by November 15, 1972.
The docu.cntation of saticf actory corpletion of required sensor and instrument calibrations is checked by UE&C QC prior to turnover of nuclear and safety related sensors and instrurents for instrument loop calibration and system testing.
l.c AEC FINDING "c.
There are no instructions, procedures, or drawings relati,e to the paragrcph a.2.11d of the FSAR requirements, which states in part.
'... All vertical trays have solid covers to six feet above their floor penetraticas.'"
RESOLb7 ION Ue are reviewing all cable trcyc to determine the specific trays for which co zers are warrante.d to provide physical protection. The drawings f or cable trays 'till be revised to indiccto the specific requirer:nL for tm covers and the TSIM will be reviced if necccccrv. to bn consistent. The com es fil]
be insi.ulled after completion of ccble inctcliation and will be checked by UEEC QC as part of final inspection of cable trays (Procedure ECP-3).
1.d AEC FINDING
" Instructions, procedures, cr drawings do ot require that the cable tray lecding specified in the CGC Frecedure ECT-3 c.nd paragrcpn a.2.2.1.13.4 of the FSAR be verified."
RESOLbTICN The primary r thod being used to control cable tray fill is by otrictly controlling cable routing to mnhe sure that cables are routed in cecordance uith GAI instructions.
CAI's cc:puter progra-for cable routing autoccticall:. euecks that cable t rmj fill is entis f actcry if cables cre rou t e c' as planned.
- Further, GPU spot checks the routing of catsles on a routine easls.
Iloweve r, to provide additional asrurance, the UEEC chech list for the procedure for ir : allation of cable (ECT-3) was mdified en Septed.ser 21, 1972, to require ins?cction of cabic travn to verify tant tray fill li-its hm a ct been exceeded. Tais visual inspection will be done as part of final inu? action of ecble trayc (cJter conpletion of cable pullir > 2t *,nich Lt. ; an c re. ~ zith ap p a ren ti;. h!nh filin *:ill be evclucted to ensure that the nc.al fill rc-ts 1-2
~
ENCLOSURK 1 engineering requirements. Ilhere necessary, cable fill will be checked by counting the number of cables to verify that the number installed agrees with gal's planned enble tray loading.
This evaluation will be documented and will be done in accordance with a procedure or addendum to the cable installation check list (LCP-3) which will be issued by November 15, 1972.
l.c AEC TI'*DINC
" Procedures for installation of the decay heat removal outlet valves and core flooding check valves were not available to direct the quality related activities for these components."
PISOLUTIO:!
Installation of valves has been performed in accordance tith GAI piping system drauints, CA1 specifications covering cleanliness, welding, and neneral installation requirer.ents, and UE&C QC procedures covering welding, cleanliness, and inspection of techanical equipt.ent. This is being formalized by means of a construction procedure ("CP-23) and QC check list which will be issued by November 15, 1972.
2.
AEC TIN. DING "Cri terion VII, ' Control of Purchased Material, Equiptent and Services '
states in part, '... Doctuaen tary evidence conform to the procure: mat that caterial and equipment requirements shall be available at the nuclear power plant site prior to installation or use of such naterial or equiprent...' Criterion XVI, ' Corrective Action ', c tates in part,
'... Measures shall be establiched to assure that cot.ditions adverse to quality... are promptly identified and corrected...'
Contrary to the above, the inspector found that the only r:aterial an?
fabrication records available en site for the Babcock and h'11cox supplied reactor coolant piping speoln vere the velding records.
incomlete :.ocunentation was noted as a defielency against This the piping spools and the receiving records dated July 1970.
The deficiency had not been corrected at the tir:e of the inspection."
PSSC L LTIC'!
It should be noted that the fabrication report received from BMT and included a certification that materia]for the piping had been been reviewed caainse codes nad specifications and certifications had found to be :atinfactor".
Suh e cently, CTU has receivau une r,at.erial certifications for this pip f u;'
fren EE.'.! and.till cot 91cte revic' of this documntation by.vvember 15, 1972.
1-3
ENCLOSURE 1 3.
AEC FI!'DINC
' Measures
" Criterion IX, ' Control of Special Processes', states in part, shall be established to assure that special processes such as welding
... are accomplished... in accordance with applicable codes, standards, specificaticos, and other special requirements. '
a.
The inrpectors found that UELC Procedure QC-8, ' Piping Lleiding Control', contains no requirement nor provision on the weld history sheet for defect renoval varificctien which is specifically impeced on the Three Mile Island 1 pipe welding by the Gilbert Associates Specification Io. 550. (si c).
b.
B&W Specification No. CS 37-3, paragraph 5.1.7, requires that electrodes for welding stainless steci shall contain a minimum of 57; delta ferrite.
Contrary to the above, the inspector found, during a review of a Grinnel test report for E-20S electrode, heat 491!63D, that chcnical analysis indicated less than 5% ferrite. This deficiency had not been identified by Grinnell or UESC QC record personnel.
Tine inspector also found that the Babcock and Uilcor documentation rccerds covering the Pressuricer surge piping spools contained utcrial records for 11.a coated electrodes uhich do not teet the ASTM chenical requirements."
RESOL'HION The UE&C wcld procedura for weld repairs to field welds (LTP-27) has required a.
inspections to be perforced to verify defect removal prior to repair velding.
- !ovever, docurentation cf this inspection has not been required in the past.
'1he weld history record forn vill be revised by :;over'aer 15, 1972, to require docu.entdtion of this inspection.
b.
The BLU npccificatica limits on ferrite levelt, do not araly te Gri'mel piping Ed w.i aut re iicr '.ere m.
spools since thcse.spcols were not cupplied by purchased and were f abricated to GAI specifications. The GAI specificatiens do not include ferrite linits; he.et.ver, Grinac21's own requiremnta are that veld nateria]s have a ferrite content o f 57; or more.
Revicu of Grinnell taaterial certifications for all piping spools rtcaived indicates Lb.t five heats, includinr, heat 91i63L, had ferrite Jevcis belca 55, the Icu st anving 3'i..
In addition, ao Terri te in t e n..at i ca is a tilab l e fce-. uve ral otLcr neate.
This mat ter is being reviceed uith Grinnell.
C> will r.dvise yvu at a later date of the final resolution.
3-4
9 ENCLOSURE 1 The BLU f abrication report far' pressurizer surge piping has been rechecked and the che:nistry requirements of the weld rads were found to incet specifi-cation requircr.an ts.
It should be noted that the electrodes in question 2 and were El 6-8-2 electrodes to specification SA 298, for which chror.iu:
nichel content are perr.it ted to be lower than for typical 18-8 type electrodes.
O 1-5
E"CLOSUIT 2 PISOLUTION OF E'iCLOSURE 2 TO AEC-DRO LETTER LATED OCTOBER 6,1972 1.
AEC FI"DI"G
'The design,
' Piping', s tatec in part,
"The FSAR. paragraph 4.1.3.2, inspection and testing of the reactor cool.mt piping is in accordance with id?SI fabricatien, line including the pressuri::er surge D31.7'.
B-1-110.6, s tates
'Nuc]enr Power Piping', paragra ANSI S31.7,'... Equipnent used to view file for radicgraphic a.
cource such in-part, interpretation shall provide a high intensity light the penetrar.:eter and holc for the specified quality level shall be re-dily visible for the specified intennity range. '
that 5-1-120.1 states in part, '... the veld ripples or weld Paragrap hirregularities en both the incide and outside shall be surface that renoved by any suitable r:echcuical process to such a degree due to irregulari ties cannot the resultint, radiographic contra it mask or be confused with the iria;c of any objectionable defect
...t Centrary to the aba ec, the Insp:ctor observe.I that t h e CO'u' An inspection agency did net :..vu :Igh intansity radiographic viewing on site and that the available equipuent appeared to be equipuent filns.
cf revealing rejectable defects in composite incapable During a review of the radiographic film representing pressurizer the weld area was characterized b, line weld No. RC-55AO,and dark areas due to inproper preparatieu aurge alternating bands of light adiograph of the weld surface prior to conducting b.
US!.SI D31.7, paragraph 1-727.4.4, st,tes in part, '... Fi lle t Tne cite and contour wclds.. / va:- f ro a convex to concer deter mired as shoun in.figarc l-7 2 7. I,. 4 (a)
. The en.:ninetien 1-727.4.2(c)3, requirca arts shall be au specified in sub-ucragraph which states in part, '... I:r. perfections that are unacceptable and any undercutting...'
shall be repaired are icelded the inspector observed a scch-o-let Contra:' tg the above, to th_ o.:t:e of the 12 lach w ol piece Uc. DC-57 in the deci_7 heat at the toe systen which contained a deep, grou.d undercut coolila of the fillet weld."
2-1
a.
ENCLOSURE 2 RESOLUTTON In regard to the radiographic viewer, our revicu of specif_ cation and Code a.
require:r.cnts indicates that there is no requirement to revieu double films The CONA'1 together. The radiography perforred is based on single film viewing.
viewer is a high intensitj viewer and is considered to ::e satisfactory for single filn viewing. Therefore, the single film revicu already given the radiographs is considered satisf actory.
have In regard to " eld joint RC-55AQ, the radiographs of this weld joint been recheched by two cualified and ex,erienced Level 3 examinors.
Ihey consider the r;.diographs and the ucld joint to be catisf actory and that the weld surface irregularities do not interfere with interpretation of the radiographc.
b.
Locking up from the floor, the weld joining the weldolet to the 18 inch decay beat closed water line (spool DC-5/) appears to be undercut.
IIoweve r,
detailed close up visual exa:Ination shows the weldolet to be properly in-f rom the ficor to be an undercut stalled with no undarcut. ' Gat appearr ic in reality a nachining scarf, which in acceptehle.
Alco, it should be noted that this is not a nuelcar class system and that the applicable code for this weld joint is E31.1.
2.
f.I:C FI'?DI!:G
" United Engineers and Ccnstructors Proc dure I?o. QC-17, paragraph IV-B ' Control of Ncnconforming Conditi;ns' states in part, '.
Qua..ity control shall caintain a ras' er log of inspection reports to
..dnate their status' and, paragraph IV-C, states in part, '... Itens that are reinscected cnd are found to be unaccapatble... s hall b e tagged with a reject tab... The nouccaforming condition and the rcferenced incpection report number shall be identifie6 en a deficiency report.
~&c rejected status and a referenced DR number shall be documented on the applicable inspection report for cross-reference."
Contrary to the above, a deficicacy report has not been iscued for a non-conforning condition that was identified in a CC:l4.:: inspection report datad Iay 23, 1972, which relates to rejectable nurnetic particle indicatiens on the Unit I reactor clecure head flange.
Furthernore, there was no evidence that the conditicas had been corrected at the tit-e c.f the inspecticn.
itESCI.l:TIO'.;
A deficiency report (M 5/>5) uns r it ten on Au.ust 31. 1972, to cover thin iter..
Further, steps have teen tnken including revision to the proceCure (QC-17) for centrol o f non-con f oraing its., to a%uce tuat simii; r s in..ica,
do act. c u?
- n
^1 f t i. i. UNC ':nc rc. ! e m n} l e u t e t 9 2 n: ' -. ~ c t ier r,-t.
to am ure that ag rup riate actica is taken regarding li e n, covereu ay L..e rep _,
2-2
ENCLOSUni 2 3.
AEC FINDTNG "UE6C precedure ECP-3, Addendun A, s tates in part, 'The quality control inspector will co:plete the attached check list as applicable While inspecting... ins tallation of the equipten t. '
Contrary to the above, the check lists are not given to the QC inspector for use while inspecting. Dates on the chech list do not agree with the date supplied by the craft perforning the function."
EESOLUTION Actual practice has been for the inspector to not fill out the check list during cable pulls but rather to take notes during pulls and to fill out and date check lists later based on the actes.
Th is is done since cables are pulled in groups and it would be impractical to fill out individual chech lists for all the cables in the group during the pull.
The site practice is considered to provide satir f actory control of cable pulling inspection; however, it is not in strict accordance eith the applicable procedure (ECP-3); this procedure will be revised by Noven.ber 15, 1972, to be in accordance with site practice.
4.
AEC FINDING "UEEC P rocedure QC-13, prior to July 6,1972, required tf.at a quarte rly field audit ho pe rformed to determina that reas u ri n g and teet equipment vere properly controlled, calibrated and inspected.
Contrary to the abcve, the records indicated that only three such audits have been tade, the first cn August 5, 1970, and the last on Novecher 13, 1971."
RESOLUTICM In the future, UEEC QC will perfor-fiele audits on a quarterly basis as required by procedure.
The next audit is scheduled for ':cverber 1972.
G20 has emphanined to UECC canage:.;ent that strict compliance sith precedure require-r.ents is candatory.
3.
AEC FINDING "UELC procedure ECP-6, paragraph 5.1. 4, requi r's monthly rotatica of the engineered safeguards motor shaf ts and t::at engineered oafeguards motors be targered monthly.
Cen t rar: to the ebeve, c;;proniuately four.on ths have el sed since the lant rotatica of the totor shcits and performance of the required r cruinr.
2-3
ENCLOSUT.E 2
,RESOLLTION The required mcggering and rotation of safeguard trotors was brought into conformance with the procedure in September 1972.
Further, the applicable construction procedure hac been revised to require documentetion of this the motor location to facilitate verification that maintenance to be kept at proper traintenance has been performed.
It should be noted that thic problem had been identified by UELC QC and docu ented en inspection reports and a deficiency report prior to the AEC audit ; heuever, renponse by construction was not ti:. 21y.
CPU nanenement cophacined to UElc tanage:..ent in late August 1972 the need to respond rapidly to all QC indicationc of non-confornances; UEEC has revised both procedures ad the organization to speed up such response.
6.
AEC FII!MNG "UESC procedurc ECP-6, paragraph 5.1.3, requires that space heaters be energined or supplerentary hcot provided on enginecred safeguards motors uithin two ucrking days af ter plecccent in storage.
Docunantation is required to be provided on fora ECP-6-1.
UCSC procedure ECP-5 also requires that 'A red indicating lamp chr.ll be installed to sbon that the circuit is energized'.
Contrary to the above, the high pressure. safety injection per:pr, desiger.ted MU?-]A, lE, cud 1C, which verc selected for revlua, uid not appear cc the heater check li c +, and the prescribed red indicating lamps had been re=oved from MUP-1A, and lu."
RESOLL710N On Au;ust 21, 1972, UEEC conrtruction started daily checks of indicating lamps for space heaters on cotors. Further, the heater chetit lis t has :,can updcted to include the ccheup motors, t.nd utll oc kept up-to-d-ate i r t..e future.
C '. ' C.C n'il l a l:' ) periodically conitor to ensure tn it snace Senters are properly ene r;;ine d.
GPU has en.phesired to UE&C :..anagement that preceuure requin r rnts nuc t b e tc t.
7.
AEC Fl:, CNG "UELC Procecure'uCP-10, require; thr.t curveillance b. perfer :d on in* strum:ntc, panels, cont rol boards, and related equipr..eu t to cssure that contrclied storage conditions t.re r aintained.
Contn e< to the above, there is no docu: :ntary evicence that t!.e required surveill ace has buen conducted.
2-4
ENCLOSUPI 2 RESCLL710N-UELC QC personnel indicated that they have perforned general surveil-not energized) electrical lance of storage conditions of stored (and installed but equipment, but have not kept records of this surveillance.
Such records are required by UE&C QC procedurcs, and will be kept in the future.
8.
AEC FINDINC "UC&C Procedure ECP-6 and ECP-10 both require that the field super-visor, quality control, be notified prior to the installation of electrical engineered safeguard equipment.
Contrary to the above, there is no evidence that the field supervisor, quality control, is notified prior to installation of engineered safe-guards equipment, nor evidence that quality control personnel had witnessed installation except for safeguards cable installation."
RES O T,L' TION Up to the tire of the AEC audit, notification to QC of the installation of c]cetrical equipcant vas handled orally.
Installation of much of this equignent vns vitnessed by QC and docur.ented on QC inspectica reports, however, the installeticn o:. sora equipacur was noc witnes.seu by QC ac required by pro-ced u re. 1.7CCC n.aaage,ent has w h a ircd (c.g., in a macting on '.cguct 2 /., 1972) to construction supc.vicion that all precedure requirenents cust be ccnplied with, e.g., tha t procedure requirencnts for QC notification and witnessing rust be ret.
Further, starting in September 1972, UE&C construction craf tc notify QC by speed letter as well as orally of plans for installation of equipc. cat.
9.
_A_EC TI.:?TNG_
"UE&C Procedure GC-17, parcgraph II.B.1, s tates in part, ' !oncon formance includes acti-ritics, materials and equipuent whose condition does
...not ecaply. ith applicable... specificcticrs.'
Contrary to the above, deficiency reports were not prepared for each instance where the cable separation criteria described in paragraph 4.4.4 of UELC procedure ECP-C were not tat."
PISOLLTIC'_;
At the time of the AEC audit, items recut ring resolution with rcrard to neparation cri turia duri ' final inspections of cables were being docu: o tted in innpection reportc and the cabics were being returned to electrical tenctruction 2-5
ENCLOSUI'I 2 for identificaticn to CAI of the need for fire barriers. This practice is in accordance with the UESC (C procedere for final irspection (QC-16) and is not considered to be a nonconformance. Hewever, in order to speed up the resolution of such separation itens, it has recently been decided to issue DR's for cases where separation problers are found in final inspections.
10.
AEC FT"DI':G "The Final Safety Analysis Report, paragraph 8. 2.2.12. c s tates in part, in re fct.:nce to cable separation
'In a very fev cases, the separation is abou; 12 inches and, in these cases, a barrier is installed bett.een the trays. '
Contrary to the separations criteria described abou, the ent;incered safeguards actuating cabinets located in the control room, do act have the separation cpecified as the eininum for cable trays, nor barriers separating the channels.
In addition, there ':cre numerous rolls of cable suspendac under the cabinets, which were ter.inated at both ends, with no docunantation indicating that this practice was unacceptable."
RESOL'J"IO::
In regard to the separation of aferuard cabinets, it is noted that these cabincts h ve steel *: alls (14 par.c miri u:) which are coated wi.th r, heat resistr '.c naterial to provide a t o hour fire ratinp. The cabinet *: alls are considered to be satisfactory fire barriers and to satisfy separation require-ments.
At the tir.e of the inspection there were cases in which cables of different channels violated ceparation criteria. Design work was under "ay at the tire to correct the cable routing to satisfy the criteria, or, should that be impossible, bcrriera vill be installed.
In ret;ard to the coils of uire sevended under the centrol consoles (there are none under the safeguard cctuation cabinets as indicated in the AEC finding), CPU concurs that the coils of,.ulticenductor cabica are presently
<;1tuc ion vill bc corrected <
either ir an u;d2sirch M let..tien and thic r
(1) chcru.ning me cabla icngthc and eliair. ting :.e coils chece field terminations exis t c:: the cab]er. cr (2) ralacating the excees cable in the rel." room vithout violating trav loading, linits where both ends of the cables are shop terminated.
~11.
AEC FI::DI::C "UC&C P rocedure CC-2, requires that all itena identified as beinr associated with the reacter sa fety, inc]uding engineered cafeguarde equipe:nt nai cc pon;nts, be inw.ec ted unca reccipt for conferrr ice with the.:p pli c ca.' c s pe el fica t ica requirc.n w.
2-6
ENCLOiU!I 2 Contrary to the above, reactor pressure sensin< tranducers, identified by number, EK-lS, were not incpected on receipt at the site and the pe rmanen t fi]c for these devices indicated that they had not been received en the site in December 1971."
RESOLUTIC" This equipn.ent was purchased by Met Ed but was installed at a vendor's plant (Pailey) on D& 1 supplied equipment.
Inadvertently, UELC QC did not chech the equiprent docu:ent as part of receiving inspection of the "U.'
co:-ponen t.
UEEC construction menorandun to t.:&C Purchasing dated October 3, 1972, requested Purchasing to adnce UL5C QC of <.ny cther similar cases so that docunentation will be proper 1; checked as part of receipt innpoccion.
The required docutantation
.- RK-18 has been requested but has not yet been received. The cabinets with these ir.strunants have been tagged " hold" per.itandard Ui:5C QC procedures to indicate that the documentation is still required for this instru:*entation.
12.
AEC FI:!DI'_:C "B&W Specification 1132/0069, paragraph 2.4, states in part, 'The vendor hill have wri tt en nrocedures f t' centrol of incrocrien pror e s.
"Jh e s e 7recedures shall cover euch items ce nondezerructive testing inspecticas...' The PL:I QA '3anual. parag raph 11.14,4, 'RT-1 Specification, 1-14-70', staten in part,
'I'.T technique procedure ill be ue:ed with this specification'.
Contrary to the above, the inspector found that no RT technique procedures were used by PD : during the radiography conducted on the Borated Unter Storaga Tank."
In:SnLir.? T C" PD'T Perfor ud radionraphy for the tanha to a pencral radir> graphic specification, but did not 'w ve a techniq"e sheet Ro.-ing ti.,; ec ifi c re'lo-graphic paranatcra f or this radiograpirf.
Revieu of the I'D:: radier,roche b.
Ui:0C QC h we indicated that the radiograohs are of nrisfactory quality.
For reccrd pur,oses, P n' has docunented the : odiographic parar,ters ua :d for the t.,
holl te1<-
nr: a t,.. : cite on a technique <;k :' t (".
' '.u.2pnrhic Te ch n iq ue Procada:v No. I for Centract 1C1.'.6, dated cept. m r 3, 1972).
2-7
ENCLOSUPS 2 13.
AEC FINDII'G "E&W Material Specification, MS-1.3, states in part, ' Carbon steel tie downs shall not be used for stainless steel r.:aterial. '
Contrary to the above, the EEW receiving report, dated May 18, 1972, reviewed by the intpector, indicated that no protection eas used between careen steel holddcun clips and stainless plate for the Dorated Water Storage Tank Materials received on May 9,1972.
In addition, the ins; 'etor could find no corrective action rerorts or other docunantation indicatinp -hat corrcetive actica had been taken to resolve this mntter in the E6', PDM, UEE.C, or CI'U records en s ito. "
1;ESOLCI_G:7 ELU issued a deviation report (072 dated September 26, 1972) to cover this protaj era.
This deviation report was cleared by PCM by buffing and cleaning the affected plater at the time the proble:s was noted.
The PD:' actica is docu-
- ..ented :n a report cat ed Septerc.ber 26, 1972.
In addition, E &'.
has revie*. cd all oti:er EU site receipt ingection repcrts to determine if sir:ilar unresolved problems are indicated; this review did uct reveal any other such open iterr.a.
14.
AEC T'1rn_i_r_G
" Site Prccedt.re 50. MCP-3, revisicn 4, paragraph 3. 60, states in part, ' Acetone is prohibited for use on site.'
Contrary to thd above, PD'A cleaning procedure No. CPI states in part 'Visibla oil and grense spots should be removed frca plates er nozzles by henduiping siith acetone prior to 1 clding the plate or noscle in to the tar:.' The inspector.mn infor ad by FD:t Quali t,- Control personnel that acetone was used curing the f abrication and cleaning of the tcnh."
RES01.C E.
F:ca an ent.incering standpoint, acetone is considered to be a saticinctcry cleanir
<..: n t.
!c' ~.t r, UT.CC elected to nrchibit its une b:. U: :C perscnnel
,s a safety prceautian.
It should be noted that the LJ ',C construct:an procedure
- rohi m.n
..m us ' c f ace t car-
..c. nct contractualli 1:riched c n _ '
and % use of acettan by PL:' 1;cs not a nonccrfurr~.nce.
!iowcVe r, in the future rl.<
uae of r ~_ t on; b y subcentracters vili not be approvad, 2-0
ENCLOSURE 2 15.
AEC FINDING "B&W Specification No. 1132/036?, paragraph 2.3, ' Control of Special Processes ' states in part, ' Vendors shall have written procedures and instructicus for the performance of all special procesces used for the items such as cleaning processes...'
Metropolitan Edison specification sheet No. 620-0005-3t -A-0, da ted Augus t 23, 1970,
'Procedurcs for control of special processes such as states in part, welding, NDT, cleaning... shall be approved by the engineer prior to use.'
Contrary to the above, the inspector observed the cleanin of the borated uste r s tarr.gc tank in progress and revicaed records indicating that testing had been cor,leted. The testiag uv perfor cad without an approved procedure available on site, although an aptroved procedure was in existence."
PISOLIJrIO" GAI had approved the cleaning and hydrostatic test procedurec in July 1971, lcug befcce perfor.ance of the work.
The PD't site personne] have stated th.t they ad confirT.;ed by telephenc with their home of fice prior to the wor'. that the precedures had been approvcd.
Iiot-;c re r, to assurc perfornir.
char only c,,p rovr? p rocedures are c*d by subcontractors. UESC Ccretructicn rene ca;.c October 11.,
le-
r.ninded UELC Purchasinc that they obauld i ai:e sure tha t.
e u/: c:dr 's c to n, nauerstuud Linc fora.:]l., o;,preve? procedurce
.:s t b e availtble prict te : tart of weri;.
UELC field QC peracunel will cbccit for such forual approval in the future.
16.
AEC FINDI':0 "PE 1 Cler--ing Procedure CP-1, stntes in pcragraph 2.1,
'it is under-Stood that prior to the cornencing '7ith the cicanin., of the tanh, all fabrication, weldinu, inrpectin;., and tes ting has becn co.pleted and cpproved by the auth ori;:ed person,. '
In addition, para;;rnph 4.2 s tater
' All weld spatter and/or slag: should be removed froa all tank ruvfaces per weld precedure specification '.T3-48. '
Contrarf to the abov2. the inspector observed the enter.al surfaces of the borated water storage tanh to contait zeld spatter..:c arc strikes.
<> rfaces could not bc examincd. duc to cori: in prc;;csc, Thc interna'
_R_E50 LUTIC::
lt should be V.cted that the ccatract for field ciectica cf the oc.: Ped unter :Lorage tcak does net re';u: re clci.ing of 15 outs: 'e surface of :.he td 2
')
ENCLOSURE 2 and that the PL:: cleaning, procedure, CP-1, is applicabic only to the inside of the tank.
liowever, PDM Weld Precedure Specificction WPS-!.8, docs require arc strikes to be ground and the sc
- face to b.
i+1sp e c t e d.
Subsequent to the AEC the outsida of the tank to inspection, PD:1 perforned a fin.1 inspection or U M
'.S. and Un c QC verified that it was cJean of are strikes.
Further, all welds on the inside of the tam have been ground meath, and the entire surface of the tank has 'oeun buf fed to f acilitate Class B cleaning.
UEnC QC has verified that the inside of the tank ir free of wcld splattet-and are strikes.
17,
,". 1 1". v. _T__ _
~
"The Final Sefety /.nal: sis cpert, par.c 6,24, Tchle 6.2, 'Sercary of
-intut, states under inspection crated.,cter S torage Requite ents ter s.
v.
requiren:nts for weids that the acceptnnce standard 9.0F'A-D-200.
The FSAR aJ so requiren that al] girth and sean welds nall be full the we, a2ar; p ro co c "rc 3 70ci
- 2. cation
.in adu,. tion, penetration.zelt,s.
i No. UPS-48, for the Scrated rater stora,e tank, FPP Steel Ccrpeny contract 20139 datef Octuner 12, 1971, para;;rc h 6.1, s tate that weld,recedure cad welder qualificatienc cre neuired in accc.rnnce with t..c late st c J.ition o f i.S '". Code Section 'M1',
red further nestes
'/ S:. Section VTIT. sill be reed for necep ccucc :t a.d..rds on *DT'.
The crecifice d n, n'so states that NOT reauirc::ents vill ccasist of 20% rac'iography.
Cen trary to the cbove, the rcquic r. nts listed in th /S ' ' cnc the work perf err.ed in accordance vith procurc ent docunents do not raree, nor had th N de ziatica frca the FSAR been identified or docuncated."
b,...,-.,-,.,,.. ~ 1.5.t
'_ae application of Section VIII of the AS:'.: 3 oiler Cede fcr Jelding rec, u rc i :nte for the tnnk in lieu et -h c. 'J; :.-D-10') rc q ui ra:.ca t s is ccaside: ad to ce n'
up ;rc -
,, of tecnnical recuire2nts, c suc ci r.ll:. in re;r rd to oi :2ining in n cad 'rel.
uinr d,.: signs. linwet :., to avoid
< ; isle cc : ca 'cn, the
is briv arended to adicure that Sectioa 'JIII t:cica ng ra ~ n !.. ants cera ucc-1 for field erectiun.
It -hoult be noced that the applicable orcer rec.uircrents ins e : d on PE.' o y..et 1:d recuired 1*'
- .ot radi c,rcoh, v' ic'.-
ans been arfor id, f
an d ti :. Pn
- d r' spee.0 c;u.ien
~?L. ', is c en n i:. w.
- th thi
- cnu '.
a.
, 10 pet r.. '.i o g rr -A,..io t 20: ac. ndiccred in the AEL: t udinr,.
O 18.
/IC F'"DI::0 ah sI &
b
. e t rmo n t..n
_ t.
F. e.
(..
v.. l a n.or c.r e..__.-. : ia n, mi t
- c u,
V I. ., t el:: ti cc :o
_t "m
c e ~ra c t ! '. e x tio i reti'.a 3,.-
staf
- v part. 'The mo t r.'
, 3 a.N r s.: uld
':e - re
&. s t is reeni*ced within a reven ble
- ri,d of t u. ( l c o:. a )
rerpan w
?-10
C'CLOSUPJ: 2 Centrary to the above, the inspector found that audit reports dated April 12, 1972, Februn y 15, 1972, January 26. 1972, and December 2 8, 1971, did not contain doctmentary evidence that corrective ac:. ion had been taken on these fi ndin;-s.
In addition, the use of an incorrect alloy of steel plate fer the fael storage liner, identified by site personnel in 1069, hnd not been resolved at the tire of the inspection.
p_r m.i.; m..s.
CPU has beca continnc sly working to e-crc::se the tite rec.cired to resol.2 udi.t fi n.!iny - en-i p r' ;rmcnce in this re;:.r, has it: roved.
ULEC nd Gp U k:.e of no p rch i ~ r. ;. c d. q; fuel s terrq;e pani liw;r mate rial as referred to by the id:; Int pector.
19.
,,.:a.,,
7_ i,0 r..,.
c.
" LUC P roce durc ';o. CC-8 restricts trans-veld weaving to a dir..ension cquc1 to two "nd one-:alf dia.<te rs of the. elect rode beinu used.
AL.
- 31.7
- pa s trcpb l-7 2 7. '..' (d). s t a t e - in part, ' Tac finished surfn.a of t'w <eit a..11
.2 r e n r.co t h l:. into L'.x ccrr.,n 2 n t r.urfcce the cur # ace..o c t t...' s s of the finished.c]d sha21 he enittble for the prever interc et, tion o f n em do r, tru, t.1ve exa=;naticas of the untdv nn IE inch ctain-Centrary to the abcve. the irgector c.bserved that less steel pipe spcol,':o. CF-1, showed shcp icelds
- ita a tn.nc-izeld waave pattern frer 1-1/4 to 1-1/2 inches 71d.
In ade.ition, the *.tesve patterno had produced deep notches across the weld, uith severe under-cutting at the er.d of the ret ve vhere it contacted the pipine bane retal, uhich c.eca not T.cet ti.e ' blend smoothly' r.nd ' surface
,t z th-req ui rer ?n ts. f t 1
ness
.sa..
y.
. e -
Q~-8 is a field nreco.ure and <jo n not.nnly to Crirr. ell shop. elds lloue t e r. Grinnell p rocedure:. du linic reld beads to 4 tincc the electro:c c
1o t.x This problen in bein; re fie:ed uith dian etc:., ;hich gpc.rea tl:.
C r i r.a c il.
.CC-T:..d u s.1 L' e c'viccd of the final re::ciucion.
In rs.c..'
tc the v '
' u -: :ce arcru!r-fri
, it i:: cen-id' red th e U c.I d ' '1r f de'-
PW l.;c C J p t 01: 3 3 tO iT" COdu, O.;')c cid ll,/ in Vi * ' Of CUGu f350 53 which pc -" i ts '
- m. M ica cf ~
.ci.c 3
- -f a c 's p r c i u. 6 the m.cCace ccrairion oc.i:- :n c.m c r i s t.- m i r t ati
~
adic',
"!. s md or cv raqu ti. <. c nar i.rt. 1:c..
t.
I r* Vi ti.'C u L40 U M. i O ;.' I. 1 p !
[GT pipO,isOOI C I'- l,
t Iri3s I' C i'
t Cca -.
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.u.'.
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i s
09 ENCLOS"I'I 3 IIESOLUT]O':S TO ITr.3 IN E :CLOSU:tE 3 TO IIC-DRO LETTER DJ TED OC.70!iE116,1972 1.
AE C TI'. E :G "l:n ?.i.narred Sa fe.c.unrds Actus'. i ne Bench to: rds, Chan: ela A, E, C,
and D.
Ti.e botton of the cugineered < ':feguarcc actuatin:: '- nc:1 boatd Ch a.m a in '., 'i, C,
.x ' D, ore cc:an tc t h.-
cabic r.m / ding rcer',
which ic locatec Jez the c.ucrol roc..
- ,ilurc l '_ effect c'_1cate closure of these opcning,s conid recult in th" requi?cd cvacua.icn of the co: trol reen if a fira occuired in the c -bJ e weading roc--.
Our in cctora di? tot fiuG dt; -inc, nor matructicr.
relative to the r:thod cf clocure of thir crening."
, u,.,,_..7,..
t n.
GlJ. 10 D rcp triac c: -i nce ri:.T drcQing,c fct n cuitob1:' harrier.
..n t...
,,. r s..,
.s_u___..~_._x___s u.
" n a t t._. -e a n: >
The two batterics,npecr to share a cor--
ventilat;cu sys tem, t-ihi ch could resi:Ac in a cu~:r.on tr uc.= cf frilure <'uould a li m occu.
a one bctt,2 c ruem n -- 6 i. t rnas::.it.ted to t he a c cor>d roor.i
- ay o f
- t. -
veni_2 3 r.tien s ys t e. "
I:;-_ r:f 'n ic:'
P aga 3-7 1:? tne F M it, pa ra m ph C. 2. 2.1:).e, covers this subject.
c Dn', m irc nen tntiv? Cic. Sul:
D
u r t a - c. this subjecc.zs re vic.:cd c...
"Jc
- C te r) U C.,
<> re at IIII CiiP in ' a r.:h 3972. AS fic. d an tb 2
T. ch rext w ILs
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-a u:, '
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..c rs. M.. t i vn t e(. b;.' cc.:51nc.m;<
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