ML20037D286
| ML20037D286 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/06/1981 |
| From: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Hovey G METROPOLITAN EDISON CO. |
| Shared Package | |
| ML20037D287 | List: |
| References | |
| NUDOCS 8107090268 | |
| Download: ML20037D286 (2) | |
See also: IR 05000320/1980012
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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$31 PARK AVENUE
KING OF PRUSSt A, PENNSYLV ANI A 19406
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MAR 0 6 31
Docket No. 50-320
Metropolitan Edison Company
ATTN: Mr. G. K. Hovey
Vice President anc Director of TMI-2
P. O. Box 480
Middletown, Pennsylvania 17057
Subject:
Inspection 50-320/80-12
This refers to your letter dated January 6,1981, in response to our letter
dated November 14, 1980.
Your letter contained responses to our findings of two deviations related to-
welding activities associated with the Submarged Demineralizer System (SDS).
The deviations were cited due to the Welding Procedure Specification (WPS) not
being available at the work location and no inprocess inspection activities
conducted on welding work activity. Tilase responses were discussed in a con-
ference call on February 10, 1981, between Mr. Lowell Tripp of this office, Mr.
Antho.ny Fasano and Mr. Richard Conte of the NRC TMI Program Office, Mr. Larry
King, Three Mile Island Unit 2 (TMI-2) Plant Operations Director and other
members of the TMI-2 staff.
With respect to Item A of Appendix A to our letter (lack of WPS in the vicinity
of welding work location), it was agreeJ that this was not a deviation from
licensee procedural requirements or the ANSI B31.1 Code.
NRC indicated that it
was regarded as a deviation from generally accepted practices in the industry
which have safety significance.
TMI-2 staff members indicated that applicable
WPSs have now been placed in the vicinity of welding activities.
We also under-
stand that the TMI-2 staff is taking steps to change general procedures to
incorporsce such actions as requirements by March 31_, 1981.
Based on these
actions and subject to our examination during a future inspection of your licensed
program, this deviation is considered resolved.
,
Item B of Appendix A to our letter regarding the apparent lack of inprocess
inspections of welding activities was also discussed in the referenced telephone
conversation.
It was stated that although there were quality control inspection
" hold points" in the SDS installation procedures, there are no quality control
inspections of inprocess welding activities. A visual inspection after completion
of welding only meets the minimal requirements of ANSI B31.1. The same Code, in
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8107090268 810306 '
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PDR ADOCK 05000320
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Metropolitan Edison Company
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Chapter VI, Paragraph 136.1 states in part..."the rules of this code and the
quality control system requirements of Appendix A-300 of Section 1 of the ASME
Boiler and Pressure Vessel Code shall apply...".
Appendix A-300 states in part
in Paragraph 302.7 on welding..."The quality control system shall include pro-
visions for indicating that welding conforms to requirements of Section IX as
supplemented by this section...".
Further, Regulatory Guide 1.143 states in
part in Section 4.2.3.2 pertaining to the System Constructor.... "(1) Inspection.
In addition to required code inspections, a program for inspection of activities
affecting quality shall be established and executed by or for the organization
performing the activity to verify conformance with the documented instructions,
procedures and drawings for accomplishing the activity. This shall include the
visual inspection of components prior to installation for conformance with
procurement documents and the visual inspection of items and systems following
installation...".
Considering these requirements and that the processed water in this system has
activity levels of N100 Ci/ml and contains corrosive elements as well as radio-
active particles, it would seem that more than a minimal inspection is warranted.
The TMI-2 staff members stated that QC inspectors do perform informal surveillance
or inspections of inprocess weldiag activities when they are in the area where
welding is being performed.
It was agreed that this deviation remains unresolved
pending further inspector programmatic review of the level of QC participation
in inprocess welding activities.
If our understanding of the results of the February 10, 1981 telephone discussion
of these matters is different from that presented above, please inform this
office within five dvs.
Your cooperation with us is appreciated.
Sincerely,
109-)'N,
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ce H. Grier
irector
cc:
J. J. Barton, Manager Site Operations, TMI-2
E. D. Fuller, TMI-2, Licensing Supervisor
E. G. Wallace, PWR Licensing Manager
J. B. Liberman, Esquire
G. F. Trowbridge, Esquire
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Ms. Mary V. Southard, Chairperson, Citizens for a Safe Environment
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