ML20037D288
| ML20037D288 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/06/1981 |
| From: | Hovey G METROPOLITAN EDISON CO. |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20037D287 | List: |
| References | |
| TLL-699, NUDOCS 8107090271 | |
| Download: ML20037D288 (3) | |
Text
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- s Metropolitan Edison Company
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Middletown, Pennsylvania 17057 Post Office Box 480 Writer's Direct Dial Number January 6
, 1980 TLL 699 Office of Inspection and Enforcement Attn:
Mr. Boyce H. Grier Director Region I U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pennsylvania 19406
Dear Sir:
Three Mile Island Nuclear Station, Unit 2 (TMI-2)
Operating License No. DPR-73 Docket No. 50-320 Inspection 50-320/80-12 This letter is forwarded in response to your report, dated November 14, 1980, concerning the subject inspection.
In that report you state:
"However certain activities appear to be deviations from commitments made with respect to the Submerged Demineralizer System." Those devia-tions, as specified in Appendix A, Notice of Deviation, aloag with our responses to the alleged deviations are specified below.
DEVIATION A.
The Technical Evaluation Report for the submerged demineralizer system transmitted to NRC by a letter from G. K. Hovey, Director, TMI-2, to J. T. Collins, Deputy Program Director, NRC TMI Program Office, dated April 10, 1980, states in part, "...The regulatory guidance followed during the design of the submerged demineralizer system was extracted from the following documents:
U. S. Nuclear Regulatory Guide 1.143 dated July 1978...."
Regulatory Guide 1.143 " Design Guidance for Radioactive Waste Management Systems, Structures and Components Installed in Light-Water Cooled Nuc'. ear Power Plants," states in part:
4.2.3.2 System Constructor (1) Inspection:
In addition to the required code inspections a program for inspection of activities affecting quality shall be established and executed by or for the organization performing the activities to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activities...."
8107090271 810306 PDR ADOCK 05000320 PDR 0
Metropettan Edison Company is a Memcer of the General Publ:c U!it:es System
' Mr. Boyes H. Grier January 6, 1980
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Implicit in this quotation is the basic quality assurance concept that activities affecting quality should be accomplished in accordance with documented instructions, procedures, and drawings which, if they are to be used, should be readily available to the person (s) performing the activities.
Contrary to the above, on July 23-25, 1980, during an inspection of the pipe welding activities relative to the fabrication of the submerged demineralizer system in the spent fuel storage pool, the inspector noted that the applicable welding procedure specification SP-4200-SS (N)-101A containing quality character-istics important to controlling weld quality was not readily available at the location where the welding activities were being performed.
RESPONSE
The Submerged Demineralizer System piping is being constructed in accordance with the requirements specified in ANSI B 31.1 r
Section 127.5 and 127.6 requires that welding procedures be qualified in accordance with the requirements of that section and that the welders performing the work be qualified to rca procedure.
In every case, during construction of the SDS, the welfers working are qualified to the welding procedure in use.
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Our present quality assurance / quality control program applicable to the SDS requires that:
1.
Welders be qualified to the welding procedure in use.
2.
The welding procedure be qualified to the requirements specified in ANSI B 31.1.
3.
The actual welding procedure in use be in the posession of the Project Welding Engineer.
Since we have not imposed the requirement upon ourselves to maintain a copy of the welding procedure in use at the specific work location, we contend that no procedural deviation o,: curred.
Furthermore, because of the qualification of the procedure and the welder qualifications that have been performed, we contend that we have complied with the intent and specific words of ANSI B 31.1 and the guidance of Regulatory Guide 1.143.
DEVIATION B l
The Technical Evaluation Report for the submerged demineralizer system transmitted to NRC by a letter from G. K. Hovey, Directo,r, TMI-2, to J. T. Collins, Deputy Program Director, NRC TMI Program Office, dated April 10, 1980, states in part,
...The regulatory guidance followed during the design of the submerged demineralizer system was extracted from the following documents:
U. S. Nuclear Regulatory Guide 1.143, dated July 1978....."
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o January 6, 1980 Ftr' Boyce H. Grier -
Regulatory Guide 1.143 " Design Guidance for Radioactive Waste Management Systems, Structures and Components Installed in" Light-Water Cooled Nuclear Power Plants" states in part, 4.2.3.2 System Constructor (1) Inspection.
In addition to required code inspections a program for inspection of activity affecting quality shall be established and executed by or for the organization performing the activity to verify conformances with the documented instruction procedures, and drawings for accomplishing the activities...."
Contrary to the above, on July 23-25, 1980, during an inspection of the pipe welding activities related to the fabrication of the submerged demineral system in the spent fuel storage pool, the inspector noted that there were no Quality Control procedures, inspection check lists, or any inprocess inspection activities inherent to a Quality Control program for the inspection of activities affecting quality.
RESPONSE
The construction of the Submerged Demineralizer System is performed in accordance with written and approved procedures.
Incorporated as an integral part of these procedures are those quality control checks that have been deemed appropriate to assure the quality of the system upon completion of construction.
Specifically, quality control inspection " hold points" are incor-porated as specific procedural steps to prevent the continuation of work until the construction quality for that step has been approved.
This approval is documented as the signature of the inspector within the body of the procedure.
We believe that this method of integrating quality control and construction activities into a single procedure is an extremely effective method to implement a quality control program.
- Further, l
we believe our quality control program for SDS construction to be in compliance with the letter and intent of the guidelines l
.provided in Regulatory Guide 1.143.
Sincerely, l,
G. K. Hovey, Vice-President and Director, TMI-2 l
GKH:LJL:djb l
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cc: Lake Barrett l
B. J. Snyder bec: TMI-2
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