ML20125B445

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Forwards Summary of Util Understanding of AEC Findings Identified in 730328 Audit Exit Interview & Util Statements Re Implementation of Corrective Actions
ML20125B445
Person / Time
Site: Three Mile Island  Constellation icon.png
Issue date: 05/15/1973
From: John Miller
METROPOLITAN EDISON CO.
To: James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
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ML20125B444 List: ... further results
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FOIA-96-208 NUDOCS 7911080521
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/ METROPOLITAN EDISON COMPANY TELEPHONE 215 - 979 2601 POST OFFICE BOX 542 RE ADING. PENNSYLV ANI A 196o3 I

l May 15, 1973

\

t ll Mr. J. P. O'Reilly, Director Directorate of Regulatory Operations, Region 1 United States Atemic Energy Commission 970 Broad Street Newark, Nov Jersey 07102

Subject:

Three Mile Island Nuclear Station Unit 1 - Docket No. 50-289 Unit 2 - Docket No. 50-320

Dear Mr. O'Reilly:

As a result of the findings identified in the March 28,

!l 1973 audit exit interview, and based upon subsequent discussions a=ong you and your staff and key representatives of Metropolitan Edison Company and CPU Service Corporation, we have initiated action.

The attachments contain a suc=ary of our understanding of your find-ings, a discussion where applicable, and a statement regarding impic-centation of corrective action. i l

It is our intent to correct these findings and to keep you informed of the current status of each item Thisinletter the attach is for- =ent and any outstanding plans to complete the item.

warded for your information.

Yours very truly, i

J. C. Miller eg Vice President f V '

  • brh Attachments 7911080 '

CC:(With Attach =ents) Mr. W.M.

Mr. H. M.Dieckamp Creitz t Mr. W. C. Kuhns Mr. W. A. Verrochi

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)pGro2l NA 49 _

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1. Flood Damage to Safeguard Equipment:

DRO Findtng:

The DRO letter dated June 27, 1972 requested that they be advised of any signifi-cant damage to nuclear safety related structures, systems, components or materials as a result of serious flooding conditions the previous week. Met-Ed letter dated June 30, 1972 states that no significant damage had occurred. Subsequently, ,

DRO inspectors became aware that the reactor building spray and decay heat removal pumps and motors had been submerged in water and were returned to the vendor for refurbishment, in contradiction to the Met-Ed letter of June 30, 1972.

Discussion:

The reactor building spray and decay heat removal pumps and motors are located in the lower level of the auxiliary building which became submerged by in-leakage of rain water on June 22, 1972 because of the incomplete stage of construction.

Flood water did not enter this or any other nuclear safety related structure.

At the time of response to the DRO letter, it was believed that the letter was concerned with damage caused by flooding due to rise in the Susquehanna River and not with rain damage. Therefore, the rain damage was not mentioned in the June 30, 1972 letter.

Corrective Action:

During the period since the flood, all nuclear related equipment which has been I

identified as being wetted or sub=erged by either rain water when installed in the plant, or by river water when stored in the lov level storage area flooded by the river, has been reviewed and dispositioned to re-establish specified caps-bility. A list of this equipment and its disposition is attached for information.

Should further significant information beccee available, we will keep you inf ormed.

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t 201i 147

THREE MILE ISLAND UNIT 1 w

  • Coepletion Date Deficiency Report Disposition _

Cause of Damage Number ar.1 Date _ 3/73 Nuclear Related Equipeer t_ Returned to vendor for re ,'-

Covered by rain water conditieningandoperationaJ Decay Heat Pumps and 0471 - 6/28/72

1. 0472 - 6/28/72 testing Motors - 1A and B 3/73 Covered by rain water Returned to vendor for re-0471 - 6/28/72 conditioning and opentional
2. Reactor Building Spray Pumps and Motors 0472 - 6/28/72 testing IA and B Motors replaced 10/72 covered by rain water Vaste Disposal Liso!d 0472 - 6/28/72 3.

Sump Pump Motors 5A and B Scaled connections opened 6/73 Partially covered by and interior inspected for Decay Heat Coolers 0472 - 6/28/72 rain water

4. evidence of contamination 1A and B Rainwater:
5. Valve Operators: Dried and inspected 2/73 0472 - 6/28/72 Covered Inspected 2/73 DHV 6A Partially covered Dried and inspected 2/73 0472 - 6/28/72 DHV 6B 0472 - 6/28/72 Covered Dried and inspected 2/73 BSV 3B Covered 6

' m 0472 - 6/28/72 o BSV 4B

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THREE MILE ISLAND UNIT 1 (Contd.)

Completion Deficiency Report Disposition _ Dge Cause of Damage Nember and Date _ S. I Nuclear Related Equipment _

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6. Valves: 6/73 Covered by rain water Cleaned and reconditiened 6/73 0843 - 4/25/73 Covered by rain water Cleaned and reconditioned 4/73 FBV - 61 0843 - 4/25/73 Cleaned with demineralized _

yBV - 74 Covered by rain water c 0472 - 6/28/72 vater DIN - 6A Cleaned with demineralized 4/73 (

Cover o by rain water j 0472 - 6/28/72 vater 7/72 DitV - 6B Cleaned with demineralized Partially covered by 0472 - 6/28/72 water 7/72 DIN - ISB rain water Cleaned with demineralized Partially covered by 0472 - 6/28/72 vater DIN - 19B rain water 7/72 Covered by rain water Cleaned with demineralized 0472 - 6/28/72 water BSV - 4B 7/72 Covered by rain water Cleaned with demineralized 0472 - 6/28/72 vater BSV - 3B 7/72 Covered by rain water Cleaned with demineralized 0472 - 6/28/72 vater WDLV - 162 Cleaned with demineralized 7/72 Covered by rain water 0472 - 6/28/72 vater WDLV - 163 7/72 Covered by rain water Cleaned with demineralized 0472 -- 6/28/72 water 7/72 WDLV - 348 Cleaned with demineralized Covered by rain water 0472 - 6/28/72 vater WDLv - 349 7/72 Wetted in storage by C1 caned with demineralized None water

7. Fuel Racks river water N

CD 7/72 Wetted in storage by C1 caned with demineralized None water S. Reactor Coolant Pump river water ,

Motor Support Stands (4)

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THREE MILE IStErD UNIT 2 Cx Completis7 Date Deficiency Report Cause of Damage _

Dispos ition_ ,

Nuclear _Related Equipment Number and Date _ }k 6/73 Partially covered by rain water C1 caned with demin- -

Decay Fest Service 0078 - 7/5/72 eralized water 1.

Coolers - 1A and B l

Returned to vendor 9/73 Partially covered by rain water for cicaning Decay Heat Coolers 0078 - 7/5/72 2.

1A and B

3. Tanks: All of the listed All in ,

Partially covered by rain water 6/73 None tanks cleaned with WDL-T-1A. B. and C None demineralized water WDL-T-5 0018 - 7/5/72 (All listed tanks)

WDL-T-8A and B 0078 - 7/5/72 kTL-T-9A and B 0078 - 7/5/72 WDL-T-11A and B 0078 - 7/5/72 WDS-T-1A and B 0078 - 7/5/72 kTS-T-3 0078 - 7/5/72 '

FB-T-1 0078 - 7/5/72 1A-T-1A and B None WDL-Z-1 Returned to vendor 4/73 Covered by rain water Control Building River 0080 - 7/7/72 for reconditioning 4.

Water Booster Pump and operational testing Motors 2A and B N

O Returned to vendor 12/72

-- Covered by rain water 0079 - 7/7/72 for reconditioning

~ ~ 5. Instrument Air Compressor - 1A and B U

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~ ~ - ~ ~ os . _ . . . . . . .

O s THREE MILE ISLAND UNIT 2 (Contd.)_

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Completion Date Deficiency Report Disposition _ _

Cause of Damage Number and Date 7/72 Nuclear Related Equipment _ Cleaned with Covered by rain water demineralized water None l 6. Miscellaneous stain-less steci piping 7/72 Partially covered by river Cleaned with None demineralized water

7. Reactor Coolant Pump water

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2. Maintenance of Safeguard Motors:

DRO Finding:

The DRO inspectors noted recurring deficiencies in safeguard motor maint rance and QC overchecks. Specifically, some safeguard motors installed and in storage had not been meggered and rotated on a periodic basis as required by Construc-tion Procedure ECP-6-2. In additica, QC and-QA did not adequately detect the deficiency and initiate corrective action.

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Discussion:

The failure to properly maintain safeguard motors is the result of an incomplete list of the motors required to be maintained, and the failure of Electrical QC personnel to systematically check all items within QC scope. l f

l Corrective Action:

To correct this situation, the existing list being used by the craf ts will be reviewed and updated as necessary by the engineers. In addition, the engineers l will prepare check lists for Craf t and QC use which will describe requirements and the necessary checks for each item. Each check list will be signed of f at I

the time of inspection by 'ath Craft and QC personnel. The Unit 1 motor check .

I lists will be co=pleted by 16,19: 3. The check lists for Unit 2 will be completed in August 1973.

l Additionally, a craf t supervisor is being identified to be specifically respons-ible for preventative maintenance checks, and is being required to report on  !

this effort. Quality control is being instructed to do periodic overchecks of preventative maintenance.

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3. Craft Hotification to QC:

DRO Finding:

Construction has not been providing written notification to QC prior to installa-including the re-installation in March tion of electrical safeguard equipment, 1973 of the reactor building spray and decay heat rc= oval pumps and motors.

Discussion _:

The finding on the general inadequacy of such notification was first raised in a DRO audit in August 1972. Met-Ed letter dated Novecher 3, 107: to the DRO '

stated that speed letters would be used to notify QC of planned installation of .

26 - 28, 1973, all safeguard equipment. This item was audited by the DRO on March at which time they were informed that no speed letters had been sent by Construc-A review tion or received by QC. We now find this infor=ation to be incorrect.

of the on-site files in the Electrical QC Engineers' office shows 158 speed 1972.

letters received for the installation of e:ectrical equipment since August In addition, a survey of the on-site QC Inspection Reports indicates the following: 1 I

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1. Last half of 1971 - 1500 Electrical Reports

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2. First half of 1972 - 2491 E1cetrical Reports  !
3. Last half of 1972 - 2000 Electrical Reports /
4. January 1973 to May 1973

- 1150 Electrical Reports These reports fall into the following major categories 227 l

1. Cable Tray 793
2. Conduit ,

1 j

t 3,473

' 3. Circuit Pulls 1,384

4. Circuit Termination 197
5. Motors / Diesel Cenerators 73
6. Penetrations 176 l
7. Control Rod Drive 106
8. Storage wi 3,n 3 4. U i e

3 20li 153 I . - . _ _

3. Craf t Notification to QC (Continued):

Discussion (continued):

Electrical Cadweld 90 9.

56

10. Audits 69
11. Miscellaneous
12. Motor Control Centers, Station Batteries, Panels, Consoles  ;

& Switchgear 497 I

l Total 7.141 During the audit by DRO on March 26 - 28, 1973, they were informed by responsible Construction and QC/QA supervision that reactor building spray and decay heat removal pumps and motors had been re-installed earlier that month without the issuance of speed letters and that no deficiency reports for these deficiencies l

had been issued. We now find this information to be incorrect in certain re-However, defici-spects.

There were no speed letters issued to cover this work. l ency reports on lack of notification to QC were issued on March 2 and 5, 1973. )

In addition, QC Inspection Reports indicate sece, but not all, of the work involv-ing the reactor building spray and decay heat pumps and motors did have proper inspection.

Corrective Action:

GPU Service Corporation Project Manager will direct the UE&C Project Mcnager to conduct a cceting with Construction Supervision. The purpose of this cecting will be to re-emphasize the need for strict adherence to the written procedure j

and the necessity for providing advance notice of schedules and schedule changes In addition, for installation of electrical saf eguard equipment and =aterials.

all Construction Procedures will be reviewed to deter =ine that positive t'struc-tions are provided to supervision en the necessity of providing to Fic1d QC written notification for installation of all safeguards and nuclear equipment.

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20Ii 154

3. Craf t Notification to QC (continued _):

Corrective Action (Continued _): ll site QA The CPUSC Manager of Quality Assurance will conduct a meeting with a i h the require-and QC Engineers instructing them to re-familiarize themselves w t i lar assignment ments of all construction procedures that pertain to their part cu or discipline.

They will be instructed to apply the requirements of all QA/QC Procedures in the strictest sense.

d by Con-All QA/QC Engineers will be instructed to review each schedule issue l d equip-struction to determine if installation of safeguards or nuclear-re ate If so, that equipment will be identified and entered on ment is contemplated.

The status of equipment on this schedule will be reviewed a QA/QC schedule.

daily.

Should this review indicate a change in status (e.g., equipment mov has from storage to installation site), the engineer will determine if this wor including i

been accomplished in accordance with applicable construction procedures, ,

Use of a new form for providing written a record of the prior notification. I notification was initiated by UELC on May 4, 1973. l 1

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4. Maintenance of Electrical Cabinet Storage conditions:

DRO Finding:

l The DRO inspectors considered that documentation of QC surveillance of cabinet storage conditions is fragmentary.

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Discussion:

i QC sarveillance was performed on January 29 and May 1,1973, and on inspection reports. This surveillance and documentation were in accordance However, the procedures are not with existing site procedures at the time.

based upon definitive check lists.

l Corrective Action:

A craf t supervisor is being identified to be specifically responsible for storage Additionally, a quality control inspector and preventative maintenance checks.

is being specifically assigned to verify this effort.

We are directing our engineers to prepare a listing of all electrical and In addition, check lists mechanical equipment that comes under QA/QC scope.

ibe will be prepared by the engineers for une by Craf ts and QC which will descr Each check list will be signed of f as re-the necessary checks for each item.

The Unit i quired at the time of inspection by both Crafts and QC personnel.

list will be updated by June 7,1973 and the check lists will be completed b 1973.

June 21, 1973. A similar effort for Unit 2 wila be complete in August, fAa i nn, a LU4 i

201; 156 f ar

  • , s l 5. Coiled Cables in CC and CR Cabinets:

DRO Finding:

DRO considered that the coils of cable below these cabinets were unsatisfactory and violated cable seps . ion criteria.

Corrective Action:

Reworking the cablea in the CC and CR cabinets is continuing to assure that l

the separation criteris, for cables within them (minimum separation of 6 inches) is met. Coils will remain in this area to provide slack for service reasons.

In any areas where the six inch separation criteria cannot be net, barriers vill be detailed by Cilbert Associates, Inc., for installation by field per-sonnel. The CC'and CR cabinets vill be reworked by May 21, 1973.

In addition, a review of the overall separation criteria docurents indicates that this information is not suf ficiently cocplete or specific to enable pro-I duction and quality control to have a complete understanding of the require- l l

nents in one or two packages. The engineers are being directed to produce this 1973 for Unit 2.

package by June 6, 1973 for Unit 1, and by August, .

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.201i 157 I

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6. Internal Electrical Audits of Tool, Cauge, and Instrument Control _:

DRO Finding:

DRO indicated that they considered that the internal audits performed by the Electrical QC group were inedequate. This is believed to be in reference to d

audits of toni, gauge, and instrument control, and to be specifically concerne with lack of specific identification of the items checked and quantitative measurements noted during the audit.

Corrective Action:

We have reviewed the manner in which internal audits are docume  :

j inspected that increased quantitative and qualitative definitions of the item It is believed that this vill ensure and conditions found should be recorded.

that meaningful audits are performed. lI l

The site procedures for internal audits have been revised to require check lists The internal to be definitive in regard to items checked and conditions noted.

auditors will be instructed to use the procedures provided and assure that the i I

I check lists are specific and not subjective.

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7. C,ontrol of Ferrite:

DRO Finding:

(

B&W Specification CS-3-37 f or reactor coolant piping requires f errite controls j

' in austenitic welds to be greater than 5%. One weld of 16-8-2 was noted with

a ferrite content of 1.5 to 2.5%. It was also found that heat No. 50311 of .

J

type E-308 electrode showed no chemical analysis of ferrite on the records, 4

as appropriate for E-308 electrode.

Discussion:

B&W Specification CS-3-37 Heat No. SC's ,. does not involve Type E-308 electrode.

requires ferrite control in all austenitic stainless steel electrodes, but identi-Over a i fies the acceptance criteria (5% minimum) for only Types 308 and 347.

for 16-8-2 year ago, CPU reviewed this matter with B&W and confirmed that, Tests were conducted by both UE6C

' electrodes, no ferrite limits were necessary.

and B&W to confirm that microfissuring is not a problem with low ferrite in i Therefore, we consider that to be no problem in this area.

16-8-2 materials.

However, to further clarify the record, B&W has processed a contract variation (CV-205-25 FEV dated May 3,1973) to confirm that the low ferrite 16-8-2 is acceptable.

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I LUt Corrective Action:

None required.

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i 201i 159 4 9

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