ML20125B450

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Discusses 790814-17 Insp of Const Activities.Noncompliance Noted:No Instructions,Procedures or Drawings Describe Testing &/Or Calibr Required for Sensors or Instruments Used in Detection of Sys Abnormalities
ML20125B450
Person / Time
Site: Three Mile Island  Constellation icon.png
Issue date: 10/06/1972
From: James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: John Miller
METROPOLITAN EDISON CO.
Shared Package
ML20125B444 List: ... further results
References
FOIA-96-207 NUDOCS 7911080522
Download: ML20125B450 (11)
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. . .. OCT 6 1972

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theropolitan Edison Company Docket Nos. 50-289 & 50-320 Attantions Mr. J. C. Mit tar Yies President *.

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? P. O. Bos 542

! Beeding, Feensylvania 19603 1

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'r This refers to the inspection conducted by Mr. Howard and other members

, of my staff an August 14-17, 1972, of construction activities authorized j , by AEC Construction Permits Nos. CFF1-40 and CFPR-66 and to the discussions L ,' of ear findings h.1J by Mr. Howard with Mr. Beaurd and other members of 4

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, year staff at the conclusion of the inspectico and to the telephone con-

  • versation between Mr. J. G. Miller and the. Director of Pagion I, Regulatory

. Operattama en October 5, 1972. .

Aeems ar==f ned during this'inspectioii' included implementation of the Quality Assurance and Quality Control Programs for control of construction in the areas of electrical and instrs==nration installation, reactor coolant piping, other Class I piping, reactor vessel and internals, the refueling enter st.orage tank, and other Class I components. In addition, quality j

centrol records were reviewed in the above areas to verify documentation es work,completad. Within these areas, the inspection consisted of

==1metive -in=tions of procedures and representative recorde, inter- '

1 visse with plant personnel, and observations by our inspectors. I i

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} During this inspectico, it was found that certain of your activities appeared

I to be in nonconformance with Appendix B to 10 CFR 50 or in concompliance l uith the Final Safety Analysis Report and sita instructions or procedures.

] ,- In addition, two items appeared to raise questions concerning the adequacy l ef construction. The items and references to the pertinent requirements are j , listed in the snelosures to this letter. Please provide us within 30 days, I

in writing, with year commenta ecocerning these items, any steps that have I

been or will be takes to correct them, any steps that have been or will be i k takaa to prevent recurrence, and the date all corrective action or preven-4 tive maaenres were or will be completed. Tour reply should emphasize, in i particular, any appropriate changes that have been or will be made to 1:n-l , prove the affactiveness of your quality assurance program to prevent re-l currence. ,

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' , I j Should you have any questions concerning this inspectiou, we will be j pleased to discuss them with you, i

l Sincarely, ,

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- ; l l i James P. O'Railly '

l Director 4

Enclosures:

1. Description of Noncompliance Items ,
2. Description of Nonconformance Items

, 3. Description of Safety Items i

! bec: A. Giambusso L l' P. Morris, RO H. Thornburg, RO R. Engelken, RO J. Keppler, RO J. Henderson, R0 RO Files i

DR Central Files

, MC PDR Local PDR NSIC DTIE State of Pennsylvania , , , , , , , , _ _ _

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i INCIDSURE 1 i

Description of Noncompliance Items _

l l Metropolitan Edison Company j Dockat Nos. 50-289 and 50-320 j i,

License Noe. CFFR-40 and CFFR-66 l

Cartain items appear to be in noncompliance with 10 CPR 50, Appendix B,

. as identified below 1

1. Criterion Y, " Instructions, Proceduras, and Drawings", states in part, j

" Activities affecting quality shall be prescribed by documented in-  ;

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structions, procedures, or drawings, of a type appropriate to the l l

sircumstances and shall be accesplished in accordanca with these j instructions, procedures, or drawings. Instructions, procedures, or draurinas shall include appropriate quantitative or qualitative acceptance

[ criteria for detar=4ning that important activities have been satisfactorily  !

i I seeesplishad."

Coutrary to the above a

j a. There are no instructions, procedures, or drawings delineating the quality aspects of the insta11stion of the individual sensors or instrumenta used in the detection of system abnormalities.

1 i b. There are no instructions, procedures, or drawings which describe I j the testing and/or calibration required for the sensors or instru- l eents used in the detsetion of system abnormalities.

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i c. There are no instructions, procedures, or drawings relative to the i Prragraph a.2.11d of the TSAR requirements, which states in part, l ". . . All vertical trays have solid covers to six feet above their j floor penetrations."

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! d. Instructions, procedures, or drawings do not require that the cabla tray loading specified in the UE&C Procedure ECP-I and paragraph a.2.2.1.13.4 of the FSAR be varified.

e. Procedures for the 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.

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2. Criterion VII, " Control of Purchased Material, Equipment and Services",

j states in part, ". . . Documentary evidence that material and equipeent

' conf orm to the procurement requirements shall be availabu at the nuclear power plant site prior to installation or use of such material or eeuip-j ment . .

." Criterion IVI, " Corrective Action", states in part,'. ..

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Measures shall be established to amours that conditions adverse to

> quality . . . are promptly identified end corrected . . ."

l Contrary to the above, the inspector found that the only sacerimi and l

fabrication records available on site for the Babcock & Wileos supplied reactor coolant piping spools were the welding records. This inceznplete l

documentation vos noted as a deficiency against the piping spools and the l

!  ; receiving records dated July 1970. The deficiency had not been corrected i at the time of the inspection.

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3. Criterion II, " Control of Specia'. Processes", states in part, ' Measures 4 shall be established to assure that special processes such as welding

( . . . are accomp11 abed . . . i'a accordance with applicable codes, stan-j dards, specifications, and et'aer special requirements."

4 Contrary to the abovet f a. The imeyectors founs that UE&C Frecedure QC-8, "Fipe Welding Control",

i containe no requirement nor provision on the weld history sheet for defect remeral v9tification which is specifically imposed on the i

j Three Mila Isir.ad 1 pipe welding by the Gilbert Associates Specification i No. 550.

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l b. 5&W Specir,1 cation No. CS 37-3, Paragraph 5.1.7, requires that electrodes

for voir',ing stainless steel shall contain a minimum of 5% delta ferrite. l l

l Crvn?;cary to the above, the inspector found, during a review of a 4 C+;1nnell test report for E-308 electrode, heat #9H633, that chem-l ical analysis indicated less than 5 ferrite. This deficiency had i

mot been identified by Grinnell or UE&C QC record persennel.

! The inspector also found that the Babcock & Wilcox docuenantatien i recordo covering the pressuriser surge piping spec 1s contained material records for line coated electrodes which do not meet the A81M chemical requirements.

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ENCLOSURL-- 't

.a i Description of Nonconformance Item Metropolitan Edison Company Dockat Hos. 50-239 and 50-320 l Licanae Nos. CPFR-40 and CFPR-66 Cartain itese appear to be in nonconformance with statements in your Final Safety Analysis Report (PSAR) and/or site procedures and instruc-tions, as identified below:

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1. 'the PSAR, Paragraph 4.1.3.2, " Piping", states in part , "The design ,
fabrication, inspection and testing of the reactor coolant piping i in,t ains the pressuriser surge line . . . is in accordance with NiSI I 331.7."

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s. ARSI E31.7, "Nuclaar Power Piping" Paragraph B-1-110.6, states in part, ". . . l sent used to view film for radiographic Equi.

interpretation chall provide a high intensity light source such that the penetrameter and hole for the specified quality level

!' aball be readily visible for the specified intensity range."

. Paragraph 5-1-120.1 states in part , ". . . the weld ripples or

- wald surf ace irregularities on both the inside and outside shall l be removed by any suitable mechanical process to such a degree that

. the resulting radiographic contrast due to irregularities cannot mask or be confused with the image of any objectionable defect . . ."

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Contrary to the above, the inspector observed that the CC:tA t in-spection agency did not have high intensity radiographic viewing equipment on site and that the available equipant appeared to be incapable of revealing rejectable defects in composite filr.s.

During a review of the radiographic film representing pressurizer surge line weld No, RC-55AQ, the veld area was characterized by alternating bands of light and dark areas due to improper prepara-i tion of the weld surface prior to conducting radiography.

l b. USASI B31.7, Paragraph 1-727.4.4, states in part , ". . . Fillet welds may vary from convex to concave. The size and centour I dstermined as shown in figure 1-727.4.4(a) . . . The namination I requirements shall be as specified in sub-paragraph 1-727.4.2(e)3,

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" . . . which states in part, " Imperfections that are unacceptable j

and shall be repaired are . . . any undercutting . . ."

Centrary to the above, the inspector observed a sock-o-let velded to the side of the 18 inch spool piece 1:o. DC-57 in the decay heat

. cooling system which contained a deep, ground undercut at the toe of the fillet weld.

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s United Engineers and Conatructors Procedure No. QC-17, Parsgraph IV-B

! 2. l l " Control of Nonconforming Conditions", states in part, ". . . Quality i

. control shall maintain a master log of inspection reports to indicate

, their status" and, Paragraph IT-C, states in part, ". . . Itcas that l

are reinspxted and are found to be unacceptable . . . shall be tagged with a reject tab . . . The conconforming condition and the referenced I inspection report number shall be identified on a deficiency report.

l The rejected status and a referenced DR nunber shall be documented on i the applicable inspection report for cross-reference."

. Contrary to the above, a deficiency report has not been issued for a

. nonconfo rming condition that was identified in a CONAM inspection report dated May 23, 1972, which relates to rejectable magneti.: particle

. indications on the Unit i rasctor closure head flange. Furthermore, ,

! there was no evidence that the condition had been corrected at the tir.e  !

', of the ins'pection. l

. 3. UE&C procedure ECP-3, Addendum A, states in part, "The quality control ,

inspector will complete the attached check list as applicable while l i inspecting . . . installation of the equipment."

Contrary to the above, the check lists are not given to the QC in-i spector for use while inspecting. Dates on the check list do not

agree with the date supplied by the craft perforcing the function.
4. UE&C procedure QC-13, prior to July 6,1972, required that a quarterly field audit be performed to determine that measuring and test equipnent were properly controlled, calibrated and inspected.

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', Contrary to the above, the records indicated that only three such audits I have been made, the first on August 5, 1970, and cl.4 last on November 18, 1971.

5. UEAC procedure ECP-6, paragraph 5.1.4, requires renthly rotation of the engineered safeguards motor shaf ts and that engineered safeguards motors be maggered monthly.

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, Contrary to the above, approxinately four months have elapsed since the last rotation of the motor shafts and perfor:ance of the re-

! quired meggering.

6. UEAC procedure ECP-6, paragraph 5.1.3, requires that space heaters be energized or supplementary heat provided on engineered safesuards motors within two working days af ter placement in storage. Docunen-tation is required to be provided on forn ECP-6-1. CE&C procedure ECP-6 D*1 1L1 i , ,, ,

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also requires that "A red indicating lamp shall be installed to show l' f

that the circuit is energised."

f Contrary to the above, the high pressure safety injection pumps, desig-

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noted MUF-1A,15, and IC, which were selected for review, did not appear on the heater check list, and the prescribed red indicating lamps had

been removed from HUF-2A , and 13.

j 7. UE&C procedure ECF-10, requires that surveillance be performed on instru-meats, panals, control boards, a.nd related equipment to assure that aantrolled storage conditir.as are maintained.

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Contrary to the above, there is no documentary evidence that the required surveillance has been conducted.

j' i 8. UE&C procedure ECP-6 and ECP-10 both require that the field supervisor, quality control, be notified prior to the installation of electrical

! ensinnered safeguard equipment.

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Contrary to the above, there is no evidence that the field supervisor,

. quality control, is notified prior to installation of engineered safe- l f guards equipment, nor evidence that quality control personnel had l l

witmassed installation except for safeguards cable installation.

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9. UE6C procedure QC-17, paragraph II.B.1, states in part, "Nonconforrance

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. . includes activities, materials and equipment whose condition does i

not comply with the applicabla . . . specification." t 1

Contrary to the above, deficiency reports were not prepared for each instance where the cabla separation criteria described in paragraph 4.4.4 l

of UE&C Procedure ECF-8 were not met. '

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10. The Final Safety Analysis Report, Paragraph 8.2.2.12.c, states in part.

in reference to cable separatien, . . . ' In a very f ew cases , the sep-aration is about 12 inches and, in these cases, a barrier is insts11ed i between the trays." ,

1 I Contrary to the separationa criteria described above, the engineeri.d l

i safeguards actuating cabinets located in the control room, do not have j j the separation specified as the minimum for cable trays, nor barriers separating the channels. In addition, there were numerous rolls of i

i cabis suspanded ur. der the cabinets, which were ter:ninated at both ends.

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- with no documentation indicating that this practice was unacceptable.

11. UE&C procedure QC-2, requires that all items identified as being l l

associated with the reactor safety, including engineered safeguards l I

equipment and components, be inspected upon receipt for confornance with the applicable specification requirements.

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, Contrary to. the above, reactor pressure sensing tranducers, identified by number, RZ.-18, were not inspected on receipt at the site and the permanent file for these devices indicated that they had not been re-  !

caived, although further investigation revealed that they were received  !

on the site in Decamber, 1971. l l

12. B&W specification 1132/0369, paragraph 2.4, statas in part, "The ven- )

der shell have written procedures for control of inspection programs. 1 These procedures shall cover such items as non-destructive testing i inspections . . ." The PDM QA Manual, paragraph 11.14.4, "RT-1 Speci-

! fication,1-14-70," states in part, "RT technique procedure will be

emed with t'21.s specification."

, Contrary to the above, the inspector found that no RT technique pro-

cedures were used by PDM during the radiography conducted on the

! Borsted Water Storage Tanit, j 13. B&W Material Specification, MS-1.3, states in part, " Carbon steel tie doene shall not be used for stainlass steel material."

Contrary to the above, the B&W receiving report, dated May 18, 1972, reviewed by the inspector, indicated that no protection was used between carbon steel holddown clips and stainless alate for the Borated Water Storage Tank Materials received on May 9, 1972. In l addition, the inspector could find no corrective action reports or other documentation indiesting that corrective action had been taken to resolve this matter in the B&W, PDM, UE&C, or GPU records on site.

14 Site procedure No. HCP-3, revision 4, paragraph 3.60, states in part,

" Acetone is prohibited for use on site."

Contrary to the above, PDH cleaning procedure No. CP1 states in part, "71sible oil and grease spots should be removed from plates or nozzles by handwiping with acetone prior to welding the plate or nozzle into the tank." The inspector was informed by PDM Quality Control personnel that acetone was used during the fabrication and cleaning of the tank.

15. B&W specification No. 1132/0369, paragraph 2.3, " Control of Special Processaa" states in part, ' Vendors shall have written procedures and instructions for the perfornance of all special processes used for the items such as . . . cleaning processes . . . Metropolitan Edison specification sheet No. 620-0005-36-A-0, dated August 28, 1970, states in part, " Procedures for control of special processes such as welding, IEff, . . . cleaning . . . shall be approved by the engineer prior to use."

i Contrary to the above, the inspector observed the cleaning of the borated i water storage tank in progress and reviewed records indicating that testing had been completed. The testing was performed without an approved

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' proced table on site, although an approved procedure was in

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16. PIM cleaning procedure CP-1, states in paragraph 2.1, "It is understood that nrior to the commencing with the cleaning of the tank, all fabricatien, welding, inspecting, and testing has been completed and approved by the l '

authorized persons." In addition, paragraph 4.2 states, "All weld spatter l and/or slag should be removed from all tank surfaces per veld procedure specification WPS-48."

Contrary to the above, the inspector observed the external surf aces of the borated water storage tank to contain weld splatter and are strikes.

The internal surfaces could not be examined, due to work in progress.

17. The Final Safety Analysis Report, page 6-24. Table 6.2, "Staumary of Requirsements for Berated Water Storage Tank" states under inspection The requirements for welds that the acceptance standard is AWA-D-100.

r FSAR also requires that all girth and seam welds shall be full penetratica 4

welds. In addition, the welding procedure specification No. WPS-48, for the borated water storage tank, FDM Steel Company contract 10139 dated i

j October 12, 1971, paragraph 6.1, states that .' eld pt:c edure and welder

- qualifications are required in accordance with the latest edition of ASE

' Code Section VIII," and further states, "ASME Section VIII will be used for acceptance standards on NDT." The specification also states that

< NDT requirements will consist of 20% radiography.

t Contrary to the above, the requirements listed in the FSAR and the work performed in accordance with procurement doeunents do not axree, nor

' had this deviation from the FSAR been identified or documented.

13. Metropolitan Edison QA Plan for Three Mile Island Unit 1, Appendix B, revision 3, paragraph VI. A, relative to audits and ccrrective action states in part, "The audit vaan leader should check to eske sure that such response is received within a reasenable period of time (1 cench) ." l I

Contrary to the above, the inspector found that audit reports dated April 12, 1972, February 15, 1972, January 26, 1972, and Deceeber 23

- 1971, did not contain documentary evidence that corrective action had been taken on these findings. In addition, the use of an incorrect alloy of stainless steel plate for the feel storage liner, identified i

by site personnel in 1969, had not been resolved at the tire of the

- inspection.

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! 19. UT.&C Procedure No. QC-8 restricts trans-weld weaving to a dimensien equal to two and on-half diameters of the electrode beinr, used. ANSI l 131.7, Paragraph 1-727.4.2(d), states in part, The finished surfthe ace of i

the weld shall rarge smoothly into the component surface . . . surface 20il 171 -

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i 1 emoothness of the finished weld shall be suitable for the proper inter-pretation of nondestructive er==inations of the welds . ..

Contrary to the above, the inspector observed that an la inch stainicas steel pipe spool, No. CF-1, showed shop welds with a trans-weld wasve pactarn from 1-1/4 to 1-1/2 inches wide. In addition, the weave patterns

. had produced deep notches across the weld, with severe undercutting at the end of the weave where it contacted the piping base metal, which s

does not meet the " blend smoothly" and " surface smoothness" requirements.

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1 E5CI45URE 3 i.

Description of Safety Iters_

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! Metropolitan Edisco Company l

Docket Nos. 50-289 and 50-320 g Licanas Nos. CFFR-40 and CPPR 66 f Certain items appear to raise gtcetianas concerning the adequacy of con-

r struction as identified below

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1. Engineered Safeguarda Actuating Bench Boards, &=nnela A, B, C, and D l De bottom of the engineered safeguards actuating bench boards, channels j  ; A. 3, C, and D, are open to the cable spreading room, which is located a  !

below the contrcl room. Failure to effect adequate closure of these e openings could result in the required evacuation of the control room if '

a fire occurred in the cable spreading room.

l! Our inspectors did not find drawings nor instruetions relative to the i method of closure of this opening.

! 2. Battery Rooms i

De two batteries appear to share a common ventilation system, which

! could result in a consen mode of failure should a fire occur in one

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battery room and be transmitted to the second room by way of the ven-

! tilation system.

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l j j METROPOLITAN EDISON COMPANY wnmanv orcentnu oveucununesconronanon '

l TELEPHONE 215 - 929 3601 l Post orFicE BOX 542 RE ADING, PENNSYLV ANI A 19603 '

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I November 3, 1972 Mr. J. P. O'Reilly, Director Directorate of Regulatory Operations, Region 1 l l

United States Ator.ic Energy Cocrission 970 Broad Street Newark, New Jersey 07102 l

SUBJECI: THREE MILE ISI.AND NUCLEAR STATION UNITS 1 AND 2 DOCKET NOS.30-289 AND 50-320 '

l 1 RESPONSE TO AEC/DRO AUDIT OF AUGUST 14 THROUGH 17, 1972 i

Dear Mr. O'Reilly:

l 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-i coglianc,e 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 construction adequacy. Our resolution j 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 coglete. We vill advise you as soon as we have j 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 UE6C construc-i tion and QC groups with TMI quality r uiremente. Additionally, GPU has

< taken over responsibility for the management direction of the UELC Quality Organization for the TSI Project.

Very truly yours, ,

l l[b A . i ~/

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,-J. G. Mille Vice President

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Enclosures ' t cc: Mr. W. G. Kuhns Mr. W. A. Verrochi 7911080 hb N, /D

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ENCLOSUPI 1 4

RESOLUTION Oy ENCLOSURE 1 TO AEC-DP.0 LETTER DATED OCTOLER 6,1972

1. AEC FINDING This general finding includes findings listed in 1.a through 1.e below, which cover areas where the AEC-DRO ineper. tors censidered that contrary to Criterion V of Appendix B to 10 CTR $0. appropriate proce dure s , instructions, or drawings were not available.

T.ESOLUTION It has been CPU's intent from the early stages of construction to perform important activities in accordance with written procedures and GPU has 4

taken action to have such procedures prepared and used. Subsequent to the AEC audit. CPU management has again e=phasized to cognizant CPU personnel and UE6C canagement that all activities affecting the quality of nuclear and sefety related parts of the plant cust be covered by appropricte written procedures, instructions or drawingc. Our resolution of the specific AEC findings is given b el ow .

1.a AEC TINDING "a. There are no instructions, procedures, or drawings delinesting the quality aspects of the installation of the individual sensors or 8

instruments used in the detection of system abnormalities."

1 RESOLUTION Requirements for installation of instrument sensors are delineated on l 4

CA7 drawings, which indicate derired locations and typical installation details.

To further clarify the requirements applicable to installation of instrument

, sensors, a UEOC construction procedures (MCP-14) wi1J be issued by November 15, l 1972, and will include quality control check points. In addition, all neclear j and safety related sensor installations vill be checked as part of UE&C's final QC inspection (Procedure QC-16) of construction work prior to turnover for 4

instrument loop calibration and system testing.

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1.b AEC FINDING 4

"b . There are no instructions, procedures or drawings which 1 describe the testing and/or calibration required for the sensors or instruments used in the detection of system abnormalities."

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ENJLOSURE 1 l

kESOLUTIO1 Testing and calibration of sensors and instruments have been performed using manufactu.*er's instructions and have been recorded on Instrument Calibration Data Sheets. This practice will be fornalized by the issue of a construction procedure (MCP-13) with a QC chech list, which will be issued by November 15, 1972 The documentation of saticfactory completion of required sens er and instrument calibrations is checked by UE&C QC prior to turnover of nuclear and r.afety related sensors and instruments for instrument loop calibration and system te.s ting.

1.c AEC TIND!NG "c. There are no instructions, procedures, or drawings relative to the paragraph a.2.11d of the FSAR requirements, which states in pert,

'... All vertical trays have solid covers to sin feet above their finar penetrations. '"

RESOLUTION We are reviewing all cable trays to determine the specific trays for which covers are warranted tc provide physical protection. The drawings for cable trays will be revised to indicate the specific requirement for the covers and the TSAR will be reviced if necescary. to be consistant. The covers will be lawtalled after completion of cable installation and will be checked by UE6C QC as part of final inspection of cable trays (Procedure ECP-3).

1.d AEC FII: DING

" Instructions, procedures, er drawings do not require that the cable tray 1cading specified in the U'6C Procedure ECP-3 and paragraph -

a.2.2.1.13.4 of the FSAR be verified."

l RESOLL* TION The primary method being used to control cable tray fill is by strictly controlling cable routing to make sure that cables are routed in accordance with CAI instructions. CAI's co=puter program for cable routing automatically checks tha t cable tray fill is satisfactory if cables are routed as planned. Further. l CPU' spot checks the routing of cables on a routine basis.

i llowever, to provide additional assurance, the UE6C check list for the procedure for installation of cable (ECP-3) was modified on September 21, 1972, I

to require inspection of cabic trays to verify that tray fill limits have not  !

been exceeded. This visual inspection will be done as part of final inspection  ;

of cable trays (af ter coupletion of cable pulling) at which time any areas with  ;

apparently high fills will be evaluated to ensure that the actual fill meets i

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ENCLOSUPI 1 engineering requirements. Where necessary, cable fill will be checked by counting the nu ber of cables to verify that the number installed agrees with

< CAI'c pAanned cable tray loading. This evaluation will be documented and will be done in accordance with a procedure or addendum to the cable installation check list (ECP-3) which will be issued by November 15, 1972.

1 1.e AEC TINDINC j l

l. " 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."

EESOLUTION l Installation of valves has been performed in accordance with CAI piping system drawings, CAI specifications covering cleanliness, welding, and general

installation requirements, and UE&C QC procedures covering velding, cleanliness, and inspection of mechanical equipment.- This is being formalized by means of a construction procedure (NCP-23) and QC check list which will be issued by November 15, 1972.

4 2. AEC TINDING

" Criterion VII, ' Control of Purchased Material, Equipment and Services' states in part, ' . . . Documentary evidence that material and equipment I conform to the procurement requirements shall be available at the nuclear l power plant site prior to installation or use of such material or equipnent ...' Criterion XVI, ' Corrective Action', states in part,

' .. . Measures shall be established to assure that conditions adverse to quality ... are pro =ptly identified and corrected ...'

Contrary to the above, the inspector found that the only material and fabrication records available on site for the Eabcock and Wilcox supplied reactor coolant piping spools were the welding records. This incomplete documentation was noted as a deficiency against the piping spools and the receiving records dated July 1970. The deficiency had not been corrected at the time of the inspection."

i RESOLUTION J

.. should be noted that the fabrication report for the piping had been received from B&W and included a certification that caterial certifications had been reviewed against codes and specifications and found to be satisfactory.

Subsequently, CPU has received the material certifications for this piping f rom B&W and will cocplete review of *u. documentation by November 15, 1972.

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ENCLOSURE 1 t

3. AEC FINDING ,

" Criterion IX, ' Control of Special Processes', states in part, ' Measures i shall be established to assure that special processes such as welding j

. . . are accomplished .. . in accordance with applicable codes, standards, t specifications, and other special requirements.' J f

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a. The inspectors found that UE&C Procedure QC-8, ' Piping Welding (

l Control', contains no requirenent nor provision on the weld history I

-i l sheet for defect removal verification which is specifically i

f eposed on the Three Mile Island 1 pipe welding by the Gilbert Associates Specification No. 550. (sic) . .

b. BLW Specification No. CS 37-3, paragraph 5.1.7, requires thre electrodes for welding stainless steel shall contain a miniman of 5% delta ferrite.

Contrary to ti.e above, the inspector found, during a review of a Grinnel test report for E-308 electrode, heat #9H63B, that chemical analysis Andicated less than 5% ferrite. This deficiency had not been identified by Crinnell or UE&C QC record personnel.

The 'inspe-tor also found that the Babcock and Wilcox documentation f! . records covering the pressuriser surge piping spools contained material records for lime coated electrodes which do not meet the ASTM chc=ic=1 requirements."

' RESOLUTION t

a. The UELC veld procedure for veld repairs to field welds (b'P-27) has required inspections to be perforred to verify defect removal prior to repair welding.

However, documentation of this inspection has not been required in the past.

The weld history record form will be revised by Novem' a ct 15, 1972, to requira docunentation of this inspection.

b. The B&W specification limits on ferrite levels do not apply to Grinnci piping spools since these spools were not supplied by B&W but rather were Met Ed purchased and were f abricated to CAI specifications. The GAI specifications do not include ferrite limits; however, Grinnell's own requirements are that veld materiaJs have a ferrite content of 5% or more. Review of Crinnell material certifications for all piping spools received indicates that five hests, including heat 9H63B, had ferrite levels below 5%, the lowest having 3%. In addition, no ferrite information is available for several other heats.

This matter is being reviewed with Crinnell. We will advise you at a later date of the final resolution.

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1 ENCLOSURE 1 The B6tf fabrication report for' pressurizer surge piping has been rechecked and the chemistry requirements of the wcld rods were found to meet specifi-l cation requirer.ents. It should be noted that the electrodes in question

, were El 6-8-2 clectrodes to specification SA 298, for which chromiu:n and nichel content are permitted to be lower than for typical 18-8 type j electrodes, i

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ENCLOSURE 2 1

RESOLLTION OF ENCLOSUPI 2 l TO AEC-DRO LETTER DATED OCI0BER 6,1972 j l

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1. AEC FINDING l

l "The FSAR, paragraph 4.1.3.2, ' Piping', states in part, 'The derign, j

- fabrication, inspection and testing of the reactor coolant piping including the pressuri:er surge line ... is in accordance with ANSI B31.7*.

a. ANSI B31.7, ' Nuclear Power Piping', paragraph B-1-110.6, states in part, ' ... Equipment used to view film for radiographic ,

interpretation shall provide a high intensity light source such that the penetrameter and hole for the specified quality level )

shall be readily visible for the specified intensf ty range.'

Paragraph B-1-120.1 states in part, ' . . . the weld ripp..es or veld surface irregularities on both the inside and outside shall be )

removed by any suitable mechanical process to such a- degree that I the resulting radiographic contrast due to irregularities cannot mas *x or be confused with the image of any objectionable defect Centrary to the above, che inspector observed that. the CONAM inspection agency did net have high intensity radior,raphic viewing equipment on site and that the available equipment appeared to bc ,

incapable of revealing rejectable defects in composite films. I During a review of the radiographic film representing prassurizer l surge line veld No. RC-55AQ, the weld area was charactetieed by I citernating bands of light and dark areas due to improper preparation  ;

of the veld surface prior to conducting radiography. '

b. USASI B31.7 paragraph 1-727.4.4, states in part, '... Fillet i welds may vary from convex to concave. The size and contour deterr.ined as shown in figure 1-727.4.4(a) ... The examination ,.-

requirenents shall be as specified in sub-paragraph 1-727.4.2(e)3, which states in part, ' . . . In: perfections that are unacceptable and shall be repaired are . . . any undercutting . . . '

Contrcry to the above, the inspector observed a sock-o-let velded to the side of the 18 inch spool piece Ne. DC-57 in the decay heat cooling system which contained a deep, ground undercut at the toe of the fillet veld."

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, ENCLOSURr 2 ,

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RESOLUTION I

a. In regard to the radiographic viewer, our review of specification and Code requirements indicates that there is no r equiremen t to review doubic films together. The radiography performed is 1 ased on singic film viewing. The CGNA )

viewer is a high intensity viewer and is considered to be satisfactory for r,ing film viewing. The refore , the single film zeview already given the radiogr'.phs is considered satisfactory.

In regard to weld joint RC-SSAQ, the radiographs of this veld joint have been rechecked by two qualified and experienced Level 3 examiners. They  ;

consider the radiographs and the veld joint to be satisfactory and that  !

the veld surface irregularities do not interfere with interpretation of '

the radiographs.  ;

b. Looking up from the floor, the veld joining the veldolet to the 18 inch l decay heat closed water line (spool DC-57) appears to be undercut. However,  !

detailed close up visual exa=ination shows the veldolet to be properly in- )

stalled with no undercut. k' hat appears from the floor to be an undercut '

is in reality a nachining scarf, which is acceptable. Also, it should be noted that this is not a nuclear class system and that the applicable code  !

for this weld joint is B31.1. '

2. AEC FINDING k

" United Engineers and Constructors Procedure No. QC-17, paragraph '

IV-B ' Control of Monconforming Conditions' states in part, ... '

l Quality control shall maintain a caster log of inspection reports to  !

indicate their status' and, paragraph IV-C, states in part, ' ... Itere j that are reinspected and are found to be unaccepatble ... shall be tagged with a reject tab ... The nonconforming condition and the referenced inspection report number shall be identified en a deficiency report. The rejected status and a referenced DR number shall be documented on the applicable inspection report for cross-reference."

I Contrary to the above, a deficiency report has not been issued for a non-conferning condition that was identified in a CONAM inspection report dated May 23, 1972, which relates to rejectable =sgnetic particle indications on the Unit I reactor closure head flange.

Fu rthe rmore , there was no evidence that the conditions had been corrected at the time of the inspection.

RESOLUTION A deficiency report (#0545) was written on August 31, 1972, to cover this iten. Further, steps have been taken including revision to the proceduro (QC-17) for control of non-conforming items, to assure that similar situations do not recur. In addition, UE6C has reviewed all outstanding inspection reports to assure that appropriate action is taken regarding items covered by the reports.

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l ENCLOSURE 2

3. AEC FINDING "UE6C procedure ECP-3, Addendum A, s tates in part, 'The quality control inspector will complete the attached check list as applicable while inspecting ... installation of the equipment. '

Contrary to the above, the check lists are not given to the QC inspector for use while inspecting. Dates on the check list do not agree with the date supplied by the craf t performing the function."

RESOLUTION Actual prcctice 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 notes. This is done since cables are pulled in groups and it would be impractical to fill out individual check lists I for all the cables in the group during the pull. The site practice is considered to provide satisfactory control of cable pulling inspection; however, it is not in strict accordance with the applicable procedure (ECP-3); this procedure will ,

be revised by November 15, 1972, to be in accordance with site practice.  !

4. AEC FINDING l "UE&C Procedure QC-13, prior to July 6,1972, required that a  !

quarterly field audit be performed to determine that ressuring '

and test equipment vere preperly controlled, calibrated and inspected.

Contrary to the above, the records indicated that only three such audits have been made, the first on August 5, 1970, and the last on November 18, 1971."

RESOLUTION In the futurc, UE6C QC will perform field audits on a quarterly basis as required by procedure. The next audit is scheduled for November 1972. CPU  !

has e=phasized to UELC canagement that strict compliance with precedure require-ments is candatory.

5. AEC FINDINC "UELC procedure ECP-6, paragraph 5.1.4, requires monthly rotation of the engineered safeguards motor shaf ts and that engineered safeguards motors be meggered monthly.

Contrary to the above, approximately four months have elapsed since the last rotation of the motor shaf ts and performance of the required negging.

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C: CLOSURE .*

RESOLUTION The required meggering and rotation of safeguard motors was brought into conformance with the procedure in September 1972. Further, the applicable conctruction procedure has been revised to require documentation of this naintenance to be kept at the motor location to facilitate verification that proper esintenance han been performed.

It should be noted that this problem had been identified by UE&C QC and documented on inspection reports and a deficiency report prior to the AEC audit ; however, response by construction was not timely. CPU management emphasized to UE6C managerent in late August 1972 the need to respond rapidly to all QC indications of non-conformances; UE&C has revised both procedures and the organiration to speed up such response.

6. AEC TINDING "UE&C procedure ECP-6, paragraph 5.1.3, requires that space heaters be energi:ed or . supplementary heat provided on enginected safeguards motors within evo working days af;er placement in storsFe. Documentation is required to be provided on form ECP-6-1. UE6C procedure ECP-6 also requires that 'A red indicating lamp shall be installed to show that the circuit is energized'.

Centrasy to the above, the high pressure safety injection pu=ps,  !

designated MUP-1A, 13, and IC, which were selected for review, did noL appear on the heater check list, and the prescribed red indicating lamps had been removed from MUP-1A, and 13."

RESOLUTION i on August 21, 1972, UE&C constructicn started daily checks of indicating la=ps for space heaters on motors. Further, the heater che:k list has been updated to include the makeup =otots, and will be kept up-to-date in the future.

UE6C QC will also periodically monitor to ensure that space heaters are properly energi:ed. GPU has e=phcsired to UE6C canagement that procedure requirenents r.ust be met.

7. AEC TINDING "UE&C F rocedure ECP-10, requires that surveillance be perforced on instruments, panels, control boards, and related equipment to assure that controlled storage conditions are e.aintained.

Contrary to the above, there is no documentary evidence that the required surveillance has been conducted.

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ENCLOSURE 2 RESOLUTION UELC QC personnel indicated that they have perforned general surveil-lance of storage conditions of stored (and installed but not energized) electrical equiptent, but have not kept records of this surveillance. Such records are required by UE&C QC procedures, and will be kept in the future.

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8. AEC FINDING l "UELC Procedure CCP-6 rnd ECP-10 both require that the field super-visor, quality contr 4, be notified prict to the installation of j, '

electrical engineered safeguard eq tipment. j Contrary to the above, there is no evidence that the field supervisor, quality control, is notified prior ,to installation of engineered safe-guards equipcent, nor evidence that quality control personnel had witnessed installation except for safeguards cabic installation." .

RESOLUTION l'p to the time of the AEC audit, notification to QC of the installation of electrical equiprent was handled orally. Installation of much of this equiprent ves witnessed by QC and docuneuted on QC inspecticn reports; however, the installation of sote equipment was not witnessed by QC as required by pro-cedure. U 50 canagement has emph. sized (e.g., in a meeting en .'.ugust 24, 1972) to construction supervision that all procedure requirements cust be complied with, e.g. , that procedure requirements for QC notification and witnessing cust be cet. Further, starting in September 1972, UE&C construction craf ts notify QC by speed letter as well as orally of plans for installation of equipment.

3. AEC FINDINC "UE&C Procedure QC-17, paragraph II.B.1, states in part, 'Noncon fo rmance

... includes activities, materials and equipment whose condition does not comply with applicable . . . specifications . '

/

Contrary to the above, deficiency reports were not prepared for each instance where the cable separation criteria described in paragraph 4.4.4 of UE&C procedure ECP-8 were not met."

RISOLUTION I-At the time of the AEC audit, itees requiring resolution with regard to separation criteria during final inspections of cables were being documented in inspection reports and the cables were being returned to electrical construction 2-5 .3 -

ENCLOSUri 2 for identification to GAI of the need for fire barriers. This practice is in accordance with the UE&C QC procedure for final inspection (QC-16) and is not considered to be a nonconformance. However, in order to speed up the resolution of such separation items, it has recently been decided to issue DR's for cases where separation problers are found in final inspections.

10. AEC FINDING

The Final Safety Analysis Report, paragraph 8.2.2.12.c, states in part, in re ference to cable separation ... 'In a very few cases, the separation is about 12 inches and, in these cases, a barrier is installed between the trays. '

Contrary to the separations criteria described nbove, the engineered safeguards actuation cabinets located in the control room, do not have the separation specified as the minimum for cable trays, nor barriers, separating the channels. In addition, there were numerous rolic of cabic suspended under the cabinets, which were terminated at both ends, with no documentation indicating that this practice was unacceptable."

RESOLUTION In regard to the separation of safeguard cabinets, it is noted that these cabinete have crcel walls (14 gauge mininum) which are coated with a heat resistanc caterial to provide a two hour fire rating. The cabinet walls are consicered to be satisfactory fire barriers and to satisfy separation require-ments. At the time of the inspection there were cases in which cables of dif ferent channels violated separation criteria. Design work was under way at the time to correct the cable ro sting to satisfy the criteria, or, should that be impossible, barriers will be installed.

In regard to the coils of wire suspended under the control consoles (there are none under the safeguard actuation cabinets as indicated in the AEC finding), CPU concurs that the coils of multiconductor cables are presently in an undesirable location and this situatien will be corrected by either (1) shortening the cable lengths and eliminating the coils where field terminations exist on the cables, or (2) relocating the excess cable in the relay room without violating tray loading limits where both ends of the cables are she.p terminated.

11. AEC FINDING "UELC Procedure QC-2, requires that all itecs identified as being associated with the reactor safety, including engineered safeguards i equipment and components, be inspected upon receipt for conformance I with the applicable specification requirements.

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P.NCLOSLTI 2 Contrary to the above, reactor pressure sensing tranducers, identified d by nu-ber, FX-18, were not inspected on receipt at the site and the permanent file for these devices indicated that they had not bs.en received on the site in December 1971."

RESOLLTION This equipment was purchased by Met Ed but was installed at a vendor's

  • plant (Bailey) on D&W supplied equipmen::. Inadvertently, UE&C QC did not check the equipment document as part of receiving inspection of the B&W component.

UE&C construction memorandun to UE6C Purchasing dcted October 3,1972, requested Purchasing to advise UE&C QC of any other similar cases so that doeurentation will be properly checked as part of receipt inspection.

The requiref. 4cumentation for RK-18 has been requested but has not yet been received. The caoinets with these instruments have been tagged " hold" per standard UE&C QC procedutes to indicate that the documentation is still required for this instrumentation.

12. AEC TINDINC l "B&W Specification 1132/0369, paragraph 2.4, states in part, 'The vendor chall have vritren procedures for control of inspection progrees. These procedures shall cover euch items as nondesctructivee )

testing inspections ...' The PDM QA Manual, paragrapn 11.14.4, 'RT-1 l Specification, 1-14-70', states in part, 'RT technique procedure vill be used with this specification' .

Centicry to the above, the inspector found that no RT technique procedures were used by PDM during the radiography conducted on the Borated Water Storage Tank."

PISOLL7 ION PDM Performd radiography for the tanks to a general radiographic specification, but did not have a technique sheet showing the specific radio-graphic paraceters for this radiography. Rev'.ew of the PDM radiographs by UE&C QC have indicated that the radiographs are of satisfactory quality. For record purposes, PDM has docu:nented the radiographic paraneters used for the tank shell velds zade at the site on a technique sheet (PDM Radiographic Technique Procedure No.1 for Contract 10146, dated September 8.1972).

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. t ENCLOSLRE 2

$ 13. AEC FINL!nc

" R &*a' Materi;l Specification, }3-1.3, sta.cs in part, ' Carbon steel tie downs shall not be used for stainless steel naterial.'

i Centrary to the above, the B&W receiving report, dated May 18, 1972, reviewed by the inspector, indicated that no protection was used between carbon steel holddown clips and stainless plate for the Borated Water Storage Tank Materials received on May 9,1972. In addition, the inspector could find no corrective action reports or other documentation indicating that corrective action had been taken to resolve this matter in the B&W, PDM, UE&C, or CPU records on site."

RESOLUTION E&W issued a deviation report (#72 dated September 25, 1972) to cover this problem. This deviation report was cicated by PDM by buffing and cleaning the af fected plates at the time the problen was noted. The PDM action is docu-cented in a report dated Septer.ber 26, 1972. In addition, B&W has reviewed all other E&W site receipt inspection reports to determine if similar unresolved problems are indicated; this review did not reveal any other such open items.

14. AEC FINDING

" Site Procedure No. MCP-3, revision 4, paragraph 3.60, states in part, 'Acctone is prohibited for use on site. '

Centrary to the above, PDM cicaning procedure No. CPI states in part 'Visfble oil and grease spots should be removed from plates or nc zles by nandwiping with acetone prior to welding the plate or nozzle into the tank.' The inspector vas informed by PDM Quality Control personnel the* acetone was used during the fabrication and cleaning of the tenk."

RESOLUTION From an engineering standpoint, acetone is considered to be a satisfactory cleaning agent. However, UE&C elected to prohibit its use by UELC personnel as a safety precaution. It should be noted that the UILC construction procedure prohibiting the use of acetone was not contractually invoked on PDM and the use of acetone by PDM was not a nonconformance. However, in the future the use ci acetone by subcontractors will not be approved.

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ENCLOSURE 2

15. AEC FINDING "B&W Specification No. 1132/0369, paragraph 2.3, ' Control of Special Processes' states in part. ' Vendors shall have written procedures and instructions for the performance of all special processes. used for the items such as . . . cleaning processes . . . ' Metropolitan Edison specification sheet No. 620-0005-36-A-0, dated August 2B, 1970, states in part, ' Procedures for control of special processes such as welding UDT, . . . cleaning . . . shall be approved by the engineer prior to use. '

contrary to the above, the inspector observed the cleaning of the borated water storage tank in progress and reviewed records indicating that testing had been completed. The testing was performed without an approved procedure available on site, although an approved procedure was in existence."

PISOLUTION GAI had approved tlee cleaning and hydrostatic test procedures in July.1971, long before perfor=ance of the work. The PDM site personnel have stated that they had confirmed by telephone with their home office prior to performing the work that the procedures had been approved. However, to assure that only approved procedures are used by subcontractors, UE6C Construction me e da te d O ct eb er 11. , 197?, terinded UE&C Purchasing that they should make sure that subcot, tractors underscand that formally approved procedurec must be available prior to start of work. UE&C field QC personnel vill check for such fornal approval in the future.

16. AEC FINDING

" PDM Cleaning Procedure CP-1, states in paragraph 2.1, 'it is under-stood that prior to the commencing with the cicaning of the tank, all fabrication, welding, inspecting, and testing has been completed and approved by the authori:ed persons. ' In addition, paragraph 4.2 states

' All weld spatter and/or slag should be removed from all tank surf aces per weld procedure specification WPS-48. '

Contrary to the above, the inspector observed the external surf aces of the borated water storage tank to contain veld spatter and are strikes.

The internal surfaces could not be exanined, due to work in progress."

RESOLUTION It should be noted that the contract for field erection of the borated water storage tank does not require cleaning of the outside surface of the tank 2-9 ,

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E';CLOSUT2 2 and that the PLM cleaning procedure CP-1, is applicable only to che inside of the tank. However, PDM Veld Procedure Specification WPS-48, does require are strikes to be ground and the surface to be inspected. Subsequent to the AEC inspection, PD:t performad a final inspection of the outside of the tank to V?S-45, and UEiC QC verified that it was c1can of are striken. Further, all colds on the inside of the tank ha.c beca ground srcoth, and the entire surface of the tank has been buffed to facilitate Class 3 cleaning. UC5C QC has i verified that the inside of the tank is free of wcld splatter and are strikes.

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17. AEC FINDING  !

"The Final Safety Analysis Report, page 6-24, Table 6.2, ' Summary of Requirements for Zorated k'ater Storage Tank' states under inspection i require:ents for velds that the acceptance standard is AVVA-D-100. l The FSAR also requires that all girth and sear. welds shall be f ull l penetration welds. In addition, the welding procedure specification No. '.!PS-48, for the borated water storage tank, PDM Steel Company l contract 10139 dated October 12, 1971, paragraph 6.1, states that j veld precedure and velder qualifications are required in accordance with the latest edition of ASME Code Section VIII, and further states

' ASME Section VIII will be cred for acceptance standards en HDT* .

The specification also states that NDT requirements uill censist of i 20% radiography. , j l

Contrary to the above, the requirements listed in the FSAR and the l work perf ormed in accordanca with procurecent documents do not agree, {

nor had this deviation f rom the FSAR been identified or documented."

PIECLUTICN I The application of Section VIII of the AS:2 Boiler Code for velding ,

requirements for the tank in lieu of the ARWA-D-100 requirements is considered I' to be an upgrading of technical requirenants, especially in regard to obtaining imprc ted veld j cint de signs . However, to avoid pessible confusion, the FCAR '

is being emended to indiccte that Sec*.' ion VIII welding requirements were used for field erection. It should be no.ed that the applicabic order recuirements invoked on PDM by Met Ed required 1~ spot radiography, uhich has been perforred, and that PD!! weld specification L'PS-46 is consistent with this and requires 1%

spot radiography, not 20% as indicated in the AEC finding.

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18. AEC FIMDIIC

" Metropolitan Edison QA Plan for Three Pdle Island Unit 1, Appendix B, revision 3, paragraph VI.A reistive to audits and corrective action states in part, 'The audit tean leader should make sure that such response is received within a reasonable period of time (1 month).'

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-l CNCLOSURE 2 Contrary to the above, the inspector found that aud c reports dated April 12. 1972, Februa ry 15, 1972, January 26, 1972, and Dacember 2 8, 1971, did not contain documentary evidence that correcrave action had i been taken on thenc findings. In addition, the use of an incorrect alloy of steel plate for the fuel storaga linct, identified by site ,

personnel in 1969, had not been resolved at the time of the inspection.

RESOLUTIO" GPU has been continuously working to decrease the tire required to resclva audit findings and performance in this regard has improved. UE&C and CPU know uf no probler.s rescrding fuel storage real liner material as referred to by the AEC intpector.

19. AEC FINDING "UC6C Procedure No. QC-8 restricts trcns-veld weaving to a dimension equal to two and one-half diameters of the electrode being used.

ANSI P.31.7, paragraph 1-727.4.2(d), states in part, 'The finished surf ace of the veld shall merge smoothly ir.to the component surfcce .

... the surface snoothness of the finished veld shall be suitable l for the preper interpretation cf nondestructive er.aminations of the l welds ...' l i

Centrary to the above, the incpector observed that an 13 inch stain- I less steel pipe spool, No. CF-1, showed shep welds uith a trans-weld ,

weave patte rn f rom 1-1/4 to 1-1/2 inches wide. In addition, the weave i patterns had produced deep notches across the wcld, with severe under- l cutting at the end of the weave where it contacted the' piping bare netal, which does nct meet the ' blend snoothly' cnd ' surf ace smeeth-ness' req uire me n ts . "

RE SOL UTION ,

QC-8 is a field procedure and does not antly to Crinnell shop welds However, Grinnell proceduren do lir.it weld beads to 4 times the electrode diancter, which apparently was not net. This problem is being reviewed with C rinne ll . AEC-DRO vill be advised of the final resolution.

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! In regard to the veld surface irregularities, it is considered that the wc}d surf aces are acceptabic to the Code, especially in viou of Code Case 23 l which permits inspection of as-velded curf aces provided the surf ace condition j permits proper inte rpretation of radiographs and other required examinations.

t Two c.ualified examiners have reviewed the radiographs for pipe spool CF-1 and consider them inte rpretable.

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1 ENCLOSUPI 3 l

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RESOLITTIONS TO ITF.I'S IN ENCLOSUPI 3 TO AEC-DRO LETTER DATED OCTOBER 6,1972

1. ACC FI!! DING "Enr,ineered Scfeguards Actuating Bench Boards, Channels A, E, C, and D.

The bottoc: of the engineered safeguards actuating bench boards,  ;

Channels /. B, C, and D, are cpen to the cable spreading room, which is located below the control room. Failure to effect adequate l closure of these openings could result in the required evacuation of I the control room if a fire occurred in the cabic spreading room. I Our inspectors did not find drawings nor instructions relative to the method of closure of this opening."

_FICCLL* TION CAI is preparing engineering drawings for a suitabic barrier.

2. AEC FIh* DING

" Bat terv Rooms

'Ihe two batteries appear to share a co ::vn ventilation system, which l could result in a cornon' mode of failure should a fire occur in one l bcttery recm and be transmitted to the second room by way of the i vent 11stion svsten."

Jir.FOILTION ,

Far.c 8-7 in the FSAR, parayaph 8.2.2.10.e, covers this subjcet.

Furthe.. this subject was reviewed with a DRL representative (Mr. Sullivan) l at the !!!I site in !! arch 1972. As noted in the FSAR: "The battery rooms are supplied and e::hausted via ecm::on ducts. Each room hac its own supply and e :haust duct system which can be autorr.atically isolated by activating isolation da ters in the ducts. The isolation dampers are activated by combination l < sn. eke and fite detectors in the ducts."

l We consider this to resolve the AEC Finding. ,. ,3 , ,,

1 143 3-1 l

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/ METROPOLITAN EDISON COMPANY wnwranv oraturnat rueucununuconposanonl PO':T OFFICE BOX 542 RE A DING, PENNSYLV ANI A 19603 TELEPHONE 215 - 929 36o1

November 3, 1972 Mr. J. P. O'Reilly, Director Directorate of Regulatory Operations, Region i United States Atomic Energy Coccission 970 Broad Street Newark, New Jersey 07102

SUBJECT:

THREE MILE ISLAND NUCLEAR STATION UNITS 1 AND 2 DOCYIT NOS.30-289 AND 50-320 FISPONSE TO AEC/DRO AUDIT OF AUGUST 14 THROUGH 17, 1972

Dear Mr. O'Railly:

j 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 AuFust 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-

! co@liance 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, 4

cr (3) to raise questions concerning construction 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 vill 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 it: prove the compliance of UE&C construc-tion and QC groups with TMI quality requirements. Additi_onally, CPU has taken over responsibility for the management direction of the UE6C Quality Organization for the TMI Project.

} } (,' O Very truly yours, ,

Ai */

h

-J. G. Mille

/)o h Vice President j s

)

aw  ;

d Enclosures '

cc: Mr. W. G. Kuhns '

Mr. W. A. Verrochi 7911080

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