ML20138J004
| ML20138J004 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/23/1985 |
| From: | Standerfer F GENERAL PUBLIC UTILITIES CORP. |
| To: | Snyder B Office of Nuclear Reactor Regulation |
| References | |
| 0339A, 339A, 4410-85-L-0206, 4410-85-L-206, NUDOCS 8510290212 | |
| Download: ML20138J004 (4) | |
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GPU Nuclear Corporation Nuclear
- , ors:reo Middletown, Pennsylvania 17057 0191 717 944 7621 TELEX 84-2386 Writer's Direct Dial Number:
(717) 948-8461 4410-85-L-0206 Document ID 0339A October 23, 1985 TMI Program Office Attn: Dr. B. J. Snyder Program Director US Nuclear Regulatory Commission Washington, DC 20555
Dear Dr. Snyder:
Three Mile Island Nuclear Station, Unit 2 (TMI-2)
Operating License No. DPR-73 Docket No. 50-320 Early Defueling Safety Evaluation Report Response to Comments GPU Nuclear initially responded to NRC Questions on the Early Defueling Safety Evaluation Report (SER) via letter 4410-85-L-0181 dated October 3, 1985. In that letter, GPU Nuclear committed to provide additional information in response to Question 14 regarding GPU Nuclear's plans for onsite testing of defueling canisters. GPU Nuclear letter 4410-85-L-0202 dated October 10, 1985, described the Quality Assurance (QA) Surveillance Program at tES Manufacturing. Additional information on the QA Surveillance Programs at Joseph Oat Corporation and Babcock & Wilcox is attached.
Implementation of these QA Surveillance Programs provides the required assurance that the canisters meet the design specifications. Based on the above programs, coupled with the prototype testing described in our previous response to Question 14, GPU Nuclear does not consider further onsite testing to be warranted.
Sincerely, 85102902128$h20 PDR ADOCK O PDR M"-
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. R. Standerfer Vice President / Director, IMI-2 FRS/RBS/emi cc: Deputy Program Director - TMI Program Office, Dr. W. D. Travers 003 I
N GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation
ATTACHMENT (4410-85-L-0206)
I INTRODUCTION
'In addition to the defueling canisters being manufactured by tES, contracts for the manufacture of defueling canisters have also been placed with Babcock & Wilcox (B&W) at Lynchburg, VA, and the Joseph Oat Corporation at Camden, NJ. Specifically, 8&W has been contracted to manufacture filter canisters and the Joseph Oat Corporation has been contracted to manufacture fuel and knockout canisters. The fo'17 wing sections describe the GPU Nuclear /Bechtel Quality Assurance
- veillance Program at B&W and the Joseph Oat Corporation; the additional actions whicn have been implemented as a result of the deficiencies identified at NES; and the actions required prior to use of the defueling canisters.
II GPU NUCLEAR /8ECHTEL QUALITY ASSURANCE SURVEILLANCE PROGRAM AT B&W AND THE JOSEPH DAT CORPORATION to GPU Nuclear letter 4410-85-L-0202 dated October 10, 1985, described the GPU Nuclear /Bechtel Quality Assurance Surveillance Program at NES which is structured to assure that a proper vendor Quality Assurance Program is in effect. The controls exercised by the program have also been implemented for the other vendors and are described below:
o A pre-award survey was performed for B&W and the Joseph Oat Corporation. Additionally, an audit of these vendors was conducted at the time of the pre-award survey.
o The Quality Assurance Manuals for B&W and the Joseph Oat Corporation were reviewed by THI-2 Project Design Engineering and Bechtel Quality Assurance and were accepted, with comments, for the start of fabrication. Full acceptance of these manuals will not be granted until all comments are satisfactorily resolved.
o THI-2 Project Design Engineering specified in the procurement documents that B&W and the Joseph Oat Corporation were required to submit designated docunents related to canister fabrication for Bechtel review prior to use. Hold and witness points were specified in the procurement documents and are supplemented by the Bechtel Quality Surveillance Plan.
i o
The Joseph Oat Corporation and B&W have been assigned a full-time
" Resident" Bechtel Supplier Quality Representative (SQR).
O In addition-to the audit conducted at the time of the pre-award survey, audits of the implementation of the Quality Assurance i
Programs for B&W and the Joseph Oat Corporation have been scheduled. The audit at the Joseph Oat Corporation is scheduled for October 23-25, 1985, and the audit at B&W is scheduled for the week of November 4,1985.
ATTACHMENT (4410-65-L-U206) o GPU Nuclear Quality Assurance elected to perform a " third-level" surveillance of B&W and the Joseph Oat Corporation, including specific hold and/or witness points, o
Following completion of the fabrication of each component, and before the item can be released for shipment, 6&W and the Joseph Oat Corporation are required to provide a document package to the SQR for review. The composition of the document package is similar to that described for NES in Attc0hment 2 of our letter dated Octooer 10, 1985.
o Upon receipt at THI-2, the CPU Nuclear Quality Control staff will perform a material receipt inspection in accordance with the receipt inspection plan.
III ADDlTIONAL ACTIONS IMPLEFENTED AS A RESULT OF THE DEFICIENCIES IDENTIFIEU AT NES The checklist program for NES components was developed as a result of the deterC nation that the normal approach to material acceptance was not adequate for the work performed by NES manufacturing. As discussed in our letter of October 10, 1985, the scope of this checklist program included a complete review of the documentation of the first shipment of each type of canister, the first two canister storage racks, and both trolley shields. This review may continue for future material deliveries based on vendor performance and/or checklist program results.
Currently, such supplementary, extraordinary actions have not been deemed necessary for either B&W or the Joseph Oat Corporation. To date, the results of the ongoing GPU Nuclear /Lechtel Quality Assurance Surveillance Program of these vendors have been satisfactory.
However,as a result of the deficiencies identified at NES, the following hold and/or witness points have been added to the Quality Assurance Surveillance Programs at d&W and the Joseph Oat Corporation:
Verify the presence, through visual inspection, of catalyst in tne o
upper and lower heads of each defueling canister.
o Verify that all poison tubes are packed in accordance with the supplier's procedures and drawings. This hold / witness point has been incorporated into the inspection plar.' fur d&W and tne Joseph l
Oat Corporation.
In addition to the above, the following " lesson-learned" actions are being implemented at B&W and the Joseph Oat Corporation:
o The resident SQRs at B&W and the Joseph Oat Corporation witness the unloading and receipt inspection of any defueling canister material I
received from NES.
l l
o ATTACHMENT (4410-8-L-0206) o A Quality Verification Program has been instituted which 3
supplements the normal hardware surveillance. This program consists of the resident SQR's review of the implementation of specific elements of the supplier's Quality Assurance Program and is designed to identify the existence of programmatic deficiencies. The Quality Verification Program has been deemed not to be necessary for NES due to the implementation of the canister checklist program, o
The Procurement Supplier Quality Decartment (PSQO) Supervisor participated in the initial meeting with the resident SQRs and vendor personnel. The purchase order and the specification and inspection requirements were discussed. The findings of the joint GPU Nuclear /Bechtel Quality Assurance Audit at NES and the results of the NES inspection by the Vendor Inspection Branch, NRC Office of Inspection and Enforcement, also were reviewed.
o As a result of previous concerns related to NES submittals of non-required Supplier Deviation Disposition Requests ($DURs), TMI-2 Project Design Engineering is planning to conduct instructive briefings and indoctrination training on tne correct processing of SDDRs.
The resident SQRs will attend these oriefings.
IV ACTIONS REQUIRED PRIOR TO USE OF THE DEFUELING CANISTERS Our letter of October 10, 1985, described the prerequisites to GPU Nuclear use of the first four filter canisters.
Determination of acceptability for use of the defueling canisters manufactured by B&W and the Joseph Oat Corporation, as well as the remaining defueling canisters to be manufactured by NES, will be based on an onsite receipt inspection in accordance with the established receipt inspection plan.
Additionally, GPU Nuclear shall review and concur in the results of any completed defueling canister checklist. The GPU Nuclear Quality Assurance Manager will notify the Office of the Director, TMI-2, in writing of the acceptability of each defueling canister for wnich a checklist is completed.
Furthermore, prior to use of the defueling canisters, GPU Nuclear shall obtain EG&G Idaho's statement of acceptability of the canisters for turnover, shipment, and storage at the Idaho National Engineering Laboratory.
Finally, GPU Nuclear reaffirms that a determination that a canister is not acceptable, based on the above review, will result in that item being placed on Quality Assurance Hold pending disposition (e.g., reject, rework, etc.), and controlled in accordance with the GPU Nuclear Quality Assurance Plan.
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