ML19320B751

Responds to NRC 800314 Ltr Re Violations Noted in IE Insp Rept 50-483/80-09.Corrective Actions:Civil & Mechanical QC Conducted Training Review Sessions W/Insp Personnel

ML19320B751
Person / Time
Site:	Callaway
Issue date:	06/06/1980
From:	Bryan J UNION ELECTRIC CO.
To:	Fiorelli G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19320B747	List: ML19320B751 ML19320B756
References
NUDOCS 8007150006
Download: ML19320B751 (4)

Text

.

UNION ELECTRIC COMPANY 8 1909 QMATIOT STREET

ST, Louis, Missouml emuMG ADON.SS:

JOHN M. BRYAN P.O.ROWtes v .MR....."' June 6, 1980 Mr. Gaston Fiorelli, Chief Reactor Construction & Engineering Support Branch US Nuclear Regulatory Commission Region III 799 Roosevelt Rd.

Glen Ellyn, IL 60137 ULNRC- 357

Dear Mr. Fiorelli:

INSPECTION REPORT NO. 50-483/80-09 This is in response to your letter of May 14, 1980 report-ing results of an inspection at Union Electric Company's Callaway Plant Site on April 23-24, 1980 and as detailed in inspection report number 50-483/80-09.

None of the material in the inspection report or in this response is considered proprietary by Union Electric Company.

The following is in response to the itemslisted in Appendix A, Notice of Violation, of the inspection report.

Infraction (483/80-09-02) 10 CFR 50, Appendix B, Criterion V, states, in part, that " Activities affecting quality shall be prescribed by documented instructions, pro-cedures . . . and shall be accomplished in accordance with these instructions, procedures, or drawings."

SNUPPS Union Electric Company Quality Assurance Manual Section io. 17, Table 17.1-1, states, in part, that "SGfety-related construction activi-ties shall be conducted in accordance with documented procedures drawings, instructions, checklists, or their equivalent.

Contrary to the above, several of the surface mounted component support plates were not installed in accordance with design drawing requirements in that the concrete expansion anchor bolts and weld attachments were

JUN 2 31980 s oon so W

, Mr. Gaston Fiore111 June 6, 1980 mislocated. Furthermore, the deficiencies were not identified and reported to design engineering for resolution.

CORRECTIVE ACTION TAKEN AND THE RESULTS ACHIE ED:

i.

Nonconformance Reports 2SN-2009-C and 2SN-2012-C and Deficiency Reports 2SD-1516-C, 2SD-1519-C and 2SD-1527-C were written to identify extents of nonconformances and to correct deficiencies found after final Quality Control inspection and sign-off of safety-related surface mounted plates.

Of the ten plates identified in these reports, three were found as a result of the NRC Inspection.

The remaining seven were found as a result of a Quality Control implemented reinspection program.

For safety-related surface mounted plates, Quality control will reinspect a minimum of fifty plates for each inspector, or all plates for any inspector that has not inspected at least fifty plates. If a nonconformance or deficiency is found for any one inspector, an additional sampling of plates will be reinspected. Any further nonconforming plates will be addressed on Ncnconformance or Deficiency Reports.

CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER NONCOMPLIANCE:

A thorough review of design and procedural require-ments related to the installation of and attachment to surface mounted plates has been accomplished.

Construction has conducted a review session with craft supervisors involved with surface mounted plate installation, re-emphasizing installation tolerances for expansion anchor relocation and movement of plate centerlines from the design loca-tion. In addition to their ongoing reinspections of completed work, Civil and Mechanical Quality Control have conducted training review sessions with their inspection personnel restating final in-spection requirements for surface mounted plate installation and reviewing checklist requirements for the installation of attachments to surface mounted plates.  !

l l

. Mr. Gaston Fiorelli June 6, 1980 THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

Reinspection of surface mounted plates is anticipated to be completed by June 13, 1980 .

at which time we expect to be in full compliance.

Infraction (483/80-09-04) 10 CFR 50, Appendix B, Criterion X, states, in part, that "A program for inspection of activities affecting quality shall be established and executed by or for the organization performing the activity to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activities."

SNUPPS Union Electric Company Quality Assurance Manual Section No. 17, Table 17.1-1, states, in part, that " Inspection of safety-related con-struction activities shall be performed to verify conformance with documented instructions, procedures, and drawings," and " Control measures shall be established to identify the need for corrective action, to provide for determination of the cause, and appropriate corrective action to prevent recurrence."

Contrary to the above, none of the installed hangers and snubbers had been QC inspected to verify piping suspension system location, configuration, and condition. The QC inspection program did not require timely inspection to ensure prompt identi-fication of nonconformances, initiation of correc-tive action, and program evaluation to prevent recurrences.

CORRECTIVE ACTION TAKEN AND THE RESULTS ACHIEVED:

Presently Work Procedures (WP-200, Rev. 10) requires Construction Supervision to notify Engineering of completed installations, at which time Engineering verifies each component for correct location. Upon verification of correct location Engineering releases the components to Quality Control for final inspection of the installation with regard to location, configuration and condition; however, WP-200 does not stipulate a specific time limit during which the Quality Control inspection is to be completed.

e

r. Gaston Fiorelli June 6, 1980 A revision to WP-200 is in process to include a requirement that final Quality Control inspection shall be completed within a thirty day period following completion of a hanger installation. .

CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER NONCOMPLIANCE:

Implementation of the revision to WP-200 will assure timely inspection of support installa-tions, to provide for prompt identification of nonconformances and for prompt action to prevent recurrence. Any identified nonconformances will be evaluated through the Trend Analysis Program to assure control of possible adverse trends and initiation of further corrective action if applicable.

THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

The above stated requirements will be incorporated into WP-200 by June 13, 1980 at which time'the inspection of individual hangers will commence.

If you have any questions regarding this response or additional information is required, please let me know.

You s very truly, gnK.$Bryan Ot\

WSS/jds cc: Mr. H. M. Wescott, NRC Region III Mr. W. A. Hansen  !

(NRC Resident Inspector, Callaway Plant Missouri Public Service Commission l