ML19351D411
| ML19351D411 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 09/16/1980 |
| From: | Bryan J UNION ELECTRIC CO. |
| To: | Fiorelli G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19351D408 | List: |
| References | |
| ULNRC-388, NUDOCS 8010100082 | |
| Download: ML19351D411 (4) | |
Text
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UNION ELECTRIC COMPANY (AI ison omAvioT sTmarv ST. Louis. Missouri
~^U=^E "II' September 16, 1980 soaa m =.va~
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Mr. Gaston Fiorelli, Chief Reactor Construction & Engineering Support Branch U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road ULNRC-388 Glen Ellyn, IL 60137
Dear Mr. Fiorelli:
INSPECTION REPORT NO. 50-483/80-20 This is in response to your letter of August 14, 1980 reporting results of an inspection at Union Electric Company's Callaway Plant Site on July 1-31, 1980 and as detailed in inspection report number 50-483/80-20.
None of the material in the inspection report or in this response are considered proprietary by Unicn Electric Company.
The following is in response to the items listed in Appendix A, Notice of Violation, of the inspection report.
Infraction (483/80-20-01) 10CFR50, Appendix B, Criterion XVI and SNUPPS PSAR paragraph 17.1.16 requires that " measures shall.
assure that the cause of the condition is determined and corrective action taken to preclude repetition".
Contrary to the above uncontrolled welding material was identified and reported in NRC report 483/80-03.
This condition has not been corrected in that during the reporting period uncontrolled welding materials were again observed at many different locations.
CORRECTIVE ACTION TAKEN AND THE RESULTS ACHIEVED:
Immediate action was taken by Daniel's (DIC)
Construction Department to police all areas and dispose of any unused welding filler material and/or stubs found lying loose.
'SEP 18 gao 8 0 20 y o po3;t
h e-September 16, 1980 Mr. Geston Fiorolli DIC Management Personnel met to determine the course of action to be taken to establish adequate control of welding consumables.
As a result of this meeting, Corrective Action Report 2G-0008 was initiated and dispositioned.
The following steps for corrective action were immediately implemented in accordance with the CAR and Inter-Office Communication PM-896:
1)
Construction and/or Engineering to conduct meetings with foremen emphasizing it is their responsibil-ity to assure their welders keep l
rods properly cleaned up, and at the'end of the shift, rod stubs are emptied into appropriate containers (WP-503 - Control of Welding Con-sumables).
2)
Second shift superintendent perform documented surveillance of field l
areas.
3)
First shift welding superintendents i
continue with documented surveillance of field areas.
4)
DIC Subcontracts Department inform all i
subcontractors performing welding of the following:
a.
All welding filler material i
shall be in controlled possession of the welder at i
all times.
Loose electrodes l
and filler wire shall not be l
left lying around.
l b.
During welding operations, all electrode and wire stubs shall be kept in a rod stub bucket.
c.
At the end of the welders shift i
or on completion of assigned welding, all unused welding filler material and/or stubs shall be returned to a controlled holding area or bent and properly disposed of in weld rod stub barrels, which are located through-out the jobsite.
M' '. Goston Fiorolli September 16, 1980 r
5)
Quality Control and Welding Engineering to increase surveillance of WP-503, paragraph 3.16 during daily activities.
CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER NONCOMPLIANCE:
Implementation of the above listed corrective action items is designed te avoid further noncompliance.
THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Implementation of the corrective action items listed on C.tR 2G-0008 and PM-896 brought DIC into full compliance on August 15, 1980; however, Items 2, 3 and 5 will be ongoing to identify and correct future adverse conditions.
Deficiency (483/80-20-02) 10CFR50, Appendix B, Criterion V and SNUPPS PSAR paragraph 17.1.5 requires that " activities affect-ing quality.
. shall be accomplished in accordance with these instructions, procedures, or drawings".
Daniel International Work Procedure WP-506 " Control of Tools Used on Stainless Steel Pipe, Plate and Shapes" requires that brushes, grinders and other tools be marked with white paint when used to fabricate stainless steel.
Contrary to the above, pipefitter and welder personnel were observed to be using unmarked brushes and grinders.
CORRECTIVE ACTION TAKEN AND THE RESULTS ACHIEVED:
DIC Construction personnel have inventoried tools intended for use on stainless steel to assure readily visible identification.
All tools intended for such usage have been marked with white paint to segregate tools used on carbon steel from those used on stainless steel, in accordance with Work Procedure (WP-506 - Control of Tool Used on Stainless Steel Pipe, Plate and j
Shapes) and Work Procedure (WP-200 - Field Fabrication and installation of Pipe and Component Supports).
Mr'. Gnston Fiorelli Ssptember 16, 1980 To stress the importance of compliance with work procedures involving tool usage on stain-less steel, the DIC General Piping Superinten-dent issued CM-1208 to all Superintendents, General Foremen and Foremen.
Craft personnel will be supervised and indoctrinated as necessary by their foremen.
Designated tool usage shall be reviewed and documented periodically at Weekly Superintendent meetings and shall be passed along to Foremen for awareness in their supervisory capacity over Craft personnel.
CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER NONCOMPLIANCE:
Implementation of WP-506 and WP-200 along with increased surveillance by Construction super-vision is designed to avoid further noncompliance.
THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
1 Full compliance was achieved by August 11, 1980.
If you have any questions regarding this response or additional information is required, please let me know.
our very truly, we ryan(g John K.
RHR/jds cc:
Mr.
H. M. Wescott, NRC Region III Mr. W. A.
Hansen, NRC Resident Inspector, Callaway Plant Missouri Public Service Commission