ML19352A193

Responds to NRC 810106 Ltr Re Violations Noted in IE Insp Rept 50-483/80-27.Corrective Actions:Surveillance Rept Reopened Until Outstanding Questions Resolved.Fittings Inspected & Unacceptable Matl Segregated

ML19352A193
Person / Time
Site:	Callaway
Issue date:	02/18/1981
From:	Bryan J UNION ELECTRIC CO.
To:	Fiorelli G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19352A192	List: ML19352A193
References
ULNRC-418, NUDOCS 8103110757
Download: ML19352A193 (10)

Text

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,- UNION ELECTRIC COMPANY teos ORATeoT eTRErr ST. Louis, MassOURI u A.u o apon s...

.AOMN M. BRYAN P.O.moze43 m s -.. . , .v. tou.s. - ..ov . , . . . . .

February 18, 1981 Mr. Gaston Fiorelli, Chief Reactor Construction & Engineering Support Branch US Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 ULNRC- 418

Dear Mr. Fiorelli:

INSPECTION REPORT NO. 50-433/80-27 This is in-response to your letter of January 6, 1981 reporting results of an inspection at Union Electric Company's

- General offices in St. Louis and at the Callaway Plant Site on November 3-7-and 12-14, 1980 and as detailed in inspection report

. number 50-483/80-27.

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

Our previous response, ULNRC-414 dated February 2, 1981 indicated that a complete response would be submitted by February 18, 1981. This response indicates the current' status of the items in Appendix A, Notice of Violation, of the inspection report. As noted in this response, item 2 requires further investigation and evaluation before the final disposition is determined. We will keep you informed asito the resolution of this item.

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

. l.) Severity Level V Violation (483/80-27-05) 10 CFR 50, Appendix'B, Criterion XVI, stated in part, " Measures shall be established to assure that...' defective material and equipment and nonconformances are promptly identified and corrected.

In the case of significant conditions adverse to

. quality, the measures shall assure that the cause of-the condition is determined and correc-tive-action taken to preclude repetition."

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o Mr. Gaston Fiorelli February 18, 1981 Contrary to the above, inadequate corrective action was taken in the following instances:

a. Surveillance report 9/79-12 dated September 25, 1979, was closed on November 12, 1980, even though two questions raised in the surveillance report requesting guidance on accep-tance criteria for measuring defects remained unanswered.

b. In the " Corrective action to preclude repetition" column on NCR 2 SN-ll41-E, "No Daniel action required" was entered even though Daniel performs functions such as site procurement, receipt inspection and installation inspections which could preclude repetition of identified problem.

c. In the " Corrective action to preclude repetition column" on NCR 2SN-2236-E dated-July'28, 1980, "No Daniel action required" was entered precluding Daniel inspecting other switchgear to ascertain

-whether " Suitable flexible wiring" was used over door hinges where leads may be subjected to flexing.

d. Even though, a deficiency report dated September 11, 1979, documented that nitrogen pressure was being lost on electrical penetration assembly No. 0712, followed by loss of nitrogen pressure in several other electrical penetrations, corrective action was not taken in a timely manner to replace the. identified defective valves to assure a dry environ-ment.

. Res ponse . (Previously submitted'in ULNRC-414)

' Item la CORRECTIVE ACTION TAKEN AND THE RESULTS ACHIEVED:

The close out engineer considered-that there was sufficient information in the surveillance to address both~ questions, however his close out did not address the. two items in question. He was instructed, on November 14,'1980, to address'every N

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Mr. Gaston Fiorelli February 18, 1981 open question in a surveillance close out memo, and not to rely on information stated in the surveillance. The surveillance in question was reopened on January 23, 1981, and will remain so until the two outstanding questions have been adequately addressed, and closed out.

CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER NONCOMPLIANCE:

We feel that the action stated above will avoid any recurrence of this noncompliance.

'DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

Full compliance was achieved on January 23, 1981.

Resoonse Item lb CORRECTIVE ACTION TAKEN AND THE RESULTS ACHIEVED:

On NCR 2SN-ll41-E, the "Cause of Nonconformance and Action to Prevent Recurrence" stated " Vendor supplied material - No inspection criteria. No

-Daniel action required". The basis of this statement was that the material was supplied by a Bechtel; vendor-and the purpose of the NCR was to have Bechtel disposition the material and also to provide corrective action with the vendor.

In the section of - the NCR entitled " Action Tr' .n to Control Nonconformance", Daniel stated that if further evaluation of the material deficiency by Bechtel indicated that further action by Daniel was.necessary,.then Daniel would_ perform further investigation. As a result of the Bechtel response, further actions were necessary and these were described in the section of the NCR " Statement of Completed Action". Specifically, during the investigation,' it was determined that all previously

< accepted fittings would'be reinspected to the inspection criteria provided by Bechtel. QCP-301,

" Inspection of Electrical-Raceway Supports",

Revision.6, incorporated _this new' inspection criteria.

Following initiation of the NCR, Daniel placed all fittings in-the~ warehouse on hold. Inspection was performed and' material identified with forming tears was segregated to assure that no. unacceptable material was_ released ~to.the field.

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Mr. Gaston Piorelli February 18, 1983 Though not documented, subsequent deliveries have been inspected for forming tears by Quality Control Inspectors. To correct this situation, the receiving inspection instructions were revised on 11/14/80 to require that a documented inspection be performed.

CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER NONCOMPLIANCE:

In the future, particular attention will be given to assessing these types of NCR's so that we can demonstrate actions taken by Daniel through back-up documentation. Discipline engineers have been made aware of this problem.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

Full compliance was achieved on November 14, 1980.

Response

Item lc-CORRECTIVE ACTION TAKEN AND THE RESULTS ACHIEVED:

. At the t ime of identification of a wiring problem on Motor. Control Centers NG03D/521 and NG04D/521, Daniel Electrical Engineering discussed the deficiencies with the Bechtel Site Liaison. It was agreed that-a Nonconformance Report would be initiated to document the problems rather than a

' Deficiency-Report since the problem appeared to be within the: Specification and not with the Vendor.

1. NCR-2SN-2123-E was initiated on June 23,'1980 and

~ transmitted to Bechtel for disposition.

Following-' transmittal of the NCR to Bechtel, the Daniel Electrical Equipment Coordinator inspected Motor Control Centers in the Warehouse and requested Discipline Area Engineers to check Motor Control Centers in the field. It was recognized at that time that the problem was generic. Initially Bechtel

' indicated that, Daniel.could expect an approval of "Use As Is" disposition, however, Bechtel required more specific information as to the location of the wiring. Daniel superseded NCR 2SN-2123-E by initiating NCR 2SN-2236-E to provide the information requested by Bechtel. . 'The-deficiencies identified were determined acceptable by_the Bechtel response to 2SN-2236-E which

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stated the-specification would be revised to allow

Class B Wiring..

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Mr. Gaston Fiorelli February 18, 1981 Daniel was deficient in not documenting the inspection of other Motor Control Centers.

NCR 2SN-2236-E has been annotated to document further inspection waich substantiated the problem as generic.

CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER NONCOMPLIANCE:

In the future, Nonconformance Reports identifying a generic problem will state explicitly that the NCR is generic in nature and sufficient inspection will be performed and documented to support the

-identification of the problem as generic.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

Full compliance was achieved on February 12, 1981.

Res ponse Item ld CORRECTIVE ACTION TAKEN AND THE RESULTS ACHIEVED:

The particular valve identified in the inspection report was for penetration 2ZSE219 on Deficiency Report 2SD-0717-E. Although the DR was listed as still open on the memo given to the NRC Inspector,

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review of the DR revealed it had been closed on 11/6/79. The other eight DR's were open at the time of the inspection and we concur that replace-

ment of these valves was not accomplished in a timely manner. Contact with the vendor revealed that maintaining the penetrations even for long periods of time with zero pressure on the nitrogen blanket should have no detrimental effect on the equipment provided the environment is not extremely humid. These penetrations were maintained'in place inside the_ Auxiliary Building.

Penetrations have been'in our maintenance program for approximately_18. months and this program consists of a monthly check for. gas pressure. If a low pressureJis noted, the penetration is repressurized and a daily' check is' performed to assure _the penetra-tion is~ maintaining the correct pressure. Since approximately April, .1980, we have performed 'tdue same 1 type-of monitoring three times.a. week and have.now replaced any' defective valves with valves of an improved design. All of: the' subject DR's have been closed.

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Mr. Gaston Fiorelli February 18, 1981 CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER NONCOMPLIANCE:

In our review of the process used to control and document this activity, we have determined that we can expedite valve change-out more effectivelv by using our maintenance procedure rather than our nonconformance procedure.

-DATE PHEN FULL COMPLIANCE WILL BE ACHIEVED:

Full compliance was achieved on February 17, 1981.

2.) Severity Level V Violation (483/80-27-06) 10 CFR 50, Appendix B, Criterion VII, stated in part, " Measures shall be established to assure that purchased material, equipment and services whether purchased directly or through contractors and subcontractors, conform to procurement documents.

These measures _shall include provisions as appro-priate, for... examination of products upon delivery.

Documentary evidence that the material and equipment conform to the procurement requirements shall be available at the nuclear power plant or fuel re-processing plant site prior to installation or use of such material or equipment."

TheLfollowing examples were contrary to the above:

a. Written receipt inspection requirements with specific acceptance criteria were not established to receipt inspect uni-struts for potential " Forming Tears" defects. The licensee stated that receipt inspections were performed without the benefit of specific written procedures.

Prior to the conclusion of the inspection, Receiving Instructions File No. B12.01 dated November 14,- 1980, was developed.

b. . Certificates.of compliance from GE which merely stated "All materials used in this shipment as called for-in the above Purchase Order have been processed by GE-PSMBD comply with ANSI product performance specification requirements" were accepted for the relays supplied; these certificates did not explicitly state that the relays met the requirements of ANSI C-37.90/1971, and therefore, did not meetathe minimum requirements of paragraph 10.2.1 of ANSI 45.2.13.

February 18, 1981 Mr. Gaston Fiorelli

c. Documentation that the following tests, prescribed in Specification E-051(Q),

were performed on the battery chargers was not available at site:

(1) Temperature raise test (2) Short circuit test (3) Efficiency test (4) Transient voltage withstand test (5) Stability and response test Item 2a - No response required

Response

Item 2b CORRECTIVE ACTION TAKEN AND THE RESULTS ACHIEVED:

Deficiency Report 2SD-2504-E was written to obtain a Certificate of Compliance for switch-gear tag no. 2NG07/023 and 2NG08/023 which specifies the ANSI Standards met.

CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER NONCOMPLIANCE:

The Services Quality Control Engineer issued SOCE-1641 on December 5, 1980, advising inspectors and technicians to review, in addition to the Material. Receiving Instructions, referenced specifications and standards in order to assure that required tests and other per-tinent data have been received.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

We will be in full compliance upon receipt of Certificate of Compliance.

. Response-

' Item 2c CORRECTIVE ACTION TAKEN AND THE RESULTS ACHIEVED:

Defi'ciency Report 2SD-2501-ER was issued on 11/28/80 to identify and' control the Battery Chargers -(2NK21/341, 2NK22/341,. 2NK23/341,.

2NK24/341 and 2NK25/341) in question. The

-Deficiency Report also identified that the following test results, prescribed by Specifi-cation 10466-E-051(Q) , Revision ~3, paragraph 15.3,-were not received at site:

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Mr. Gaston Fiorelli February 18, 198)

NEMA PV5 6.05 Temperature Raise Test 6.07 Short Circuit Test 6.09 Efficiency Measurement 6.10 Power Factor Measurement 6.12 Audible Noise Test 6.13 Stability and Response 6.14 Transient Voltage With-standability Test The Deficiency Report requested that Bechtel obtain the documentation from the E-051-2 vendor. Subsequent to the issue of the Deficiency Report a review was performed of Bechtel Specification 10466-E-051(O),

Revision 3 and documentation previously received with the Battery Chargers. This review established that Bechtel had approved Power Conversion Products procedure PS77-8, titled, " Production Test Procedure of SNUPPS Battery Chargers in Accordance with NEMA PV-5-1976 and Technical Spec. 10466". This procedure does not require production tests to be performed for those tests identified as missing and therefore documentation of these tests are not contained in the documentation package for the subject chargers. The review further-established that the subject tests are performed in accordance with Bechtel approved Power Conversion Products procedure PS77-10 titled " Design Test in Accordance with NEMA PV-5-1976 and SNUPPS Tech.

Spec.- 10466". These prototype test results are forwarded to Bechtel Engineering in accordance with Specification 104 66-E-051 (Q) . After approval, the test report is then forwarded to the site as a part of Bechtel's vendor print register. The test reports in question were received on: site July 13, 1977 and may be found in Daniel Document

Control. The report is' identified as "E-051-0055-01 Power Conversion Products".

Power Conversion Product's letter, dated January 8, 1981, in response to Deficiency-Report-2SD-2501-ER further substantiates that the documentation that was initially received was correct _and complete.

Bechtel will be contacted to determine if the above interpretation of the documentation requirements satisfy the intent of the specification. Deficiency Report 2SD-2501-ER will remain open pending Bechtel's

response..

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Mr. Gaston Fiorelli February 18, 1981 i

f I CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER NONCOMPLIANCE:

1. a) Place the test reports in the documentation package if Bechtel determines that it is required by specification. .

b) If documentation is correct, Bechtel will be requested to evaluate the need for a specification change for clarity of documen-tation requirements.

2. An evaluation of the review of vendor documentation received on site has been initiated. Based upon the results of this evaluation, appropriate corrective action will be taken.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

The-date when full compliance will be achieved will be dependent upon the corrective action resulting from the evaluation above.

Additional information regarding item 2 will be provided when it becomes available.

Very truly yours, at, John

. yan WSS/jds

- cc: Mr. H. M.~ Wescott, NRC Region III Mr.:W. A. .Hansen, NRC Resident Inspector,.Callaway Plant Missouri Public Service Commission i

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o STATE OF MISSOURI )

) sS CITY-or sT. Louis )

Robert J. Schukai, of lawful age, being first duly sworn upon oath says that he is General Manager-Engineering (Nuclear) for Union Electric Company; that he has read the foregoing document and knows-the content thereof; that he has executed the same for and on behalf of said-company with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.

By \

Rober J. chukai

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Gener ager-Engineering Nuclear SUBSCRIBED and sworn to before me this 18th day of February, 1981 Lec ,s 4Y Y 52.4#E s ng PAimCir .- 9, DORRis

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