ML20002B466

Responds to NRC 801020 Ltr Re Violations Noted in IE Insp Rept 50-483/80-25.Corrective Actions:Change Order to Purchase Number Was Initiated & Controlled Pamphlets Are Being Issued to Welders

ML20002B466
Person / Time
Site:	Callaway
Issue date:	11/14/1980
From:	Bryan J UNION ELECTRIC CO.
To:	Fiorelli G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20002B467	List: ML20002B466
References
ULNRC-398, NUDOCS 8012110630
Download: ML20002B466 (3)

Text

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,, , UbmON ELECTRIC COMPANY 1901 GRATIOT STR Err ST. Louts. MissOURt M Asu%e Aponess.

' .".*Ed.'"I^," Noyember 14, 1980 .v. to v7.. ..". ."o E.* . . . . .

Mr. Gaston Fiorelli, Chief Reactor Construction & Engineering Support Branch US Nuclear Regulatory Commission Region III 799 Roosevelt Rd.

Glen Ellyn, IL 60137 ULNRC-398

Dear Mr. Fiorelli:

INSPECTION REPORT NO. 50-483/80-25 This is in response to your letter of October 20, 1980 reporting results of an inspection at Union Electric Company's Callaway Plant Site on September 30 thru October 3, 1980 and as detailed in inspection report number 50-483/80-25.

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 items in Appendix A, Notice of Violation, of the inspection report.

Infraction (483/60-25-01) 10 CFR 21.31 states in part that, "Each individual, corporation, partnership, or other entity subject to the regulations in this part shall assure that each procurement document for a facility or a basic component issued by him, her, or it...

specifies when applicable that the provisions of 10 CFR Part 21 apply." 10 CFR 50 Appendix B, Criterion IV states in part that, " measures shall be established to assure that applicable-regulatory requirements...are suitably included or referenced in the documents for procurement of material...

whether purchased by the applicant or by its contractors or subcontractors."

L -trary to the above, Purchase Order Number 7186-SR-82399 issued to Raychem Corporation for safety related electrical cable splice and termi-nation kits did not specify that the provisions of 10 CFR 21 apply.

8012_13o(pso

o Mr. Gaston Fiorelli Nove#)er 14, 1980

Response

CORRECTIVE ACTION TAKEN AND THE RESULTS ACHIEVED:

Daniel Electrical Engineering initiated a Change Order to Purchase Order Number 7186-SR-82399,

. on October 20, 1980, to indicate that the pro-visions of 10 CFR 21 apply to the Purchase Order issued to Raychem Corporation.

CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER NONCOMPLIANCE The Electrical Materials Engineer has been cautioned to review all purchase orders at the time of issue for 10 CPR 21 applicability. In addition, an in depth review of all exinting electrical purchase orders is being conducted to assure that 10 CFR 21 requirements are noted if applicable. This review will be completed by November 15, 1980.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

Daniel will be in full compliance November 15, 1980.

Infraction (483/80-25-03) 10 CFR 50, Appendix B, Criterion IX, states in part,

" Measures shall be established to assure that special processes, including welding..., are con-trolled and accomplished by qualified personnel using qualified procedures in accordance with applicable

. codes..."

The SNUPPS Project Quality Assurance Manual, Section 17.1.9 states in part that, "The SNUPPS utilities require that special processes be controlled.

Special processes will be accomplished...with appli-cable codes..."

The ASME B&PV Code, S-74, Article NA-4000, subarticle NA-4411, states in part that, "The program shall include measures to control the issuance and dis-position of documents, such as...', instructions, procedures,... including changes thereto, which pre-scribe the activities affecting quality. These measures shall assure that documents including changes,... and distributed to and used at the location where the prescribed activity is performed."

Mr. Gaston Fiorelli November 14, 1980 Contrary to the above, welding was not being accomplished in accordance with applicable codes, in that controlled welding procedure specifications with the associated technique sheets were not located at the prescribed activity (welding).

Response

CORR}CTIVE ACTION TAKEN AND THE RESULTS ACHIEVED:

Controlled pamphlets have been published and are being issued to the welders from the Filler Material Control Rooms each day. To the extent practicable uncontrolled general welding information pamphlets have been removed from the field.

CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER NONCOMPLIANCE:

Issue and control of welding pamphlets has been outlined in Work Procedure 503 (Control of Welding Consumables).

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

Daniel was in full compliance November 3, 1980 with the issue of WP-503, Revision 12.

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

Ver';- truly yours ,

I

\ %O4 1 Jo n K. Bryan [

' (

WSS/jds cc: Mr. H. M. Wescott, NRC Region III Mr. W. A. Hansen (NRC Resident Inspector, Callaway Plant)

Missouri Public Service Commission m e ~ v e- w -