ML20010F572

Responds to NRC 810625 Ltr Re Violations Noted in IE Insp Rept 50-483/81-04.Corrective Actions:Rework of Seam Weld Underway at Time of Insp.Licensee Maintains That Qa/Qc Insp Program Properly Identified & Controlled Deficiency

ML20010F572
Person / Time
Site:	Callaway
Issue date:	08/20/1981
From:	Capone D UNION ELECTRIC CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20010F568	List: ML20010F572
References
ULNRC-484, NUDOCS 8109100365
Download: ML20010F572 (4)

Text

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e U NION ELccTmc COMPANY

1. 90f CRATIOT STR E ET - as 7. LOUIS M AILING ADDRESS August 20, 1981 sv. Iovis lo7aise Mr. James G. Keppler, Director US Nuclear Regulatory Commission Region III 799 Roosevelt Rd.

Glen Ellyn, IL 60137 ULNRC- 4 84

Dear Mr. Keppler:

INVESTIGATION REPORT NO. 50-483/81-04 This is in response to your letter of June 25, 1981 reporting results of an investigation at Union Electric Company's Callaway Plant, Unit 1 on February 20, March 3-6, 23-27, 1981 and as detailed in investigation report No. 50-483/81-04.

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

The following is in response to the item in Appendix A, Notice of Violation of the investigation report.

Severity Level V Violation (483/81-04LO2) 10 CFR Part 50, Appendix B, Criterion IX, states,

" Measures shall be established to assure that special processes, including welding, heat treat-ing, and nondestructive testing, are controlled

~

and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and i other special requirements."

Pipe piece No. SP, part of the accumulator dis-

. charge line from accumulator TEPOIA, was manu-factured to material specification ASME SA-358.

4 Specification SA-358 requires " Radiographic Examination in Accordance with ... ASME .."

Section I, Paragraph PW-51.

ASME Code,Section I, Paragraph PW-51 states

" Sections of weld that are shown by radiography to have any of the following types of imperfections i shall be judged unacceptable and shall be repaired..."

$1.3.1 Any type of crack,.or zone of l incomplete fusion or penetration.

A109100365 810902

. PDR ADOCK 05000483 0 PDR AUG 2 41981

Mr. James G. Keppler August 20, 1981 Contrary to the above, on March 6, 1981, the inspector determined from a review of radio-graphs of the seam weld on pipe piece No. SP at film location markers 13-14 that the film indicated apparent incomplete fusion and excess reinforcement and yet the pipe piece had not been judged unacceptable or repaired.

CORRECTIVE ACTION TAKEN AND THE RESULTS ACHIEVED:

The subject deficiency was initially found during the field installation process at Callaway. The deficiency was first documented on NCR #2SN-0501-P on April 30, 1979. Subsequent to the NCR being returned by Bechtel, the field installer, DIC, reworked the apparent deficiency under DR #2SD-0699-P, dated 9/6/79. The rework and final inspection was completed by 11/15/79.

Per NRC Investigation Report #81-04 initial contact by the alleger was on or about October 11, 1979.

Subsequent NRC investigation led to conclusion in report #81-04 that the vendor originally improperly accepted the radiographic records. Additional field radiographs were made showing conclusively the weld radiographic acceptability during the NRC investiga-tion. In summary the apparent deficiency was properly identified and controlled through the field QA/QC inspection program, and the subject pipe now has been found by both the licensee and the NRC to be acceptable.

CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER NONCOMPLIANCE:

Considering the time intervals involved and the isolated nature of the apparent deficiency, further corrective action with the vendor at this time would not appear to be productive. Union Electric Company will continue to maintain a vigilant QA/QC program to identify and resolve deficiencies found in the field including appro-priate corrective action with vendors as necessary.

The above corrective action was discussed in a telephone conversation with Mr. W. J. Key on August 20, 1981.

e Mr. James G. Keppler August 20, 1981

, THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

Not applicable.

The architect engineer has reviewed the circumstances of the disposition of the Nonconformance Report No. 2SN-0501-P and their response will be in the project files for review. The A/E admits use of the incorrect edition of the ASME Code in the evaluation of the nonconformance report. Union Electric will direct Bechtel to instruct their engineers to exercise more care in selection of the proper Code edition when evaluating nonconformance reports.

1 l Very truly yours,

. A Donald W. Capone Manager-Nuclear Engineering DAO/jds cc: Mr. J. E. Konklin, NRC Region III Mr. W. A. Hansen, NRC Resident Inspector, Callaway Plant Missouri Public Service Commission l

STATE OF MISSOURI )

) SS CITY OF ST. LOUIS )

r D. W. Capone, of lawful age, being first duly sworn upon.

cath says that he is Manager, Nuclear Engineering for Union Electric Company; that he has read the foregoing document and knows the content thereof; the_ 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.

n By .

] D. W. Capond Manager, Nuclear Engineering SUBSCRIBED and sworn to before me this 20th day of August, 1981 4

I BARBARA J. PF4FF ' #

1 NOTARY PUBLIC, STATE OF MISSOURI WY COMMIS$10N ERPIMS APRIL 22,1985 ST. LOUIS COUNTY i

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