ML20058J145
| ML20058J145 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 07/21/1982 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20058J137 | List: |
| References | |
| ULNRC-567, NUDOCS 8208090175 | |
| Download: ML20058J145 (8) | |
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UNION ELECTRIC COMPANY 1901 GRATIOT STREET ST. Louis. MissouRs MAluNS ADDR...s DONALDF..CHNELL P. O
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SOEL 14.
Ju1y 21, 1982
..R.....,
s Mr. C. E. Norelius, Director Division of Engineering and Technical Programs s
US Nuclear Regulatory Commission
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Region III 799 Roosevelt Road ULNRC-567 Glen Ellyn, IL 60137
Dear Mr. Norelius:
CONSTRUCTION TE'AM ASSESSMENT REPORT APRIL 26 TO MAY 7, 1982 This letter is in response to your' letter of June 15, 1982 which transmitted the special construction team assessment report of the inspection conducted during the period of April 26 to May 7, 1982.
Our responses to the items of noncompliance and other findings are presented below in the order listed within the body of inspection 9 port 50-483/82-03.
None of the material in the inspection report or in this response is considered proprietary by Union Elechric/ Company.
(50-483/82-03-01) OPEN ITEM Interface problems between site groups are evident in responses to RCIs and FCRs, in procedural violations regarding identification of s
cut cable, and from numerous com.;.ents made by licensee and contractor personnel.
Increased attention should be given to this area by Union Electric.
Response
S Union Electric Quality Assurance wilh perform a surveillance to investi-) \\
gate the interface difficulties ider.tified by the Inspector.
The results of this surveillance will be reported to the appropriate s
levels of management for correction as acessary.
This surveillance will be complete and documented by A';3ur 2, 1982.
(50-483/82-03-02) SEVERITY LEVEL {g Jp TTON During review of the licensee's a'udit files, the Inspector found a number of cases in which followup and closecut actions on audit find-ings have not been accomplished in a timely manner.
This failure to take timely corrective action is considered to be in noncompliance with s
8208090175 820804 682 PDR ADOCK 05000483 s.
O PDR
Mr. C.
E. Morelius July 21, 1982 Criteria XVI of 10CPR50, Appendix B.
Corrective Action Taken And The Results Achieved:
The assigned UE QA engineers were aware of the status of their respec-tive items at the time of the NRC inspection.
Each item is tracked on an automated recordkeeping system, and the assigned UE QA engineers receive weekly printouts on their respective open items.
Actions taken-by the Superintendent, Site Quality Assurance since the inspection includc. reiteration of the importance of timely action in evaluation of QA open items and audit findings.
Required actiom to bring all items to a current status are being identified.
Corrective Action To Be Taken To Avoid Further Noncompliance:
The Supervising Engineers, Quality Assurance will pay closer attention to the number of open items to assure timely action and close out.
Recent organization changes, including the establishment of an additional Supervising Engineer, Quality Assurance will help in avoiding further noncompliance.
The Date When Full Compliance Will Be Achieved:
We expect that UE QA action on these items will be current by September 30, 1982.
(50-483/82-03-03) OPEN ITEM Approximately 25-30 surveillances per month are conducted by the UE QA staff.
These surveillances are mostly reactive; i.e.,
they are normally used to direct QA attention to matters which are identified by other means.
The licensee agreed that although much of the surveil-lance a:tivity is reactive in nature, a planned approach should be documented for the overall surveillance program.
Response
Union Electric Quality Assurance does plan surveillances and conducts them accordingly; however, the Inspector found insufficient documenta-tion of this planning effort.
Union Electric Construction and Startup Quality Assurance groups will document a planned approach for their overall surveillance program.
This action will be complete by September 1, 1982.
(50-483/82-03-04) OPEN ITEM During the audit the Inspector discussed with the licensee the following concerns regarding the trend analysis system:
Mr. C.
E.
Norelius July 21, 1982 1.
Trend analysis reports do not always indicate that past report results have been considered, or make clear whether an identified adverse trend applies to only one discipline or all disciplines.
In addition, the criteria for determining whether a trend is adverse are not clearly defined.
2.
The time required for the dispositioning of nonconformance reports and deficiency reports has been identified as an adverse trend for more than a year.
Response
1.
A clarification is necessary in regard to this item.
Each trend analysis report is processed through an on-site computer which compares the current report with previous reporting periods, lists previously identified trends, and provides a current status of these trends.
Previour.
reports are thus automatically taken into con-sideration.
It should be noted that the trend analysis program is based on identifying problem areas and breaking them down into responsible disci-plines.
We feel this mechanism provides the visibility necessary to determine which disci-pline is at fault.
We concur with the inspector's comment that we lack clearly defined criteria to determine whether or not an identified tren6 is adverse.
Union Electric will work with Daniel in establish-ing criteria for determining adverse trends.
It is expected that this will be completed by October 1, 1982.
2.
The finding is correct.
However, in reviewing this item, it has been found that discrepancies exist between the data extracted from the Trend Analysis Data Base and the data contained in the NCR/DR logs.
Taking into consideration the discrepancies noted, an adverse trend in fact may not exist.
It will be necessary to perform
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an extensive review of the Trend Analysis Data Base with respect to programming in order to determine the actual status of this item.
The review will be completed by September 1, 1982 and, if necessary, corrective action will be determined at that time.
Mr. C.
E.
Norelius July 21, 1982 (50-483/82-03-05) OPEN ITEM During interviews with RICo QC inspection personnel the following concerns and observations were elicited:
1.
RICo QC inspection personnel do not feel that they have stop work / process authority.
Subsequent discussions with UE QA representa-tives indicated that stop work authority is not formally documented within the RICo quality program.
2.
RICo QC inspectors stated that they have been instructed to perform inspections of field welds through paint for installed Category II over Category I HVAC duct work and support.
Response
1.
The absence of formally documented stop work authority for RICo QC personnel has been corrected.
A new procedure, titled " Instruction for Implementation of Stop Work Action" was approved by the RICo QA Manager on May 17, 1982.
2.
A review of II/I weld inspection by RICo has been made with the following results.
Union Electric QA advised RICo during a meeting on March 10, 1982 that shop fabrication welds for the non-safety related ductwork classed as II/I would have to be inspected as well as the field welds that fall in this same classification.
It was agreed that shop welds rec *ived at the site with paint applied could be inspected for II/I purposes without removing the paint.
All II/I field welds were required to be inspected prior to painting.
This was confirmed in a memorandum dated March 11, 1982, but the requirements were misinterpreted.
To assure there is no question regarding weld inspection for II/I ductwork, the following actions will be taken:
a.
All II/I ductwork shop welds either have been or will be inspected at the site.
This inspection is in addition to the shop weld inspection performed by the fabricator.
This site inspection of shop welds will be with welds in the as-received condition.
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Mr. C. E.
Norelius
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July 21, 1982 b.
All II/I ductwork field welds are required to be inspected prior to painting; for those inspections which were performed af ter paint-ing, an NCR/DR will be processed in accordance with normal plant procedures.
The status of all field weld inspections will be. defined by August 2, 1982.
(50-483/82-03-06) SEVERITY LEVEL IV VIOLATION During a review of Deficiency Reports generated by QC inspectors, the NRC Inspector noted that several DRs recommended training of craft personnel as corrective action.
For five of the DRs reviewed (2SD-5234-E, SD-5461E, SD-4236, SD-5502-E, and SD-4326-E), the inspec-tor found that no documented formal training had been given to the craft personnel.
The failure to take prompt corrective action to preclude repetition is an item of noncompliance contrary to the requirements of 10CFR50, Appendix B, Criteria XVI.
Response
Corrective Action Taken And The Results Achieved:
Training of craft personnel did take place, but the inspector is correct in noting that the training was not documented.
Action is being taken to assure prompt, documented training of craft personnel when required as part of the corrective action of deficiency reports.
Corrective Action To Be Taken To Avoid Further Noncompliance:
A new group is being developed within Delcon, the electrical contractor, which will provide a comprehensive program to correct this noncompliance.
An experienced, fully qualified individual will be appointed to organize the groth which will be responsible for:
1.
Craft / engineering training.
2.
Procedures review.
3.
Overview of nonconformance/ deficiency reports to assure corrective action is correctly stated.
4.
Audit / surveillance responses and implemen-tation overview.
Until the new program is developed and implemented, documented train-ing sessions will be provided by knowledgeable Delcon personnel for craft and/or engineering as the need arises.
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Mr.
C.
E. Norelius July 21, 1982 The Date When Full Compliance Will Be Achieved:
Documented training sessions should be completed by July 23, 1982.
Full compliance will be achieved by October 1, 1982, at which time the program set up under the direction of a new group leader will be fully implemented.
(50-483/82-03-07) SEVERITY LEVEL IV VIOLATION Deficiency Report 2SD-4326-E initiated on September 9, 1981 identified that, in main control panels RL001/RL002, RL005/RL006 in the control room, the field installed cables violated the minimum separation criteria.
The recommended corrective action, dated January 4,
- 1982, was to disposition the DR when the panel manufacturer would be on site.
The inspector interviewed the persons involved with the disposition and established that they did not actually look into the cabinet and determine that the problem was related to the physical routing of cables belonging to Safety Groups 1 and 4 and also non-safety related cables.
The inspector informed the licensee that in this instance the cause of the adverse condition was not determined, and that this is contrary to the requirements of 10 CFR 50, Appendix B, Criterion XVI, and is another example of the item of noncompliance identified in finding 82-03-06.
Corrective Action Taken And The Results Achieved:
The inspector's finding that the cause of the adverse condition was not determined is correct.
However, Deficiency Report 2SD-4326-E was initiated in September 1981 and the Delcon field engineer respon-sible for the main control panels at that time, and also responsible for the dispositioning of the DR, did physically examine the cabinet.
The engineer recognized'that fire barriers should have been supplied by the vendor.
The Project Electrical Engineer and the responsible engineer elected to handle the problem by arranging to have the vendor come on site to inspect and disposition the violations.
They began coordination with the vendor to arrange a date for the inspection.
In the meantime, the DR went undispositioned.
The lack of promptness in dispositioning 2SD-4326-E was primarily due to difficulties in scheduling the vendor on site.
Following the NRC Inspection, meetings were held on site (May 11, 1982 and June 9, 1982) involving Union Electric, Bechtel and Daniel per-sonnel to determine the cause of the problems and to establish corrective action.
During the first meeting it was agreed to tabulate and summarize all separation problems.
Delcon performed the tabulation and prepared their analysis of the results.
The analysis was then forwarded to Union Electric for UE/Bechtel review.
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i Mr.
C.
E.
Norelius July 21, 1982 Corrective Action To Be Taken To Avoid Further Noncompliance:
The program outlined in response to item (82-03-06) is designed to avoid further noncompliance in cable separation during field instal-lation.
The Date When Full Compliance Will Be Achieved:
The overall program designed to avoid further noncompliance will be in effect by October 1, 1982.
(50-483/82-03-08) SEVERITY LEVEL IV VIOLATION Deficiency Report 2SD-5409-E, initiated on February 4, 1982, identifies that eight safety group channel 4 cables, four belonging to the EFE system, and four belonging to the NGH system, were terminated with
" incorrect hardware, using field supplied Burndy 2-hole lugs with 1/2" bolt hardware of unknown origin."
cause of deficiency was that the incorrect hardware was intentionally installed to expedite system release.
Another deficiency report on the subject of termination, 2SD-6078-E, was initiated on April 6, 1982, identifying that cables in the Electrical Penetration Room Group 4 digital termination cabinet RJ-160A were ter-minated with the wrong type of lugs.
The terminations on the panel were initiated through Work Assignment WA-CTM-1492 dated June 23, 1981.
Terminations appeared to have progressed through April 6, 1982 without verification that the wrong type of lugs was used by the cognizant terminations engineering personnel.
The inspector noted that corrective action was not taken in a timely manner to correct the nonconforming condition, in that the correct hardware had not been procured several months after WA-CTM-1492 was initiated.
The inspector informed the licensee that this is contrary to the requirements of 10 CFR 50, Appendix B, Criterion XVI, and is an item of noncompliance.
Corrective Action Taken And The Results Achieved:
A review of the sequence of the DRs and work assignments shows that the original work which created the nonconforming condition described in the April 1982 DR was done prior to the work described in the February 1982 DR.
Consequently, work had not progressed without correc-tive action.
Specifically, deficiency report 2SD-6078-E was initiated on April 6, 1982, but the work identified as deficient was performed under WA-CTM-1492, issued on June 23, 1981 and completed on September 14, 1981.
l Mr. C.
E.
Norelius July 21, 1982 During the foregoing investigation, we discovered why incorrect size lugs had been installed.
When temporary nylon screws and washers are used for testing purposes, the instruction in QCP-304 states that the stud hole size need not be determined.
All the lugs in these panels will be inspected and the incorrect size lugs will be replaced.
QCP-304 will be revised so that the stud hole size will be inspected when temporary nylon screws and washers are used.
In addition, Delcon has issued a Work Assignment to replace the temporary hardware and has revised WP-304 to address " temporary" terminations and how they are to be handled.
These two actions will correct the deficiencies.
Corrective Action To Be Taken To Avoid Further Noncompliance:
The revisions to WP-304 and QCP-304 will avoid further noncompliance in the area of the specific deficiencies.
Additionally, the program outlined in responso to item (82-03-06) is intended to avoid deficien-cies similar to those described in DRs 2SD-5409-E and 2SD-6078-E.
The Date When Full Compliance Will Be Achieved:
OCP-304 will become effective by July 23, 1982.
The overall program designed to avoid further noncompliance in this area will be in effect by October 1, 1982.
Very truly yours, Donald F.
Schnell RHR/FDF/jds cc:
Mr.
J.
E.
Konklin, NRC Region III NRC Resident Inspector, Callaway Plant Missouri Public Service Commission 1