ML20062G659

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Responds to NRC Re Deviation Noted in Insp Rept 50-483/78-10.Finds No Proprietary Matl.Corrective Actions: Weld Rod Stubs Removed & Disposed of, & Personnel Instructed to Respond Promptly to Audits
ML20062G659
Person / Time
Site: Callaway 
Issue date: 12/22/1978
From: Bryan J
UNION ELECTRIC CO.
To: Heishman R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
ULNRC-302, NUDOCS 7901160119
Download: ML20062G659 (4)


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UNION ELECTRIC COMPANY

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f ool GRATIOT STREET ST. Louis, MISSOURI December 22, 1978

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Mr. R.

F. Heishman, Chief Reactor Construction & Engineering Support Branch U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road

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Glen Ellyn, IL 60137

/ s4 ULNRC-302 O,'

Dear Mr. Heishman:

INSPECTION REPORT NO. 50-483/7 -10

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This is in response to your l'etter of November 24, 1978 reporting results of an inspection at Usion-Electric Company's Callaway Plant Site on October 2-4, 1978 and as detailed in inspection report number 50-483/78-10.

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

Theresponselistedbelowcorrespondstotheitehslisted in Appendix A, Notice of Violation, of the inspection reporti-Infraction

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1. 10CFR50, Appendix B, Criterion V, requires,'in G

part, that activities affecting quality shall be accomplished in'accordance with instructions i and procedures.

4 Paragraph 17.1.5 of the SNUPPS PSAR requires that these activities shall be accomplished in accordance with the applicable instructions and procedures.

J' Paragraph 3.16 of Work Procedure number WP-503, Control of Welding Consumables, Revision 6 dated May 5, 1978, states in part that " Loose electrodes and filler wire shall not be left lying around but shall be contained in a portable container or a weld pouch."

Inter-office memorandum CM-450, dated June 9, 1977, from the Welding Superintendent to All Super-intendents and Welders on the subject of Rules

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7901160119 g4.

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Mr.

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F. Heishman

  • for Welding Control states in part " Weld rod stubs shall be put in stub containers and emptied in a trash container at the end of the shift."

Contrary to the above on October 4,1978, the RIII inspector observed a large quantity of E7018 weld rod stubs lying around in the stiffener channels that are attached to the liner plate at the fourteenth lift area of the containment exterior wall.

(483/78-10-02).

a. CORRECTIVE ACTION TAKEN AND THE RESULTS q

ACHIEVED

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The weld rod stubs identified by the NRC Inspector have been removed and properly disposed of.

Other areas of the plant are being checked to insure that all weld rod stubs have been properly disposed of.

b. CORRECTIVE ACTION TAKEN TO AVOID FURTHER NONCOMPLIANCE Interoffice Communication CM-883 has been issued to all Daniel supervision and Daniel welders instructing them of the importance of complying with this pro-cedural requirement.

Daniel letter DLSC-80-2746 has been issued to the subcontractor working in this area informing him of these requirements.

In addition, g

weld rod waste containers have been fabricated and placed in each building for disposal of weld rod stubs.

A program of monitoring compliance with weld rod control has been implemented and will continue until a level of confidence has been achieved that this problem is under control.

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c. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED March 1, 1979
2. 10CFR50, Appendix B, Criterion V, requires, in part, that activities affecting quality 1

shall be accomplished in accordance with instructions and procedures.

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Mr.

R. F. Heishman 1 I

Paragraph 17.1.5 of the SNUPPS PSAR requires that these activities shall be accomplished in accordance with the applicable instructions I

and procedures.

Paragraph 5.3.4 of UE QA Procedure number QA-106, Revision 5 requires that responses to audits, where corrective action is indicated are to be submitted within 30 days after receipt of the audit report.

contrary to the above, five of the eight i

audits reviewed by the RI inspector identi-fled that the Constructor (audited organiza-tion) did not respond within the required time.

(483/78-10-06)

a. CORRECTIVE ACTION TAKEN AND THE RESULTS I

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ACHIEVED t

Daniel personnel directly involved in audit responses-have been reminded of the requirement for making timely responses to Quality Assurance audits.

The responses to the two Union Electric l

QA Monthly Audits which were due since the NRC infraction was identified have been submitted in a timely manner.

b. CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER NONCOMPLIANCE The Daniel Project Manager has issued a directive (PM-638) to all Department Managers concerning this infraction.

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directive emphasizes the requirement for 1

making timely responses to Quality Assurance audits.

The Union Electric Site QA Group will contact Nuclear Construction and/or Daniel as appropriate when a response is not received within 30 days of submittal of the audit report.

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DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED December 26, 1978 P

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Mr. R. F. Heishman.

If you have any questions regarding this response or

, additional information is required, please let me know.

You very truly,

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John K.

ryan WSS/jds a..

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R. Schweibinz

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