ML20062F694
| ML20062F694 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 11/28/1978 |
| From: | Bryan J UNION ELECTRIC CO. |
| To: | Heishman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 7812200237 | |
| Download: ML20062F694 (4) | |
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UNION ELECTRIC COMPANY 1900 GRATIOT STRErr Sr. Louis. MissOURS M AeWNG ADDRE.h JOHN K.
8tvAM P. O..O n 94.
Noyember 28, 1978
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Mr. R.
F.
Heishman, Chief Reactor Construction & Engineering Support Branch n
U.S. Nuclear Regulatory Commission Region III
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799 Roosevelt Road
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I Glen Ellyn, IL 60137 ULNRC-295 '
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Dear Mr. Heishman:
a 1;
INSPECTION REPORT NO. 50-483/78-08
)
This is in response to your letter of October 27, 1978 reporting results of an inspection at Union Electric Company's Callaway Plant Site on July 24-27 and August 10 and 11, 1978 and as detailed in inspection report number 50-483/78-08.
None of the material-in the. inspection report or in this response are considered proprietary by-Union Electric Company ~.
The response listed below corresponds to the items listed' in Appendix 3G Notice of Violation, of the-inspection repbrt;-
Deficiency 1.
10CFR50, Appendix B, Criterion V, requires, in part, that activities affecting quality shall be prescribed by docu-mented instructions, procedures and shall be accomplished in accordance with these instructions, and procedures.
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Paragraph 17.1.5 of the SNUPPS PSAR requires the prepara-tion of procedures, instructions, drawings or checklists of a type appropriate to the activity and its importance to safety.
Paragraph 4.2.2 of ANSI N45.2.12 requires that one of the members shall be appointed as the leader for each audit team.
His responsibilities include orientation of the team, coordinating the audit process, establishing the pace of the audit, assuring communications within the team and with the organization being audited, participation in the audit performance, and coordinating the preparation and issuance of reports.
t 1220023j f.'0V 0 01978
Mr. R. F. Heishman November 28, 1978 Contrary to the above, review of the audit procedure (AP-III-03 Quality Assurance Surveillance and Audit) failed to produce a requirement that a team leader be appointed for each audit team.
4 (483/78-08-04) a.
CCRRECTIVE ACTION TAKEN AND THE RESULTS ACHIEVED Since the date of the finding a team leader has been appointed for each audit which consisted of more than one auditor.
The audit reports now name
-the team leader.
This item has also been discussed within the Q.A.
Department and each.of the DIC auditors has also re-read ANSI N45.2.12.
Note:
It will remain Ehe responsibility of the Project Q.A. Manager to direct the department and review each auditor's report as it is developed.
b.
CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER NONCOMPLIANCE Construction Procedure AP-III-03 is now under t
revision to include the requirement to establish a temm leader for any audit which consists of more than one auditor.
i DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED c.
Construction Procedure AP-III-03 will be revised to include the above requirements by January 31, 1979.
2.
10CFR50, Appendix B, Criterion XVI, states, in part, that
" Condition adverse to quality.
.are properly identified and corrected."
Paragraph 17.1.16 of the SNUPPS PSAR states in part, " Conditions adverse to quality are properly identified, reported, corrected and that the corrective action is appropriate and effective."
Paragraph 2.2 of ANSI N45.2.6 which is endorsed by Regulatory Guide 1.58 states in part, "Each person who verifies con-formance of work activities to quality requirements shall be certified by his employer as being qualified to perform his assigned work."
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'Mr. R. F. Heishman November 28, 1978 i
r Contrary to the above, the July audit report No. 77-07-01 dated August 3, 1977 found that the containment liner I
subcontractors project welding supervisors who were i
engaged in visual examination of welds were not certified as required by ANSI N45.2.6.
Closecut of this item was j
not prompt and not appropriate.
Closecut of this action was in June of 1978 and was based on the conclusion that j
certification of personnel who performed visual examination of welds was not required.
j Comment 1
The above mentioned audit item was originated by Daniel in Quality Assurance Report 77-07-01.
The item was i
-concerned with the. certificates of the subcontractor's i
welding supervisors which did not conform to the require-
-l ments of ANSI N45.2.6 - 1973, paragraph 2. 2. 4.
(Note:
the i
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item did not pertain'to the abilities of the supervisors) i; Several discussions and considerable correspondence between i
Bechtel, SNUPPS, Union Electric and Daniel took place prior to resolution of the audit finding.
In these dis-cussions it was stated by Bechtel that consideration had i
been given to the question of whether to apply'the full l
scope of ANSI'N45.2.6 to all of the subcontractor's site activities.
From this review it was concluded that the:
present specification was adequate..
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j As indicated above, the reviews and correspondence con-i cluded.that Bechtel's intent of paragraph 7.5.3 of' Specification ~10466-C151A to which the subcontractor was working should be interpreted to mean that inspectors carrying out visual welding inspection are not required to have certificates conforming to ANSI N45.2.6.
l Since this was the designer's intent and interpretation of the specification which was concluded by them to be
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adequate, the response was accepted and the audit item i
j closed out.
The designer's requirements for weld examination as reconfirmed by Bechtel are:
Specification 10466-C-151A, Technical Specification for Erecting Reactor Building i
Liner Plate and Accessory Steel, Paragraph 7.5, Weld Examination, identifie: specific examinations to assure L
liner seam weld' quality and integrity.
Specifically radiographic, magnetic particle (or. liquid penetrant),
soap bubble (visual and vacuum-box test) and halogen l
leak testing examinations are imposed and are considered to be adequate for determining weld acceptability. 'The i
specification further requires that personnel performing l
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R. F. Heishman November 28, 1978 4
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these examinations be qualified in accordance with SNT-TC-1A for the specific technique and method used.
SNT-TC-1A qualification requirements for each specific NDE technique indicated above include provisions for visual examination which are reflected in applicable personnel certifications.
Other examinations, including visual inspections, are carried out in accordance with the subcontractor's approved QA program.
Certifications i
for these other examinations and inspections have not been specified by the designer because these measures are over and above the requirements deemed necessary to I
assure acceptable weld quality.
As explained to the inspector, the initial audit item
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was subject to intensive evaluation by Bechtel, SNUPPS, Union Electric and Daniel. The delay in close out was not due to inattention on the part of the concerned parties.
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a.
CORRECTIVE ACTION TAKEN AND THE RESULTS ACHIEVED We believe that the audit item was responsibly closed out and that additional corrective action would neither contribute to the integrity of the reactor building liner plate nor improve the quality of the inspection effort.
b.
CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER NONCOMPLIANCE t
Not applicable for the above reason.
c.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED x
Not applicable for the above reasons.
If you have any questions regarding this response or additional informatio.4 is required, please let me know.
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t V,er b uly yours, I-
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[ John K. Bryan (
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