ML19318C956
| ML19318C956 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 05/22/1980 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19318C952 | List: |
| References | |
| 50-482-80-08, 50-482-80-8, NUDOCS 8007070087 | |
| Download: ML19318C956 (1) | |
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Docket No. STN 50-482/80-08 Appendix A NOTICE OF DEVIATION Based on the results of the NRC inspection conducted on April 7-11 and 28-29, 1980, it appears that certain of your activities deviate from commitments made in your Final Safety Analysis Report (FSAR) as indicated below:
Failure to Designate Cable Tray For Use in Class IE And II/I as Safety-Related FSAR, Section 8.1.4.3 commits to IEEE 366, 1971 and also commits all electrical equipment associated with the Class IE electrical system to the Quality Assurance Requirements in Chapter 17 of the FSAR.
IEEE Standard 336, 1971 identifies cable raceways in the scope of the standard and invokes ANSI N45.2-1971 requirements for activities within that scope.
10 CFR 21.3 requires the " dedication" of a " commercial grade item" after receipt when that item is designated for use as a basic component.
Contrary to the above:
Cable tray for Wolf Creek is purchased via nonsafety-related Bechtel Specification 10466-E-034 as an off the shelf or " commercial grade item" as defined in 10 CFR 21.
The IE inspector was informed by Bechtel per-sonnel on site and in Gaithersburg that the cable tray had been qualified for its intended use in the seismic supported raceway system of IE cables and, therefore, did not require the designation of "Q" or safety-related material.
This was further substantiated to the IE inspector when he reviewed a letter to the Executive Director, SNUPPS from the Project Engineering Manager, Bechtel dated August 20, 1979, subject IE Information Notice 79-14, relating to 10 CFR 50, Appendix B requirements for cable tray.
Qualification testing substantiates the functional use of " commercial grade item" in a safety-related application.
The testing qualifies the material as safety-related quality; it does not preclude the designation as safety-related.
The failure to designate the material as safety-related exempts it from QC and QA requirements and from the generic reportability requirements of 10 CFR 21 and 10 CFR 50.55(e).
This is a deviation from FSAR coruitments and has generic implications i
at all SNUPPS sites.
8007070
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