ML19337A878
| ML19337A878 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 08/28/1980 |
| From: | Koester G KANSAS GAS & ELECTRIC CO. |
| To: | Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML19337A876 | List: |
| References | |
| KMLNRC-025, KMLNRC-25, NUDOCS 8009300612 | |
| Download: ML19337A878 (3) | |
Text
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MANSAS GAS AND ELECTRIC COMPANY
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August 28, 1980 Mr W C Seidle, Chief Reactor Construction and Engineering Support Branch US Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive Suite 1000 Arlington, TX 76011 KMLNRC-025 Re: NRC Docket No. STN 50-482/Rpt 80-15
Dear Mr. Seidle:
This letter is written in response to your letter of July 28, 1980, which transmitted Inspection Report 50-482/80-15.
As requested the finding is being addressed in three parts:
a)
Corrective steps which have been taken and the results achieved; b)
Corrective steps which have been taken to avoid further non-compliance; and c)
The date when full compliance will be achieved.
Finding A review of the following Daniel procedures for installation and inspection of cable raceway and raceway supports revealed that these procedures do not appro-priately address the activities associated with II/I supports and raceway:
WP-X-300, Rev 5,
" Installation of Electrical Raceway" WP-X-302, Rev 3,
" Installation of Electrical Raceway Supports" QCP-X-300, Rev 4, " Installation of Electrical Raceway" Specifically:
1.
WP-X-300, paragraph 4.1.9 requires that copies of work assignments for Class IE and II/I be sent to QC.
However, the work assignment sheet (Exhibit A) does not provide provisions for the identification of II/I raceway.
The rework assignment (Exhibit D) does provide for II/I race-way identification.
r 8009300612 201 N. Market - Wictwa. Kansas - MadMoress: PO. Box 208 I Wfchita. Kansas 67201 - Teleonone: Area Coce (316) 261-6451
Mr W C Seidle KMLNR l-025 August 28, 1980
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With the exception of paragraph 4.1.9 and Exhibit D, WP-X-300 does not address II/I raceway with regard to documentation of records storage or retention.
3.
WP-X-302, paragraph 3.23 requirer QC inspection of II/I supWrts via a raceway installation card marked with the symbol II/I. Howeter, WP-X-300, paragraph 4.1.18, which requires the raceway installation card for Class IE, does not address II/I.
4.
WP-X-302, paragraph 3.12 requires that QC inspect Class IE and II/I supports, but the work assignment (Exhibit B) does not require the identification of II/I raceway supports.
The rework assignment (Exhibit D) does provide for II/I raceway support identification.
5.
QCP-X-300 does not address II/I raceway, even though there exists a requirement for QC to receive II/I raceway installation cards, and II/I work assignments for notification of final or in-process inspection requirements of WP-X-300 and WP-X-302.
i J
Tne above are examples of failure to provide appropriate procedures for 5
activities affecting quality as required by Appendix B, 10 CFR 50.
j
Response
1.
The three procedures identified above will be revised to more appropriately control installation and inspection of II/I supports and raceway.
Speci-fically, these procedures will be revised to include the following:
j a)
All cable tray received on site (after 9/1/80) will be inspected at receipt to confirm that the material received is the correct size, type and configuration as set out on the purchase order.
This inspection will be documented and the items will be appro-priately marked (such as painted stripe) to identify acceptable material.
This material will be designated "Q" but may be in-stalled in any location regardless of safety classification.
Any nonconforming material iden"ified during this inspection will be processed in accordance with the existing procedures for the control of nonconforming materials / items.
b)
For cable tray already on site, but not installed, the above inspection and marking will be completed prior to installation or use.
c) ~ "Q" raceway that is installed is currently required to be inspected 4
for correct size and type of material prior to installation of cable.
This requirement will be extended to include II/I raceway.
If II/I trays already contain cable, no additional cable will be pulled until the inspection is completed.
Installation inspection of raceway designated "Q" or II/I will be completed prior to
' installation of cable.
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- Mr W C Seidle KMIERC-025 August 28, 1980 l
d)
Procedure WP-X-300 and QCP-X-300 will be revised so that the work assignment sheet will identify to craft engineering and QC personnel both the "Q" and II/I items.
Both "Q" and II/I items will be treated in the same manner with regard to inspection, documentation, records and control of nonconforming items or activities.
I e)
A revision to WP-X-300 or QCP-X-300 will be made to clarify that records of both "Q" and II/I activities will be processed and retained in accordance with the established program for QA records.
f)
Procedure WP-X-300 will be revised to address II/I items.
g)
Procedure WP-X-302 will be revised to include II/I raceway supports on the work assignment card.
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2.
The revisions and clarifications to procedures WP-X-300, WP-X-302 and
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QCP-X-300 as indicated above should avoid further noncompliance.
3.
The indicated procedure changes and training / indoctrination of craft and QC personnel should be complete by November 1,1980.
l Please advise if you need additional information.
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l Yours very truly, th h
GLK:cks cc T Vandel (NRC Site Insp.)
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