ML19344F532

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Responds to NRC 800523 Ltr Re Deviation Noted in IE Insp Rept 50-482/80-08.Corrective Actions:Raceway Seismic Test Program Conducted by Ae Confirmed Structural Adequacy of Commercial Grade Cable Trays
ML19344F532
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 06/24/1980
From: Koester G
KANSAS GAS & ELECTRIC CO.
To: Seyfrit K
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML19344F496 List:
References
KMLNRC-004, KMLNRC-4, NUDOCS 8009150381
Download: ML19344F532 (2)


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KANM QAS AND ELECTMX COMANY GLEPeN L. nO ESTER vact petsigtset.optsattoses June 24, 1980 ,

Mr. W.C. Seidle, Chief Reactor Construction and Engineering Support Branch U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive Suite 1000 Arlington, Texas 76012 KMLNRC-004 Ref: NRC Docket No. STN 50-482/Rpt. 80-08

Dear Mr. Seidle:

This letter is written in response to your letter of hay 23, 1980, which transmitted Inspection Report 50-482/80-08. As requested the deviation is being addressed in three parts:

a) Corrective steps which have been taken and the results ,

achieved 1 b) Corrective steps which have been taken to avoid further noncompliance 1 and c)- The date when full compliance will be achieved.

Finding 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 10CFR21. The IE Inspector was informed by Bechtel personnel 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 Diractor, SNUPPS, from the Project Engineering Manager, Bechtel, dated August 20, 1979, subject IE Information Notice 79-14, related to 10CFR50, Appendix B requirements for cable tray.

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201 N. Market - Wichita. Kansas - Mad Addrsss P.O. Bct 206 / Wichsta. Kansas 67201 - Telechone: Area cme (316) 26*-6431

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?Mr. W.C. Seidle KMLNRC-004 June 24, 1980 Qualificat! ion testizig. substantiates the functional use of " commercial grade item" in a safety-related application. - The testing qualifies the

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material'ac safety-related quality; it does not preclude the designation as safety-related. TheLfailure to designate the material as safety-related

- exempts it from QC and QA requirements and from the ' generic reportability

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requirements-of 10CFR21 and 10CFR50.55(e).

This is a' deviation from FSAR commitments and has generic implications at

-all SNUPPS. sites.

Response

a) Our review of this finding confirms that indeed we have purchased

- cable tray as commercial grade material for all locations through-out the plant' and such procurements have not been designated "Q".

However, the design and installation of the Class IE cable tray system has been~ carried out in~accordance with a QA Program. The-supports for the cable tray have been purchased and installed as ]

'"Q" items. .The Raceway Seismic Test Program conducted by our A/E has confirmed the structural adequacy of the commercial grade 4

cable trays.used at Wolf Creek.

- b)- The' existing quality control procedure for the installation of .)

electrical raceway - (QCP-X-300 Rev.4) Section 1.2 will be revised -

to clearly indicate'the definition of installation. Section 1.2-shall read " Installation'is defined to conunence when the raceway is placed in the permanent position designated by the approved drawings." From the point in time of cable tray installation in a class IE location it has been treated as class IE and has been subject to QA'and QC requirements including reporting ~of significant

' safety problems as set out under Part 21 and 10CFR50.55(e) . This has been in effect and governed by Section 3.9 of (QCP-X-300) .

c)- Procedure QCP-X-200 will be revised as indicated above by July 24, 1980..

- Please . advise if 'you need additional information. i Yours very truly, l

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