ML19345C427

Responds to NRC 800426 Ltr Re Violations Noted in IE Insp Rept 50-483/80-07.Corrective Actions:Class IE Cable Tray Sys Has Been Designed & Installed.Use of Commercial Grade Tray Sys Incorporated

ML19345C427
Person / Time
Site:	Callaway
Issue date:	11/05/1980
From:	Bryan J UNION ELECTRIC CO.
To:	Fiorelli G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19345C425	List: ML19345C427
References
ULNRC-396, NUDOCS 8012040672
Download: ML19345C427 (2)

Text

-.

Y UNION ELECTRIC COMPANY

,g 190% GR ATaoT STREET ST. Louis. Mtssount MAtWNO ADDRESSI sown x.anvAN p.o.monime

. -..... - November 5, 1980 "'*"*"'""a'"'"

Mr. Gaston Fiorelli,-Chief Reactor Construction and Engineering Support Branch U. S. Nuclear 'egulatory R Commission Region III-799 Roosevelt Road Glen Ellyn, IL 60137 ULNRC- 396

Dear Mr. Ficrelli:

l-INSPECTION REPORT NO. 50-483/80-07 n'f: ULNRC-355,-5/28/80 This is a supplemental response to your letter of April 26, 1980 reporting results of an inspection at Union Electric Company's Callaway Plant Site on March 11-14, 1980 as detailed in Inspection Report No. 50-483/80-07. Our initial response, provided in the reference, advised that there were some outstanding questions and that.a supplemental response would be provided at such time that answers could be obtained. For your convenience the Notice of Violation contained in Appendix A to your April 26 letter i- repeated below in this supplemental responce. None of the material'in this response is considered proprietary by. Union Electric Company.

Infraction (483/80-07-01) 10 CFR 50, Appendix B, Criterion IX states in part, that, " Measures.shall be established to assure that special processes, including welding,...are controlled and accomplis,hed by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications,..."SNUPPS PSAR, paragraph 17.1.9 states, in part, that "The SNUPPS utilities require that special processes be controlled. Special processes will be i

accomplished under specified and controlled conditions by~ qualified personnel using qualified procedures and equipment in accordance with applicable codes, standards, specifications, criteria or other special requirements."

i

! Contrary to the above, measures were not established to control welding in that, there was no welding procedure specification or qualification of the as welded / brazed condition for the cable tray fittings, .i.e. T's, EL's, etc.

8012040ft,y WV12 e

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Mr. Gaston Fiorelli o 'U. S. Nuclear: Regulatory Commission LPage'Two' 1

RESPONSE

Class lE cable tray systems for the Callaway Plant have

been designed and installed under 10CFRSO Appendix B QA Programs, and incorporate the'use of commercial

-grade tray components. The use of commercial grade tray components was justified by the Bechtel Power Corporation Cable _ Tray and Conduit Raceway Seismic

Test Program, results of which have been presented-to the NRC.._ Since cable tray was procured to commercial grade standards under a "non Q" specification all of the measures cited in the infraction were not imposed on the-manufacturer.

Based upon the foregoing, it is the position of Union Electric Company that the Class lE cable tray systems installed at Callaway are in compliance with licensing commitments and are adequate to protect the health and safety of the public.

Very truly yours, f

h\ AA 8A John K. Bryan (

i RPN/sla l cc: H. M. Wescott, NRC Region III  ;

W. A. Hansen, NRC Resident Inspector '

Missouri Public Service Commission h I b

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