ML19350D295

Responds to NRC 810223 Ltr Re Violations Noted in IE Insp Rept 50-483/81-02.Corrective Actions:Procedure Revision Initiated to Incorporate Cable Repair Procedure & Debris & Const Matl Removed from All Installed Cable Trays

ML19350D295
Person / Time
Site:	Callaway
Issue date:	03/25/1981
From:	Bryan J UNION ELECTRIC CO.
To:	Fiorelli G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19350D293	List: ML19350D295
References
ULNRC-428, NUDOCS 8104150161
Download: ML19350D295 (4)

Text

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UNION ELECTRIC COMPANY 1901 GRATIOT STREET sT. Louis, Mr..ouni JOHN 80 .RVAN p go g g v........., March 25, 1981 .v. . u... u . . . v . , . . . . .

Mr. Gaston Fiorelli, Chief Reactor Construction & Engineering Support Branch US Nuclear Regulatory. Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 ULNRC- 428

Dear Mr. Fiorelli:

INSPECTION' REPORT NO. 50-483/81-02 This is in response to you'r letter of February 23, 1981 reporting results of an inspection at Union Electric Company's Callaway Plant Site on January 5-30, 1981 and as detailed in inspection report number 50-483/81-02.

None of the material in the inspection report or in this response is considered proprietary by Union Electric Company.

The following is in response to the items in Appendix A, Notice of Violation, of the inspection report.

Severity Level VI Violation (483/81-02-02) 10 CFR 50, Appendix B, Criterion V and SNUPPS PSAR paragraph 17.1.5 states: " Activities affecting quality shall be prescribed by documented instructions.................and shall be accomplished in accordance with these

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instructions."

Contrary to the above: (1) There is no procedure for the repair of damaged electrical cable jackets (instructions are contained on drawings only). (2) Daniel International Work Procedures requiring that installed cables be kept free of construction materials and other debrie were not followed.

Response

Item (1):

i CORRECTIVE ACTION TAKEN AND THE RESULTS ACHIEVED:

A procedure revision te vip-303 " Installation of Wire and Cable" has been initiated to incorporate a cable ret; air procedure and proper -

control and documcc.cetion methods.

8 I e4 2 30 ldi MAR 2 71981

e Mr. Gaston Fiorelli March 25, 1981 CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER NONCOMPLIANCE:

Daniel Engineering and Quality Control will coordinate the revision of QCP-303 " Inspection of Cable Pulling" to align with the revision to WP-303. Issue and implementation of WP-303 and OCP-303 is designed to avoid further non-compliance.

THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

Daniel will be in full compliance by April 30, 1981 with the issue of the revision to WP-303 and QCP-303.

Item (2):

CORRECTIVE ACTION TAKEN AND THE RESULTS ACHIEVED:

Daniel Construction performed an inspection of all installed cable tray and removed any debris or construction material found, leaving the installed cable tray in an acceptable condition.

The Construction Manager issued CM-1297 to all personnel on January 14, 1981, directing thbm to adhere to project and procedural requirements in the area of cable tray cleanliness and protection.

This letter was issued as a follow-up to DES-120 which was issued on May 9, 1980 to all Electrical Superintendents, General Foremen and Foremen.

Appropriate craft personnel have been informed of the importance of meeting cleanliness requirements.

The foremen have been monitoring the installed cable tray and when necessary remind their crews of the requirements.- Field action to control this

problem has proved beneficial as indicated by a i recent surveillance.

CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER l NONCOMPLIANCE:

Daniel considers this to be a problem which can be-

! controlled only by impressing on all involved personnel the importance of compliance to the requirements of protection of installed cable. The Construction Manager will periodically issue a l reminder letter (if warranted) instructing and directing craft personnel in this area.

l l

Mr. Gaston Fiorelli March 25, 1981 In addition, a training film is being developed by Quality Control with the assistance of the General Electrical Superintendent and the Project Discipline Electrical Engineer. The film will cover quality related activities involving electrical installation. It is our intention to develop a keener awareness on the part of foremen and the film will illustrate the foreman's responsibility in this area. Appropriate Fore-men (responsible for each of the crafts involved in areas where electrical installations are made) will view the training film.

If a particular crew or an individual member of any crew is found to be negligent in carrying out project requirements, the crew or member of the crew will be scheduled into a training session which will include viewing the film. This problem will also be discussed periodically (as warranted) in the weekly Superintendent's meeting.

THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

Full compliance will be achieved by June 15, 1981, following development of film and subsequent viewing by appropriate Foremen.

If you have any question regarding this recponse or if additional information is required, please let me know.

V(yf? truly yours, f(

bblJ E

n K.

.S rya l DAO/jds cc: Mr. J. Konklin, NRC Region III Mr. W. A. Hansen, NRC Resident Inspector, Callaway Plant Missouri Public Service Commission

STATE OF MISSOURI )

) SS CITY OF ST. LOUIS )

John K. Bryan, of lawful age, being first duly sworn upon oath says that he is Vice President-Nuclear and an officer of Union Electric Company; that he has read the foregoing document and knows the content thereof; that he has executed the same for and on behalf of said company with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.

I By Y$f$

.{oh~n'K.'Bfyan [

QA i

v:.ce President \

W2 clear SUBSCRIBED and sworn to before me this 25th day of March, 1981 h

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• t h o _ ' 1: >_ _ _ lW h f w PATRICIA ANN Oogggs NOTARY FUELO STATE op MISSOURI MY CO".::.;,ss;0N GPIRES gg ST. LOUIS COUNTY P

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