ML20027C179

Responds to NRC 820825 Ltr Re Violations Noted in IE Insp Rept 50-483/82-06.Corrective Actions:Review of All Completed Work Assisgnments for non-Q non-scheduled Raceway within Seismic Ii/I Boundaries in Process

ML20027C179
Person / Time
Site:	Callaway
Issue date:	09/23/1982
From:	Schnell D UNION ELECTRIC CO.
To:	Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20027C150	List: ML20027C179
References
ULNRC-583, NUDOCS 8210130555
Download: ML20027C179 (2)

Text

__

UNION ELECTRIC COMPANY se,ot onArnor svnser er. Louis. Missouri

• /f,1,*,*,","'" September 23, 1982 ,,, ,,o ....

Mr. R. L. Spessard, Director Division of Projects and Resident Programs US Nuclear Regulatory Commission Region III 799 Roocevolt Road Glen Ellyn, IL 60137 ULNRC-583

Dear Mr. Spessard:

INSPECTION REPORT NO. 50-483/82-06 This letter is in response to your letter of August 25, 1982 which transmitted the report of the 'nspection conducted during the period of July 21-31, 1982 of activities at Callaway Plant Unit 1. Our response to the item of noncompliance is presented belou.

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

(50-483/82-06-01) SEVERITY LEVEL V VIOLATION 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, states, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings...and shall be accomplished in accordance with these instructions, procedures or i drawings."

Daniel International Corporation's Procedure QCP-307, Inspection of Electrical Seismic II/I Installations, Revision 0, dated 3-12-82, section 3.1 states, "The Project Electrical Engineer shall-Ime respon-sible for ensuring that applic'able' Seismic II/I related material /

equipment is installed in accordance with...this procedure." Section L

3.2 of QCP-307 states, " Electrical Quality Control shall be responsible for inspection of Seismic II/I related materials and installations in accordance with this procedure...."

Contrary to the above, the junction box and hanger installation above i Class IE conduit 4U1029 on the 1988 ft. elevation had not been inctalled

! or inspected according to procedures governing Seismic II/I installations.

l t

l 8210130555 821005

! PDR ADOCK 05000483 0 PDR I SEP 2 7 E02 L

.4 s, <

, Mr. R. L.,Spessard 2-Corrective Action Taken And The Results Achieved:

The conduit leading to the "in line~ pull box" (junction box),

originates in the Turbine Building (a non-seismic area), goes through the Auxiliary Building, Area'5 (a seismic area) and then to the condensate Storage Water Tank (a non-seismic area). Work assign-ment WA-LGX-4003 was written in error as it did not specify II/I requirements and was therefore not forwarded to Quality Inspection to perform the required inspection. The work was. performed per C-0600 series drawings, and thus all work was completed to II/I

~. details and signed off by Engineering.

Work Assignment WA-LGX-4003 has been superseded by WA-LGX-1501 to

~

provide Quality Inspection of the portion of conduit routing which is designated as II/I. This action will bring the' documentation into compliance and assure supports are in compliance with.II/I criteria.

Work Assignment WA-LGX-1501 was forwarded to Quality Inspection on August 17, 1982, for processing.

The problem identified by the Inspector was a case where the Work Assignment was mistakenly written for a non-seismic designated area, though a portion of the conduit would route through ~a seismic area.

Daniel has completed a review of t!.e drawings to assure the same problem does not exist in other areas. The review identified one other instance, specifically, Work Assignment WA-CMX-4002, which has been superseded by Work Assignment WA-CMX-1501 to impose II/I require-ments. No other deficiencies were identified. These two cases are considered isolated instances.

Corrective Action To Be Taken To Avoid Further Noncompliance:

A review of all completed Work Assignments for Non-Q Non-scheduled raceway within Seismic II/I boundaries is in process to assure identi-fication and compliance with II/I requirements.

The Date When Full Compliance Will Be Achieved:

Full compliance will be achieved upon completion of Work Assignments WA-LGX-1501 and WA-CMX-1501 and when the review of Non-Q Non-scheduled raceway is completed. The expected completion date is December 10, 1982.

If you have any questions regarding this response or if additional

.information is required, please let me know.

Very truly yours, id )

WSS/jds Donald F. Schnell cc: Mr. H. M. Wescott, NRC Region III NRC Resident Inspector, Callaway Plant

. Missouri Public Service Commission t