ML20031A726
| ML20031A726 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 08/21/1981 |
| From: | Bryan J UNION ELECTRIC CO. |
| To: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20031A723 | List: |
| References | |
| ULNRC-488, NUDOCS 8109250320 | |
| Download: ML20031A726 (6) | |
Text
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UNION ELECTRIC COMPANY 1901 GRATIOT STREET sT. Louis Missouri JOHN K.
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August 21, 1981
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Mr.
C.
E.
Norelius, Acting Directc!
Divis;.on of Engineering urd Technical Inspection US Nuclear Regulatcry Commission
.agion III 7t 1 Roosevelt Road Glt 7 Ellyn, IL 60137 ULNRC-488
Dear Mr. Norelius:
INSPECTION REPORT NO. 50-483/81-14 This is in response to your letter of July 23, 1981 report-ing results of an inspection at Union Electric Company's Callaway Plant Site on June 16-19, 1981 and as detailed in inspection report number 50-483/81-14.
None of the material in the inspection report or in this response is considered proprietary by Union Electric Company.
Because additional time is required to prepare our response to Violation No. 3 (50-483/81-14-03), we request that the submittal date for this item be extended to September 21, 1981.
The following is in response to the remaining items in Appendix A, Notice of Viola-tion, of the inspection report.
Severity Level V Violation (50-483/81-14-01) 10 CFR 50, Appendix B, Criterion XVI, states in part, " Measures shall be established to assure that conditions adverse to quality such as deviations and nonconformances are promptly identified and corrected."
The StTUPPS PSAR, Paragraph 17.1.16, states in part, "The SNUPPS utilities have established a corrective action program which deter: nines and assures that conditions adverse to quality are promptly identified, reported, corrected and that the corrective action is appropriate and effective."
Contrary to the above, as of June 17, 1981, the licensee's electrical contractor or licensee's test group, as applicable, failed to identify wire No. 1NK21-1, in Battery Charger Panel No.
2NK21/341, which was improperly-terminated in Ohh83
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Mr.
C.
E.
Norelius August 21, 1981 that only the edge of the lug was placed under the terminal screw head.
Response
CO?iECCIVE ACTION TAKEN AND THE RESULTS ACHIEVED:
Wire No. lNK21-1 in Battery Charger No. 2NK21/341 was properly terminated on Terminal Block No. 5, Terminal 8 under the direct supervision of the system Startup Engineer.
CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER NONCOMPLIANCE:
a.
Review and evalun:e the Cable Termination and Jumper Records associated with Battery Charger No. 2NK21/341.
b.
Review the Temporary Alteration Contro: Log and Instructions to determine if a temporary alter 4 tion was authorized or the instruction requires clarification.
c.
Require the Supervisor, Component Testing to submit a report detailing the conditions and circumstances associated with this item.
d.
Schedule training on the requirements of Union Electric's Temporary Alteration Control Program and Responsibilities of the Startup Test Technician regarcing the restoration of wiring to its "as found" condition.
e.
Re. wise the Nuclear Construction Administrative Iristructions to rer'. ire a closecut inspection by the Startup Test Technician, upon completion of any testing activity which required modifica-tion of the tested equipment to encure that j
the c:quipmant is restored to the "as built" condition.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
a.
Cable Termination and Jumper Records for Work Assignment Numbers WA-CJM-009 and WA-CJM-009A were reviewed with the conclusion that termina-tion of Wire No. 1NK21-1 in Battery Charger Panel No. 2NK21/341 were conducted, inspected and documented in accordance with established approved procedures prior to release for test.
This action was completed on June 25, 1981.
Mr.
C.
E.
Norelius August 21, 1981 b.
The Temporary Alteration Control Pro cam s
was evaluated by review of Nuclear Con-struction Administrative Instruction No. 11, Temporary Alteration Control, with the con-clusion that the existing program is adequr.9 to provide the Startup Test Technicians with direction regarding the controls imposed on alterations.
This action was completed on July 3, 1981.
c.
The Supervisor, Component resting investigated the conditions contributing to this item and submitted the required report on July 6, 1981.
A review of these activities has resulted in the conclusion that a Startup Test Technician had left the jumper termination in the condition found by the NRC Intpector with the assumption that testing was not complete and would be corrected when final scheme testing of the Alarm /
Annuciator circuit was completed.
This improperly terminated connection should have been controlled by the Temporary Alteration Program as required by Nuclear Construction Administrative Instructions.
The technician failed to comply with these instruc-tions. Further evaluation indicated that this condition would have been identified and corrected during final scheme testing.
d.
The required training was completed on July 23, 1981.
e.
The revision to Nuclear Construction Administra-tive Procedure (flCAI-16 ) will be issu.ed by September 15, 1981.
Test technicians have been directed to comply with this requirement in the l
interim.
Severity Level V Violation (50-483/81-14-04) 10 CFR 50, Appendix B, Criterion X, states in part "A program for inspection of activities affecting quality shall be established and executed to l
verify conformance with the documa.e5 instructions, procedures, and drawings for accomplishing the activity.
Examinations, measurements, or teste of material or products processed shall be performed for each work l
operation where necesaary to assure quality."
Mr.
C.
E. Norelius August 21, 1981 The SNUPPS PSAR, Paragraph 17.1.10, states in part, *The SNUPPS utilities quality assurance program has established requirements for control of inspection activities affecting quality to certify conformance with documented instructions, procedures, and drawings."
IEEE Std. 384-1974, Paragraph 5.1.2, states in part, " Exposed Class lE raceway shall be marked in a distinct permanent manner at intervals not to exceed 15 feet and at points of entry to and exiting from enclosed areas.
Class lE raceways shall be marked prior to the installation of their cables."
Daniel's procedure number WP303, Revision 5, Paragraph 3.31, states in part, " Raceways may have cables installed in them even though they have not been com-pleted.
Incomplete raceways, as a minimum, muct be marked and properly supported."
Contrary to the above, as of June 19, 1981, there was o documented evidence that cable trays 1C8K54 and 1J1K27 were inspected for seismic requirements (i.e. location and support), for marklig per IEEE-384 requirements, or for proper size per tne de2ign documents prior to the installation of their cablea.
Response
CORRECTIVE ACTION TAKEN AND THE RESULTS ACHIEVED:
STOP/ START Work Order #39 was issued on June 19, 1981 which stopped the installation of Class lE cable through raceway that had not been inspected and accepted by Quality Control.
Upon further discussion and investigation, it was determined that an assess-ment by engineering prior to cable pulling was sufficient provided the raceway was permanently identi-fied.
This was discussed with Mr.
R.
Love on July 2, 1981 and he indicated that an engineering evaluation of the structural adequacy of the raceway systen and.
a QC inspection for burrs, sharp edges, cleanliness, and marking prior to the pull are acceptable provided DIC procedurcs are clarified to address the requirements for the engineering evaluation and the inspection ' for -
the marking of tray.
L
'Mr C.
E.
Norelius August 21, 1981 CORRECTIVE AyTION TO BE TAKEN TO AVOID FURTHER NONCOMPLIANCE:
WP-303 and QCP-303 have been revised to address j
and clarify the criteria for installing cable in raceway prior to Quality Control inspection of the completed raceway.
THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
1 QCP-303, Revision 6, became effective June 22, 7.981; WP-303, Revision 7,became effective July 10, 1981.
Stop Work Order #39 was lifted on July 11, 1981, at which time Daniel was in full compliance.
t If you have any question regarding this response or if additional information is required, please let me know.
i ry truly yours, f W[^'
John K. Bryan DAO/jds i
cc:
Mr.
J.
E.
Fonklin, NRC Region III l
NRC Resider.c Insp.c+ 7r, Callaway Plant Missouri Public Service Commission l
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STATE OF MISSOURI )
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D.
W.
Capone, of lawful age, being first duly sworn upon oath says that he is Manager, Nuclear Engineering for 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.
3 i
B Mh5L D.
W. Capone Manager, Nuclear Engineering 4
5 SUBSCRIBnD and sworn to before me this 21st day of August, 1981 1
l N/
BARBARA J. PFAFF fl0TARY PUBUC, STATE OF MISSOURI MY COMMISSION EXPlRES APR!t 22,1985 ST. LOUIS COUNTY
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