ML20031D963
| ML20031D963 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 09/21/1981 |
| From: | Bryan J UNION ELECTRIC CO. |
| To: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20031D953 | List: |
| References | |
| ULNRC-510, NUDOCS 8110140411 | |
| Download: ML20031D963 (3) | |
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UNION ELECTRIC COMPANY 1909 GRATIOT STMEET 1
ST. Louis, MasseJont JOHN M. hmVAN g a g
l September 21, 1981 i
Mr C.
Norelius US nuclear Regulatory Commission
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Region III
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799 Roosevelt Road Glen Ellyn, IL 60137 ULNRC-510
Dear Mr. Norelius:
INSPECTION REPORT NO. 50-483/81-14 Ref: ULNRC-488, dated August 21, 1981 The referenced letter provided responses to two of the three violations identified in the subject inspuction report and requested that the submittal date for the response to the third violation (no. 50-483/81-14-03) be extended to September 21, 1981.
I The following is in response to violation no. 50-483/81-14-03.
None of the material in the inspection report or in this response is j
considered proprietary by Union Electric Company.
Severity Level IV Violation (50-483/81-14-03) 10 CFR 50, Appendix B, Criterion V, states in part, " Activities af fecting quality shall be prescribed by documented instructions, procedures, or drawings and shall be accomplished in accordance with these instruccions, procedures, or drawings."
The SNUPPS PSAR, Paragraph 17.1.5, states in part, "The quality assurance program established by the SNUPPS utilities reg"fres documented instructions, procedures, drawings, or checklists These activities shall be accomplished in accordance with the applicable instructions, procedures, drawings or checklists."
ANSI N45.2-1971, Paragraph 11, states in part, "If mandatory inspection hold points, which require witnessing or inspecting by the purchaser's designated representaL xa and beyond which work shall not proceed without the consent of the purchaser's designated representative....
Such consent shall be documented prior to the continua-tion of work beyond the designated hold point."
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Mr.
C.
Norelius September 21, 1981 WP-304, Revision 2, Paragraph 3.2, states,
" Hold Points, as indicated by an asterisk (*)
preceding a paragraph nu.nber indicates that the next item of work shall not be started until Electrical Quality Control has completed required inspections per Reference 2.2."
WP-304, Revision 2, Paragraph 4.1.6 which is marked with an asterisk, states in part,
" Electrical Quality Control is to be notified prior to start of testing on any safety related cables."
Contrary to the above, of the approximate 100 test records reviewed for the period between 10/3/A0 ar.d 5/20/81, only 11 test records indicated that the tests had been witnessed by Quality Control.
Consent to work beyond the designated hold point was not documented on the remaining test reports reviewed.
Responae COh.RECTIVE ACTION TAKEN AND THE RESULTS ACHIEVED:
Based on a review of project requirements pertain-ing to cable testing it has been determined that Quality control should witness all safety-related cable tests required by WP-304.
All safety-related cables tested and not witnessed by Electrical Quality Control.iill be retested with Electrical Qua]ity Control present to witness the tests.
CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER NONCOMPLIAUCE:
QCP-304, " Inspection of Cable Terminations and Testing", will be revised to indicate that all safety-related cable tests are to be witnessed by Electrical Quality Control.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
OCP-304 will be revised by October 21, 1981.
All safety-related cables previously tested and not witnessed by Quality Control will be retested by December 3, 1981.
K.
truly y urs,l' 1
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DAO/jds yLJohn K.
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cc:
Mr.
J.
E.
Konklin, NRC Region III u
NRC Resident Inspector, Callaway Plant Missouri Public Service Commission J
b STATE OF MISSOURI )
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Robert J. Schukai, of lawful age, being first duly sworn upon oath says that he is General Manager-Engineering (Nuclear) 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.
By
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Robert-J.Tschukai Gen 4r jal Mager-Engineering Nuclear SUBSCRIBED and sworn to before me this 21st day of September, 1981
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$4 l A4 BARBARA J. PFAF le0TARY PUBLN, STATE 0F FISSOURI MY CIWWIS$40N EXPfRES APR:L 22,1935 ST. LOUIS COUNTY