ML20041B422

Responds to NRC Re Violations Noted in IE Insp Rept 50-483/81-25.Corrective actions:WP-303 Revised to Require That Calculations Be Made & Pulls Monitored for All safety-related Pulls

ML20041B422
Person / Time
Site:	Callaway
Issue date:	01/14/1982
From:	Schnell D UNION ELECTRIC CO.
To:	Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20041B416	List: IR 05000483/1981025 ML20041B422
References
ULNRC-538, NUDOCS 8202230623
Download: ML20041B422 (4)

Text

UNION ELECTRIC COMPANY 1901 GRATIOT STREET ST. Louis. MISSOURI MAlWNG ADORESS:

DONALD F. SCHNELL P.O.WOMtes vacs Poe sicaNT ST. LOUIS. MISGount 83tes Mr.

C.

E.

Norelius, Director Division of Engineering and Technical Inspection US Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 ULNRC-538

Dear Mr. Norelius:

INSPECTION REPORT NO. 50-483/81-25 This is in response to your letter of December 15, 1981 reporting results of an inspection at Union Electric Company's Callaway Plant Site on November 10-13, 1981 and as detailed in inspection report number 50-483/81-25.

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

With regard to open item number 50-483/81-25-02 concerning the applicability of IEEE-279 to the instrument sensing lines, we wish to correct your interpretation of our position.

Although the inspection report states that licensee representatives acknowledged the requirements, our intent was to acknowledge only the NRC's position.

Our position is that the instrument sensing lines are not within the scope of IEEE-279.

We are prepared to discuss this further with the Region III inspector.

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

Severity Level V Violation (50-483/81-25-03) 10 CFR 50, Appendix B, Criterion X, states in

part, "A program for inspection of activities affecting quality shall be established and executed to verify conformance with the documented instructions, procedures and drawings for accomplishing the activity.

Examinations, measurements, or tests of material or products processed shall be performed for each work operation where necessary to assure quality."

8202230623 820218 PDR ADOCK 05000483

,JAN 18 E02 G

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Mr. C.

E.

Norelius January 14, 1982 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 verify conformance with documented instructions, procedures, and drawings."

Bechtel Drawing No. E-01013 (Q), Revision 5,

" Installation, Inspection, and Testing Details for Electrical Equipment and Cable", paragraph 5.3.4, states in part that, "Neither the pulling tension nor the sidewall pressure shall exceed the maximum value in Appendix B."

Appendix B to drawing E-01013 (Q) lists the maximum pulling tension for Cable Code J1P as 32 pounds and 65 pounds for Cable Code CO2.

Contrary to the above, cable pull tensions had not been measured, nor had pulling calculations been performed to verify that the maximum allowable cable pulling tension and sidewall pressure had not been exceeded for five previously pulled J1P and CO2 cables.

Response

CORRECTIVE ACTION TAKEN AND THE RESULTS ACHIEVED:

The problem identified by the Region IIT inspector is limited to small cables hand-puller'.nrough conduit.

We have determined that in addition to cable codes J1P and CO2, the inspector's finding is applicable to cable codes C03, J1T, J1Q, J2P, X11, and X58.

For these cable types, investigation is underway to identify those cables pulled through conduit for which pulling calcula-tions had not been performed and pulling tensions had not been monitored.

For each cable so identi-fied, the pulling tension and sidewall pressure will be calculated based on the length, size, and configuration of the associated conduit.

A comparison of the calculated values and the maximum allowable values of pulling tension and sidewall pressure will be utilized to identify cable schemes requiring rework.

CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER NONCOMPLIANCE:

WP-303 has been revised to require that calculations be made and the pulls monitored for all safety-related pulls unless deemed unnecessary by electrical engineering.

It should be noted that the instances in which calculations and monitoring are not con-i sidered necessary shall be limited to short lengths i

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i Mr. C.

E.

Norelius January 14, 1982 of conduit through which the cable is actually pushed instead of pulled.

In these instances, the justification for not performing calculations and monitoring pulls will be documented on a Cable Pulling Calculation Sheet.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

The investigation into previously pulled cables should be completed by January 15, 1982.

A completion date for any required rework will be determined at that time.

For current cable pulling activities, calculations are made and pulls monitored in accordance with WP-303.

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

Very truly yours,

,)

-pun e

Donald F.

Schnell DAO/jds cc:

Mr.

J.

E.

Konklin, NRC Region III NRC Resident Inspector, Callaway Plant Missouri Public Service Commission

STATE OF MISSOURI )

)

SS CITY OF ST. LOUIS )

Donald F. Schnell, of lawful age, being first duly sworn upon oath says that he is Vice President-Nuclear and an of ficer 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 Jehalf 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 psl d

4/

Donald F.

Schnell Vice President Nuclear SUBSCRIBED and sworn to before me this 14th day of January, 1982

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CARBARA J. PFAFF NOTARf filDUC, STATE Or ft!?SCf!R!

MY COMMIS510*J CXTIRES AN.!L 22, 19.13 ST. LOUIS COUNTY