ML20050C427
| ML20050C427 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 03/25/1982 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20050C407 | List: |
| References | |
| ULNRC-549, NUDOCS 8204080492 | |
| Download: ML20050C427 (4) | |
Text
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UNION ELECTRIC COMPANY leOf ORNTIOT sTRErr ST. Louis. MissOURs
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March 25, 1982 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-54 9
Dear Mr. Norelius:
INSPECTION REPORT NO. 50-483/81-25 This is to clarify Union Electric Company's response to your letter dated 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.
None of the material in the inspection report or in the response is considered proprietary by Union Electric Company.
The content of the original response letter dated January 14, 1982 is reiterated below to clarify the intent of this document.
The following is in recponse to the item.in Appendix A, Notice of Violation, of the inspection report.
Severity Level V Violation (50-483/81-25-03) f 10 CPR 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."
The SNUPPS PSAR, paragraph 17.1.'10, states in part, "The SNUPPS utilitics' quality assurance program has established requirements for control of inspection activities affecting quality to verify conformance with documented instructions, procedures, and drawings."
MAR 2 9 MSE P204080492 820401 PDR ADOCK 050004B3 O
Mr.
C.
E.
Norelius March 25, 1982 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 C02 cables.
Original Response CORRECTIVE ACTION TAKEN AND THE RESULTS ACHIEVED:
The problem identified by the Region III inspector is limited to small cables hand-pulled through 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, investiga-tion is underway to identify those cables pulled through conduit for which pulling calculations had not been performed and pulling tensions had not been monitored.
For each cable so identified, the pulling tension and sidewall pressure will be calculated based on the length, size, and configura-tion of the associated conduit.
A comparison of the l
calculated values and the maximum allowable values l
of pulling tension and sidewall pressure will be utilized to identify cable schemes requiring rework.
j Revised Response l
CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER NONCOMPLIANCE:
WP-303 is being revised to require a closer evaluation of tension calculations and tension l
monitoring for cables which can only be subjected I
to low tension values.
The cable codes affected are J1P, J1T, J1Q, J2P, C02, C03, X11 and X58.
I WP-303 is being revised to require that calculations be made and tension monitored for the cables previously mentioned when 3 or less of these cables are " exclusively" routed through a conduit unless the anticipated tension required to complete the pull is considered negligible.
In the instances where the anticipated tension is considered negligible, the justification for not performing i
l
T Mr. C.
E.
Norelius March 25, 1982 tension monitoring will be documented on a
" Cable Pulling Calculation Sheet attached to the " Cable Pull Record".
The justification will include the " maximum allowable tension" for a cable and/or group of cables in comparison to the anticipated tension required to complete the pull.
There are numerous situations where there may be one or more of these 8 cable codes included in a conduit with other types of cables which can be subjected to higher tension valves.
Calculations and tension monitoring are not performed or documented, in these instances, unless deemed necessary by engineering based on their evaluation of the cable pull from the " pull walkdown" or if other guidelines in WP-303 are not met.
DATE WIIEN FULL COMPLIANCE WILL BE ACIIIEVED:
The evaluation into previously pulled cables was completed as of January 21, 1982.
The required rework as a result of the investigation was completad as of January 29, 1982.
The revision to WP-303 will be issued by March 24, 1982.
Calculations are currently performed and tension monitored as described above.
If you have any question regarding this response or if additional information is required, please let me know.
Very truly yours, Donald F.
Schnell RMD/jds cc:
Mr.
J.
E.
Konklin, NRC Region III NRC Resident Inspector, Callawa_y Plant Missouri Public Service Commission
4 STATE OF MISSOURI )
)
Donald F.
Schnell, 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 han 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 /
Donald F.
Schnell Vice President Nuclear SUBSCRIBED and sworn to before me this 25th day of March
, 1982 l"
g BAREARA J. PfAFF NOTARY PUBLIC, STATE OF MISSOURI MY GOMMISSION EXP! ret Ar di. 22,1983 ST. LOUIS COUNTY i
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