ML20086J958
| ML20086J958 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 01/10/1984 |
| From: | Edelman M CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | Little W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20086J951 | List: |
| References | |
| NUDOCS 8401260146 | |
| Download: ML20086J958 (3) | |
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> 3 P.C. Box 5000 - CLEVELAND, CElo 44101 - TELEPHONE (216) 622-9800 - lLLUMINATING BLDG. - 55 PUBLICSQUARE Serving The Best Location in the Nation MURRAY R. EDELMAN
{CE PRESloENT January 10, 1984 u,9 Mr. W. S. Little, Chief Engineering - Branch II U.S. Nuclear Regulatory Commission, Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 RE:
Perry Nuclear Power Plant Docket Nos. 50-440; 50-441 Response to I.E. Report
Dear Mr. Little:
This letter is to acknowledge receipt cf Inspection Report Number 50-440/
B3-35; 50-441/83-34 attached to your letter dated December 14, 1983. inis report identifies areas examined by Mr. N. Merriweather during his inspection conducted November 14-18, 1983; at the Perry Nuclear Pouer Plant.
Attached to this letter is our response to the one Severity Level V Violation described in the Notice of Violation dated December 14, 1983.
This response is in accordance with the provisions of Section 2.201 of the NRC's "Rttles of Practice", Part 2, Title 10, Code of Federal Regulations.
Our response has been submitted to you within thirty days of the date of the Notice of Violation as you required.
If there are additional questions, please do not hesitate to call.
Very truly yours, M. R. Edelman Vice President Nuclear Group MRE:pab Attachment cc:
Mr. M. L. Gildner USNRC, bite Mr. C. E. Norelius, Director Division of Projects and Resident Programs U.S. Nuclear Regulatory Commission, Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 U.S. Nuclear Regulatory Commission c/o Document Manage'nent Branch Washington, D.C.
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4 RESPONSE TO ENFORCEMENT ITEM Below is our response to Appendix A, Notice of Violation, of United States Nuclear Regulatory Commission I.E. Report 50-440/83-35; 50-441/83-34.
I.
Noncompliance 440/83-35-01 A.
Severity Level V Violation 10CFR50, Appendix B, Criterion V, as implemented by CEI Corporate Nuclear Quality Assurance Program Manual, Section 0500, requires that activities affecting quality be performed in accordance with documented instructions and procedures of a type appropriate to the circumstances.
L. K. Comstock (the electrical contractor) procedure 4.3.3 is the procedure used for Installing safety-related cables. This procedure requires safety-related cables to have a training radius greater than or equal to the manuf acturer's minimum recommended training radius as shown in the procedure.
Contrary to the above, on November 16, 1983, the inspector observed several safety-related cables exiting cabletray sections 1839 and 1840 which violated the mininum training radius requirements of procedure 4.3.3.
B.
Response
1.
Admission or Denial of Alleged Violation We concur with the inspector's observation that the cables identified exiting cable tray sections 1839 and 1840 did have training rad 11 in violation of the requirements of the L. K. Comstock procedure 4.3.3 (Revision 5-11-83) " Cable Pulling."
2.
Reason for Admitted Violation Improper colling resulted in the cable partially supporting the weight of the coil causing training rad 11 violations.
The cables that were temporarily coiled at the ends of tray numbers 1839 and 1840 had been draped over the tray end plates without giving adequate support to prevent the cable from supporting the coll, and caused a training radius of approximately 1.5 inches on tray 1839 and approximately 2.5 inches on tray 1840.
Training radil were violated in that they were not in accordance with the manufacturer's recommendations as dictated in procedure 4.3.3.
3.
Corrective Action Taken and Results Achieved The cables with training radius violations in trays 1839 and 1840 were docu.;nted on Nonconformance Reports P033-2424 (LKC-2668) and P033-2425 (LKC-2569) respectively. The cables are to be trained and supported to eliminate tralr.ing radius violations. A megger test is to be perfortaed and documented.
e RESPONSE TO ENFORCEMENT ITD!
PAGE 2 4.
Corrective Action Taken to Prevent Recurrence To prevent possible recurrence of training radius violations caused by the practice of draping cables over the Instrumentation tray end plates, Engineering Change Notice 10560-33-2144, Revision A, has been issued. This Engineering Change Notice makes provisions for removing blind end plates and replacing them with tray drop outs.
5.
Date of Full Compliance Actions required to close Nonconformance Reports P033-2424 and P033-2425 will be completed by January 27, 1983. Full compliance will be achieved by February 17, 1984.
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