ML20235U313
| ML20235U313 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 07/13/1987 |
| From: | Capone D UNION ELECTRIC CO. |
| To: | Gardner R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| RTR-NUREG-CR-3691 GL-86-15, ULNRC-1550, NUDOCS 8710140033 | |
| Download: ML20235U313 (3) | |
Text
>
r
' UNION
. Etscriac d
1901 Gratiot Street. St. Louis gu1y 13, 1987 Mr. Ronald N. Gardner Section Chief, Reactor Safety Division U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137
Dear Mr. Gardner:
ULNRC-1550 DOCKET NUMBER 50-483 l
CALLAWAY PLANT i
ENVIRONMENTAL QUALIFICATION INSPECTION CLOSEOUT 3
References:
- 1) ULNRC-1540 dated June 29, 1987
- 2) SLNRC 84-002 dated February 2, 1984
- 3) Callaway SER Supplement 3, Section 3.11.4.2(4) 1 (NUREG-0830, Supplement 3, May, 1984)
{
This letter is provided in response to a request from NRC Region III (telephone conversation July 8, 1987 between Mr.
R. N. Gardner (NRC) and Messrs.
G.
L.
- Randolph, A.~C.
Passwater, and D. Shafer (UE)).
In that conversation, NRC (Mr. R. N. Gard-ner) requested that Union Electric Company provide a justifica-tion for continued operation for the Callaway Plant while the NRC is reviewing information provided in Reference 1 on Kulka terminal block qualification.
It should be noted that terminal blocks in instrumentation circuits inside containment were spliced around prior to Callaway fuel load as' discussed in References 2 and 3.
The current issue deals with only Kulka I
terminal blocks used inside containment in power and control
]
applications.
It is Union Electric's position that the reference letter provided to the NRC on June.29, 1987, demonstrates an adequate basis to establish the qualification of Kulka terminal blocks.
Also, in accordance with Generic Letter 86-15, since we are able to make a finding of operability and have provided to-the NRC a report that demonstrates reasonable assurance that the terminal blocks will perform their safety function when called upon to mitigate the accidents for which they are designed,<we have determined that these findings are not reportable under'10 CFR 50.72, 50.73, Part 21, the Technical Specifications or any.
i other pertinent reporting requirements. to Reference 1 discusses the partial type. test data from Conax and states that analysis based on NUREG/CR-3691-8710140033 870713 PDR ADOCK 05000483 G
PM 1
o GUL16 1987 i
Maihng Addrest P.O. Box 149, St. Louis, MO 63166 L
ypf
and EPRI Reports NP-1558 and NP-4172SP, has been used to address the effects of aging and irradiation on Kulka terminal blocks.
Since Callaway is a recent vintage plant, having become fully operational in December, 1984, the Kulka terminal blocks currently installed have experienced minimal aging.
Accordingly, Conax Report IPS-675, in conjunction with the relatively short duration of service in an operating environment, sufficiently justifies their continued use.
Furthermore, to avoid the' possibility of any precipitous action involving change out or splicing around these terminal blocks, we believe the facts presented to support our position justify their continued use at least until Refuel 3, scheduled for the Spring of 1989.
Terminal bl acks made of materials with lower activation energies than tSe material used in these Kulka terminal blocks have been qualified throughout the industry and have qualified lives of 40 years.
Kulka terminal blocks in use at Callaway, even with service extended until Refuel 3, closely approximate unaged blocks.
As such, the Conax report provides assurance that the blocks will perform their intended safety function and Callaway can be operated with no adverse impact on public health or safety.
Again it should be made clear that Union Electric's conclusion reached in the reference documents is that adequate basis for the qualification of Kulka terminal blocks has been provided.
If you have any further questions in this matter, please contact us.
Very truly yours,
- bt Q
Donald W.
Capone Manager, Nuclear Engineering DES / tar
]
a cc:
W.
L.
Forney Chief, Reactor Project Branch /
U.S.
Nuclear Regulatory Commission Region III 799 Rosevelt Road I
Glen Ellyn, Illinois 60137 Bruce Little Callaway Resident Office U.S. Nuclear Regulatory Commission RR#1 Steedman, Missouri 65077 Tom Alexion Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 316 j
7920 Norfork Avenue j
Bethesda, MD 20014 l
l l
l l
l l
}
J