ML19309B366

Responds to NRC 800207 IE Insp Repts 50-445/80-03 & 50-446/80-03.Corrective Actions:Engineering Personnel Reviewed Cable Lubrication Requirements W/Key Const Personnel Involved W/Cable Pulling

ML19309B366
Person / Time
Site:	Comanche Peak
Issue date:	03/05/1980
From:	Gary R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML19309B364	List: ML19309B366
References
TXX-3105, NUDOCS 8004040083
Download: ML19309B366 (3)

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March 5, 1980 TXX-3105 Mr. W. C. Seidle, Chief Reactor Construction and Engineering Support Branch V. S. Nuclear Regulatory Commission Office of Inspection & Enforcement 611 Ryan Plaza Dr., Suite 1000 Docket Nos. 50-445/80-03 Arlington, Texas 76012 50-446/80-03 COMANCHE PEAK STEAM ELECTRIC STATION 1981-83 2300 MW INSTALLATION RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT N0. 80-03 DOCKET N05. 50-445 & 50-446 FILE N0. 10130

Dear Mr. Seidle:

We have reviewed the report dated February 7,1980 on the inspection by your Resident Inspector, Mr. R. G. Taylor, of the activities authorized by NRC Construction Permits No. CPPR-126 and 127 for the Comanche Peak facility. We have responded to the findings listed in Appendix A of that report.

To aid in the understanding of our response, we have repeated the re-quirement and your findings followed by our corrective action.

We believe the attached information to be responsive to the Inspector's findings. If you have any questions, please advise.

Very truly yours, l R. . Gary i Attachment l RJG:df I

8004040%3 -

Inspection Report No. 80-03 TXX-3105 Page 2 APPENDIX A NOTICE OF VIOLATION Based on results of the NRC inspection conducted on February 4s 1980, it appears that certain of your activities were not conducted in full compliance with the conditions of your NRC Construction Permits No. CPPR-126 and 127 as indicated below:

Failure to Follow Procedures for Cable Pulling 10 CFR 50, Appendix B, Criterion V states in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."

Brown and Root Procedure 35-1195-EEI-7, " Cable Installation,"

Revision 2, as modified by Interim Change Notice 1, contains the following implementing requirements:

1. Paragraph 2.1 requires that cables shall be handled with care during installation and protected from abrasion or other damage due to pulling over rough surfaces or obstructions with sharp edges.

2. Paragraph 4.1.2 contains the cable manufacturer's recommenda-tion that lubricant be used when pulling cables in conduit which contain previously installed cables.

Contrary to the above:

At approximately 6:30 p.m. on February 4,1980, the Resident Reactor Inspector observed a green (safety train B), two conductor, number 12 AWG cable being pulled through conduit C13G04189 which contained several other previously installed green cables:

i 1. The installed cables were not protected from abrasion or other i

damage in that a large Hilti bolt was attached to the end of a pull rope to facilitate threae 1 the rope through the conduit and when the rope was pulled ur. through the conduit, the sharp-edged blunt end of the bolt was on the top thereby generating a condition for abrasion or other damage to the _ installed cables.

Inspection Report No. 80-03

.TXX-3105 Page 3

2. The cable was not lubricated prior to pulling it through the conduit.

This is an infraction.

Corrective Steps Which Have Been Taken and Results Achieved An evaluation was made by CPSES Electrical Engineering of all involved cables referenced by NRC Inspection Report 80-03 and identified in Non-conformance Report E-1971. These cables were pulled out of the conduit for visual inspection and tested for insulation resistance. It was determined that the integrity of the cables was not adversely affected.

Corrective Steps Which Have Been or Will Be Taken to Avoid Further Noncompliance Preventive measures include the following actions:

1. To assure adequate field supervision of cable pulling operations, the TUSI Engineering and Construction Manager instructed construc-tion personnel not to pull any cable without foreman level super-vision present during the pulling operation. This was documented by memo on February 13, 1980.

2. Engineering personnel reviewed cable lubrication requirements with key cor.struction personnel involved with (able pulling. The re-quirements of procedure 35-1195-EEI-7 shall be met.

Date of Full Compliance i

Corrective actions were initiated on February 7,1980, and completed by February 12, 1980. Preventive measures were initiated on February 13, 1980 and are now in effect.

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