ML19324B303
| ML19324B303 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/23/1989 |
| From: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-89738, NUDOCS 8911060017 | |
| Download: ML19324B303 (3) | |
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Log i TXX 89738
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File # 10130 IR 50 445/89 65 IR 50 446/89 65 7t# ELECTRIC Ref. # 10CFR2.201 i
$2d,Yiwar.,
October 23. 1989 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington. D. C.
20555 1
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES) 1 DOCKET NOS. 50 445 AND 50 446 I
NRC INSPECTION RLPORT NOS. 50 445/89 65: 50 446/89 C5
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REf?0NSE TO NOTICE OF VIOLATION i
Gentlement i
TV Electrit; has reviewed the NRC's letter dated September 22, 1989, concerning t
the insper, tion conducted by Mr. M. Runyan, other inspectors and NRC i
consultar.tt during the period of August 2 through September 5. 1989. This i
inspection covered activities authorized by WRC Construction Permits CPPR 126 and CPPR-127 for CPSES Units 1 and 2.
Attached to the NRC's letter was a Notice of Violation.
l TV Electric hereby raponds to the Notice of Violation in the attachment to this letter.
Si nce, rely.
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t William J. Cahill Jr DAR/smp Attachment e
Mr. R. D. Martin. Region IV l
Resident Inspectors. CPSES (3) h; 89110gh[
4 gg PDR fgof n
4(9 North Ohve Street LB St Dallas, Texa.s 73201
I Attachment to TXX 89738 Page 1 of 2 e
NOTICE OF VIOLATION (445/8965 V 01)
Criterion V of Appendix B to 10 CFR Part 50, as implemented by Section 5.0, Revision 1, of the TU Electric Quality Assurance Manual, requires that activities affecting quality shall be prescribed by and accomplished in i
accordance with documented instructions, procedures, or drawings, Specification 2323 ES 100 Revision 6 " Electrical Installation Class I, !!,
or Non Safety," Section !!!, paragraph 3.1.5.14 states, in part, that for conduit, "All fittings shall be wrench tightened (such that they cannot be loosened by hand)."
Contrary to tne above, the following concerns were identified during an NRC i
inspection of the applicant's room and area turnover activities:
a.
In room 74, conduits C14007913, 13G01422. C1 PAS 11, and C13034061 had loose fittings.
b.
In room 74, an elbow for conduit C13001413 had loose screws.
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c.
In room 74, junction boxes JB15 0169, JB15 177G, and JB15 165G had loose i
screws.
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d.
In room 74, a mounting bracket for a conduit support near CIMS S37 25 upper bracket was loose, e.
In room 74, emergency light panel CP1 ELBP SG 284 had a spring nut off the unistrut channel, i
i f.
In room 198, electrical junc. ion box TC061 had loose conduit fittings.
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In room 198, conduits C11G08147 and C11K11273 had loose fittings.
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i RESPONSE TO NOTICE OF VIOLATION
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(445/8965 V-01) i TV Electric accepts the alleged violation and the requested information i
l follows:
1.
Reason for Violation J
The violation occurred because of inattention to detail by personnel l
performing final walkdowns prior to room and area turnover.
Specifically, in some cases walkdown personnel did not physically check conduit fittings and fasteners for electrical equipment, such as conduit, boxes and panels, to ensure that they could not be loosened by hand.
As a result, various loose conduit fittings and electrical equipment f asteners were not identified or corrected during room and area walkdowns.
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s-o Attachment to TXX 89738 Pace 2 of 2 2.
[orrective Sigps Taken and Results Achioggd A Deficiency Report (DR) was written to document the noncompliance with specification and walkdown procedure requirements.
The disposition of this DR reflects the corrective actions stated below.
The walkdown supervisor for room and area turnover pertaining to electrical equipment comptied a listing of rooms that had been previously finalized.
A reverification walkdown will be conducted in these rooms.
As a minimum, conduit, boxes and panels will be inspected for loose unions, fittings and fasteners.
Any discrepancies will be noted during these reverification walkdowns and will be properly dispositioned in accordance with approved programs.
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Corrective Steos Which Will Be Taken to Avoid Further violations The electrical discipline room and area walkdown supervisor administered dor 9mented training to appropriate walkdown personnel on the walkdown I
procedure attributes pertaining to his discipline.
In addition, the supervisor held a group counseling session to emphasize the importance of j
procedure compliance and the need to physically verify that connections and fasteners on electrical equipment cannot be loosened by hand.
A copy l
of the violation and the response have been routed to all respensible j
electric 61 discipline walkdown engineers for required reading.
In addition to the above actions, TV Electric considered programs i
I currently and previously in place designed to ensure safety related components were properly fabricated and inspected prior to room and area turnover.
Collectively these programs provided an acceptable product.
However, some construction, start up and operations work has occurred l
during or af ter these programs were completed which could have resulted in the deficiencies identified in the violation and in other deficiencies noted by TV Electric during the walkdown process.
The number of these discrepancies is small and does not challenge the adequacy of the above
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processes.
However, to minimize these discrepancies, the plant Manager.
Project Manager. Start up Manager, and the Directors of Construction and Quality Assurance have issued memoranda to emphasize the need to maintain l
the finalized configuration and integrity of equipment during ongoing and future work processes.
4.
Date of Full Compliance Full compliance will be achieved upon completion of the reverification j
walkdowns, Full compliance will be achieved prior to Unit I fuel load.
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