ML19329B149

Responds to NRC 761020 Ltr Re Violations Noted in IE Insp Rept 50-346/76-18.Corrective Actions:Disagrees W/Finding & Provides Defense of Spec Change Re Cable Support in Vertical Conduit Risers

ML19329B149
Person / Time
Site:	Davis Besse
Issue date:	11/24/1976
From:	Roe L TOLEDO EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19329B143	List: ML19329B146 ML19329B149
References
NUDOCS 8001300723
Download: ML19329B149 (3)

Text

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' LOWELL E. ROE <

' , November 24, 1976 .

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We President Facihties Deveicament 14198 259-5242

. Docket No. 50-346 ..

. Serial No.' 160 Mr. James G. Koppler .*

Regional Director, Region III Directorate of Regulatory Operations ~

U. S. Nuclear Regulatory Commission 799 Roosevelt Road '

N Glen Ellyn, Illinois 60137

Dear Mr. Keppler:

Toledo Edison acknowledges receipt of your October 20, 1976 letter rnd

, enclosed inspection report referencing the apparent noncompliances with NRC regulations. These items resulted from the site inspection conducted by your office on September 21-23, 1976.

Toledo Edison offers the following information regarding these apparent v noncomplie.nces, including corrective action and steps taken to avoid ,

further occurrences. ,

Deviation In relation to the disposition of EIR No. 447, "The inspector concluded that the specification change uas inappropriate and contrary to the intent of NEC 300-19 and good engineering practice." .

Th'c National Electrical Code, Para. 300-19 establishes criteria for the support of conductors in vertical rac_cuays. Our Specification No. 7749-E-14, Section 10.3 covers the installation of conduit. Section 11.0 of this speci-fication covers the installation of wire and cable in cable trays and conduit.

Paragraph 10.3.2.c originally uns worded, " Vertical conduit riscrs of more than 20 feet shall be provided with approved cable clamps or supports."

The Engineering Inspection Team by means of EIR 447 construed this specifi- ,

cation paragraph to apply to the need for cable clamps on the cable within conduit if the conduit riser was more than 20 feet. To clarify this situa-tion and to permit proper closecut of EIR 447, Specification 7749-E-14, Paragraph 10.3.2.e uns revised for clarification and to fully cover cable support requirements in vertical conduit risers even though this subject should more properly belong in Section 11.0 of Specification 7749-E-14 ,

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8,0013007 N THE TOLEDO FOISON COMPANY EDISON PLAZA 300 NADISON AVEbuE TOLEDO. OHIO 43052

. , . " ' . Mr. James C. Keppler .

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Nov mbsr 24, 1976 (S)

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The revised para. 10.3.2.e. now reads,. "All vertical conduit risars

. , carrying power cables shall. have clic prov'ision for supporting the cabics in accordance with the 1971-National Electric Code, Section 300-19.

All vertical conduit risers carry *ing control or instrumentation cabic, which are over 20 feet in length and terminate at.the upper end shall ..

have the cables restrained by wedge grom= cts or split,Kellem Grips at the upper end to prhvent strain on the terminalq."

This specification change is considered to be appropriate, to be in accor-dance with good engineering practice, and to meet the intent of the NEC Section 300-19. In addition, all cable, both power and instrumentation, was installed as required by Specification 7749-E-14 uith the use of a

- c tension dynamometer which assures that less than the maximum allowabic

" tension was applied to any'cabl'e cither while being pulled' or in the as installef condi' tion. The requirement in paragraph 10.3.2.e calling for a

'cabic' restraint en' instrumentation or control cable which is over 2G feet in length in the vertical, and terminating at the upper end, exceeds the requirements of the NEC Section 300-19 and is for the purpose of,termina-o,p tion protection and not related to conductor tension strain.' -

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Infraction _ .

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() 2a. "EIR Nos. 2152, 2157, and 2511 are relative to exceeding the minimum bending radius of cables. Part of the recommended action / analysis

.was to rework said cables in order to increase bending radius.

.It did not appear that any attemnt whatsoever uns made to correct the problem. No documented evidence was available indicating that:

• (1) Work had been attempted or accomplished (other than insulation resi, stance testing), (2) Why work could not be accomplished, and (3) design approval of existing conditions had been obtained.

, Considering the above, the EIT still made an acceptance finding."

"The IE Inspector identified the above as an infraction contrary to 10CFR50, Appendix 3, Criteria X."

Engineering Inspection Report (EIR) item Nos. 2152, 2157, and 2511

. are being re-evaluated by Gaithersburg Power Divisio_n (cpni relative

. to exceeding the minimum bending riidlus of cables. Furthermore, prior EIR reports will be reviewed to determine if other items

, relative to exceeding the minimum bending radius of cables require engince' ring re-evaluation.

When corrective action is required,* the action taken will be correctly documented as to the extent of work done. In those cases where due to physical limitiations, the rework, as prescribed in the corrective O action, is impracticable to perform; documented evaluation will be

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obtained indicating the reasons why the reuork could not be accomplished.

This evaluation will be returned to CPD for further evaluation. Wherc

,' applicabic, design approval of existing conditions will be given and the justification for approval documented. , ,

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,. 'Mr. James C. Kuppler .

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' Nov mber 24, 1976 .,. , ,. .

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To ensure that complete documentation.is included, all future EIR items

, will be closely monitored by GFD and TECo in order to insure that proper EIR dispositioning is documented and implemented.

Full compliance will be achieved by the week ending December 17, 1976. ,,

2b. " Corrective action to EIR Items 2515 and 2516 appeared to have inadver-

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.tently compromised. In one case, installed cable supports had been cut, and,in another, cables were disarranged to preclude placement of required

. covers. This matter was determined to be an infraction, contrary to 10CFR50, Appendix B, Criterion XIV. (Similar observations were reported in IE Inspection Report No. 050-346/76-13, Paragraph 2.f, Report Details)."

e Engineering Inspection Report (EIR) Item Nos. 2515 and 2516 reported poor workmanship related problems at MCC BEllD and EV1424 respectively.

Th.2 problems verc corrected and e.he EIR's properly closed. However, since the closcout, new similar type conditions at the same locations were observed during the IE Inspection. These conditions existed because additional work uns currently in progress by the contractor. This uork

.will be completed and inspected to previously established installation procedures by December 17, 1976.

To preclude the same conditicns as cited in the above EIR items from recurring, the applicable contractors have been cautioned to continue to comply with their existing procedures.

v. Bechtel and TECo will monitor activities to assure contractors procedures are being properly implen.cnted.

Yours very truly, LER.s 1

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