ML20154G540
| ML20154G540 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/16/1988 |
| From: | Beck J TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| TXX-88449, NUDOCS 8805240417 | |
| Download: ML20154G540 (3) | |
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MEE log # TXX-88449
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File # 10130 C
C IR 86-26 p,f,,$c%2 7UELECTRIC 01 i
i wma. c.c=a.a May 16, 1988 i,an.maa, m,am 1
U. S. Nuclear Regulatory Commission L
Attn: Document Control Desk Washington, D.C.
20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS 50-445 AND 50-446 INSPECTION REPORT N05. 50-445/86-26; 50-446/86-22 i
REVISED RESPONSE TO NOTICE OF VIOLATION (N0V) ITEM A (445/8626-V-02)
REF:
TV Electric Letter TXX-7120 from W. G. Counsil to NRC dated December 31, 1987 Gentlemen:
The referenced letter provided our revised response to Notice of Violation item A (445/8626-V-02).
In that response we stated that the Unit I walkdown for pulling aids per CPE-SWEC-FVM-EE/ME/IC/CS-90 would be completed in order to correct this finding. As a result of activities completed in December 1987 and other installation practices, the walkdowns need not be performed for this issue. Our res)onse to Notice of Violation 445/8626-V-02 is hereby revised to t
reflect these clanges and to update the status of our revision to i
specification 2323-ES-100.
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Where revised responses are provided, the revised sections are denoted by a revision bar in the right margin.
Very truly yours, i
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W. G. Counsil By:
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Vice President, Nuclear Engineering ROD /grr c-Mr. R. D. Martin, Region IV r
Resident inspectors, CPSES (3) i po\\
I 8905240417 630516 PDR ADOCK 05000445 ursh mun surero LDS) Mas, Teses 1MI I
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Att'achment to TXX-88449 May 16, 1988 Page 1-of 2 NOTICE OF VIOLATION IyJ T T4457E626 W 3]2)
A.
Criterion V of Appendix B to 10 CFR Part 50, as implemented by the TUGC0 Quality Assurance Plan (QAP), Section 5.0, Revision 3, dated July 31, 1984, requires that activities affecting quality shall be prescribed by and accomplished in accordance with documented instructions, procedures, or drawings of a type appropriate to the circumstances.
Paragraph 3.1.2.e of TUGC0 Procedure QI-QP-11.3-40, Revision 14, dated January 9, 1984, states, in part, "Verify that... all cable pulling aids have been removed (i.e., fish tape, tape rope, etc.)."
Paragraph 3.1.1.2.c of the above procedure, Revision 18, dated May 18, 1984, states, "Verify that... pulling aids (i.e., rollers, fish tape, tag rope) have been removed from raceway."
Contrary to the above, TUGC0 inspectors performing post construction inspections failed to identify cable pulling ropes remaining in Class lE conduit C12018896 and Class 1E :able tray T130ACG57 located in the Unit I reactor building and auxiliary building, respectively (445/8626-V-02).
REVISED RESPONSE TO ITEM A (4457B626-V-02)
TV Electric accepts the alleged violation and the requested information follows:
1.
Reason for Violation Regarding cable tray T130ACG57 construction procedures controlling cable pulling activities performed subsequent to QC acceptance of raceway systems did not require QC reverification of pulling aid removal.
Regarding conduit C12018896, Revision 14 of Ql-QP-11.3-40 in effect at the time of post construction inspection required QC inspectors to identify visible pulling aids but did not require the removal of junction box, pull box or conduit covers to verify that pulling aids had been removed.
2.
Corrective Steps Taken and Results Achieved Honconformance Report (NCR) E-86-1038835 and Construction Deficiency Report (COR) 87-4746EC (previously NCR E-86-103981) were issued to address 1
pull ropes in conduit C12018896 and cable tray T159ACG57, respectively.
I Both documents have been dispositioned "rework" by directing the removal i
of the pull ropes.
NCR E-86-1038835 has been closed.
1 Corrective Action Request (CAR) 87-59 has been initiated which will aditets the generic implictions of this violation and will define a w@riate corrective actions.
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4 Attachment to TXX-88449 i
Hay 16, 1988 Page 2 of 2 3.
Corrective Steps Which Will be Taken to Avoid Further Violations f
On July 24, 1987, Procedure eel-7, "Cable Pulling," was revised to require removal of all pulling aids (pull ropes, fish tape, etc.) af ter cable 1
pulls into covered cable trays or conduit are completed. After further i
evaluation it was determined that, with certain restrictions, it is acceptable to leave cull ropes in conduit runs. On October 28, 1987, i
Design Change Authorization (DCA) 58763, Rev. O to 2323-ES-100 was issued j
j providing this allowance and detailing the restrictions, i
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A OCA to revise 2323-ES-100 has been issued which emphasizes that pull l
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ropes are to be left in conduits only when their removal may result in damage to adjacent cables.
t Quality Instruction Ql-QP-ll.3-40, "Post Construction Inspection of Electrical Equipment and Raceways," has been deleted.
In process inspections for pulling aids are performed in accordance with procedures j
NOA-3.09-3.02, "Electrical Raceway-Cable Tray," and NOA-3.09-3.03, "Electrical / Raceway Conduit Procedure." These procedures provide
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inspection criteria commensurate with the requirements contained in Specification 2323-ES-100.
On November 6,1987, the Director of Construction issued a directive
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requiring that all visible metal fish tapes be removed from Unit I and
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Vnit 2 raceways, or if removal was not feasible an NCR was to be written.
This action was reported complete on December 18, 1987.
The completion of l
j this activity and inspection attributes wnich require that coadults be i
j free of foreign debris prior to the installation of electrical penetration i
i seals completes our corrective action for this finding.
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4.
Date When Full Compliance Will be Achieved full compliance has been achieved.
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