ML20210S473

Ack Receipt of 861009,31 & s Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-445/86-06 & 50-446/86-04

ML20210S473
Person / Time
Site:	Comanche Peak
Issue date:	02/10/1987
From:	Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
NUDOCS 8702170638
Download: ML20210S473 (2)

See also: IR 05000445/1986006

Text

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In Reply Refer To:' FEB I O INT

Dockets: 50-445/86-06

50-446/86-04

Texas Utilities Generating Company

ATTN: Mr. W. G. Counsil

Executive Vice President

400 North Olive L.B. 81

Dallas, Texas 75201

Gentlemen:

Thank you for your letters of October 9,1986, October 31, 1986, and

January 22, 1987, in response to our letters and Notice of Violation dated

August 26, 1986, ar.d December 30, 1986. We have reviewed your reply and find

it responsive to the concerns raised in our Notice of Violation. We will

review the implementation of your corrective actions during a future

inspection to determine that full compliance has been achieved and will be

maintained.

Sincerely,

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E. H. Johnson, Director

Division of Reactor Safety

and Projects

cc:

Texas Utilities Electric Company

ATTN: G. S. Keeley, Manager

Licensing

Skyway Tower

400 North Olive Street

Lock Box 81

Dallas, Texas 75201

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Juanita Ellis

President - CASE

1426 South Polk Street

Dallas, Texas 75224

Renea Hicks

Assistant Attorney General

Environmental Protection Division

P. O. Box 12548

Austin, Texas 78711-2548

Administrative Judge Peter Bloch

U.S. Nuclear Regulatory Comission

Washington, D.C. 20555

Elizabeth B. Jahrson

Administrative Judge

Oak Ridge National Laboratory

P. O. Box X, Building 3500

Oak Ridge, Tennessee 37830

Dr. Kenneth A. McCollom

1107 West Knapp ,

Stillwater, Oklahoma 74075

Dr. Walter H. Jordan

881 Outer Drive

Oak Ridge Tennessee 37830

Anthony Roisman, Esq.

Executive Director

Trial Lawyers for Public Justice

2000 P. Street, N.W. Suite 611

Washington, D.C. 20036

Texas Radiation Control Program Director

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! Leg # TXX-6213

File # 10130

IR 86-06

• TEXAS UTILITIES GENERATING COMPANY IR 86-04

SKYWAY TOWER . 489 NORTH OLIVE STREET. LB. 88 . DALLAS, TEXAS 7M01

January 22, 1987 ~~~- '

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Mr. Eric H. Johnson, Director I. , _

Division of Reactor Safety and Projects

U. S. Nuclear Regulatory Commission L-

611 Ryan Plaza Drive, Suite 1000

Arlington, TX 76011

SUBJECT: COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446

INSPECTION REPORT NOS.: 50-445/86-06 AND 50-445/86-04

SUPPLEMENTAL RESPONSE FOR INFORMATION TO NRC

NOTICE OF VIOLATION (N0V) ITEM A(2)

REF: 1. TUGC0 Letter TXX-5037 from W. G. Counsil to E. H. Johnson

dated October 9, 1986.

2. TUGC0 Letter TXX-6071 from W. G. Counsil to E. H. Johnson

dated October 31, 1986.

Dear Mr. Johnson:

We have reviewed your letter dated December 30, 1986, requesting additional

information to our responses referenced above regarding NOV 445/8604-V-02

(Item A(2)). We hereby respond to the request for supplemental information in

the attachment to this letter.

Very truly yours,

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W. G. ouns 1

By: [, . /

G. S. Keeley

W/y

Manager, Nuclear ticensing

RSB/amb:lw

Attachment

c - NRC Region IV (0 + 1 copy)

Director, Inspection and Enforcement (15 copies)

U. S. Nuclear Regulatory Commission

Washington, D. C. 20555

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Mr. V. S. Noonan

Mr. D. L. Kelley

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. Attachment to TXX-6213'

January 22,--1986

Page 1 of 2

NOTICE OF VIOLATION

ITEM A(2) 446/8604-V-02

SUPPLEMENTAL REQUEST FOR INFORMATION

In your response to Item A(2), you mention that problems related to the

overflowing of electrical cable from the cable trays that were identified by

the NRC inspector had been previously identified by applicant personnel and

were in the process of being reworked. Accordingly, you did not agree that

the NRC identified condition was a violation and, therefore, did not provide

the information required by the NOV.

Based on our review of the information provided in your response and

additional information provided by members of your staff, we cannot agree that

the cited condition had been, or necessarily would have been, identified as a

result of the rework that had been undertaken. While we agree that many of

the same cables were involved in both the NRC identified condition of

overflowing cable tray siderails and the rework being conducted, we disagree  ;

that the NRC identified problem would necessarily have been resolved by

pulling the cables back to remove interlacing and then reinstalling these

cables in the same size cable tray. In addition, the NRC inspector did not

identify any QC hold tags (indicating an identified problem) during the NRC

inspection.

SUPPLEMENTAL RESPG : TO ITEM A(2)

As a result of discussions with the NRC Resident Inspector and our review of

this violation, we have determined that a revision to our response is

required. The revised response below will provide the supplemental

information requested.

1. Reason for Violation

f We admit the violation, and the requested information follows.

The deficiences noted in this violation involving unacceptable cable

installation'were the result of corrective actions in progress per

NCR E-85-101983 and inadequacies in the cited TUGC0 Inspection Instruction

QI-QP-11.3-26 and B&R Construction Procedure EEI-7. Specifically,

criteria governing the installation and inspection of electrical cable

were found insufficient to prevent the improper cable installation

identified in the NOV.

2. Corrective Steos Taken

A request for engineering clarification (RFIC E-11180) was initiated on

March 4,1986 requesting engineering to evaluate cable tray nodes

T240SF001, 02, 03, 04, and 05 for siderails and to document installation

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problems encountered during cable rework associated with NCR E-85-101983.

i A design change (DCA #24,289) was issued on April 4, 1986, to replace the

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12" tray nodes with 18" width trays to correct the stated cable overfill

and irregular routing problems. Construction Deficiency Report CDR-87-801

was issued on January 19, 1987 to identify the need for reinspection of

existing cable installations for cable overfill conditions. If the

disposition of the CDR indicates that corrective action is required, a CAR

will be generated,

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. Attachment to TXX-6213

January 22, 1986

Page 2 of 2

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3. Action to Prevent Recurrence

Inspection Instruction QI-QP-11.3-26 and Construction Procedure EEI-7 have

been revised to address the specific requirements of the electrical

erection specification in the areas identified in the NOV. An additional

inspection attribute has been incorporated into the inspection instruction

prohibiting cables from extending above the top of cable tray siderails

except where entering and exiting the cable tray.

4. Date of Como11ance

Implementation of design change DCA-24,289 and associated cable rework is

scheduled to be completed by July 1,1987. A change notice (DCN #5) was

issued against the Installation Procedure EEI-7 on October 31, 1986.

Revision 31 of Inspection Instruction QI-QP-11.3-26 is scheduled to be

issued by January 31, 1987, upon completion of requisite training. If

required, appropriate corrective action to disposition CDR-87-801 will be

completed by July 1,1987.

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