ML20211G620
| ML20211G620 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/19/1987 |
| From: | Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| NUDOCS 8702250452 | |
| Download: ML20211G620 (2) | |
See also: IR 05000445/1986014
Text
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FEB I 9 FR
In Reply Refer To:
Dockets: 50-445/86-14
50-446/86-11
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 letter of January 16 1987, in response to our letter
and the attached Notice of Violation dated October 31, 1986. Your response to
Item B.5 (446/8611-V-11) of the NOV indicates disagreement with our stated
violation.
We have reviewed the additional information provided in your response and the
requirements contained in the referenced procedures.
Based on these reviews,
we agree that the stated condition is not a violation of your facility
procedures. We therefore, are withdrawing Item B.5 as an example of
Violation B.
We have also reviewed your responses to the other Items of the NOV and find
them responsive to our concerns. 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,
c- wt cep6d BY,
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E. H. Johnson, Director
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Division of Reactor Safety
and Projects
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Texas Utilities Electric Company
ATTN:
G. S. Keeley, Manager
Licensing
Skyway Tower
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400 North Olive Street
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Lock Box 81
Dallas, Texas
75201
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Texas Utilities Generating Company
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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
78711-2548
Administrative Judge Peter Bloch
U.S. Nuclear Regulatory Consnission
Washington, D.C.
20555
Elizabeth B. Johnson
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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Log # TXX-6186
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File # 10130
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IR 86-14
TEXAS UTILITIES GENERATING COMPANY
86-11
SKYWAY TOWER . 400 NORTH OLIVE NTREEF. L B. 88 DALLAS. TEXAS 75201
January 16, 1987
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i JAN 2 31987
Mr. Eric H. Johnson, Director
Division of Reactor Safety and Projects
U. S. Nuclear Regulatory Commission
-
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611 Ryan Plaza Drive, Suite 1000
Arlington, TX 76011
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446
RESPONSE TO NRC NOTICE OF VIOLATION
INSPECTION REPORT NOS. 50-445/86-14 AND 50-446/86-11
Dear Mr. Johnson:
We have reviewed your letter dated October 31, 1986, concerning the inspection
conducted by Mr. H. S. Phillips and other members of the Region IV Comanche
Peak Task Group during the period June 1-30, 1986.
This inspection covered
activities authorized by NRC Construction Permits CPPR-126 and CPPR-127 for
Comanche Peak Steam Electric Station Units 1 and 2.
Attached to your letter
was a Notice of Violation.
On December 1,1986, per a telecon with your Mr. T. Westerman, we requested
and received an extension to December 19, 1986. On December 18, 1986, per a
telecon with your Mr. T. Westerman, we requested and received an additional
extension to January 16, 1987.
We hereby respond to the Notice of Violation in the attachment to this letter.
Very truly yours,
-
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W. G. Counsil
WJH/mlh
c - NRC Region IV (0 + 1 copy)
Director, Inspection & Enforcement (15 copies)
U. S. Nuclear Regulatory Commission
Washington, D.C.
20555
Mr. V. S. Noonan
Mr. D. L. Kelley
A isnlAl0% OF 19.% 4% i 188 till.% 019C1 Nit' tD% IPA %Y
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Attachment
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Page 1 of 15
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ITEM A (445/8614-V-01 & 446/8611-V-01)
A.
Criterion XV of Appendix B to 10 CFR Part 50 as implemented by Section
17.1.15 of the Final Safety Analysis Report (FSAR) and by Texas Utilities
Generating Company (TUGCO) Quality Assurance Plan (QAP) Section 15.0,
Revision 5.0, dated October 18, 1985, requires the identification,
tagging, segregation and documentation of nonconforming parts or
components.
Brown & Root (B&R) Procedure CP-QAP-16.1, Revision 26, dated September 17,
1981, requires the identification, tagging, segregation and documentation
of nonconforming parts or components.
Contrary to the above, on June 23, 1986, the NRC inspector found that two
damaged thermocouples had been returned from the field and instead of
tagging and segregating them as nonconforming items they stored them in
warehouse B bins with six other conforming or acceptable thermocouples
(445/8614-V-01; 446/8611-V-01).
RESPONSE TO ITEM A (445/8614-V-01 & 446/8611-V-Oll
We admit the violation and the requested information follows.
1.
Reason for Violation
The damaged thermocouples were returned to the warehouse utilizing
Material Return to Warehouse (MRTW) Forms in accordance with project
procedure CP-CPM-8.1 (Section 3.5).
The damage to these items is recorded
on the MRTW Form (W15836) which was accepted by Warehouse and QC
personnel. The violation resulted from the failure of Warehouse and
Quality Control personnel to properly implement procedures for the control
and segregation of nonconforming material.
2.
Corrective Action Taken
A Nonconformance Report (NCR E-86-201710) was issued to identify the
damage to the thermocouples specified above. These thermocouples have
been segregated by relocation to the QA hold area pending completion of
the disposition. Construction and Quality Control have performed a joint
reinspection of all warehouse storage areas for damaged material and have
identified three additional damaged components.
These items, which were
also documented as damaged per the MRTW Form, have been documented on
Nonconformance Report E-86-201817 and relocated to the QA hold area for
disposition.
3.
Action to Prevent Recurrence
Warehouse and QC receiving personnel will be retrained in the requirements
of the applicable receiving and inspection procedures with emphasis on the
segregation of damaged material.
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Attachment
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Page 2 of 15
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ITEM A (445/8614-V-01 & 446/8611-V-01) CONT'D
4.
Date of Comoliance
Training activities will be completed by January 21, 1987.
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Attachment
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Page 3 of 15
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ITEM B.1 (446/8611-V-03 & 446/8611-V-02)
B.
Criterion V of Appendix B to 10 CFR Part 50, as implemented by FSAR
Section 17.1.5 and TUGC0 QAP Section 5.0, Revision 3, dated July 31, 1984,
requires that 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.
B.1.
Paragraph 3.6 of B&R Procedure MCP-10, Revision 9, dated July 2,
1985, states, in part, " Items shall merit additional protection if
construction work threatening the integrity of equipment is in
progress".
Section E-7.3 of Appendix B to the above procedure states, in part,
" Installed Instruments do not require class "B" or above storage,
however, adequate protection from construction activities and the
environment will be provided."
Contrary to the above, on June 19, 1986, the NRC inspector observed
the following conditions:
a.
Cables in tray sections T24RREA16 and T248 REC 11 were not
protected from welding in progress overhead (446/8611-V-03), and
b.
Level transmitters 2LT-539 and 2LT-537 and their associated
tubing were observed to be uncovered and unprotected while
grinding (to prepare the area for painting) was in progress
above the instruments and in the immediate vicinity of the
tubing.
The instruments were covered with dust and grit from
the grinding (446/8611-V-02).
Attachment
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Page 4 of 15
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RESPONSE TO ITEM B.1 (446/8611-V-03 & 446/8611-V-02)
We admit the violation and the requested information follows.
1.
Reason for Violation
Conditions described in this finding are the result of the failure by
personnel performing grinding and welding to implement requirements
specified per CP-CPM 14.1, " Guidelines for the Protection of Permanent
Plant Equipment."
2.
Corrective Action Taken
.
The subject level transmitters and cables will be inspected for damage and
dispositioned in accordance with Nonconformance Reports I-86-202744 and E-
86-202745.
3.
Action to Prevent Recurrence
All appropriate construction personnel have been trained on Construction
Procedure CP-CPM 14.1 titled, " Guidelines for the Protection of Permanent
Plant Equipment."
The importance of craftmanship, protection of permanent equipment, and
procedural compliance was conveyed to all construction craft personnel at
a special meeting on July 24 and 25, 1986.
The use of disciplinary
measures in the event of a violation was also discussed.
Disciplinary
'
measures will be taken where it is determined that a violation was
1
committed by a person who had been instructed as to the proper
requirements. A project directive was issued to engineering and
construction personnel concerning the protection of permanent plant
equipment which defined disciplinary actions to be taken.
These actions
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!
include a warning for the first offense and automatic termination of the
employee for the second offense.
4.
Date of Como11ance
Corrective measures associated with Nonconformance Reports I-86-202744 and
E-86-202745 will be accomplished by June 1, 1987.
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Attachment
Page 5 of 15
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ITEM B.2 (446/8611-V-06)
B.
Criterion V of Appendix B to 10 CFR Part 50, as implemented by FSAR
Section 17.1.5 and TUGC0 QAP Section 5.0, Revision 3, dated July 31, 1984,
requires that 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.
B.2.
Paragraph 3.6.2 of TUGC0 Instruction QI-QP-11.3-23, Revision 13,
dated September 6, 1985, " Class lE Conduit Raceway Inspections,"
states, in part, "... Identification shall be as indicated below:
"A" Train - Orange - p
Associated "A" Train - Orange with white stripe...
A typical conduit identification number is depicted as follows:
"C14R16397..."
Contrary to the above, orange conduit C23905257, which runs along
the ceiling of the safeguards building pipe tunnel, was color coded
orange with a white stripe where it exited junction box JB2S-5789,
but orange only along the remainder of the run. The rigid conduit
connected to flex conduit C23905357 and junction box JB2S-571, was
physically marked C2395357.
The first digit of the unique five
digit identifier was not applied (446/8611-V-06).
._ __.
Attachment
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Page 6 of 15
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RESPONSE TO ITEM B.2 (446/8611-V-06)
We admit the violation and the requested information follows.
1.
Reason for Violation
Conditions described in this finding are the result of the failure by
personnel to properly implement the color coding and identification
requirements of EEI-16, " Field Color Coding of Electrical Cable" and QI-
QP-11.3-23, " Class 1E Conduit Raceway Inspections."
For clarification purposes, the governing procedure at the time of the
inspections was QI-QP-11.10-1A and not QI-QP-11.3-23 as stated in the NRC
inspection report. However, the applied inspection criteria was the same.
2.
Corrective Action Taken
Nonconformance Reports M-86-201905 and M-86-201938 were written to
identify and correct the noted discrepant conditions.
Nonconformance Report M-86-201938 was dispositioned, work completed and
the conduit satisfactorily reinspected August 8, 1986.
3.
Action to Prevent Recurrence
Responsible construction and inspection personnel have been retrained in
the applicable procedures with emphasis placed on color coding and raceway
identifications.
In order to determine the accuracy of related inspections performed by the
inspectors of record, a review of Quality Surveillance reinspection
results was conducted. The results of the review concluded that previous
inspections by both inspectors of record were satisfactory, supporting the
conclusion that the errors were isolated.
4.
Date of Comoliance
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The corrective measures associated with Nonconformance Report M-86-201905
!
will be accomplished no later than June 1,1987.
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Attachment
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Page 7 of 15
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ITEM B.3 (446/8611-V-05) CONT'D
e
B.
Criterion V of Appendix B to 10 CFR Part 50, as inipl$mented by FSAR
.
Section 17.1.5 and TUGC0 QAP Section 5.0, Revision 3,, dated July 31, 1984,
requires that 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.
"
B.3.
Paragraph 3.8.3 of TUGC0 Instruction QI-QP-11.3-23, Revision 13, dated
September 6,1985, " Class 1E Conduit R5ceway Inspections," states, in
'
part, " Safety-related junction boxes containing. safety-related cable
shall be color coded prior to cable installation ... Paint color shall
match as close as possible the appropriate cable jacket = color of
.
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safety-related cables ... where a raceway 'o'r junction box contains
only associated cables, at least one white horizontal stripe shall be
N
applied over each applicable Train color coded marking..."
Contrarytotheabove,junctionboxJB2S-578%containedTrain"h"
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orange cable, as well as at least one associated "A" Train cable but
was color coded orange with a white stripe, indicating only associated q
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cables.
It was noted that junction box JB25-571 did not have the #
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suffix physically indicated on the box (446/8611-V-05).
x
RESPONSE TO ITEM B.3 (446/8611-V-05)
%
We admit the violation and the requested information follows.
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1.
Reason for Violation
Conditions described in this finding are the result of the failure by
personnel to properly implement the color coding and identification
^
requirements of EEI-16, " Field Color Coding of Electrical . Cable" and QI-
QP-11.3-23, " Class IE Conduit Raceway Inspections."
For the purpose of clarification, the governing procedure at the time of
the above inspections was QI-QP-11.10-1A and not QI-QP-11.3-23 as stated
in the NRC Report. However, the applied inspection criteria was the same.
2.
Corrective Action Taken
- .
Nonconformance Reports E-86-201921, M-86-201905 and M-86-201939 were
written to identify and correct the noted discrepant conditions.
Nonconformance Report E-86-201921 was dispositioned, work completerf and
the conduit satisfactorily reinspected August 5, 1986.
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Attachment
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Page 8 of 15
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RESPONSE TO ITEM B.3 (446/8611-V-05) CONT'D
3.
Action to Prevent Recurrence
Responsible construction and inspection personnel have been retrained in
the applicable procedures with emphasis placed on color coding and raceway
identifications.
In order to determine the accurac'y of related inspections performed by the
inspectors of record, a review of Quality Surveillance reinspection
results was conducted. The results of the review concluded that previous
inspections by both inspectors of record were satisfactory, supporting the
conclusion that the' errors were isolated.
4.
Date of Compliance
The corrective measures associated with Nonconformance Reports M-86-201905
and M-86-201939 will be accomplished no later than June 1, 1987.
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Attachment
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Page 9 of 15-
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ITEM B.4 (446/8611-V-07)
B.
Criterion V of Appendix B to 10 CFR Part 50, as implemented by FSAR
Section 17.1.5 and TUGC0 QAP Section 5.0, Revision 3, dated July 31, 1984,
requires that 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.
B.4.
Paragraph 3.2.1.e of TUGC0 Instruction QI-QP-11.3-28, Revision 30,
dated May 21,1986, " Class IE Cable Terminations," states, in part,
with respect to adequacy of Flexible / Unique /Servicair flexible conduit
installation, "... Verify that the connection is hand tight, as a
.
minimum."
Contrary to the above, the connectors were loose (not hand tight) for
flexible conduits C22705459 and C23#10114 where they attach to the
rigid conduits. Cables were installed, terminated, and energized.
This condition was also observed on approximately ten additional Class
IE conduits (446/8611-V-07).
RESPONSE TO ITEM B.4 (446/8611-V-07)
We admit the violation and the requested information follows.
1.
Reason for Violation
The conditions described in this finding were found to only exist for
flexible conduit C22905459. This condition was the result of the failure
by the QC inspector to properly implement the requirements of QI-QP-11.3-
28, " Class IE Cable Terminations."
The connector that attaches the rigid conduit to flexible conduit
C23J10114, when reexamined, was found to be hand tight.
Although not specifically documented, each of the reported deficiencies
was evaluated by the TUaC0 representative during the course of the NRC's
inspection of this activity. With the exception of flexible conduit
.
C22905459, the remaining flex connectors identified as deficient involved
'
either in-process work, i.e. installations that were not complete and
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therefore not yet required to be " hand tight", or the flex connectors
involved non-1E installations (i.e. C-train) which are not subject to QI-
QP-11.3-28 inspection.
(NOTE: Non 1-E flex connector installations are
routinely verified by responsible craft personnel prior to room and area
turnovers.)
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Attachment
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Page 10 of 15
RESPONSE TO ITEM B.4 (446/8611-V-07) CONT'D
2. Corrective Action Taken
A review of other completed IE flexible conduit connectors was performed
by the TUGC0 representative at the time of the inspection and no
additional nonconformances were identified. Note that this review was
conducted informally and was not documented.
Nonconformance Report E-86-201807 was issued concerning conduit C22905459
to identify the loose flex conduit connections.
Nonconformance Report E-86-201807 was dispositioned, work completed and
the conduit satisfactorily reinspected July 30, 1986.
3.
Action to Prevent Recurrence
Construction personnel were retrained to assure all flex connectors are
tightened at the time of termination. The two connections noted have been
tightened or verified to be tight.
The inspector of record has been retrained in the applicable procedure
requirements of QI-QP-11.3-28. A review of Quality Surveillance
reinspection results was conducted to determine the accuracy of
inspections performed by the inspector of record.
The results of the
review concluded that previous inspection results were satisfactory,
supporting the conclusion that the error was isolated.
4.
Date of Comoliance
Compliance has been achieved, as described above.
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Attachment
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Page 11 of 15
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ITEM B.5 (446/8611-V-11)
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B.
Criterion V of Appendix B to 10 CFR Part 50, as implemented by FSAR
Section 17.1.5 and TUGC0 QAP Section 5.0, Revision 3, dated July 31, 1984,
requires that 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.
B.5.
TUGC0 Instruction QI-QP-11.3-26, Revision 24, dated October 11, 1985,
.
" Electrical Cable Installation Inspection," paragraph 3.2.1.j, states,
" Cable ends - Cable ends shall be sealed with heat shrink caps or tape
after pulling activities." Paragraph 4.7.1 of B&R Engineering
Instruction EEI-7, Revision 5, dated October 8, 1982, " Cable Pulling,"
states, " Cable ends shall be sealed with heat shrink caps or~ tape
during the period prior to the terminations."
,
Contrary to the above, unlanded conductors in cable spreading room
panel CP2-ECDPPC-03 did not have end protection through the
,
application of heat shrink caps or tape. This condition was observed
to be widespread throughout the plant. Some of the conductors were
marked with a " spare" designation, others were not.
It was observed
4
that TUGC0 Instruction QI-QP-11.3-28, Revision 30, dated May 21, 1986,
" Class IE Cable Terminations", did not address conductor end
protection for cables which have had their outer jackets removed, but
>
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have not been terminated.
In addition, none of the
procedures / instructions addressed the marking of " spare"
cables / conductors using the "SP" designator (446/8611-V-11).
RESPONSE TO ITEM B.5 (446/8611-V-11)
We deny the alleged violation for the reasons that follow.
,
i
Instructions QI-QP-11.3-26, " Electrical Cable Installation Inspection," and
EEI-7, " Cable Pulling," apply to the construction activities involved in
routing cables from origination to destination. The cable may contain several
individual conductors which are either terminated or designated as spare or as
'
unused.
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Page 12 of 15
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RESPGNSE TO ITEM B.5 (446/8611-V-11) CONT'D
Instruction QI-QP-11.3-26, Revision 24, dated October 11, 1985, " Electrical
Cable Installation Inspection", paragraph 3.2.1.j, states, " Cable ends -cable
ends shall be sealed with heat shrink caps or tape after pulling activities."
Paragraph 4.7.1 of EEI-7 states, " Cable ends shall be sealed with heat shrink
caps or tape during the period prior to the terminations." The intent of this
procedure is to provide protection to the cable end prior to, during and after
construction pulling activities. The cable as a unit (ngt individual
conductors) is capped or protected.
Instructions QI-QP-11.3-28, Revision 30, dated May 21,1986, " Class 1E Cable
Terminations", and EEI-8, " Class IE and Non-class IE Cable Terminations" do
not require unused conductors within a " terminated cable" to have cable end
protection even though the outer jacket has been removed.
It is not the
intent of these procedures or specification requirements to provide conductor
end protection for unused conductors within a terminated cable. Unused
conductors are tied and segregated from terminated conductors.
A subsequent inspection of Panel CP2-ECDPP03 by craft revealed the following:
1.
There were no cables or conductors observed with the SP marking in this
panel. None were required.
Note: Only those cables specifically designated spare by Engineering via
Design Change Authorizations or Nonconformance Reports are marked
"SP".
Unused conductors within any terminated cable are not
required to be marked "SP".
As previously noted, individual
conductors are either terminated or designated as " spare" or unused.
2.
Cable NK 245644 3C #10 had only two conductors landed. The additional
,
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conductor was bundled as required and marked with the cable number NK
245644.
There was no end cap or tape applied.
None was required.
3.
There were two cables (EB 205321 and EB 205327) that had tape on the ends.
These cables met the requirements of Instructions QI-QP-11.3-26 and EEI-7.
TUGC0's evaluation of this finding indicates that the existing conditions were
in accordance with the applicable procedures and accurately reflect the
specification requirements.
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Attachment
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Page 13 of 15
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ITEM B.6 (446/8611-V-12)
B.
Criterion V of Appendix B to 10 CFR Part 50, as implemented by FSAR
Section 17.1.5 and TUGC0 QAP Section 5.0, Revision 3, dated July 31, 1984,
-
requires that 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.
B.6.
Paragraph 3.1.3.c of TUGC0 Instruction QI-QP-11.3-26, Revision 24,
dated October 11,1985, " Electrical Cable Installation Inspection,"
states, in part, "... If field color coding becomes necessary, Class
1E and associated Class 1E cables shall be color banded at intervals
not exceeding 5 feet, and shall be visible at all openings..."
Contrary to the above, at elevation 832 feet in the safeguards
'
,
building, the black cable installed in junction box JB2S-956G was not
color coded green at the junction box opening.
In room 85D of the
safeguards building, the black cable installed in junction box JB2S-
'
544B was not color coded blue at the junction box opening.
In
,
.
addition, this cable was not color coded at the first " upstream"
condulet opening (446/8611-V-12).
l
RESPONSE TO ITEM B.6 (446/8611-V-12)
-
We admit the violation and the requested information follows.
1.
Reason for Violation
Conditions described in this finding were the result of the failure by
personnel to implement the color coding requirements of EEI-16, " Field
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Color Coding of Electrical Cable", and QI-11.3-26, " Electrical Cable
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Installation Inspection."
2.
Corrective Action Taken
Nonconformance Reports E-86-201808 and E-86-201824 were written to
identify and disposition the conditions in junction boxes JB2S-544B and
JB2S-956G respectively.
Both Nonconformance Reports have been dispositioned, work completed and
the cables satisfactorily reinspected July 17, 1986.
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Attachment
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Page 14 of 15
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RESPONSE TO ITEM B.6 (446/8611-V-12)
3.
Actions to Prevent Recurrence
Responsible construction personnel have been re-trained to the
requirements of EEI-16, " Field Color Coding of Electrical Cable."
The inspector of record for JB2S-956G is no longer on site, however, the
inspector of record for J82S-544B was retrained to QI-QP-11.3-26,
" Electrical Cable Installation Inspection."
In order to determine the accuracy of inspections performed by the
inspectors of record, a review of Quality Surveillance reinspection
results was conducted. The results of the review concluded that previous
inspections by both inspectors were satisfactory, supporting the
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conclusion that the errors were isolated.
4.
Date of Comoliance
Compliance has been achieved, as described above.
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Attachment
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Page 15 of 15
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ITEM C (445/8614-V-03 & 446/8611-V-10)
C.
Criterion V of Appendix B to 10 CFR Part 50, as implemented by FSAR
Section 17.1.5 and TUGC0 QAP Section 5.0, Revision 3, dated July 31, 1984,
requires that 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.
Contrary to the above, TUGC0 Instructions (QI-QPs) did not address process
control for drilling holes in solid bottom cable tray to facilitate
installation of fittings and/or cable TY-RAPS (445/8614-V-03; 446/861-V-
10).
RESPONSE TO ITEM C (445/8614-V-03 & 446/8611-V-10)
We admit the violation and the requested information follows.
1.
Reason for Violation
Conditions described in this finding are the result of the inadequacy of
the applicable specification (2323-ES-100) to adequately provide
requirements for the drilling of cable tray to facilitate Ty-rap
installations.
2.
Corrective Action Taken
Specification 2323-ES-100 was revised by an approved design change (DCA-
12562). Construction and inspection procedures EEI-7, " Cable Pulling,"
CP-CPM-14.1, " Guidelines for Protection of Permanent Plant Equipment,"
and QI-QP-11.3-26, " Electrical Cable Installation Inspections" were
revised to provide criteria for installation and verification of completed
installations. These actions ensure proper process control of the
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installation of Ty-raps and were completed June 16, 1986.
Applicable construction and quality personnel were trained in the revised
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requirements of the procedures listed above.
Existing installations of Ty-rap are adequate since process controls did
exist to prevent cable damage. These controls included:
1) Verification
of the absence of conditions which could be damaging (i.e. rough edges,
burrs) in a tray prior to cable pulling, 2) Monitoring the cable pull
process, and 3) Verification of the correct installation of ty-raps (i.e.,
spacing and type).
3.
Actions to Prevent Recurrenqg
The corrective actions taken will prevent recurrence.
4.
Date of Comoliance
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Compliance has been achieved, as described above.
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