ML20212E576
| ML20212E576 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/30/1986 |
| From: | Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| NUDOCS 8701050361 | |
| Download: ML20212E576 (3) | |
See also: IR 05000445/1986006
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In Reply Refer To:
Dockets: 50-445/86-06
DEC 3 01986
50-446/86-04
Texas Utilities Generating Company
ATTN: Mr. W. G. Counsil
Executive Vice President
400 North Olive Street, L.B. 81
Dallas, Texas
75201
Gentlemen:
Thank you for your letters dated October 9,1986, and October 31, 1986, in
response to our letter dated August 26, 1986. As a result of our review of
your letters, we find that we are in need of additional information with
respect to Item A(2) in the Notice of Violation (NOV).
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.
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- Therefore, we request that you provide the information requested in the NOV
for this item within 20 days of your receipt of this letter.
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We have no further questions regarding Items A (1) and B of the NOV.
Sincerely,
Oricinal Signed By
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E. H. Johnson, Director
Division of Reactor Safety and
Projects
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Texas Utilities Electric Company
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ATTN:
G. S. Keeley, Manager,
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Licensing
Skyway Tower-
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400 North Olive Street
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Lock Box 81
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Dallas, Texas 75201.
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Juanita Ellis
President - CASE
1426 South Polk Street
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Dallas, Texas
75224-
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Renea Hicks
Assistant Attorney General
Environmental Protection Division
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P.O. Box 12548
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78711-2548
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Administrative Judge Peter Bloch
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U. S. Nuclear Regulatory Commission
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Washington, D.C.
20555
Elizabeth B. Johnson
Administrative Judge
Oak Ridge National Laboratory
P.O. Box X, Building 3500
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Oak Ridge, Tennessee 37830
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Dr. Kenneth A. McCollom
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1107 West Knapp
Stillwater, Oklahoma 74075
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Texas Utilities Generating Company
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Dr. Walter H. Jordan
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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-5037
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File # 10130
TEXAS UTILITIES GENERATING COMPANY
IR 86 06
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86-04
October 9, 1986
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Mr. Eric H. Johnson, Director
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Division of Reactor Safety and Projects
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U. S. Nuclear Reg'ulator.v Commission
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Arlington, Texas 76012
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611 Ryan Plaza Drive, tutte 1000
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SUBJEC7:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
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DOCKET NOS. 50-445 AND 50-446
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RESPONSE TO NRC NOTICE OF VIOLATION
INSPECTION REPORT NOS.: 50-445/86-06 AND 50-446/86-04
Dear Mr. Johnson:
1
We have reviewed your letter dated August 26, 1986, concerning the inspection
conducted during the period February 1, through March 31, 1986 by Mr. H.S.
.
Phillips and other members of the Region IV Comanche Peak Group. This
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inspection covered activities authorized by NRC Construction Permits CPPR-126
and CPPR-127 for Comanche Peak Steam Electric Station Units 1 and 2.
Attached
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to your letter"was a Notice of Violation.
We requested and received a two week extension in providing our response
during a telephone conversation on September 25, 1986.
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We hereby respond to the Notice of Violation in the attachment to this letter.
4
Very truly yours,
,
W. G. Counsil
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By:
,..
G. S. Keeley
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Manager, Nuclear Lil:pfising
RSB/gj
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Attachments
c - Region IV (Original + 1 Copy)
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Director, Inspection & Enforcement (15 copies)
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U. S. Nuclear Regulatory Comission
Washington, D.C.
20555
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Mr. V.S. Noonan
Mr. 'O.L. Kelley
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Attachment to TXX-5037
Page 1
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October 9, 1986
ITEM A (445/8604-V-02)
A.
Criterion V of Appendix 8 to 10 CFR Part 50, as implemented by Section
5.0, Revision 3, dated July 31, 1984, of the TUGCo QA Plan (QAP), requires
that activities affecting quality shall be prescribed by and accomplished
in accordance with documented instruction, procedures, or drawings.
Paragraph 4.2.2.3a of Gibbs and Hill (G&H) Specification 2323-ES-100.
Revision 2, " Electrical Erection." states, in part, "All cables and
individual conductors shall be installed in a workmanlike manner.
shall be neatly trained, without interlacing, in all cable trays, trench
Cables
boxes and panels ...." Paragraph 4.2.2.4 of this specification states, in
part, " Cables in cable trays ... shall be laid therein whenever possible.
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Cable in trays shall be laid to a uniform depth."
Contrary to the above:
1.
TUGCo Instruction QI-QP-II.3-26, Revision 24, dated October 11
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1985 " Electrical Cable Installation Inspection." did not address
specification requirements with respect to workmanlike
installation, training of cables without interlacing, or
installation of cables to a uniform depth. Also, Brown & Root
(B&R) Procedure EEI-7, Revision 6, dated March 26, 1986, " Cable
Pulling," did not address installation of cables in trays to a
uniform depth.
2
Cables were observed to be spilling over the siderails of cable
trays T240SF003, 004, 005, 006, 007, 008 and T240SDA91. Cables
were also not laid in the tray at the ver,tical to horizontal
transition between cable tray section T240SF003 and T240SF004.
RESPONSE TO ITEM A (1)
,
1.
Reason f_gr Violation
The attributes of concern in this violation relate to broad, standard
terms that, in general, address good workmanship. The electrical erection
,
specificatTUh, 2323-ES-100, does nat provide a clear discussion of these
attributes.
Requirements involving the interlacing of trained cable are
addressed procedurally for some applications, but, in general, these
attributes are not addressed by implementing procedures.
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Attachment to TXX-5037
October 9, 1986
RESPONSE TO ITEM A (1) - CONT'D
2.
Corrective Slep.s Taken AD.d .th.g Results Achieved _
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The electrical erection specification will be reviewed and revised as
necessary to clarify these general requirements.
The two procedures noted
'in the violation (QI-QP-11.3-26 and eel-23) will be reviewed
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to ensure compliance with
be performed as necessary.the clarified specification.Reinspections will
NCR's E86-202317, E86-104159 and E86-250405 have been written to address
the issues in this violation.
- 3.
Corrective Stap.1.tn Avoid Recurrence
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additional requirements that were addressed in a gen
require clarification.
the applicable implementing procedures and instructions s
and revised as necessary to ensure compliance with the revised
specification.
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4.
QA.tg Whitti full Como11ance Will. bg Achieved
The date for fu,ll compliance will be provided not later than October 31,
1986. '
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Attachemnt to TXX-5037
October 9, 1986
RESPONSE TO ITEM A (2)
We do not agree that part A(2) is a violation of the referenced criteria.
Between December 6, 1985, and August 5, 1986, CPSES issued NCR E85-1019
six (6) subsequent revisions addressing the interlacing of instrumentation and
and control cables.
Essentially, all of the cables identified on these NCRs
were common to (or were routed through) the areas identified by the NRC
inspector.
In all cases, the NCR disposition directed construction to pull the cables
back through the original routing and then reinstall.
While attempting to
complete the prescribed disposition, additional NCRs were issued addressing
cables above the siderail (E86-100847 R.1 dated 3/3/86, E86-100848 R.1 dated
3/3/86, E86-201010 dated 3/3/86, and E86-20ll50 dated 4/11/86).
.
The dispositions for these NCRs required reworking the c
obtaining slack from origin to destination as necessary. ables which included
Apparently, sometime during the course of this rework on all associated NCRs,
the NRC inspector performed his surveillance of the area in question and
issued the subject report.
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We feel that the cable trays / cables in question were being controlled
satisfactorily by applicable procedures, personnel were working within
prescribed boundaries, and the apparent violations were the result of
observations made while rework was in progress.
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Attachment to TXX-5037
Page 4
October 9, 1986
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ITEM B (446/8604-V-03)
B.
Revision 3, dated JulyCriterion V of Appendix 8 to 10 CFR part 50
31, 1984, of the TUGCo QAP, requires that
accordance with documented instructions, proced
paragraph 4.2.1 5.b(2) of G&H Specification 2323-ES-100
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Revision 2,
of a vertical raceway, for No.18 through No. O con
vertical riser length is 25 feet or greater.
Paragraph 3.11.3.a of TUGCo Instruction QI-QP-11.3-26, Revision 24, a
paragraph 3.1 of B&R Procedure EEI 23, Revision 1, dated July
" Cable Support Grip Installation," reflect the above specification 21, 1983,
requirements.
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Contrary to the above, cable support grips were not evident on cables
(with conductors in the above size range) installed in cdele tray risers
containing tray sections T23GECX91 and T24GEDG98 that were greater tha
feet in height.
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RESPONSE TO ITEM 8
1.
Reaso_n f0.t Violation
The electrical erection specification, 2323-ES-100, Revision 2, and the
noted TUGCo instruction, QI-QP-11.3-26, Revision 24
describe ti.a sequence for cable installation (e.g.,,the point in the
do not clearly
process when cable grips must Le installed). Cable grips are not required
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until the installation is complete.
2.
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Corrective Steps Taken and ,the Results Archieved
This specification and instruction will be reviewed and revised as
necessary to clarify when cable grips must be installed.
in the vi3Tation will be installed at the proper time.
The grips noted
3.
Corrective Steps in Avoid Recurrence
.
The electrical erection specification will be reviewed to verify that the
installation sequences are properly addressed.
revised as necessary and the applicable implementing procedures andThe sp
instructions shall be reviewed and revised as necessary to ensure
compliance with the revised specification.
4.
DLtg Mhan Egl],Comoliance will hg Achieved
The date for full compliance will be provided not later than October 31,
1986,
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Log # TXX-6071
File # 10130
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IR 86-06
TEXAS UTILITIES GENERATING COMPANY
IR 86-04
BKYWAY TOWER . 480 NOR1H OLIVE STREET. LB. 88 . DALLAS. TEXAS 753DI
October 31, 1986
75Y1".hff?.03,
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Mr. Eric H. Johnson, Director
&c19
Division of Reactor Safety and Projects
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U. S: Nuclear Regulatory Commission
611 Ryan Plaza Drive, Suite 1000
Arlington, Texas . 76012
SUBJECT: COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446
SUPPLEMENTAL RESPONSE TO NRC NOTICE OF VIOLATION
INSPECTION REPORT NOS.: 50-445/86-06 AND
50-446/86-04
Dear Mr. Johnson:
We responded to Inspection Report Nos. 50-445/86-06 and 50-446/86-04 on
October 9, 1986 (TXX-5037).
In the response to Notice of Violation, Item A
(445/8604-V-02), we stated that we would provide the date of full compliance
by October 31, 1986. The "Date When Full Compliance Will Be Achieved" is June
1, 1987.
Very truly yours,
lhh
W. G. Co
il
By:
.
.
G. S. Keeley
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Manager, NuclearMcensing
RSB/amb
c - Region IV (Original + 1 copy)
Director, Inspection and Enforcement (15 copies)
U. S. Nuclear Regulatory Commission
Washington, D. C.
20555
Mr. V. S. Noonan
Mr. D. L. Kelley
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A Dis 1510N OF TEX A5 LTELETIES FLECTRIC lintPANY
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