ML20215N765

Notice of Violation from Insp on 860601-30

ML20215N765
Person / Time
Site:	Comanche Peak
Issue date:	10/31/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20215N761	List: IR 05000445/1986014 ML20215N760 ML20215N765
References
50-445-86-14, 50-446-86-11, NUDOCS 8611070246
Download: ML20215N765 (4)

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-APPENDIX'A NOTICE OF VIOLATION Texas' Utilities Electric Company Dockets:.50-445/86 50-446/86-11

-Comanche Peak Steam klectric Permits: CPPR-126 Station, Units 1 and 2 CPPR-127:

During an NRC inspection conducted on June 1-30, 1986, violations of NRC requirements were identified. The violations involved: A. failure to identify, tag,' segregate and report nonconforming components; B~. failure to follow electrical-procedures, e.

welding and grinding; (2)g., (1)-to failure failure applytoproper protect electrical components identification numbers to from conduit and junction box; (3) failure ~ to properly ~ color code. conduit and junction box;-(4) failure to hand ~ tighten connectors between flexible and rigid

-conduit; (5)' failure to protect unlanded and-installed cable; (6) failure to

' color code installed cable every 5 feet; and C. failure to provide instructions which address drilling holes in cable trays and protecting installed cable. -In accordance with the " General Statement of Policy and~ Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986), the violations a.re listed below:

A. Failure to Identify, Tag, Segregate and Report Nonconforming Thermocouples Criterion XV of Appendix B to 10 CFR Part 50 as implemented by Section'17.1.15 Utilities Generatingof the Final Company Safety)

(TUGCo Analysis Quality Assurance Report (FSAR) and by Texas 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). -

This is a Severity Level V violation. (SupplementII)

8. Failure to Follow Electrical ~ Procedures Criterion V of Appendix B to 10 CFR Part 50, as implemented by FSAR Section.17.1.5 and TUGCo QAP Section 5.0, Revision 3, dated. July 31, 1984, requires that activities affecting quality shall be prescribed by 8611070246 861031 '

PDR ADOCK 05000445 G PDR

f-2 documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

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".

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Section E-7.3 of Appendix B to the abo $e 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 T24BREC11 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 un grinding (to prepare the area for painting) protected was while 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).

2. Paragraph 3.6.2 of_TUGCo Instruction QI-QP-11.3-23, Revision 13.-

dated September 6,1985, " Class 1E Conduit Raceway Inspections,"

states, in part, ". . . Identification shall be as indicated below:

"A" Train - Orange - 0 Associated "A" Train - Orange with white stripe . . . .

A typical conduit identification number is depicted as follows:

"C14R16397 . . . ."

Contrary to the above, orange conduit C23005257, 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-5780, but orange only along the remainder of the run. The rigid conduit connected to flex conduit C23005357 and junction box JB25-571, was physically marked C2305357. The first digit of the unique five digit identifier was not applied (446/8611-V-06).

3. Paragraph 3.8.3 of TUGCo Instruction QI-QP-11.3-23, Revision 13,

dated September 6, 1985, " Class 1E Conduit Raceway Inspections,"

states, in part, " Safety-related junction boxes containing safety-related cable shall be color-coded prior to cabic installation

. . . Paint color shall match as close as possible the appropriate

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cable jacket color of safety-related cables . . . where a raceway or junction box contains only associated cables, at least one white horizontal stripe shall be applied over each applicable Train color coded marking . . . ."

Contrary to the above, junction box JB2S-5780 contained Train "A",

orange cable, as well as at least one associated "A" Train cable, but was color coded orange wi.th a white stripe, indicating only associated cables. It was noted that. junction box JB25-571 did not have the 9 suffix physically indicated on the box (446/8611-V-05).

4. Paragraph 3.2.1.e of TUGCo Instruction QI-QP-11.3-28, Revision 30, dated May 21,1986, " Class 1E 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 C22005459 and C23010114 where they attach to the rigid conduits. Cables were installed, terminated, and energized.

This condition was also observed on approximately ten additional Class 1E conduits (446/8611-V-07).

5. TUGCo 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 l

that TUGC0 Instruction QI-QP-11.3-28, Revision 30, dated May 21, 1986, l

" Class 1E Cable Terminations," did not address conductor end i protection for cables which have had their outer jackets removed, but 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).

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6. Paragraph 3.1.3.c of TUGCo Instruction QI-QP-11.3-26, Revision 24, dated October 11,1985, " Electrical Cable Installation Inspection,"

i I states, in part, ". . . If field color coding becomes necessary, l Class 1E and associated Class 1E cables shall be color banded at intervals not exceeding 5 feet, and shall be visible at all openings . . . ."

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4 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).

This is a Severity Level IV violation based on the six examples described above (Supplement II).

C. Failure to Prescribe Procedures / Instructions Criterion V of Appendix B to 10 CFR Part 50, as implemented by FSAR Section 17.1.5 and TUGCo 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, TUGCo 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; 446/8611-V-10).

This is a Severity Level IV violation. (SupplementII)

Pursuant to the provisions of 10 CFR 2.201, Texas Utilities Electric Company is hereby required to submit to .this office, within 30 days of the date of the letter transmitting this' Notice, a written statement or explanation in reply, including for each violation: (1) the reasons for the violations if admitted, (2) the corrective steps which which have been taken'and the results achieved, (3) the corrective steps which will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending your response time.

Dated at Arlington, Texas this 31th day of October 1986

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