TXX-4932, Responds to Violations Noted in Insp Repts 50-445/85-13 & 50-446/85-09.Corrective Actions:Insp Findings Evaluated & Nonconformance Repts Issued for Valid Deficiencies

Responds to Violations Noted in Insp Repts 50-445/85-13 & 50-446/85-09.Corrective Actions:Insp Findings Evaluated & Nonconformance Repts Issued for Valid Deficiencies

ML20206N087
Person / Time
Site:	Comanche Peak
Issue date:	08/14/1986
From:	Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
TXX-4932, NUDOCS 8608260083
Download: ML20206N087 (7)

Text

I Log # TXX-4932 File # 10130 IR 85-13 85-09 TEXAS UTILITIES GENERATING COMPANY 88KYWAY TOWER e 400 NORTH OLIVE NTREET.1.I5. m B e DAILAN. TEXAN 75308 August 14, 1986

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Mr. Eric H. Johnson, Director Division of Reactor Safety and Projects B l 51986 U. S. Nuclear Regulatory Commission l'Lp 611 Ryan Plaza Drive, Suite 1000 "

Arlington, TX 76012

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT NOS.: 50-445/85-13 AND 50-446/85-09

Dear Mr. Johnson:

In a phone discussion with Mr. D. M. Hunnicutt on July 3, 1986, we advised Region IV that the schedule for corrective action as stated in our response to Violation 445/8513-V-01 has been modified.

The attachment to this letter provides a revised response which expands and modifies our original response.

Very truly yours,

, M D141 W. G. Counsil JWA/gj Attachment 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 8609260003 860814 PDR ADOCK 05000445 G PDR 2K6%

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f Revised Response (8-14-86) to Violation 445/8513-V-01

1. Reason for the Violation We have reviewed each of the findings identified in the Notice of Violation and conclude that a lack of understanding of the requirements for sleeve identifications was the cause of those findings.

2. Corrective Steps Which Have Been Taken and Results Achieved All findings have been evaluated by Engineering and NCR's written for valid deficiencies. Many of the sleeves noted are unused and do not require identification until they are utilized. Those sleeves which were found to have incorrect / incomplete identification are being corrected.

Generic NCR's were written for Unit I buildings to identify and resolve any installations which did not properly reflect design requirements prior to the issuance of DCA-21,464. Disposition of these generic NCR's involved field verifications which have recently been completed. For Unit 2 buildings, field verifications have been initiated to insure compliance with design requirements. These efforts are scheduled for completion by October 15, 1986.

3. Corrective Steps Which Will be Taken to Avoid Further Violations Design change, DCA-21,464 was issued in Julf,1985 to clarify through sleeve identification requirements. Construction Installation Procedures ECP-19 & ECP-19A are being revised to incorporate design requirements.

Craft personnel will be trained to the revised procedures by August 20, 1986. Surveillance will verify that design requirements are being properly implemented. The surveillance will be completed by September 30, 1986.

4. Date When Full Compliance Will Ba Achieved September 30, 1986

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. TEXAS UTILITIES GENERATING CO31PANY CONFERENCE HEMORANDUM OATE 11oly 3.1984 RECORDED BY:

TIME a.15 am J. W. Audas I -

ORIGINATED BY: RECEIVED BY:

J. W. Audas D. M. Hunnicutt Reaion IV SUBJECT LOMANCHE PEAK STEAM ELECTRIC STATION Violation 445/8513-V-01

SUMMARY

T snnko to Mr. Hunnicutt in Mr. Westerman's absence. I advised Mr. Hunnicutt that we were not meetino our schedule for corrective action as stated in our response to violation 445/8513-V-01. I stated that we would send a letter revising this schedule.

Note: Licensing received notice of this change by telecopy on July 2,1986 at 4:30 p.m. However, the memo was dated June 27, 1986. Review of this issue indicates that Licensing should have been notified of this change prior to June 1, 1986.

I have attached copies of the violation, the response, and the memo of June 27. 1986, to aid in understanding this issue.

FOLLOW-UP ACTION Licensino to prepare letter to Region IV (with input from CC/Encineerinq) modifying our resoonse.

DISTRIBUTION JWA.JCH, DRW, JSM, GSK, D. Noss, J.F. Streeter, L.D. Nace, W.G. Counsil

.( No+tc . J Wol~koa - rw 0 1 D. Criterion V of Appendix B to 10 CFR Part 50, as implemented by the TUGC0 .

QAP, Section 5.0, Revision 2, dated May 21, 1981, requires that activities ~

affect'ing 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, l or drawings.

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i Paragraph 3.1.1, subparagraphs b and c, of TUGC0 Procedure QI-QP-11.3-8, -

- Revision 0, -issue date July 7,1978, " Identification and Color-Coding Inspections," require that conduit designation shall be applied with black

. ink or paint and that identification of conduit be verified at both sides of all walls and slabs through which conduit passes.

Paragraph'3.1.1, subparagraph b, of TUGC0 Procedure QI-QP-11.2-23.7, Revision 1, issue date January 5,1980, " Verify Conduit Identifications,"~

~~ similarly requires that conduit be identified on both sides of all walls-_

and' slabs'through'which conduit passes. Subparagraph c. of this paragraph

' states, in part, " Groups of embedded conduits which are flush with the surface of walls, floors and manholes shall be identified on the surface or the wall, floor, or manhole by attaching an identification template near the conduit bank. . . ." - " ~

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Contrary to the above, the following examples of incomplete and missing '

- conduit identifications were noted in the Unit 1. lower cable spread room, .

" auxiliary building, and safeguards building: .

1.

Two conduits attached to embedded conduit wall sleeve TSW-A-020 were not identified on the identification template and one conduit which

_ . _ . . __ ._ was. identified on the_ template as being present did not, in fact, exist. -

2.

Two banks of embedded conduit wall sleeves below sleeve TSW-A-023 had no form of identification.

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3. At tray section T14GCDH27, there were four floor sleeves which were not identified by either identification template or conduit marking.

4. At tray section T24WAEF, there were two floor sleeves with an i

incomplete identification template; i.e., the template contained only the letters TFS.

5. Below battery pack CPI-ELBPSG-187 (circuit ESB7-11), there were two floor sleeves which were not identified.

6.

At a tray section above junction box JB1A-1332, the embedded conduit wall sleeves were not identifiei by either identification template or marking.

7. - Three of five floor sleeves at tray 'section T220ABA41 were unmarked.

- 8. Four floor sleeves at tray scction T120ABB23 were unmarked.

9.

Conduits attached to embedded conduit wall sleeve TSW-A-030 were not identified on the identification template which was present.

This is a Severity Level IV violation (Supplement II) (445/8513-V-01).

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.  ? R:;sponse to Notice of Violation

, Item D -(445/8513-V-01)

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1. Reason for the Violation We'have reviewed each of these findings and concluded that a lack of '

understanding of the requirements for sleeve identifications was the cause of those findings. Many of the sleeves noted are unused and do not require identifications until they are utilized. Those sleeves

%hidh were found;To have incorrect /inconplete identification are being

,, corrected. '.

2.'~ Corrective Steps Which ilave BEen Taken and Results' Achieved To ensure compliance within the ES-100 Specification requirements for {

sleeve identification, we will be performing walkdowns of all power i

. and non-power through-wall and through-floor sleeves. In

' addition,'we have' initiated a comparison review of ES 100, Drawing

. 2323-El-1701, DCA',21464 and Installation and Inspecticn procedures to

. ' ensure that design 'requirenients are consistently implemented.

3. Corrective Steps Which Will be Taken to Avoid Further Violations Following the documeritation review we will train personnel to ensure ,

proper understanding of these requirements. It is anticipated that  ;

the above actions will be completed by June 1, 1986.

Quality Surveillance of the activity will be performed by July 2, 1986, to assess the effectiveness of training.

4. Date When Full Complia'nce Will'8e Achieved The date of full compliance will be June 1, 1986.

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hhject,__, , COMANCHE. PEAK STEAM ELECTRIC STATION r1 TEM D (445/8513-V-01) -

TRACKING ITEM 219 . __.

IDENTIFICATION AND COLOR CODINC OF CONDUlTS -

REF: 1) TXX-4694

2) CPPA-48,955 The following is submitted to providf the current status of the enrrective actions specified in Reference 1. The innue involves identification and color coding l of conduits. ~

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corrective actions specified by' Reference'l are as follows:

a) Concluct a walkdown of all power and non power through floor sleeves.

b) Af ter complation of these walkdowns, an EngineerinP. review wt11 be performed of drawings, design changes and instalIntion and innpection procedures.

c) Conduct training of appropriate personnel. ,

d) Date of compliance scheduled for June 1, 1986.

e) Quality Surveillance scheduled for July 2, 1986 ,to verify compliance.

Performance of the initial walkdown p.cncrnted NCR's which identiifr,1 a potentfally reportable item /cvent (SN-162/SDAR-Up-86-32). Due to rhe.

initiation of this item and the ensuing evaluation, which involves additional walkdowne scheduled for completion by November 10, 1986, our previously indiented completion dates for the corrective action for the Notice of Violation cannot be met.

The corrective actions will be completed after the Engineering evaluation of SDAR CP-86-32 which is currently scheduled for December 31, 1986. We request an extension to January 31, 1987 as the date of compliance for corrective action specified in our .

response for the Notice of Violation.

If any additional information can be provided please contact mc or my staf f directly.

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R. P. Baker Site Coordinatnar RPB/NDH/sc ccs ARMS n#4 .J ,h p s, p e wee -e