TXX-6186, Forwards Response to NRC Re Violations Noted in Insp Repts 50-445/86-14 & 50-446/86-11 on 860601-30. Corrective Actions:Ncr E-86-201710 Issued to Identify Damage to Thermocouples.Receiving Personnel Will Be Retrained

Forwards Response to NRC Re Violations Noted in Insp Repts 50-445/86-14 & 50-446/86-11 on 860601-30. Corrective Actions:Ncr E-86-201710 Issued to Identify Damage to Thermocouples.Receiving Personnel Will Be Retrained

ML20212R458
Person / Time
Site:	Comanche Peak
Issue date:	01/16/1987
From:	Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
TXX-6186, NUDOCS 8702020665
Download: ML20212R458 (16)

Text

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.- 4 Log # TXX-6186 File # 10130 IR 86-14 TEXAS UTILITIES GENERATING COMPANY 86-11 SKYWAY TOWER . 400 NORTH OLIVE STREET. LB. 88 . DAllAB. TEXAS TS301 January 16, 1987 r, ~ .

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b JAN 2 31987 Mr. Eric H. Johnson, Director Division of Reactor Safety and Projects "g- - --- '

U. S. Nuclear Regulatory Commission

i 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, concernir.g 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, I6M W. G. Counsil WJH/mlh c - NRC Region IV (0 + 1 copy) 1 Director, Inspection & Enforcement (15 copies)

U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. V. S. Noonan Mr. D. L. Kelley 8702020665 870116 5 DR ADOCK 0500 gf s un usiox or rms twmu nrcruic antmr II Q

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Attachment

. TXX-6186 Page 1 of 15 NOTICE OF VIOLATION ITEM A (445/8614-V-01 & 446/8611-V-01) o ,

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 .1at two damaged thermocouples had been returned from the field and instead of tagging and segregating them as nonconforming items they storedThem in warehouse B bins with six other conforming or acceptable thermocouples (445/8614-V-01; 446/8611-V-01). A RESPONSE TO ITEM A (445/8614-V-01 & 446/8611-V-01)

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 disposi, tion. 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 TXX-6186 Page 2 of 15 NOTICE OF VIOLATION 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 TXX-6186 Page 3 of 15 NOTICE OF VIOLATION JTEM 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.I. 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 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 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 TXX-6186 Paga 4 of 15 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 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 include a warning for the first offense and automatic termination of the employee for the second offense.

4. Date of Compliancg Corrective measures associated with Nonconformance Reports I-86-202744 and E-86-202745 will be accomplished by June 1,1987.

Attachment TXX-6186 Page 5 of 15 NOTICE OF VIOLATION ITEM B.2 (446/8611-V-06)

B. Criterion V of Appendix 8 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 - 9 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 TXX-6186 Pags 6 of 15 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 IE 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 The corrective measures associated with Nonconformance Report M-86-201905 will be accomplished no later than June 1, 1987.

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Attachment-3 TXX-6186

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NOTICE OF VIOLATION ITEM B.3 (446/8611-V-05) CONT'D B. Criterion V of Appendix B to 10 CFR Part 50, as implemented by FSAR 1 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 i 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 IE Conduit Raceway Inspections," states, in

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part, " Safety-related junction boxes containing safety-related cable shall be color coded prior to cable installation ... Paint color shall i match as close as possible the appropriate cable jacket color of j safety-related cables ... where a raceway or junction box contains

only associated cables, at least one white horizontal stripe shall be i

applied over each applicable Train color coded marking..."

Contrary to the above, junction box JB2S-5789 contained Train "A",

i orange cable, as well as at least one associated "A" Train cable, but was color coded orange with a white stripe, indicating only associated 1 cables. It was noted that junction box JB25-571 did not have the #

l suffix physically indicated on the box (446/8611-V-05).

I RESPONSE TO ITEM B.3-(446/8611-V-05) i i We admit the violation and the requested information follows.

i 1. Reason for Violation Conditions described in this finding are the result of the failure by 1 personnel to properly implement the color coding and identification

! requirements of EEI-16, " Field Color Coding of Electrical Cable" and QI-j 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-II.10-1A and not QI-QP-11.3-23 as stated i j in the NRC Report. However, the applied inspection criteria was the same.

l 2. Corrective Action Taken j Nonconformance Reports E-86-201921, M-86-201905 and M-86-201939 were i written to identify and correct the noted discrepant conditions.

l Nonconformance Report E-86-201921 was dispositioned, work completed and the conduit satisfactorily reinspected August 5, 1986.

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Attachment TXX-6186 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 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 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 TXX-6186 Page 9 of 15 NOTICE OF VIOLATION 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 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 cenduits C22905459 and C23S10114 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). .

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 1E Cable Terminations."

The connector that attaches the rigid conduit to flexible conduit C23910114, when reexamined, was found to be hand tight.

Although not specifically documented, each of the reported deficiencies was evaluated by the TUGC0 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 therefore not yet required to be " hand tight", or the flex connectors involved non-lE 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.)

Attachment TXX-6186 4

Page 10 of 15 NOTICE OF VIOLATION 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 dispositior.ed, 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-ll.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 TXX-6186 Page 11 of 15 NOTICE OF VIOLATION ITEM B.5 (446/8611-V-11)

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

" Class 1E Cable Terminations", did not address conductor end 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-ll).

RESPONSE TO ITEM B.5 (446/8611-V-ll)

We deny the alleged violation for the reasons that follow.

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.

Attachment TXX-6186 Page 12 of 15 NOTICE OF VIOLATION RESPONSE 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 (agl individual conductors) is capped or protected.

In2tructions QI-QP-11.3-28, Revision 30, dated May 21,1986, " Class 1E Cable Terminations", and EEI-8, " Class 1E and Non-class 1E 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 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.

TUGCO's evaluation of this finding indicates that the existing conditions were in accordance with the applicable procedures and accurately reflect the specification requirements.

Attachment TXX-6186 Page 13 of 15 NOTICE OF VIOLATION, ITEM B.6 (446/8611-V-12)

8. 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 typ(ap)ropriate to the circumstances and shall be accomplished in accordance wffi 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 IE 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 850 of the safeguards building, the black cable installed in junction box JB2S-5448 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).

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 eel-16, " Field Color Coding of Electrical Cable", and Q1-11.3-26, " Electrical Cable Installation Inspection."

2. Corrective Action Taken Nonconformance Reports E-86-201808 and E-86-201824 were written to identify and disposition the conditions in junctinn boxes JB2S-544B and JB2S-956G respectively.

Both Nonconformance Reports have been dispositioned, work completed and the cables satisfactorily reinspected July 17, 1986.

r Attachment TXX-6186 Page 14 of 15 NOTICE OF VIOLATION 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 JB2S-5448 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 conclusion that the errors were isolated.

4. Date of Como11ance Compliance has been achieved, as described above.

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Attachment TXX-6186 Page 15 of 15 NOTICE OF VIOLATION 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 those 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 installation of Ty-raps and were completed June 16, 1986.

Applicable construction and quality personnel were trained in the revised 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 Recurrence The corrective actions taken will prevent recurrence.

4. Date of Comoliance Compliance has been achieved, as described above.