TXX-6387, Suppls Response to Violations Noted in Insp Repts 50-445/86-06 & 50-446/86-04.Corrective Actions:Rev 7 to B&R Const Installation Procedure EEI-7, Cable Pulling, Revised to Incorporate Requirements of DCA
| ML20215L441 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/08/1987 |
| From: | Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| TXX-6387, NUDOCS 8705120247 | |
| Download: ML20215L441 (6) | |
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Log # TXX-6387 M
File # 10130 IR 86-06 IR 86-04 E
E Ref # 10CFR2.201 1UELECTRIC May 8, 1987 M hm G. Ommil Emuone Ske Preudme U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.
20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 INSPECTION REPORT NOS.: 50-445/86-06 AND 50-446/86-04 REVISED DATE OF FULL COMPLIANCE FOR NOTICE OF VIOLATIONS (N0V)
ITEMS A(1), A(2) AND B REF:
- 1) TUGC0 Letter TXX-5037 from W. G. Counsil to E. H. Johnson dated October 9, 1986.
- 2) TUGC0 Letter TXX-6071 from W. G. Counsil to E. H. Johnson dated October 31, 1986,
- 3) TUGC0 Letter TXX-6213 from W. G. Counsil to E. H. Johnson dated January 22, 1987.
Gentlemen:
In pursuing the corrective actions as delineated in our referenced responses to NOV 446/8604-V-02 [ Items A(1) and A(2)] and 446/8604-V-03 (Item B), we have determined that revisions to our responses are required. We hereby submit our revised responses in the attachment to this letter. The original Notice of Violation and the TU Electric responses have been included to aid in understanding our revised responses. Those portions of the responses which have been revised are denoted by a revision bar in the right margin.
The Corrective Action section for NOV 446/8604-V-02 [ Item A(1)] was updated to show that the proposed corrective action has been co:apleted. The overall review of G&H Electrical Erection Specification 2323-ES-100 has taken longer than anticipated, therefore, the Date of Full Compliance has been revised from j
June 1,1987, (Reference 2) to September 1,1987.
Our response to NOV 446/8604-V-02 (Item A(2)] (Reference 3) has been revised
,I to clarify our corrective action and indicate the new dates of compliance.
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TXX-6387 May 8, 1987 Page 2 of 2
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In pursuing the Corrective Steps to Avoid Recurrence for NOV 446/8604-V-03 (Item B), we have determined that additional measures may be required. -We are currently developing a course of action that will ensure cable grips are i
installed where needed. We will provide a revised response no later than June 30, 1987. The original Date of Full Compliance was October 31, 1986.
Very truly yours, i
Wh<l W.G.Counsl1
/
By:
.,1 G. S. Keeley 7
Manager, NucleafTie isti'g--
RSB/mlh Attachment c - Mr. E. H. Johnson, Region IV Mr. D. L. Kelley, RI - Region IV Mr. H. S. Phillips, RI - Region IV I
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1 Attachment to TXX-6387 May 8, 1987 Page 1 of 4 NOTICE OF VIOLATION ITEM A (445/8604-V-02)
A.
Criterion V of Appendix B to 10 CFR Part 50, as implemented by Section 5.0, Revision 3, dated July 31, 1984, of the TUGC0 QA Plan (QAP), requires that activities affecting quality shall be prescribed by and accomplished in accordance with document 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. Cables shall be neatly trained, without interlacing, in all cable trays, trench boxes and panels...." Paragraph 4.2.2.4 of this specification states, in part, " Cables in cable trays... shall be laid therein whenever possible.
Cable in trays shall be laid to a uniform depth."
Contrary to the above:
1.
TUGC0 Instruction QI-QP-11.3-26, Revision 24, dated October 11, 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 CEI-7, Revision 6, dated March 26, 1986,
" Cable Pulling," did not address installation of cables in trays to a uniform depth.
REVISED RESPONSE TO ITEM Afl) 1.
REASON FOR VIOLATION The attributes of concern in this violation relate to broad, standard terms that, in general, address good workmanship. The electrical erection specification, 2323-ES-100, does not arovide a clear discussion of these attributes.
Requirements involving t1e interlacing of trained cable are addressed procedurally for some ap lications, but, in general, these attributes are not addressed by im lementing procedures.
2.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED DCA-25475, Rev. O was issued October 1,1986, to G&H Specification 2323-ES-100, " Electrical Erection," to clarify the general requirements for installation and training of cables in cable trays. The B&R t
Construction Installation Procedure EEI-7, Rev. 7 " Cable Pulling," was revised by Document Change Notice (DCN) No. 5 on October 31, 1986, to incorporate the requirements of the DCA. Revision 31 to TUGC0 Inspection Instruction QI-QP-ll.3-26, " Electrical Cable Installation Inspection," was issued on January 23, 1987, to incorporate the requirements of the DCA.
NCRs E86-202317, E86-104159 and E86-250405 have been written to address the specific issues in this violation.
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9 Attachment to TXX-6387 May 8, 1987 Page 2 of 4 REVISED RESPONSE TO ITEM Aft) - CONT'D 3.
CORRECTIVE STEPS TO AVOID RECURRENCE The electrical erection specification will be reviewed to identify any additional requirements that were addressed in a geaeral manner and require clarification. The specification will be revised as necessary and the applicable implementing procedures and instructions shall be reviewed and revised as necessary to ensure compliance with the revised specification.
4.
Date When Full Como11ance Will Be Achieved The reviews and revisions described in Section 3 will be completed no later than September 1, 1987.
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Attachtnt to TXX-6387 May 8, 1987 Page 3 of 4 NOTICE OF VIOLATION ITEM Af2) (446/8604-V-02)
A.
Criterion V of Appendix B to 10 CFR Part 50, as implemented by Section 5.0, Revision 3, dated July 31, 1984, of the TUGC0 QA Plan (QAP), requires that activities affecting quality shall be prescribed by and accomplished in accordance with documented instruction, procedures, or drawings.
Paragraph 4.2.2.3.a of Gibbs & 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.
Cables shall be neatly trained, without interlacing, in all cable trays, trench boxes and panels..." Paragraph 4.2.2.4 of this specification states, in part, " Cables in trays... shall be laid therein whenever possible. Cable in trays shall be laid to a uniform depth".
Contrary to the above:
2.
Cables were observed to be spilling over the sideralls of cable trays T240SF003, 004, 005, 006, 007, 008 and T240SDA91.
Cables were also not laid in the tray at the vertical to horizontal transition between cable tray section T240SF003 and T240SF004.
(446/8604-V-02)
REVISED RESPONSE TO ITEM A(2)
We admit the violation and the requested information follows.
1.
Reason for Violation The cited instances of unacceptable cable installation observed in March 1986 were caused by poor craft workmanship and aggravated by corrective actions in progress to resolve interlacing problems previously identified on NCR E85-101983 in December 1985.
In addition, a review of B&R Construction Installation Procedure EEI-7 and TUGC0 Inspection Instruction QI-QP-ll.3-26 indicated that criteria governing the installation and inspection of electrical cable were insufficient to prevent the improper cable installation cited in the violation (N0V).
2.
Corrective Steos Taken and Results Achieved A request for engineering clarification (RFIC E-Ill80) was initiated on March 4, 1986, requesting that engineering evaluate cable tray nodes T240SF001, 002, 003, 004, and 005 for siderails and to document installation problems encountered during cable rework associated with NCR E85-101983. Design Change Authorization DCA-24,289, Rev. O, was issued on April 4,1986, to replace all or portions of 12" tray nodes T240SF001, T240SF002, T240SF003, and T240SF004 with 18" width trays to minimize cable congestion in the existing trays. DCA-24,289, Rev. 1, was issued on June 12, 1986, to further modify the cable tray assembly to alleviate installation problems associated with the irregular routing.
The design
Attachment to TXX-6387 May 8, 1987 Page 4 of 4 2.
Corrective Steos Taken and Results Achieved - cont'd change was implemented and the field installation was inspected and accepted by Quality Control on July 14, 1986.
DCA-24,479, Rev. O, was issued on May 12, 1986, to add 6" siderails from cable tray node T240SF005 through T240SF008 to prevent cable tray spillover.
The design change has been implemented, but final acceptance of the field installation is still pending QC inspection. No modification to cable tray node T240SDA91 was required. A review of the original raceway design for the cable tray nodes in question indicates that they were adequately sized to accommodate the scheduled cable runs and that modifications were made only to facilitate cable installation.
The cable rework associated with NCR E85-101983 is in progress.
3.
Corrective Steps Which Will Be Taken to Avoid Further Violations A Document Change Notice (DCN #5) was issued against Rev. 7 of B&R Construction Installation Procedure EEI-7 on October 31, 1986, to provide clarification of the G&H Electrical Erection Specification 2323-ES-100 requirements regarding cable installation above the cable tray siderails.
Appropriate craft personnel were trained to the revised procedural requirements. CDR 87-801 was issued on January 19, 1987, to document the lack of specific inspection criteria for cable tray spillover and the need for reinspection of existing cable installations for such conditions. G&H Electrical Erection Specification 2323-ES-100 will be revised to prohibit cables from extending above the top of cable tray siderails without prior Engineering approval, except where entering and exiting the cable tray.
Procedure EEI-7 will be revised to incorporate the additional 2323-ES-100 requirement (s) and the appropriate craft personnel will be trained to the revised procedural requirements.
TUGC0 Inspection Instruction QI-QP-11.3-26 was revised on January 23, 1987, to include an additional inspection attribute on cable tray overfill. Training of affected QC personnel was completed prior to issuance of the revised inspection procedure.
Existing cable installations will be reinspected to the revised requirements of procedure QI-QP-11.3-26.
4.
Date When Full Comoliance Will Be Achieved The cable rework associated with NCR E85-101983 will be completed by July 1, 1987.
G&H Electrical Erection Specification 2323-ES-100 will be revised by May 29, 1987.
Subsequent to the revision of Specification 2323-ES-100, Instruction QI-QP-ll.3-26 will be revised as required and existing cable installations will be reinspected. This reinspecton will be conducted as part of an overall room by room reinspection program and will be completed prior to fuel load.
B&R Construction Installation Procedure EEI-7 will be revised by September 1, 1987, with the appropriate craft personnel trained to the revised procedural requirements by October 1, 1987.
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