TXX-6481, Revises Response to Item B of Violation Noted in Insp Repts 50-445/86-06 & 50-446/86-04.Corrective Actions:Procedures for Engineering Insps of Class 1E Cable Runs Will Be Issued. Completion Date for Cable Rework Revised to 870901
| ML20234E970 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/30/1987 |
| From: | Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| TXX-6481, NUDOCS 8707080056 | |
| Download: ML20234E970 (3) | |
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-w Log # TXX-6481 4
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File # 10130 5
IR 86-06
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r IR 86-04 Ref: 10CFR2.201 7UELECTRIC William G. Counsil becutsve Vwe Preaknt 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 N0.:
50-445/86-06 AND 50-446/86-04 REVISED DATES OF FULL COMPLIANCE TO NOTICE OF l
VIOLATION (NOV) ITEM A(2) AND REVISED RESPONSE TO NOV ITEM B
REFERENCE:
- 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
- 4) TV Electric Letter TXX-6387 from W. G. Counsil to NRC dated May 8, 1987 l
Gentlemen:
In our response to NOV 446/8604-V-03 [ Item B] (Reference 4), TV Electric stated that we were developing a course of action that would ensure that cable grips were installed where needed, and that we would provide a revised
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response no later than June 30, 1987. We hereby respond to Item B in the attachment to this letter.
The original Notice of Violation has been included to aid in understanding our revised response.
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In pursuing the corrective actions as delineated in our response (Reference 4) to NOV 446/8604-V-02 [ Item A(2)], we have determined that a revision to the date when full compliance will be achieved is required. Our response stated I
that the cable rework associated with NCR E85-101983 would be completed by July 1, 1987. Rework of the subject cables has been delayed due to work on Unit 1 switchgear. Accordingly, the date for completion of cable rework associated with NCR E85-101983 is hereby revised to be September 1, 1987.
Very truly yours, 8707080056 G70630
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s gDR ADOCK 0500 5
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g W. G. Counsil RSB/mlh Attachment c - Mr. R. D. Martin, Region IV Resident Inspectors - CPSES (3) o\\
400 North Olive Street LB 81 Dallas, Texas 75201
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Attachment to TXX-6481 June 30, 1987 Page 1 of 2 NOTICE OF VIOLATION. ITEM B
,r (446/8604-V-03)
B.
Criterion V of Appendix B to 10 CFR Part 50, as implemented by Section 5.0, Revision 3, dated July 31, 1984, of the TUGCo QAP, requires that activities affecting quality shall be prescribed by and accomplished in accordance with documented instructions, procedures, or drawings.
Paragraph 4.2.1.5.b(2) of G&H Specification 2323-ES-100, Revision 2, requires that a cable support be provided as close as practicable to the top of a vertical raceway, for No.18 through No. O conductor sizes, when the vertical riser length is 25 feet or greater.
Paragraph 3.11.3.a of TUGCo Instruction QI-QP-11.3-26, Revision 24, and paragraph 3.1 of B&R Procedure EEI 23, Revision 1, dated July 21, 1983,
" Cable Support Grip Installation," reflect the above specification requirements.
Contrary to the above, cable support grips were not evident on cables (with conductors in the above size range) installed in cable tray risers containing tray sections T23GECX91 and T24GEDG98 that were greater than 25 feet in height.
RESPONSE TO ITEM B (446/8604-V-03)
TV Electric accepts the alleged violation and the requested information follows:
1.
Reason for Violation Cable support grips are needed to defer possible long term (life of the l
plant) detrimental effects of the weight of the cable on the cable itself.
Even though our standard practice is to install support grips after the placement of all cables in a tray section, our review of these findings has indicated that no systematic program or guidance has been provided specifically directing the installation or sequence for the installation of cable grips. A program or guidance is required to assure that the final completed cable and tray installation conforms to design and installation requirements. When the NRC inspection was performed, cable grips had not been installed in tray sections T23GECX91 and T24GEDG98 since additional work in these sections was anticipated.
Since l
Engineering had not directed the installation of cable grips, the inspection per Paragraph 3.11.3.a of QI-QP-11.3-26 was not required.
Attachment to TXX-6481 June 30, 1987 Page 2 of 2
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RESPONSE TO ITEM B (Cont'd) l (446/8604-V-03) 2.
Corrective Steos Taken and Results Achieved Field Verification Method (FVM) procedures will be issued providing instructions and criteria for engineering inspections of Class 1E cable runs to determine where cable grips are required. As sequenced by the project schedule, the inspections will be conducted on individual cable installations as work that could-affect the need for cable grips at that location is completed.
Design Change Authorizations, (DCA's) will be issued as required to specify the required cable grip installations based on the results of these inspections.
Specification 2323-ES-100,
" Electrical Erection Specification," will be revised to state that l
Engineering is responsible for identification of required Class 1E cable support grip installations.
Should additional work on a cable installation be identified after the engineering inspection has been completed, engineering will specify the installation of any required cable support grips.
j Deficiency Report (DR) #C-87-2743 has been issued to document the l
conditions described in this violation.
3.
Corrective Steos Which Will be Taken to Avoid Further Violations q
The corrective steps taken in Section 2 above should prevent further recurrence of this violation.
4.
Date When Full Comoliance Will be Achieved The revision to Specification 2323-ES-100 vill be issued no later than September 1, 1987.
The required FVMs will be issued by October 15, 1987.
The performance of engineering inspections, generation of DCAs and installation of cable grips will be completed prior to fuel load for Unit 1 and Unit 2, respectively.
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