TXX-7120, Revised Response to Violation Item a (445/8626-V-02) Noted in Insp Repts 50-445/86-26 & 50-446/86-22.Corrective Actions:Nonconformance Rept E-86-103883S & Const Deficiency Rept 87-4746EC Issued to Address Pull Ropes

Revised Response to Violation Item a (445/8626-V-02) Noted in Insp Repts 50-445/86-26 & 50-446/86-22.Corrective Actions:Nonconformance Rept E-86-103883S & Const Deficiency Rept 87-4746EC Issued to Address Pull Ropes

ML20238E143
Person / Time
Site:	Comanche Peak
Issue date:	12/31/1987
From:	Counsil W, John Marshall TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
TXX-7120, NUDOCS 8801050016
Download: ML20238E143 (3)

Text

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M

== Log # TXX-7120

\ L  : File # 10130

= = IR 86-26 IR 00' 1UELECTRIC wmiam c. couma December 31, 1987 Execuene Vwe President V. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555

SUBJECT:

COMANCllE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 REVISED RESPONSE TO NRC INSPECTION REPORT NOS. 50-445/86-26; 50-446/86-22 REF: (1) TV Electric Letter TXX-6562 from W. G. Counsil to NRC dated July 13, 1987 Gentlemen:

The referenced letter transmitted our response to Notice of Violation item A (445/8626-V-02). As a result of changes in the structure of our electrical construction and inspection procedures, further evaluation of the effects of pull ropes in conduit, 6nd further development of our Post Construction Hardware Validation Program, we have determined that our original response requires revision. Our response to Notice of Violation Item A is hereby revised accordingly.

Where revised responses are provided, the revised sections are denoted by a revision bar in the right margin.

Very truly yours, N. 6. lou rs E (

W. G. Counsil By:

J. S. Marshall Supervisor, Generic Licensing RDD/grr c - Mr. R. D. Martin, Region IV Resident inspectors, CPSES (3)

$$[$00$

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400 North Ohve Street LB 81 Dallas. Texas 75201

~ Attachment to TXX-7120

December 31, 1987 Page 1 of 2 '

NOTICE OF VIOLATION If[M A (4T5/8626-V-02) ,

A. Criterion V of Appendix B to 10 CFR Part 50, as implemented by the TUGC0 Quality Assurance Plan (QAP), Section 5.0, Revision 3, dated July 31, 1984, requires that activities affecting quality shall be prescribed by and accomplished in accordance with documented instructions, procedures, or drawings of a type appropriate to the circumstances.

Paragraph 3.1.2.e of TUGC0 Procedure QI-QP-11.3-40, Revision 14, dated ,

January 9,1984, states, in ) art, " Verify that ...all cable pulling aids-have been removed (i.e., fis1 tape, tape rope, etc.)."

Paragraph 3.1.1.2.c of the above procedure, Revision 18, dated May 18, 1984, states, " Verify that ... pulling aids (i.e., rollers, fish tape, tag rope) have been removed from raceway."

Contrary to the above, TUGC0 inspectors performing post construction inspections failed to identify cable pulling ropes remaining in Class 1E conduit C12018896 and Class 1E cable tray T130ACG57 located in the Unit I reactor building and auxiliary building, respectively (445/8626-V-02).

REVISED RESPONSE TO ITEM A (445/8626-V-02]

TV Electric accepts the alleged violation and the requested information follows:

1. Reason for Violatic3 Regarding cable tray T130ACG57, construction procedures controlling cable g pulling activities performed subsequent to QC acceptance of raceway systems did not require QC reverification of pulling aid removal.

Regarding conduit C12018896, Revision 14 of QI-QP-11.3-40 in effect at the time of post construction inspection required QC inspectors to identify ,

1 visible pulling aids but did not require the removal of junction box, pull

' box or conduit covers to verify that pulling aids had been removed.

-2. Corrective Steps Taken and Results AcM eved

• Nonconformance Report (NCR) E-86-1038835 and Construction Deficiency Report (CDR) 87-4746EC (previously NCR E-86-103981) were issued to address pull ropes.in conduit C12018896 and cible tray T130ACG57, respectively.

Both documents have been dispositioned " rework" by directing the removal' of the pull ropes. NCR E-86-1038835 has been closed.

l Corrective Action Request (CAR) 87-59 has been initiated which will address the generic implications of this violation and will define appropriate corrective actions.

. .- Attachment to-TXX-7120 December 31, 1987 Page 2.of 2

3. Corrective Steps Which Will be Taken to Avoid Further Violations On July 24, 1987, Procedure eel-7, " Cable Pulling," was revised to require removal of all pulling aids (pull ropes, fish tape, etc.) after cable pulls into covered cable trays or conduit are completed. After further evaluation it was detennined that, with certain restrictions, it is acceptable _to leave pull ropes in conduit runs. On October 28, 1987, Design Change Authorization (DCA) 58763 Rev. O to 2323-ES-100 was. issued providing this allowance and detailing the restrictions.

A DCA to revise 2323-ES-100 is being prepared which will emphasize that pull ropes are to be left in conduits only when their removal may result in damage to adjacent cables.

Quality Instruction QI-QP-11.3-40, " Post Construction Inspection of

' Electrical Equipment and Raceways," has been deleted. In process inspections for pulling aids are performed in accordance with procedures-NQA-3.09-3.02, " Electrical Raceway-Cable Tray," and NQA-3.09-3.03,

" Electrical / Raceway Conduit Procedure." These procedures provide inspection criteria conunensurate with the requirements contained in Specification 2323-ES-100.

l On November 6, 1987 the Director of Construction issued a directive I requiring that all visible metal fish tapes be removed from Unit 1 and Unit 2 raceways,-or if removal was not feasible an NCR was to be written.

This action was reported complete on December 18, 1987.

A walkdown of existing Unit 1 installations will be performed as part of our Post Construction Hardware Validation Program (PCHVP). The walkdown will be perfonned as directed by procedure CPE-SWEC-FVM-EE/ME/IC/CS-90 and Quality Instructions NQI 3.09-E-002, "PCHVP Reinspection of Electrical l

Conduit," and NQI 3.09-E-003, "PCHVP Reinspection of Electrical Equipment." These procedures provide inspection criteria for pulling. aids that are commensurate with the requirements contained in Specification 2323-ES-100. A similar walkdown will be performed for existing installations in Unit 2.

4. Date When Full Compliance Will be Achieved l The DCA revising 2323-ES-100 will be issued no later than January 29, 1988.

The Unit I walkdown per CPE-SWEC-FVM-EE/ME/IC/CS-90 will be completed no later than May 15, 1988.

The Unit 2 walkdown will be performed no later than fuel Load.

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