View source for TXX-6402, Revised Response to Violation Item B Noted in Insp Repts 50-445/85-18 & 50-446/85-15.Corrective Steps Taken & Action to Prevent Recurrence Sections Updated to Show Results Achieved.Dates of Full Compliance Moved to 870831 & 880331

{{Adams
| number = ML20215L763
| issue date = 05/07/1987
| title = Revised Response to Violation Item B Noted in Insp Repts 50-445/85-18 & 50-446/85-15.Corrective Steps Taken & Action to Prevent Recurrence Sections Updated to Show Results Achieved.Dates of Full Compliance Moved to 870831 & 880331
| author name = Counsil W, Keeley G
| author affiliation = TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
| addressee name = 
| addressee affiliation = NRC OFFICE OF ADMINISTRATION &amp; RESOURCES MANAGEMENT (ARM)
| docket = 05000445, 05000446
| license number = 
| contact person = 
| document report number = TXX-6402, NUDOCS 8705120365
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 3
}}

=Text=
{{#Wiki_filter:p Log # TXX-6402
                                                       =======               File # 10130 FE IR 85-18 IR 85-15
                                                       =        =            Ref # 10CFR2.201 181 ELECTRIC HiHimm G. Cound bnutiw ikr />rsidens 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.: 50-445/85-18 AND 50-446/85-15 REVISED DATE OF FULL COMPLIANCE FOR NOTICE OF VIOLATION (N0V)
ITEM B REF:      1) TUGC0 Letter TXX-4848 from W. G. Counsil to E. H. Johnson dated July 9, 1986.
: 2) TUGC0 Letter TXX-6134 from W. G. Counsil to E. H. Johnson dated December 12, 1986.
: 3) TUGC0 Letter TXX-6386 from W. G. Counsil to E. H. Johnson dated April 14, 1987.
Gentlemen:
In pursuing the corrective steps as delineated in our response (Reference 1) to NOV 445/8518-V-01 (Item B), we have determined that an update to the Date of Full Compliance is required. We hereby submit our revised response in the attachment to this letter. The original Notice of Violation has been included to aid in understanding our revised response. Those portions of the response which'have been revised are denoted by a revision bar in the right margin.
The Corrective Steps Taken and the Action to Prevent Recurrence sections have been updated to show results achieved. The Date of Full Compliance for the completion of CAR 63 has been revised from December 31, 1986 to August 31, 1987, for Unit 1 and Common, and March 31, 1988 for Unit 2.
Very truly yours, h                11 W. G. Coun il By:         ,                /
G. S. Keeley            /
Manager, NucleaPlc 1;Tn'g RSD/mlh                                                                  Y Attachment c - Mr. E. H. Johnson, Region IV Mr. D. L. Kelley, RI - Region IV Mr. H. S. Phillips, RI - Region IV B 7 s i g g 75              45 a                       =                                                                 /

Attachment to TXX-6402 May 7, 1987 Page 1 of 2 NOTICE OF VIOLATION ITEM B (445/8518-V-01)
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 QAP, 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 instruction, procedures, or drawings.
Paragraph 4.4.5 of Gibbs and Hill (G&H) Electrical Erection Specification 2323-ES-100. Revision 2, dated October 5,1980, requires electrical conduit installation to be in accordance with Drawings 2323-El-1701 and 2323-El-1702. Detail 18C of Drawing 2323-El-1701 limits the maximum length of conduit from an end device to its associated junction box to 15 feet.
Contrary to the above, the installed conduit lengths for primary coolant sample supply and return isolation solenoid valves 1HV-4631A and IHV-4631B were observed to be approximately 30 feet.
REVISED RESPONSE TO ITEM B
: 1.         REASON FOR VIOLATION Installation of electrical raceways for 1-HV-4631A & 1-HV-4631B is not in accordance with the requirements of the design. Construction procedures require engineering authorization in the form of design documents to be issued for any deviations from the design. However, the raceway was installed without a change to a design document.
QC Procedure QI-QP-11.3-28 did not adequately address the inspection requirements to detail 18C of Drawing 2323-El-1701 and 2323-El-1702.
: 2.          CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED
: a. NCR E86-102718 was issued on June 23, 1986, to document unacceptable conduit installation for isolation solenoid valves 1HV-4631A and 1HV-4631B. NCR E86-102718 was converted to NCR-CE-87-3226 on March 11, 1987 and was dispositioned by Engineering on April 23, 1987.      DCA
                        #21,912, Rev. 2, was issued on April 29, 1987, to revise Detail 18 of drawing 2323-El-1701 allowing conduit runs of up to 50 ft. in length.
: b. CAR-063 was revised on July 29, 1986, to include walkdown and identification of Detail 18 installations. Field verification has been performed in accordance with Engineering Procedure CPE-FVM-EE-022, " Instruction to Acquire Data for Tracability of IE Pigtail Extensions". Detail 18 walkdowns for Unit 1 and Common are complete with 31 Class IE detail 18C splices and 40 Class 1E detail 18C pigtails identified. An engineering evaluation of these installations is in progress. In the event an installation exceeds the 50 ft.
maximum it will be documented on an NCR. Resolution of CAR-063 includes the above corrective action associated with NCR-CE-87-3226.
A similar program is being developed for Unit 2.

Attachment to TXX-6402 May 7, 1987 Page 2 of 2 REVISED RESPONSE TO ITEM B - CONT'D
: 3. CORRECTIVE STEPS TO AVOID RECURRENCE
: a. Applicable craft personnel were retrained in the existing procedures   l to be followed in requesting deviations from the design documents.
: b. QC Procedures QI-QP 11.3-28 was revised on March 7, 1986, to include specific inspection requirements to Detail 18C of drawing 2323-El-1701 and 2323-El-1702, and revision training for appropriate QC Inspectors has been performed.
: 4. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance will be achieved with the completion of CAR-063 scheduled for August 31, 1987 - Unit 1 and Common, and March 31, 1988 - Unit 2.}}