TXX-5037, Responds to NRC Re Violations Noted in Insp Repts 50-445/86-06 & 50-446/86-04.Corrective Actions:Electrical Erection Spec Reviewed & Revised to Clarify General Requirements & Procedures QI-QP-11.3-26 & EEI-23 Revised: Difference between revisions

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{{#Wiki_filter:,e Log # TXX-5037 File # 10130 TEXAS UTILITIES GENERATING COMPANY                                 IR 86-06
{{#Wiki_filter:,e Log # TXX-5037 File # 10130 TEXAS UTILITIES GENERATING COMPANY IR 86-06
                        -v. v ro.. .     r ouv. .r==1. i... .. . MM.AB. T== ==               86-04 October 9, 1986 ggg               1 Mr. Eric H. Johnson, Director Division of Reactor Safety and Projects                                                     @
-v.
U. S. Nuclear Regulatory Commission _
v ro...
l 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76012
r ouv..r==1. i...... MM.AB. T====
86-04 1
October 9, 1986 ggg Mr. Eric H. Johnson, Director Division of Reactor Safety and Projects U. S. Nuclear Regulatory Commission _
611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76012


==SUBJECT:==
==SUBJECT:==
Line 27: Line 30:


==Dear Mr. Johnson:==
==Dear Mr. Johnson:==
We have reviewed your {{letter dated|date=August 26, 1986|text=letter dated August 26, 1986}}, concerning the inspection conducted during the period February 1, through March 31, 1986 by Mr. H.S.
We have reviewed your {{letter dated|date=August 26, 1986|text=letter dated August 26, 1986}}, concerning the inspection conducted during the period February 1, through March 31, 1986 by Mr. H.S.
Phillips and other members of the Region IV Comanche Peak Group. 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.
Phillips and other members of the Region IV Comanche Peak Group. 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.
We requested and received a two week extension in providing our response during a telephone conversation on September 25, 1986.
We requested and received a two week extension in providing our response during a telephone conversation on September 25, 1986.
We hereby respond to the Notice of Violation in the attachment to this letter.
We hereby respond to the Notice of Violation in the attachment to this letter.
Very truly yours, l                   ndth W. G. Counsil By:
Very truly yours, l
G. S. Keeley
ndth W. G. Counsil By:
                                                                                                /
/
6 7 Manager,NuclearLii:psing RSB/gj                                                                           l     -
G. S. Keeley 6 7 Manager,NuclearLii:psing RSB/gj l
Attachments c - Region IV (Original + 1 Copy)
Attachments c - Region IV (Original + 1 Copy)
Director, Inspection & Enforcement (15 copies)
Director, Inspection & Enforcement (15 copies)
U. S. Nuclear Regulatory Commission Washington, D.C. 2055" Mr. V.S. Noonan                       Occk $Mjj9 Mr. D.L. Kelley                                     pMS                               gl
U. S. Nuclear Regulatory Commission Washington, D.C.
                                .< tunnom or snu nunun nortnec nnorm
2055" Occk $Mjj9 Mr. V.S. Noonan Mr. D.L. Kelley pMS gl
    ]Ll}
]Ll}
.< tunnom or snu nunun nortnec nnorm


  ~
~
Page 1 Attachment to TXX-5037 October 9, 1986 NOTICE OF VIOLATION ITEM A (445/8604-V-02)
Page 1 Attachment to TXX-5037 October 9, 1986 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 TUGCo QA Plan (QAP), requires that activities affecting quality shall be prescribed by and accomplished i in accordance with documented instruct 4on, procedures, or drawings.
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 TUGCo QA Plan (QAP), requires that activities affecting quality shall be prescribed by and accomplished i in accordance with documented instruct 4on, procedures, or drawings.
Paragraph 4.2.2.3a of Gibbs and Hill (G&H) Specification 2323-ES-100.
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.
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."
Cable in trays shall be laid to a uniform depth."
Contrary to the above:
Contrary to the above:
: 1.       TUGCo Instruction QI-QP-ll.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 EEI-7, Revision 6, dated March 26, 1986, " Cable Pulling," did not address installation of cables in trays to a uniform depth.
1.
2       Cables were observed to be spilling over the siderails of cable trays T240SF003, 004, 005, 006, 007, 008, and T240SDA91. Cables I were also not laid in the tray at the vertical to horizontal transition between cable tray section T240SF003 and T240SF004.
TUGCo Instruction QI-QP-ll.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 EEI-7, Revision 6, dated March 26, 1986, " Cable Pulling," did not address installation of cables in trays to a uniform depth.
RESPONSE TO ITEM A (1)
2 Cables were observed to be spilling over the siderails of cable trays T240SF003, 004, 005, 006, 007, 008, and T240SDA91.
: 1. Reason fg 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 provide a clear discussion of these attributes. Requirements involving the interlacing of trained cable are addressed procedurally for some applications, but, in general, these attributes are not addressed by implementing procedures.
Cables I
were also not laid in the tray at the vertical to horizontal transition between cable tray section T240SF003 and T240SF004.
RESPONSE TO ITEM A (1) 1.
Reason fg 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 provide a clear discussion of these attributes. Requirements involving the interlacing of trained cable are addressed procedurally for some applications, but, in general, these attributes are not addressed by implementing procedures.
L
L


Attachment to TXX-5037 October 9, 1986 RESPONSE TO ITEM A (1) - CONT'D
Attachment to TXX-5037 October 9, 1986 RESPONSE TO ITEM A (1) - CONT'D 2.
: 2. Corrective Steps Taken and the Results Achieved The electrical erection specification will be reviewed and revised as necessary to clarify these general requirements. The two procedures noted in the violation (QI-QP-11.3-26 and EEI-23) will be reviewed and revised to ensure compliance with the clarified specification. Reinspections will be performed as necessary.
Corrective Steps Taken and the Results Achieved The electrical erection specification will be reviewed and revised as necessary to clarify these general requirements. The two procedures noted in the violation (QI-QP-11.3-26 and EEI-23) will be reviewed and revised to ensure compliance with the clarified specification. Reinspections will be performed as necessary.
NCR's E86-202317, E86-104159 and E86-250405 have been written to address the issues in this violation.
NCR's E86-202317, E86-104159 and E86-250405 have been written to address the issues in this violation.
: 3. Corrective Steps la Avoid Recurrence The electrical erection specification will be reviewed to identify any additional requirements that were addressed in a general 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.
3.
: 4. Data When Full Como11ance will b.g Achieved The date for full compliance will be provided not later than October 31, 1986.
Corrective Steps la Avoid Recurrence The electrical erection specification will be reviewed to identify any additional requirements that were addressed in a general 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.
Data When Full Como11ance will b.g Achieved The date for full compliance will be provided not later than October 31, 1986.


Page 3 Attachemnt to TXX-5037 October 9, 1986 RESPONSE TO ITEM A (2)
Page 3 Attachemnt to TXX-5037 October 9, 1986 RESPONSE TO ITEM A (2)
We do not agree that part A(2) is a violation of the referenced criteria.
We do not agree that part A(2) is a violation of the referenced criteria.
Between December.6, 1985, and August 5, 1986, CPSES issued NCR E85-101983 and six-(6) subsequent revisions addressing the interlacing of instrumentation and and control cables. Essentially, all of the cables identified on these NCRs were common to (or were routed through) the areas identified by the NRC inspector.
Between December.6, 1985, and August 5, 1986, CPSES issued NCR E85-101983 and six-(6) subsequent revisions addressing the interlacing of instrumentation and and control cables.
Essentially, all of the cables identified on these NCRs were common to (or were routed through) the areas identified by the NRC inspector.
In all cases, the NCR disposition directed construction to pull the cables back through the original routing and then reinstall. While attempting to complete the prescribed disposition, additional NCRs were issued addressing cables above the siderail (E86-100847 R.1 dated 3/3/86, E86-100848 R.1 dated 3/3/86, E86-201010 dated 3/3/86, and E86-201150 dated 4/11/86).
In all cases, the NCR disposition directed construction to pull the cables back through the original routing and then reinstall. While attempting to complete the prescribed disposition, additional NCRs were issued addressing cables above the siderail (E86-100847 R.1 dated 3/3/86, E86-100848 R.1 dated 3/3/86, E86-201010 dated 3/3/86, and E86-201150 dated 4/11/86).
The dispositions for these NCRs required reworking the cables which included obtaining slack from origin to destination as necessary.
The dispositions for these NCRs required reworking the cables which included obtaining slack from origin to destination as necessary.
Line 70: Line 82:


Page 4 Attachment to TXX-5037 October 9, 1986 NOTICE OF VIOLATION ITEM S (446/8604-V-03)
Page 4 Attachment to TXX-5037 October 9, 1986 NOTICE OF VIOLATION ITEM S (446/8604-V-03)
B. Criterion V of Appendix B to 10 CFR part 50, implemented by Section 5.0, Revision 3, dated hly 31, 1984, of the TUGCo QAP, requires that activities affecting quality shall be prescribed by and accomplished in i          accordance with documented instructions, procedures, or drawings.
B.
Paragraph 4.2.15.b(2) of G&H Specification 2323-ES-100, Revision 2, requires that a cable support be provided as close as practical 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.
Criterion V of Appendix B to 10 CFR part 50, implemented by Section 5.0, Revision 3, dated hly 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.
i Paragraph 4.2.15.b(2) of G&H Specification 2323-ES-100, Revision 2, requires that a cable support be provided as close as practical 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,
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.
" 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.
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
RESPONSE TO ITEM B 1.
: 1. Renon far Violation The electrical erection specification, 2323-ES-100, Revision 2, and the noted TUGCo instruction, QI-QP-ll.3-26, Revision 24, do not clearly describe the sequence for cable installation (e.g., the point in the process when cable grips must be installed).     Cable grips are not required until the installation is complete.
Renon far Violation The electrical erection specification, 2323-ES-100, Revision 2, and the noted TUGCo instruction, QI-QP-ll.3-26, Revision 24, do not clearly describe the sequence for cable installation (e.g., the point in the process when cable grips must be installed).
: 2. Corrective Steps Taken and the Results Archieved This specification and instruction will be reviewed and revised as necessary to clarify when cable grips must be installed. The grips noted in the violation will be installed at the proper time.
Cable grips are not required until the installation is complete.
: 3. Corrective Steps in Avoid Recurrence The electrical erection specification will be reviewed to verify that the installation sequences are properly addressed. 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.
2.
: 4. DALq Ifhan BLl_l. Compliance will hg Achieved The date for full compliance will be provided not later than October 31, 1986.}}
Corrective Steps Taken and the Results Archieved This specification and instruction will be reviewed and revised as necessary to clarify when cable grips must be installed.
The grips noted in the violation will be installed at the proper time.
3.
Corrective Steps in Avoid Recurrence The electrical erection specification will be reviewed to verify that the installation sequences are properly addressed.
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.
DALq Ifhan BLl_l. Compliance will hg Achieved The date for full compliance will be provided not later than October 31, 1986.}}

Latest revision as of 23:53, 5 December 2024

Responds to NRC Re Violations Noted in Insp Repts 50-445/86-06 & 50-446/86-04.Corrective Actions:Electrical Erection Spec Reviewed & Revised to Clarify General Requirements & Procedures QI-QP-11.3-26 & EEI-23 Revised
ML20211E163
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 10/09/1986
From: Counsil W, Keeley G
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To: Johnson E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
TXX-5037, NUDOCS 8610220370
Download: ML20211E163 (5)
v • d • e


Text

,e Log # TXX-5037 File # 10130 TEXAS UTILITIES GENERATING COMPANY IR 86-06

-v.

v ro...

r ouv..r==1. i...... MM.AB. T====

86-04 1

October 9, 1986 ggg Mr. Eric H. Johnson, Director Division of Reactor Safety and Projects U. S. Nuclear Regulatory Commission _

611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76012

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT NOS.: 50-445/86-06 AND 50-446/86-04

Dear Mr. Johnson:

We have reviewed your letter dated August 26, 1986, concerning the inspection conducted during the period February 1, through March 31, 1986 by Mr. H.S.

Phillips and other members of the Region IV Comanche Peak Group. 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.

We requested and received a two week extension in providing our response during a telephone conversation on September 25, 1986.

We hereby respond to the Notice of Violation in the attachment to this letter.

Very truly yours, l

ndth W. G. Counsil By:

/

G. S. Keeley 6 7 Manager,NuclearLii:psing RSB/gj l

Attachments c - Region IV (Original + 1 Copy)

Director, Inspection & Enforcement (15 copies)

U. S. Nuclear Regulatory Commission Washington, D.C.

2055" Occk $Mjj9 Mr. V.S. Noonan Mr. D.L. Kelley pMS gl

]Ll}

.< tunnom or snu nunun nortnec nnorm

~

Page 1 Attachment to TXX-5037 October 9, 1986 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 TUGCo QA Plan (QAP), requires that activities affecting quality shall be prescribed by and accomplished i in accordance with documented instruct 4on, 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.

TUGCo Instruction QI-QP-ll.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 EEI-7, Revision 6, dated March 26, 1986, " Cable Pulling," did not address installation of cables in trays to a uniform depth.

2 Cables were observed to be spilling over the siderails of cable trays T240SF003, 004, 005, 006, 007, 008, and T240SDA91.

Cables I

were also not laid in the tray at the vertical to horizontal transition between cable tray section T240SF003 and T240SF004.

RESPONSE TO ITEM A (1) 1.

Reason fg 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 provide a clear discussion of these attributes. Requirements involving the interlacing of trained cable are addressed procedurally for some applications, but, in general, these attributes are not addressed by implementing procedures.

L

Attachment to TXX-5037 October 9, 1986 RESPONSE TO ITEM A (1) - CONT'D 2.

Corrective Steps Taken and the Results Achieved The electrical erection specification will be reviewed and revised as necessary to clarify these general requirements. The two procedures noted in the violation (QI-QP-11.3-26 and EEI-23) will be reviewed and revised to ensure compliance with the clarified specification. Reinspections will be performed as necessary.

NCR's E86-202317, E86-104159 and E86-250405 have been written to address the issues in this violation.

3.

Corrective Steps la Avoid Recurrence The electrical erection specification will be reviewed to identify any additional requirements that were addressed in a general 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.

Data When Full Como11ance will b.g Achieved The date for full compliance will be provided not later than October 31, 1986.

Page 3 Attachemnt to TXX-5037 October 9, 1986 RESPONSE TO ITEM A (2)

We do not agree that part A(2) is a violation of the referenced criteria.

Between December.6, 1985, and August 5, 1986, CPSES issued NCR E85-101983 and six-(6) subsequent revisions addressing the interlacing of instrumentation and and control cables.

Essentially, all of the cables identified on these NCRs were common to (or were routed through) the areas identified by the NRC inspector.

In all cases, the NCR disposition directed construction to pull the cables back through the original routing and then reinstall. While attempting to complete the prescribed disposition, additional NCRs were issued addressing cables above the siderail (E86-100847 R.1 dated 3/3/86, E86-100848 R.1 dated 3/3/86, E86-201010 dated 3/3/86, and E86-201150 dated 4/11/86).

The dispositions for these NCRs required reworking the cables which included obtaining slack from origin to destination as necessary.

Apparently, sometime during the course of this rework on all associated NCRs, the NRC inspector performed his surveillance of the area in question and issued the subject report.

We feel that the cable trays / cables in question were being controlled satisfactorily by applicable procedures, personnel were working within prescribed boundaries, and the apparent violations were the result of observations made while rework was in progress.

Page 4 Attachment to TXX-5037 October 9, 1986 NOTICE OF VIOLATION ITEM S (446/8604-V-03)

B.

Criterion V of Appendix B to 10 CFR part 50, implemented by Section 5.0, Revision 3, dated hly 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.

i Paragraph 4.2.15.b(2) of G&H Specification 2323-ES-100, Revision 2, requires that a cable support be provided as close as practical 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 1.

Renon far Violation The electrical erection specification, 2323-ES-100, Revision 2, and the noted TUGCo instruction, QI-QP-ll.3-26, Revision 24, do not clearly describe the sequence for cable installation (e.g., the point in the process when cable grips must be installed).

Cable grips are not required until the installation is complete.

2.

Corrective Steps Taken and the Results Archieved This specification and instruction will be reviewed and revised as necessary to clarify when cable grips must be installed.

The grips noted in the violation will be installed at the proper time.

3.

Corrective Steps in Avoid Recurrence The electrical erection specification will be reviewed to verify that the installation sequences are properly addressed.

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.

DALq Ifhan BLl_l. Compliance will hg Achieved The date for full compliance will be provided not later than October 31, 1986.

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