IR 05000445/1986006

Ack Receipt of 861009,31 & s Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-445/86-06 & 50-446/86-04

ML20210S473
Person / Time
Site:	Comanche Peak
Issue date:	02/10/1987
From:	Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
NUDOCS 8702170638
Download: ML20210S473 (2)

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In Reply Refer To:' FEB I O INT Dockets: 50-445/86-06 50-446/86-04 Texas Utilities Generating Company ATTN: Mr. W. G. Counsil Executive Vice President 400 North Olive L.B. 81 Dallas, Texas 75201 Gentlemen:

Thank you for your letters of October 9,1986, October 31, 1986, and January 22, 1987, in response to our letters and Notice of Violation dated August 26, 1986, ar.d December 30, 1986. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.

Sincerely,

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/Tl HHf E. H. Johnson, Director Division of Reactor Safety and Projects cc:

Texas Utilities Electric Company ATTN: G. S. Keeley, Manager Licensing Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 RIV:CPRTh CPRT .5F '

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= Texas Utilities Generating 2 Company Juanita Ellis President - CASE 1426 South Polk Street Dallas, Texas 75224 Renea Hicks Assistant Attorney General Environmental Protection Division P. O. Box 12548 Austin, Texas 78711-2548 Administrative Judge Peter Bloch U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Elizabeth B. Jahrson Administrative Judge Oak Ridge National Laboratory P. O. Box X, Building 3500 Oak Ridge, Tennessee 37830 Dr. Kenneth A. McCollom 1107 West Knapp ,

Stillwater, Oklahoma 74075 Dr. Walter H. Jordan 881 Outer Drive Oak Ridge Tennessee 37830 Anthony Roisman, Esq.

Executive Director Trial Lawyers for Public Justice 2000 P. Street, N.W. Suite 611 Washington, D.C. 20036 Texas Radiation Control Program Director bec to DMB (IE01)

bec distrib. by RIV:

• RPB * MIS System

• RRI-0PS *RSTS Operator

• RRI-CONST *R&SPB

• T. F. Westerman, RSB DRSP V. Noonan, NRR R. Martin, RA L. Chandler, OGC *RSB

• RIV File J. Taylor, IE

• D. Weiss, RM/ALF J. Conklin, IE

• I. Barnes, CPTG * Project Inspector

• R. Hall P. Wagner

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! Leg # TXX-6213 File # 10130 IR 86-06

• TEXAS UTILITIES GENERATING COMPANY IR 86-04 SKYWAY TOWER . 489 NORTH OLIVE STREET. LB. 88 . DALLAS, TEXAS 7M01 January 22, 1987 ~~~- '

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Division of Reactor Safety and Projects U. S. Nuclear Regulatory Commission L-611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 SUBJECT: COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 INSPECTION REPORT NOS.: 50-445/86-06 AND 50-445/86-04 SUPPLEMENTAL RESPONSE FOR INFORMATION TO NRC NOTICE OF VIOLATION (N0V) ITEM A(2)

REF: 1. TUGC0 Letter TXX-5037 from W. G. Counsil to E. dated October 9, 1986.

2. TUGC0 Letter TXX-6071 from W. G. Counsil to E. dated October 31, 1986.

Dear Mr. Johnson:

We have reviewed your letter dated December 30, 1986, requesting additional information to our responses referenced above regarding NOV 445/8604-V-02 (Item A(2)). We hereby respond to the request for supplemental information in the attachment to this letter.

Very truly yours, h th b W. G. ouns 1 By: [, . /

G. S. Keeley W/y Manager, Nuclear ticensing RSB/amb:lw Attachment c - NRC Region IV (0 + 1 copy)

Director, Inspection and Enforcement (15 copies)

U. S. Nuclear Regulatory Commission Washington, D. C. 20555

Mr. V. S. Noonan Mr. D. L. Kelley

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. Attachment to TXX-6213'

January 22,--1986 Page 1 of 2

NOTICE OF VIOLATION ITEM A(2) 446/8604-V-02 SUPPLEMENTAL REQUEST FOR INFORMATION In your response to Item A(2), you mention that problems related to the overflowing of electrical cable from the cable trays that were identified by the NRC inspector had been previously identified by applicant personnel and were in the process of being reworked. Accordingly, you did not agree that the NRC identified condition was a violation and, therefore, did not provide the information required by the NOV.

Based on our review of the information provided in your response and additional information provided by members of your staff, we cannot agree that the cited condition had been, or necessarily would have been, identified as a result of the rework that had been undertaken. While we agree that many of the same cables were involved in both the NRC identified condition of overflowing cable tray siderails and the rework being conducted, we disagree ;

that the NRC identified problem would necessarily have been resolved by pulling the cables back to remove interlacing and then reinstalling these cables in the same size cable tray. In addition, the NRC inspector did not identify any QC hold tags (indicating an identified problem) during the NRC inspection.

SUPPLEMENTAL RESPG : TO ITEM A(2)

As a result of discussions with the NRC Resident Inspector and our review of this violation, we have determined that a revision to our response is required. The revised response below will provide the supplemental information requested.

1. Reason for Violation f We admit the violation, and the requested information follows.

The deficiences noted in this violation involving unacceptable cable installation'were the result of corrective actions in progress per NCR E-85-101983 and inadequacies in the cited TUGC0 Inspection Instruction QI-QP-11.3-26 and B&R Construction Procedure EEI-7. Specifically, criteria governing the installation and inspection of electrical cable were found insufficient to prevent the improper cable installation identified in the NOV.

2. Corrective Steos Taken A request for engineering clarification (RFIC E-11180) was initiated on March 4,1986 requesting engineering to evaluate cable tray nodes T240SF001, 02, 03, 04, and 05 for siderails and to document installation l

problems encountered during cable rework associated with NCR E-85-101983.

i A design change (DCA #24,289) was issued on April 4, 1986, to replace the

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12" tray nodes with 18" width trays to correct the stated cable overfill and irregular routing problems. Construction Deficiency Report CDR-87-801 was issued on January 19, 1987 to identify the need for reinspection of existing cable installations for cable overfill conditions. If the disposition of the CDR indicates that corrective action is required, a CAR

will be generated, k _ - .

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. Attachment to TXX-6213 January 22, 1986 Page 2 of 2

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3. Action to Prevent Recurrence Inspection Instruction QI-QP-11.3-26 and Construction Procedure EEI-7 have been revised to address the specific requirements of the electrical erection specification in the areas identified in the NOV. An additional inspection attribute has been incorporated into the inspection instruction prohibiting cables from extending above the top of cable tray siderails except where entering and exiting the cable tray.

4. Date of Como11ance Implementation of design change DCA-24,289 and associated cable rework is scheduled to be completed by July 1,1987. A change notice (DCN #5) was issued against the Installation Procedure EEI-7 on October 31, 1986.

Revision 31 of Inspection Instruction QI-QP-11.3-26 is scheduled to be issued by January 31, 1987, upon completion of requisite training. If required, appropriate corrective action to disposition CDR-87-801 will be completed by July 1,1987.

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