ML20214P744

Forwards Revised Response to Violations Noted in Insp Repts 50-445/86-14 & 50-446/86-11.Corrective Actions:Procedures EEI-7,CP-CPM-14.1 & QI-QP-11.3-26 Revised & Applicable Const Personnel Trained in Revised Requirements

ML20214P744
Person / Time
Site:	Comanche Peak
Issue date:	05/29/1987
From:	Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
TXX-6473, NUDOCS 8706040002
Download: ML20214P744 (5)

Text

,

==

Log # TXX-6473

- ~

File # 10130 IR 86-14 C ~~-

IR 86-11 7UELECTRIC Ref # 10CFR50.55(e)

Milliam G. Omndi ne,uisai,, n,#,, May 29, 1987 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. 50-445/86-14 AND 50-446/86-11 REVISED DATE OF FULL COMPLIANCE FOR NOTICE OF VIOLATION (NOV)

ITEMS 8.1 AND C Ref: 1) TUGC0 Letter TXX-6186 from W. G. Counsil to Eric H. Johnson Dated January 16, 1987.

Gentlemen:

In reviewing our corrective actions, as delineated in our referenced response to NOV 445/8614-V-03 and 446/8611-V-10 (Item C), we have determined that a revision to our response 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.

Also, the referenced letter provided our response to NOV 446/8611-V-03 [ Item B.I.a] and NOV 446/86-11-V-02 [ Item B.1.b]. Our response stated that corrective measures associated with Nonconformance Reports E-86-202745 and I-86-202744 (for Items B.I.a and B.I.b respectively) would be accomplished by June 1, 1987. Due to delays in related construction activities, this date is no longer achievable. Accordingly, our response to item B.1 is hereby revised to indicate that corrective measures associated with Nonconformance Reports E-86-202745 and I-86-202744 will be completed by July 15, 1987.

Very truly yours, 47 W. G. Counsil WJH/dl l c - Mr. E. H. Johnson - Region IV CPSES Resident Inspector - 3 copies l e,

$[f0$000k!Ob G

I

(

lW brth Olne Street L R 81 Dallas, ksas 75201 3 j

l l

Attachment to TXX-6473 May 29, 1987.

[ Page-1 of 4 NOTICE OF VIOLATION l ITEM C (445/8614-V-03 & 446/8611-V-10)

C. . Criterion V of Appendix B to 10 CFR Part 50, as implemented by FSAR

. Section 17.1.5 and TUGC0 QAP Section 5.0, Revision 3, dated July 31, 1984, L requires that activities affecting quality shall be prescribed by l documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these i

instructions, procedures, or drawings.

Contrary to the above, TUGC0 Instruction (QI-QPs) did not address process control for drilling holes in solid bottom cable tray to facilitate l installation of fittings and/or cable TY-RAPS (445/8614-V-03; 446/8611-V-i 10).

l REVISED RESPONSE TO ITEM C (445/8614-V-03 & 446/8611-V-10)

We admit the violation and the requested information follows:

f l 1. Reason For Violation i

i Installation procedures did not clearly describe the controls in effect to prevent damage to installed cable while drilling holes in cable trays to facilitate Ty-rap or tray fittings installation. Also, the applicable inspection procedures did not clearly require verification of the absence of cable damage resulting from the hole drilling. process.

2. Corrective Action Taken Procedures eel-7,'" Cable Pulling", CP-CPM-14.1, " Guidelines for Protection of Permanent Plant Equipment", and QI-QP-11.3-26, " Electrical Cable Installation Inspection", were revised (Revisions 7, 2, and 27 respectively) to clearly define installation and inspection instructions i to assure installed cables are not damaged during hole drilling operations. Applicable construction and quality personnel were trained in the revised requirements of the procedures. All of these actions were completed as of September 18, 1986.

Existing installations are considered adequate since proceduralized

process controls to prevent or identify cable damage resulting from hole i

drilling did exist, although not specifically delineated as such. These j controls included: 1) Verification of the absence of cable damage during i verification of the correct installation of Ty-raps, and 2) Verification l of the absence of cable damage through reinspection of cable rework resulting from tray rework or installation. Additionally, for personnel protection and practical purposes,- electrical craft training includes precautions to be observed as an integral part of their activities.

Measures taken to prevent contact with energized or potentially energized I

cable while drilling holes in cable tray are considered standard craft

! safety practice.

Attachment to TXX-6473 May 29, 1987 Page 2 of 4 REVISED RESPONSE TO ITEM C (445/8614-V-03 & 446/8611-V-10) CONT'D

3. Actions To Prevent Recurrence The corrective actions taken will prevent recurrence.

4. Date Of Como11ance Compliance has been achieved, as described above.

t

9 Attachment to TXX-6473 May 29, 1987

'Page 3 of 4 NOTICE OF VIOLATION ITEM B.1 (446/8611-V-03 & 446/8611-V-02)

B. Criterion V of Appendix B to 10 CFR Part 50, as implemented by FSAR Section 17.1.5 and TUGC0 QAP Section 5.0, Revision 3, dated July 31, 1984, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomr.lished in accordance with these-instructions, procedures, or drawings.

B.I. Paragraph 3.6 of B&R Procedure MCP-10, Revision 9, dated July 2, 1985, states, in part, " Items shall _ merit additional protection if construction work threatening the integrity of equipment is in progress". ,

Section E-7.3 of Appendix B to the above procedure states, in

, part, " Installed Instruments do not require Class "B" or above storage, however, adequate protection from construction activities and the environment will be provided."

Contrary to the above, on June 19, 1986, the NRC inspector

_ observed the following conditions:

a. Cables in tray sections T24RREA16 and T24BREC11 were not protected from welding in progress overhead (446/8611-V-03),and

b. Level transmitters 2LT-539 and 2LT-537 and their associated tubing were observed to be uncovered and unprotected while grinding (to prepare the area for painting) was in progress above the instruments and in the immediate vicinity of the tubing. The instruments were covered with dust and grit from the grinding (446/8611-V-02).

REVISED RESPONSE TO ITEM B.1 (446/8611-V-03 & 446/8611-V-02) l We admit the violation and the requested information follows:

1. Reason For Violation Conditions described in this finding are the result of the failure by personnel performing grinding and welding to implement requirements specified per CP-CPM 14.1, " Guidelines for the Protection of Permanent Plant Equipment."

Attachment to TXX-6473 May 29, 1987 Page-4 of 4 REVISED RESPONSE TO ITEM B.1 (446/8611-V-03 & 446/8611-V-02) CONT'D

2. Correction Action Taken The subject level transmitters and cables will be inspected for damage and dispositioned in accordance with Nonconformance Reports I-86-202744 and E-86-202745.

3. Action To Prevent Recurrence All appropriate construction personnel have been trained on Construction Procedure CP-CPM 14.1 titled, " Guidelines for the Protection of Permanent Plant Equipment."

The importance of craftmanship, protection of permanent equipment, and procedural compliance was conveyed to all construction craft personnel at a special meeting on July 24 and 25,1986. The use of disciplinary measures in the event of a violation was also discussed. Disciplinary measures will be taken where it is determined that a violation was committed by a person who had been instructed as to the proper requirements. A project directive was issued to engineering and construction personnel concerning the protection of permanent plant equipment which defined disciplinary actions to be taken. These actions include a warning for the first offense and automatic termination of the employee for the second offense.

4. Date Of Comoliance Corrective measures associated with Nonconformance Reports I-86-202744 and E-86-202745 will be accomplished by July 15, 1987.

1 i

r l

t