ML20212E576

Ack Receipt of 861009 & 31 Ltrs Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-445/86-06 & 50-446/86-04.Addl Info Required Re Item A(2) Concerning Overflowing of Electrical Cable from Cable Trays

ML20212E576
Person / Time
Site:	Comanche Peak
Issue date:	12/30/1986
From:	Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
NUDOCS 8701050361
Download: ML20212E576 (3)

See also: IR 05000445/1986006

Text

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In Reply Refer To:

Dockets: 50-445/86-06 DEC 3 01986

50-446/86-04

Texas Utilities Generating Company

ATTN: Mr. W. G. Counsil

Executive Vice President

400 North Olive Street, L.B. 81

Dallas, Texas 75201

Gentlemen:

Thank you for your letters dated October 9,1986, and October 31, 1986, in

response to our letter dated August 26, 1986. As a result of our review of

your letters, we find that we are in need of additional information with

respect to Item A(2) in the Notice of Violation (NOV).

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.

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Therefore, we request that you provide the information requested in the NOV

for this item within 20 days of your receipt of this letter.

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We have no further questions regarding Items A (1) and B of the NOV.

Sincerely,

Oricinal Signed By

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E. H. Johnson, Director

Division of Reactor Safety and

Projects

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Texas Utilities Electric Company ,

ATTN: G. S. Keeley, Manager, ,

Licensing

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400 North Olive Street ,-

Lock Box 81 ,

Dallas, Texas 75201.

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Juanita Ellis

President - CASE

1426 South Polk Street ~

Dallas, Texas

75224- ,

Renea Hicks

Assistant Attorney General

Environmental Protection Division .

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P.O. Box 12548

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Austin, Texas 78711-2548

l Administrative Judge Peter Bloch

! U. S. Nuclear Regulatory Commission

l Washington, D.C. 20555

Elizabeth B. Johnson

Administrative Judge

Oak Ridge National Laboratory

i P.O. Box X, Building 3500

i Oak Ridge, Tennessee 37830

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Dr. Kenneth A. McCollom

! 1107 West Knapp

' Stillwater, Oklahoma 74075

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Dr. Walter H. Jordan i

881 Outer Drive l

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Anthony Roisman, Esq.

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Trial Lawyers for Public Justice

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Washington, D.C. 20036

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Log # TXX-5037

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File # 10130

TEXAS UTILITIES GENERATING COMPANY IR 86 06

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October 9, 1986

"2 "eLMM  ? $ @ j M []

Mr. Eric H. Johnson, Director # 1

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Division of Reactor Safety and Projects \ OCT I 0 m

U. S. Nuclear Reg'ulator.v Commission

611 Ryan Plaza Drive, tutte 1000 a\l -g

Arlington, Texas 76012

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SUBJEC7:

' COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446

i

RESPONSE TO NRC NOTICE OF VIOLATION

INSPECTION REPORT NOS.: 50-445/86-06 AND 50-446/86-04

1 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

i e

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.

4

Very truly yours,

,

,

W. G. Counsil

,..

By:

G. S. Keeley n 7

Manager, Nuclear Lil:pfising

RSB/gj /

Attachments

c - Region IV (Original + 1 Copy)

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Director, Inspection & Enforcement (15 copies)

U. S. Nuclear Regulatory Comission

Washington, D.C. 20555

,

Mr. V.S. Noonan

Mr. 'O.L. Kelley

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Page 1 i

Attachment to TXX-5037

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October 9, 1986

NOTICE OF VIOLATION

ITEM A (445/8604-V-02)

A.

Criterion V of Appendix 8 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

in accordance with documented instruction, 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-II.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,"

uniform did not address installation of cables in trays to a

depth.

2

Cables were observed to be spilling over the siderails of cable

trays T240SF003, 004, 005, 006, 007, 008 and T240SDA91. Cables

were also not laid in the tray at the ver,tical to horizontal

transition between cable tray section T240SF003 and T240SF004.

RESPONSE TO ITEM A (1) ,

1. Reason f_gr Violation

,

The attributes of concern in this violation relate to broad, standard

terms that, in general, address good workmanship. The electrical erection

specificatTUh,

attributes. Requirements 2323-ES-100, does nat provide a clear discussion of these

involving the interlacing of trained cable are

addressed procedurally for some applications, but, in general, these

attributes are not addressed by implementing procedures.

,

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Attachment to TXX-5037

October 9, 1986

RESPONSE TO ITEM A (1) - CONT'D

2.

Corrective Slep.s Taken AD.d h.th.g Results Achieved _

i

The electrical erection specification will be reviewed and revised as

necessary to clarify these general requirements. The two procedures noted

'

'in the violation

to ensure compliance (QI-QP-11.3-26

with and eel-23) will be reviewed

be performed as necessary.the clarified specification.Reinspections will

NCR's E86-202317, E86-104159 and E86-250405 have been written to address

the issues in this violation.

,

.

- 3. Corrective Stap.1.tn Avoid Recurrence

additional

require clarification. requirements that were addressed in a gen

the applicable implementing procedures and instructions s

and revised as necessary to ensure compliance with the revised

specification.

.

4.

QA.tg Whitti full Como11ance Will. bg Achieved

The

1986.date ' for fu,ll compliance will be provided not later than October 31,

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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 E85-1019

and(6)

six subsequent

control cables. revisions addressing the interlacing of instrumentation and

Essentially, all of the cables identified on these NCRs

were

inspector. common to (or were routed through) the areas identified by the NRC

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 E86-20ll50 dated 4/11/86).

The dispositions for these NCRs required reworking the c

obtaining slack from origin to destination as necessary. ables which included

Apparently, sometime during the course of this rework on all associated NCRs,

x the

issued NRC theinspector performed his surveillance of the area in question and

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.

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Page 4

Attachment to TXX-5037

October 9, 1986

,

NOTICE OF VIOLATION

ITEM B (446/8604-V-03)

B.

Revision 3, dated JulyCriterion V of Appendix 8 to 10 CFR part 50

31, 1984, of the TUGCo QAP, requires that

accordance with documented instructions, proced

,

paragraph 4.2.1 5.b(2) of G&H Specification 2323-ES-100 Revision 2,

of a vertical raceway, for No.18 through No. O con

vertical riser length is 25 feet or greater.

Paragraph 3.11.3.a of TUGCo Instruction QI-QP-11.3-26, Revision 24, a

paragraph 3.1 of B&R Procedure EEI 23, Revision 1, dated July

,

" Cable Support Grip Installation," reflect the above specification 21, 1983,

requirements.

3

Contrary to the above, cable support grips were not evident on cables

(with conductors in the above size range) installed in cdele tray risers

,

containing tray sections T23GECX91 and T24GEDG98 that were greater tha

feet in height.

RESPONSE TO ITEM 8

1. Reaso_n f0.t Violation

The electrical erection specification, 2323-ES-100, Revision 2, and the

noted TUGCo instruction, QI-QP-11.3-26, Revision 24

do not clearly

'

, describe ti.a sequence for cable installation (e.g.,,the point in the

process

until the when cable is

installation grips must Le installed). Cable grips are not required

complete.

2.

i

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 vi3Tation 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.

revised as necessary and the applicable implementing procedures andThe sp

instructions shall be reviewed and revised as necessary to ensure

compliance with the revised specification.

4. DLtg Mhan Egl],Comoliance will hg Achieved

The date

1986, for full compliance will be provided not later than October 31,

i

• • TOTAL PAGE.06 ++ . - - - - . -

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- ._ - -

Log # TXX-6071

• " * *

File # 10130

IR 86-06

TEXAS UTILITIES GENERATING COMPANY IR 86-04

BKYWAY TOWER . 480 NOR1H OLIVE STREET. LB. 88 . DALLAS. TEXAS 753DI

October 31, 1986

75Y1".hff?.03, .

Mr. Eric H. Johnson, Director

OL

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Division of Reactor Safety and Projects  ;--

U. S: Nuclear Regulatory Commission 1

611 Ryan Plaza Drive, Suite 1000

Arlington, Texas . 76012

SUBJECT: COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446

SUPPLEMENTAL RESPONSE TO NRC NOTICE OF VIOLATION

INSPECTION REPORT NOS.: 50-445/86-06 AND

50-446/86-04

Dear Mr. Johnson:

We responded to Inspection Report Nos. 50-445/86-06 and 50-446/86-04 on

October 9, 1986 (TXX-5037). In the response to Notice of Violation, Item A

(445/8604-V-02), we stated that we would provide the date of full compliance

by October 31, 1986. The "Date When Full Compliance Will Be Achieved" is June

1, 1987.

Very truly yours,

lhh

W. G. Co il

By: . .

G. S. Keeley -

Manager, NuclearMcensing

RSB/amb

c - Region IV (Original + 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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A Dis 1510N OF TEX A5 LTELETIES FLECTRIC lintPANY

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