TXX-6562, Responds to NRC Re Violations Noted in Insp Repts 50-445/86-26 & 50-446/86-22.Corrective Action:Nonconformance Rept E-86-1038835 & Const Deficiency Rept 87-4746EC Issued to Address Specific Pull Ropes & Cable Tray,Respectively

Responds to NRC Re Violations Noted in Insp Repts 50-445/86-26 & 50-446/86-22.Corrective Action:Nonconformance Rept E-86-1038835 & Const Deficiency Rept 87-4746EC Issued to Address Specific Pull Ropes & Cable Tray,Respectively

ML20235P893
Person / Time
Site:	Comanche Peak
Issue date:	07/13/1987
From:	Counsil W, Keeley G TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
TXX-6562, NUDOCS 8707200661
Download: ML20235P893 (3)

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Log. # TXX-6562' File # 10130 m . = IR 86-26 ib = = IR 86-22 H# ELECTRIC Ref: '# 10CFR2.201 l~ I William G. Counsil '~

' Executive Vice President

.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 RESPONSE YO.NRC INSPECTION REPORT NOS. 50-445/86-26'AND 50-446/86-22 Gentlemen:

. We'have reviewed your. letter dated April 2, 1987, concerning the inspection conducted by Mr. I. Barnes and'other members of.the Region IV Comanche Peak

' Group during the period September 1 through October 31, 1986. 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 were Notices of Violations, Deviations and one Unresolved Item.

All Violations, Deviations and the Unresolved Item except for NOV Item A (445/8626-V-02) were addressed in TV Electric Letter TXX-6472 dated Junc 5, T1987.

On June 4, 1987,'per a telecon with Mr. Bob Warnick, we requested an extension for NOV Item A (445/8626-V-02) until July 13, 1987.

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

Very truly yours, W. G.- Counsil By: .

G. S. Keeley Manager, Nuclear L nsing RDD/mlh-Attachment c - Mr'. R. D. Martin, Region IV Resident Inspectors, CPSES (3)

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8707200'661'B707132-PDR. ADDCK'05000445 g-G PDQ 4, 0 400 North Olive Street LB 81 Dallas Texas 75201 tll

Attachment to TXX-6562 July 13, 1987 Page 1 of 2 l NOTICE OF VIOLATION ITEM A (445/8626-V-02)

A. ' Criterion V of Appendix B to 10CFR Part 50, as implemented by the -TUGCo Quality Assurance Plan -(QAP), Section 5.0,' Revision 3, dated July 31, 1984, requires'that activities affecting quality shall be prescribed by and accomplished in accordance with documented instructions, procedures, or drawings of a type appropriate to the circumstances.

Paragraph 3.1.2.e-of TUGC0 Procedure QI-QP-11.3-40, Revision 14, dated January 9,1984, states, in part, " Verify that . . all cable pulling -

aids have been removed (i.e., fish tape, tape rope, etc.)."

Paragraph 3.1.1.2.c of the above procedure, Revision 18, dated May 18, 1984,' states, " Verify that . . . pulling aids (i.e., rollers, fish tape, ,

tag rope) have been. removed from raceway."

Contrary to the above, TUGC0 inspectors performing post construction inspections failed to identify cable pulling ropes remaining in Class 1E conduit C12018896 and Class 1E cable tray T130ACG57 located in the Unit I reactor building and auxiliary building, respectively (445/8626-V-02).

RESPONSE TO ITEM A (445/8626-V-02)

TU Electric accepts the alleged violation and the requested information follows:

l' 1. Reason For Violation Regarding cable tray T130ACG57, construction procedures controlling cable pulling activities performed subsequent to QC acceptance of raceway systems did not require QC reverification of pulling aid removal.

Regarding conduit C12018896, Revision 14 of QI-QP-11.3-40 in effect at the time of post construction inspection required QC inspectors.to identify visible-pulling aids but did not require the removal of junction box, pull' box or conduit covers to verify that pulling aids had been removed.-

2. Corrective Steos Taken And Results Achieved Nonconformance Report (NCR) E-86-103883S and Construction Deficiency Report (CDR) 87-4746EC (previously NCR E-86-103981) were issued to address pull ropes in conduit C12018896 and cable tray T130ACG57, respectively.

Both documents have been dispositioned " rework" by directing the removal of the pull ropes.

Corrective Action Request (CAR) 87-59 has been initiated which will address the generic implications of this violation and will define appropriate corrective actions.

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lY Attachment to TXX-6562 L' July 13,1987 '

Page 2'of 2 NOTICE OF VIOLATION RESPONSE TO ITEM A (445/8626-V-02) CONT'D

3. Corrective Steos Which Will.Be Taken To Avoid'Further Violations-A draft. revision (Revision.8) of construction Procedure EEI-7.has been-prepared .which requires removal . of all pulling aids (i.e. pull ropes, fishtape, etc.) after cable pulls into covered cable trays orL conduit are completed. Pending implementation 'of EEI-7, Revision 8, the Director of .

Construction has issued. instructions to appropriate construction staff'to

. remove' pulling aids upon completion'of cable pulls as described in the

-draft procedure...

Quality In!,truction QI-QP-11.3-40, Revision.26, has been revised by a

- Document Change Notice (DCN) to require the removal of condulet covers to

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verify pulling aid removal. A previous revision of this procedure' (Revision 15,' dated February 13,'1934) required removal of junction box,.

pull box and termination box covers to-facilitate verification of pulling -

aid ~ removal.

4. Date When Full Comoliance Will Be Achieved Compliance will be addressed'through the action plan developed to resolve.

CAR 87-59 which is-anticipated by September 30, 1987-. The necessary

! corrective actions will be completed by December 31,'1987.

Revision 8 of EEI-7 will be implemented by ' July '27,1987.

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