ML19269E062

Forwards Requests for Addl Info Required to Complete Evaluation of Application for OL

ML19269E062
Person / Time
Site:	Comanche Peak
Issue date:	05/22/1979
From:	Baer R Office of Nuclear Reactor Regulation
To:	Gary R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
NUDOCS 7906230163
Download: ML19269E062 (20)

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WASHINGTON. D. C. 20555 g,,; .,f UAY 2 21379 m Docket Nos. - 50-445 and 50-446 Mr. R. J. Gary Executive Vice President and General Manager Texas Utilities Generating Company 2001 Bryan Towers Dallas, Texas 75201

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR COMANCHE PEAK STEAM ELECTRIC STATION, UNITS 1 AND 2 Enclosed are requests for additional information which we require to complete our evaluation of your application for operating licenses for Comanche Peak Steam Electric Station, Units 1 and 2. These requests for additional infor-mation are the results of our review of the information in your FSAR through Amendment , and cover those areas of our review performed by the Auxiliary Systems Branch, Materials Engineering Branch, Structural Engineering Branch, Effluent Treatment Systems Branch, o.adiological Assessment Branch, Geosciences Branch and Hydrology-Meteorology Branch. Please amend your FSAR to include the information requested in the Enclosure. Your schedule for responding to the enclosed request for additional information should be submitted within three weeks. Based on your schedule fo: response and our workload, we will determine any licensing review schedule adjustments and inform you of any significant changes. Sincerely, n. f -{r $ f 5',l.W " Robert L. Baer, Chief Light Water Reacter: Brancn No. 2 Division of Project '.anagemen: E n c'. c s u re : 3 e C: r.: ECu".d Request fer A d d i ti o e.a l I n f o r~.a ti on 2250 316 ces w/ enclosure: See next page 7006230ff]g

Te,.as Utilities Generating Company ccs. fiicholas S. Reynolds, Esq. Cebevoise & Liberman 1200 Seventeenth Street Washington, D.C. 20036 Spencer C. Relyea, Esq. Worsham, Forsythe & Sampels 2001 Eryan Tov.er Callas, Texas 75201 t'r. Honer C. Schmidt Project Manager - T ucl ar Plants Texas Utilities Generating Conrany 2L;l Eryan Toscer Callas, Texas 75201 Mr. H. R. Rock Gibbs and Hill, Inc. 393 Seventh Avenue I,ew York, i;ew York 10001 Fr. A. T. Parker Westinghouse Electric Corporation P. O. Box 355 Pi ttsburgh, Pennsyl vania 15230 2250 317 e

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575 ENCLOSURE 1 SECO'iD ROUND REQUEST FOR ADDITIONAL INFORMATION COMAfiCHE PEAK STEAM ELECTRIC STATION UNITS 1 AND 2 TEXAS UTILITIES GENERATitiG COMPANY DOCKET N05.: 50 445 50-446 2250 318 O

E'.*Y

1979 Auxiliary Systems Branch Comanche Peak Steam Electric Station Unit Nos. 1 and 2 Docket Nos. 50-445 and 50-446 005.4 Your response to our inquiry 005.3 is unacceptaole.

Footnote 6 of the Codes and Standards Rule, Section 50.55a of 10 CFR Part 50, states that the use of specific Code Cases may be authorized by the Commission upon request. Therefore, each Quality Group A com-ponent within the reactor coolant pressure boun'dary to which a Code Case has b'een applied should be identified by Code Case number, revi-sion, and title. This includes those ASME Code Cases which are iden-tified as acceptable to the Commission in Regulatory Guides 1.84 and 1.85. 21250 319 4 O e

GY 2 : % 73 121-1 121.0 MATERIALS ENGINEERING BRANCH - MATERIALS INTEGRITY SECTION 121.7 Provide the date of the purchase order for your reactor vessels, identifying the firm with whom the purchase orders were placed, the vessel fabricator, and applicable edition of ASME Code requirement pursuant to 10 CFR Part 50.55a(c). 121.8 Identify each material (plate, and/or forging and weld metal) in the beltline region (as defined by Paragraph II.H, Appendix G, 10 CFR Part 50) for Unit Nos. 1 and 2 and provide a sketch showing the location of these materials in the reactor vessels. Provide the following infor-ation for each material: (1) Chemical analyses; particularly those elements known to ' affect irradiation sensitivity and degrade the upper shelf fracture energy (Cu, P, and S). Estimate the maximum anticipated change in RT and (2) upper shelf fracture energy as a function of b EOL fluence at the inner wall for materials in the beltline region of the reactor vessel. 121.9 We require that your inspection program for Class 1, 2 and 3 components be in accordance with the revised rules in 10 CFR Part 50, Section 50.55a, paragraph (g). Accordingly, submit the following information: (1) A preservice inspection plan which is consistent with the required edition of the ASME Code. TFis inspection plan should include any exceptions you propose to the code requirements. (2) An inservice inspection plan submitted within six months-of the anticipated date for commercial operation. This preservice inspection plan will be required to support the safety evaluation report finding regarding your compliance with preservice and inservice inspection requirements. Our determination of your compliance will be based on: (1) That edition of Section XI of the ASME Code referenced in your FSAR or later editions of Section XI referenced in the FEDERAL REGISTER that you may elect to apply. (2) All augmented examinations established by the Commission when added assurance of structural reliability was dee ed necessary. Examples of augrented examinaticn requirements can be found in the *,9C positions on: (1) high energy 2250 320

/AY L CTn 121-2 fluid systems in Section 3.6 of the Standard Review Plan (SRP), NUREG-75/087, and (2) turbine disk integrity in Section 10.2.3 of the SRP. Your response to this item should define the app 1';able edition (s) and subsections of Section XI of the 'E Code. If any of the examination requirements of the pc ticular edition of Section XI you referenced in the FSAR cannot be met, a request for relief must be submitted, including complete technical justification to support your request. Detailed cuidelines for the oreparation and content of the inspection programs to be submitted for staff review and for relief requests are attached as an Apoendix to Question 121.9 of our review questions. 2250 32l' O e O

PAY t t GII ATTACHMENT A APPENDIX T0 QUESTION 121.9 GUIDANCE FOR PREPARING PRESERVICE AND tiSERVICE INSPECTION PROGRAMS AtiD RELIEF REQUEST PURSUANT TO 10 CFR 50.55a(g) A. Description of the Preservice/ Inservice Insoection Program This program should cover the requirements set forth in Section 50.55a(g) of 10 CFR Part 50 and the ASME Boiler and Pressure Vessel Code, Section XI, Subsections IWA, IWB, IWC and LWD. The guidance provided in this enclosure is intended to illustrate the type and extent of information that should be provided for NRC review. It also describes the information necessary for " request for relief" of items that cannot be' fully inspected to the requirements of Section XI of the ASME Code. By utilizing these guideline, licensees can significantly reduce the need for requests for additional information from the NRC staff. B. Contents of the Submittal The information listed below should be included in the submittal: 1. For eacn facility, include the applicable date of the ASME Code and the appropriate addendum date. 2. The period and interval for which this program is aDplicable. 3. Provide the proposed codes and addenda to be used for repairs, modifications, additions or alternations to the ' facility which might be implemented during this inspection period. 4. Indicate the examinations that you have exempted under the rules' of Section XI of the ASME Code. A reference to the applicable paragraph of the code that grants the exemption is satisfactory. The inspection requirements for exempt components should be stated (e.g., visual inspection during a pressure test). 5. Identify the inspection and pressure testing requirements of the applicable portion of Section XI that are deemed impractical because of the limitation of design, geometry or materials of construction of the components. Provide the information requested in the following section of this appendix for the inspections and pressure tests identified in Item 4 above. 2250 ;22 O

i.'J 2 : *i73 C. Recuest for Relief frem Certain Inspection and Testinc Recuirements It has been the staff's experience that many requests for c!'ef from testing requirements submitted by licensees have not ber.a supported by adequate descriptive and detailed technical information. This detailed infomation is necessary to: (1) docu ent the impracticality of the ASME Code requirements within the limitations of desian, geometry and materials of construction of components; and (2) detemine whether the use of alternatives will provide an acceptable level of quality and safety. Relief recuest submitted with a justification such as " impractical," " inaccessible," or any other categorical basis, require additional info mation to permit the staff to make an evaluation of that relief request. The objective of the guidance provided in this section is to illustrate the extent of the infomation that is required by the fiRC staff to make a proper evaluation and to adequately document the basis for granting the relief in the staff's safety Evaluation Report. The-f4RC staff believes subsequent requests for additional infomation and delays in completing the review can be considerably reduced if this infomation is provided initially in the licensee's submittal. For each relief request submitted, the following infomation should be included: 1. An identification of the component (s) and/or the exanination requirement for which relief is requested. 2. The number of items associated with the requested relief. 3. The ASME Code class. 4. An identification of the specific ASME Code requirement that has been detemined to be impractical. ~ 5. The infomation to support the detemination that the requirement is impractical; f.e., state and explain the basis for requesting relief. 6. An identification of the alternative examinations that are proposed: (a) in lieu of the requirements of Secticn XI; or (b) to su:plement examinations performed partially in compliance with the requirements of Section XI. 2250 ]23 O

?%Y : : 17, -3 7. A description and justification of any changes expected in tne overall level of plant safet'y by performing the proposed elternative examinattens in lieu of the examination required by Section XI. If it is not possible to perfom alternate examinations, discuss the impact on the overall level of plant quality and safety. For inservice inspection, provide the following additional information regarding the inspection frequency: State when the request for relief would apply during the 8. inspection period or interval (i.e., whether the request is to defer a.n examination). 9. State when the proposed alternative examinations will be implemented and performed.

10. State the time period for which the requested relief is needed.

Technical justification or data must be submitted to supDort the relief request. Opinions without substantiation that a change will not affect the quality level are unsatisfactory. If the relief is requested for inaccessibility, a detailed description or drawing A which depicts the inaccessibility must accompany the request. relief recuest is not required for tests prescribed in Section XI that do not apply to your facility. A statement of "N/A" (not applicable) or "None" will suffice. D. Re:uest for Relief for Radiation Considerations Exposures of test personnel to radiation to accomplish the examina-tions prescribed in Section XI of the ASME Code can be an important factor in detemining whether, or under what conditions, an examina-tion must be performed. A request for relief must be submitted by the licensee in the manner described above for inaccessibility and most be subsequently approved by the NRC staff. We recogni::e that some of the radiation considerations will only be known at the time of the test. However, the licensee generally is aware, from experience at operating facilities, of those areas where relief will be necessary and should submit as a minimum, the following infomation with the request for relief: 1. The total estimated man-rem exposure involved in the examir.aticn. 2. Tne radiation levels at the test area. 2250 324

~ !~l,Y 2 t 'E . 3. Flushing or shielding capabilities which might reduce radiation levelt. 4. A proposal for alternate inspection techniques. 5. A discussion of the considerations involved in remote inspections. 6. Similar welds in redundant systems or similar welds in the same systems which can be inspected. 7. The results of preservice inspection and any inservice results for the welds for which the relief is being requested. 8. A discu'ssion of the consequences if the weld which was not examined, did fail, 2250 325 O

v;T t t GTs COMANCHE PEAK NPP UNITS 1 & 2 STRUCTURAL ENGINEERING BRANCH .FSAR Q-2 EVALUATION 130.26 In your reply to Q-130.20, you dismissed the damage notential of tornado ( 3. 3.2 ) missiles impacting on the " Blow-out" panels and the consequences of missiles passing through the opening developed by the elimination of this type of panel at the established release pressure. Provide a descripticn of the specific barrier, and sketches, used to stop any missiles that enter the Category I structures through the opening developed by the elimination of the " Blow-out" panels. 130.27 State the criteria used to account for accidental torsional effect (3.7.2) of all Category I structures, including the Containment building. It is our position that a minimum of 55 accidental eccentricity should be considered due to the fact that both construction tolerances anc the internal structures would introduce some degree of eccentricity e f fec t. This can be accomplished by evaluating the structure consider-ing 5% of the largest base mat dimension as an accidental eccentricity. That is the distance between the actual center of mass and the center of rigidity must be modified by the 5% eccentricity. Provide information to demonstrate the extent to which the containment structure and the components located within the structure are capable of witnstanding the largest load resulting from this criteria together

6. i *.1 ctner applicable loads.

In addition, provide the same informaticn for al' c:rer Category I structures. 2250 326

' *J.. $75 . 133.25 In ycur answers to Q130.5, 16, 18, and 25, you stated how you considered (3.3.1) (3.8.3) the design and acceptance criteria identified in ACI-359 and SRP (3.8.4) 3.8.1, 3.8.3 and 3.8.4 to valicate the actual structural design of the Category I structures of the Comanche Peak NPP. In your con-clusions, you stated that the actual design meets the requirements of ACI-359 and SRP 3.8.1, 3.8.3 and 3.S.4. Provide a detailed description of the specific controlling sections and cceponents investigated in ycur re-evaluation', including psetinent sketches and results. 130.19 State the testing frequency of water, ice and aggregate used in the (3.3) construction of this NPP. In addition, state the limits used for chloride content of the mixing water / cement cn concrete paste that are used and verified in the construction of this NPP. 130.30 State the locaticn of inspection of pumped concrete, as acclicable. (3.5) The staff requires that pumped concrete be sampled at the elevation at which it is to be placed. This requirement is stated in section 4.8 of ANSI N45.2.5 - 1974. State if you follow this requirement. 130.31 Provide details on the orientation error of the Reactcr Pressure (3.8) Vessel support structure, including the re-orientation efforts with "ll structural details. In addition, address in detail how you a plan to develop shear resistance through the use of the rebar rein-forcement and grout effectiveness. 2250 c27 O

A1 22 *si?,-n

,ddress the design ccnsiderations for the Reactor Pressure '/essel's gjj' uplift and lateral displacement in view of the lack of any hold-down systems. 2250 328 9 O O

uv t. *Ir; 320-1 320.0 EFFLUENT TREATMENT SYSTEMS BRAiiCH 320.9 In our review of gaseous waste process systems using reccmbiners (11.3) with gas recirculation back to the compressors, we have had several reports frcm operating plants that catalyst migration has occurred, contaminating lines containing high hydrogen concentrations. What type of catalyst will be used, and what steps will be taken to prevent catalyst migration? 2250 329 e O

F.',Y t 2 T: 331-1 331.0 RADIOLOGICAL ASSESSMENT 331.8 Your response to Items 331.1 and 331.5 regarding the (12.1) qualifi.aticns of the individuals responsible for the radiation protection design review is unacceptable. Provide evidence that the individual responsible for these ongoing reviews will meet the qualifications recuirements for,the Radiation Protection Manager as presented in Regulatory Guide 1.3, " Personnel Selection and Training". 331.9 Describe the features that have been incorporated (12.2) into the design to permit plant operators and main-tenance personnel to maintain occupational radiation exposures as low as is reasonably achievable by minimizing and controlling the buildup, transport, and deposition of activated corrosion products in the reactor coolant and auxiliary systems in the Comanche Peak units. If you have followed the provisions of WCAP-8872, justify departures from the guidance therein. ~ 331.10 Describe precautions taken to prevent inadvertent (12.3) personnel access during fuel transfer to the very high radiation areas in the vicinity of the fuel 2250 330 O

i3.. ::: 331-2 331.10 - cont'd transfer tube. If there is sufficient permanent shielding to assure acceptable levels in adjacent, potentially occupied areas, provide relevant plan and elevaticn drawings. 331.11 Your response to Item 331.4 and 331.7 is incomplete. (12.5) Shew, on Figure 12.3-21, placement of monitoring instruments, and traffic patterns for male and female workers from unrestricted areas through the plant and change areas, and return. 22i0 33i 9 O

REQLESTS FOR AD:IT:::.A. INFORMAT!::. CCMAN:WE PEA 4 STEA!' ELECTRIC STATIC *, TEXA5 UTILITIES GENERATING COMPANY DOCKET N05. 50-445/446 GEOSCIENCES BRANCH 361.25 As requested previcusly in f;RC questiens 361.4 and 351.17, (2.5.1.2) provice copies cf the telephone conversations with A. Winslew and J. Montgomery of the U. 5. Geological Survey, regarding the non-subsidence potential of the Cretaceous sandstcne in the site vicinity. Individual letters from the USGS personnel, which you are attempting to obtain, although desirable, are not essential. 361.26 The NRC is to be advised, on the four month basis currently (2.5.1.2) (Position) established and until such time that the matter of nineral rights within the exclusion area is resolved with the N?.C staff, of the status of hydrocarbon exploration and development within a 5 m'.le radius of the plant site. This information (well location map and an explanatory table), is to be sub-nitted in the format described in your January 31, 1979 resocnse to NRC question 361.14 and in the attachment to your Jan. 19, 1979 letter to NRC (C, K. Feist to R. Naventi). 361.27 The applicant has provided the NRC staff with a copy of Geomap's (2.5.1.2)* site vicinity structural contour map of the Marble Falls horizon. This ccntour map shows several faults in addition to the fault identified in the FSAR by the applicant. None of the Geomap faults are closer than six niles to the site. The applicants" basis for conclucir.; that their fault does not extend through the Faisozoic secticr. (therefere r.ct capable) is based u::n their 2250 332 O

SY 0 ; E: interpretationofwellspenetratingthePennsylhanian Strawn formatien (FSAR Fig. 2.5.1-23). These data are -~ meager. In order to ccnfir. the Applicants interpretaticn (non-faultingoftheStraven) provide,ifchailable,Geomap's (or similar source) structural contour map of that horizun. 251.25 Two prominent local Paleozoic hydrocarbon horizon producers - (2.5.1.2) the Big Saline and Strawn - are not shown on FSAR Figure 2.5:1-11, Lccal Geologic Column. Revise this figure to include these two horizons. 351.29 Landgrahitydatahaverecentlybeenmadeavailablefromthe (2.5.1.1) National Geophysical and Solar-Terrestrial Data Center (NOAA) at 50ulder, Colorado for large porticns of the conterminous United States. Determine the coverage Of the NCAA data applicable for the circled area represented on FSAR Figure 2.5.1-8'(Regional Bouguer Gravity Map) and the, feasibility of revising or complementing the infomation presented on this figure. Revise secticns of the FSAR (2.5.1.2.2 and 2.5.1.2.4, perhaps others) as appropriate. 351.30 Based upon hydrocarbon exploration within the past few years (2.5.1.2) as well as earlier work (G. L. Turner, 1957) several FSAR figures (2.5.1-3 and 2.5.1-5 perhaps others) repuire revisien in order c reflect our current knowledge of subsurface structure. The abcve 1957 paper describes a nu-ter of nortneast-: rending structures (faults) ir ediately scuth cf the site extendir.g ir,tc Sc erwell, Ecs;ue, and Ccryell ccur. ties. The Gecmap coverage of the site area sho.cs several other.similar trending faults extendir; beyond 2250--333

MY22 E 2-the region shown in Turner's 1957 paper. F.evise all appropriate FSAR figures and text in keeping with currently available information. 2250 334 e 9 m e

REOU STS FOR A;0!TIONAL INFORMATION g CCMANCHE FEM STEA. ELECTRIC STATION TEXAS UTILITIES GENERATING COMPANY DOCKET N05. 50 445/;46 HYDRCLOGY METEOROLOGY BRAMCH 371.1* In your analysis of a postulated release of radioac'tive aterial into (ESP) the groundwater, you state that the nearest public water supply well is 3.1 miles away from the site while Figure 2.4-35 in the FSAR shows domestic and stock water wells that are just beyond the property line about 2 niles from the plant. It is our position that the well prohiding tne most critical indirect or direct pathway to nan should be considered in this analysis. Document that the well you used prohides the most critical pathway. Alternately,rehiseyobr analysis. 371.15 You state that parapet walls on safety related buildings hahe (RSP) relief openings to ensure that a design water depth of eight inches is not exceeded. In addition, each building has a rcof drainage systemdesignedtopasstheYolumeofwaterresultingfromasix inch-one hour rainfall with a maximum intensity of two inches in fiheminbtes. Our experience shows that roof drains often become. blocked with debris and do not function as designed; therefore, it is = ourpositionthatthereliefopeningswhichyobareprohidingin j parapet walls, must be capable of passing a sufficient amount of water from the Probable Maxinum Precipitation to limit roof ponding to no morethanyourdesignlehelofeightinchesassbmingthatallroof drains are blocked. You should identify the location, size and elecnion of each relief opening and sho,. by pertinen; analysis that roof pending will not exceed eight inches. 2250 335 o O}}