ML20006E189
| ML20006E189 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/01/1990 |
| From: | Lyons J Office of Nuclear Reactor Regulation |
| To: | Brink B CITIZENS FOR FAIR UTILITY REGULATION |
| References | |
| NUDOCS 9002220253 | |
| Download: ML20006E189 (5) | |
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February 1, 1990 4
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-Mrs-Betty Brink, Board Member Citizens for Fair Utility: Regulation'
<7600~Anglin Drive-s
- Fort Worth,= Texas 76148'
Dear Mrs. Brink:
SUBJECT:
- ERRATA TO STAFF RESPONSE TO CFUR ISSUES
-'Please replace pages 3, 4, and 7 of the staff response issued on January 30, 1990 with the reviesd pages 3, 4, and 7 attached hereto. Marginal bars indicate the areas of change.
Sincerely, Original signed byl James E. Lyons, Chairman Allegation Review Committee
-Comanche Peak Project Division l
Enclosure:
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~ Mrs.. Betty Brink 2-Icbruary 1, 1990 cc w/ enclosure:
Mr. Robert F. Warnick Jack R. Newman, Esq.
Assistant Director Newman & Holtzinger for Inspection Programs 1615 L Street, NW Comanche Peak Project Division Suite 1000 U. S. Nuclear Regulatory Commission Washington, D.C.
20036 P., O. Box-1029 j
Granbury, Texas 76048' Chief, Texas Bureau of Radiation Control Texas Department of Health Regional Administrator, Region IV 1100 West 49th Street U. S. Nuclear Regulatory Commission Austin, Texas 78756 011 Ryr.n Plaza Drive, Suite 1000 Arlington, Texas 76011 Honorable George Crump I
County Judge Ms. Billie Pirner Garde, Esq.
Glen Rose, Texas 76043 Robinscr, Robinson, et al.
103 East College Avenue Mr. William J. Cahill, Jr.
Appleton, Wisconsin 54911 Executive Vice President TU Electric Mrs. Juanita Ellis, President 400 North Olive Street, Lock Box 81 1
Citizens Association for Sound Energy Dallas, Texas 75201 1426 South Polk Dallas, Texas 75224
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E. F. Ottney i
P. O. Box 1777 Glen Rose, Texas 76043 j
4 Mr. Roger D. Walker Manager, Nuclear Licensing Texas. Utilities Electric Company 400 North Olive Street, L. B. 81 Dallas,~ Texas 75201 1
Texas Utilities Electric Company c/o Bethesda Licensing 3 Metro Cer, tar, Suite 610 Bethesd% t%ryland 20814 William A. Burchette, Esq.
Counsel for Tex-La Electric Cooperative of Texas Heron, Burchette, Ruckert & Rothwell 1025 Thones Jefferson Street, NW l
Washington, D.C. 20007 GDS ASSOCIATES,-INC.
Suite 720 1850 Parkway Place Marietta, Georgia 30067-8237 1
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The risk'that the CPSES spent fuel pools will.not have sufficient storage capacity is an economic risk only, not a safety risk. The CPSES spent
-f fuel pools meet the minimum design capacity guidelines for a dual shared.
facility of one full core discharge plus two normal fuel discharge cycles L(322 fuel assemblies for CPSES) as set forth in ANS 57.2. The CPSES Technical Specifications, which will be-a part of the license, limit the storage capacity to no more than 1116 fuel assemblies as is currently-l~
designed. Any future changes to the storage capacity will require a license amendment and the attendant opportunity for a hearing. However, it should be noted that the Comission has determined that spent fuel pool modifications using previously approved methods involve a no significant
. hazard consideration as defined in 10 CFR 50.92 and, therefore, do not require that a hearing be held prior to issuance of the amendment.
The Consission addressed the issue of long term storage of spent fuel in its August 31. 1984 Waste Confidence Decision.
Currently 10 CFR 51.23 states in~part:
The Comission has made a generic determination thet for at least 30~ years beyond the expiration of reactor operating licenses no significant environmental impacts will result from the storage of spent fuel in reactor facility storage pools or independent spent fuel stcrage installations located at reactor or away-from-reactor sites.
The background discussion from the review and proposed revision of the Waste Confidence Decision and a conforming amendment to 10 CFR Part 51, which was published in tie Federal Register on Septemver 28, 1989, (Attachment.1) describes the actions te.en to date by the Commission.
The proposed revision te the Waste Confidence Decision reaffirms and.
supplements the 1984 findings and the' environmental analyses supporting them.
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Check valve failures that occurred during hot functional testing in April and May 1989 were critical and would have contaminated systems outside containment. TU Electric's response to the check valve failures L
was inadequate, according to the NRC's July 10, 1989 report. Additional Borg-Warner check valve problem: have been identified by the NRC since initial failures in April and Hay.
Evaluation t.
L As stated in the December 7, 1989 meeting, CFUR's concerns were derived from the findings in the NRC's Augmented Inspection Team's (AIT) report and subsequent NRC inspection reports and letters regarding the check l
valv'e' failures. The NRC review of Borg-Warner check valve issues is still in progress.
Previous inspections related to this topic are documented
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, j in NRC Inspection Reports 50-445/89-30, 50-446/33-30; 50-445/89-52, 50-446/89-52; 50-445/89-64, 50-446/89-64; 50-445/89-71, 50-446/89-71;
'50-445/89-73, 50-446/89-73; 50-445/89-84, 50-446/89-84; and 50-445/89-88, 446/89-88.
Tne NRC staff has concluded that the applicant's corrective action program to reset and control the bonnet elevation of Borg-Warner check valves will effectively. prevent the previously observed phenomenon where the valve disk jammed under the seat ring. Although some problems'have been encountered in the implementation of these corrective actions, the applicant's commitment to conduct a functional backflow test and/or radiographic examination for each valve will provide reasonable assurance that all Borg-Warner check valves are capable of performing their design function.
In NRC Inspection Report 50-445/89-73,50-446/89-73(Attachment 2),the NRC identified 12 open items regarding various issues staming from the l.
AFW backflow events. To date, two of these open items have been closed as documented in NRC Inspection Reports 50-445/89-84, 5U-446/89-84 and 50-445/89-88, 50-446/89-88 (Attachments 3 and 4). All open items will be closed out prior to licensing and the closecuts will be documented in NRC Inspection Report 50-445/90-00,50-446/90-03 and subsequent reports.
In addition to the open items, the NRC'has issued an enforcement action, EA-89-219 dated January 25,1990-(Attachment 5). That action is being' taken to emphasize the importance of the lessons learned from the check valve failure events.
An issue not raised in the Stay Request, but in CFUR's subsequent November 8, 1989 letter to the NRC, was that the NRC had identified ddditional Borg-Warner Check valve problems since the initial failures in April and May.
TV Electric reported the failure of a swing arm in a Borg-Warner check valve installed in the service water system.
As the-result of discovering the failed swing arm, the NRC staff is reviewing the service suitability of the Borg-Warner check valve swing arms. The applicant, along with its consultant, Aptech, conducted an extensive series of nondestructive tests on the swing arms to identify and replace the discrepant swing arms. An extensive engineering analysis was performed to demonstrate the acceptability of those swing arms which were not replaced. That analysis is now under review and the NRC will ensure that the check valves operate properly prior to making a decition on a Unit 1 fuel load license.
The AIT report indicated that, during the check valve failure events, operations personnel failed to effectively reccanize and act on conditions adverse to quality. The staff's concerns regarding those findings are described in the subsequent enforcement action (EA-89-219). However, we consider the significance of these findings related to TU Electric's transition' from construction activities to an operational environment.
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1 Bulletin 87-02 required that a general sample of fasteners from warehouse stock be tested. As required by the bulletin, TV Electric had the fasteners tested by a laboratory they had qualified to perfom *h's type of. testing.
o The tests were performed in accordance witi' the requirtents of the applicable fastener's specification, grade, and class. TV Electric responded by letters dated July 22 and January 11, 1988, and found that all of the fasteners tested were acceptable for use.
CAR-38-36 addressed the generic adequacy of fasteners other than fasteners supplied by Aircom.
It was concluded that no generic problem existed based for the most part on the results of testing to support IE Bulletin 87-02.
In addition, the NRC concluded in NUREG-1349 (a summary of utility test data responding to IEB 87-02) that the test results generally "did not indicate'a safety concern relating to the use of mismarked or counterfeit fasteners in the nuclear industry." NRC Inspection Reports 50-445/88-56,50-446/88-52; 50-445/89-03, 50-446/89-03; 50-445/89-18, 50-446/89-18: and 50-445/89-78, 50-446/89-78(Attachments 6through9)addressedSuppiements1and2to i
NRC Bulletin 87-02 as well as other matters related to counterfeit parts.
As documented in the NRC inspection reports referenced above and TV Electric corrective action report (CAR) numbers 88-34, 35, and 36, in response to NRC Bulletin 87-02, a significant number of ' safety related and non-safety related fastenters of questionable quality and quality documentation were purchased from Aircom Fasteners, Inc., a fastener distribution company.
As a result, TU Electric tested 96 of the fasteners from Aircom which had not been installed in the plant for conformance to specification require-ments. As. documented in the TV' Electric and NRC. documents referenced above, only very minor deviations from specification requirements for chemical and physical properties wert noted. Thereby TU Electric demonstrated that this sample of 96 Aircom fasteners selected for test would be acceptable for use had they been installed.
Subsequently, after review of the foregoing information by the NRC staff and in response to questioning, TU Electric selected a representative sample of 200 fasteners installed in electrical cable tray support systems.
This sample was biased to include fasteners most likely supplied by Aircom Fastener Inc.
These 200 fasteners were removed and subjected to the same physical and chemical testing as were the initial 96 fasteners noted above 4
to determine if they met the purchase order and specification requirements.
As a result of chemical and physical testing of this sample of 200 previously installed fasteners, supplied in part by Aircom, the NRC is satisfied that these fasteners met the requirements of the specification or, in those few cases where they departed from the specification, the deviations did not affect the structural capability of the fasteners. Thus, they are adequate for the intended service.
In addition to the NRC activities discussed above, NRC representatives witnessed the testing of these 200 fasteners at South Western Labora~
tories on October 30 and November 1,1989 and observed that all
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