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.JAA 2 41!E5 Docket Nos: 50-445, 50-446 Texas Utilities Electric Company ATTN:
M.D. Spence, President, TUGC0 Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Sub,4ct:. Comanche Peak Response Team Action Plan
Dear Mr. Spence:
On October 19 and 23, 1984, we met with you and members of your staff, at your request, to discuss the Program Plan and Issue-Specific Action Plans (the
" Plan") submitted to the NRC on October 8, 1984. This Plan was developed in response 'to the NRC letter of September 18, 1984, requesting additional information as a result of the Techni~ al Review Team assessment of certain c
onsite detivities at Comanche Peak. These activities were in the electrical / instrumentation, civil / structural, and test programs areas.
By letter dated November 21, 1984, the staff received Revision 1 to the Program Plan. We noted that you have incorporated into the revised Program Plan many of the general comments raised in the referenced meetings, such as, the need for obtaining an external perspective and independent assessment, identifying a basis for selection of samplge. sizes, identifying root causes, and consideration of all relevant informationf a particular area. We also note that you are still reconsidt: ring the Program Plan and are going to revise the Issue-Specific Action Plans to address our comments. Since we have not received your revised Issue-Specific Action Plans, we are providing our detailed coments in an Enclosure to this letter so that you may consider them in your revision.
You will soon be receiving.the Supplemental Safety Evaluation Reports (SSERs) in the electrical / instrumentation, civil / structural, and test programs areas.
The SSERs will provide further clarification and additional actions required as part of our continuing assessments.
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"GARDE 054
d M. D. Spence.
Prior to approval of your plan, the NRC requires you -to resolve all the
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matters discussed herein. As discussed at these meetings, the_TRT will continue to assess the actions you are taking pursuant to the Plan, and revisions thereto. As part of this assessment I will be meeting with you periodically to discuss the progress of the Plan.
Sincerely,
[g o an Director manche P ak Project
Enclosure:
As stated i
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Enclosure s
COMMENTS ON COMANCHE PEAK RESPONSE TEAM ISSUE-5PECIFIC ACTION PLANS I.
Electrical /Instrumentatio'n Area a.1. Heat Shrinkable Cable Insulation Sleeves 1.
When clarifying the construction installation procedures to identify the conditions which require actual installation of nuclear heat shrinkable insulating sleeves, revision of procedure QI-QP-11.3-40
" Post Construction Inspection of Electrical Equipment and Raceways" should be considered to assure that the inspection of nuclear heat shrinkable insulating sleeves is documented.
a.2. Inspection Reports on Butt Splices 1.
The, action plan does not identify the record retention system used to indicate how the additional inspection reports (which document the required butt splice witnessing) were obtained.
2.
The action plan does not state the basis for selecting the additional sample of twelve cables.
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3.
Phase 2 of the action plan, irfespective of findings in s
Phase 1, which requires the identification of all drawings on which butt spl1ces occur, shall be implemented. Amendment 44 of the FSAR permits only limited amounts of butt splices to be used, and the NRC staff accepted the practice on this basis.
4.
It should be noted, Phase 2 is also accomplished as part of action plan Item I.a.3, Section 4.A (third paragraph) and Section 4.8.
a.3. Butt Splice Qualification i$
Identify those cables and circuits in which butt splices exist '
in control panels.
2.
Section 4.A (paragraph 3) should be coordinated with action
' p.lan Item I.a.2, Phase 2 in verifying butt splices in appropriate
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panels.
3.
Section4.Bshouldbecoordinated;withactionplanItem:.a.2, Phase 2 in verifying butt splices in bundles.
4.
The action plan does not take into account completed butt splice installations which may not be found staggered due_to the o
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a.4. Agreement Between Drawings and Field Terminations 1.
The action plan does not define what is meant by circuit reliability requirements used as the criteria by TUEC engineering for specific acceptance / rejection criteria.
2.
The NRC staff does not agree with TUEC's position of acceptable conditions based on operability alone.
In this issue operability, as well as, conformance of hardware to the "as built" configuration drawings and documents is o'f concern.
3.
Acceptable conditions, in the action plan, using cable /
conductor terminations of a size larger, should be supplemented to
- include the requirement for a good connection to be established.
4.
The action plan shall identify all the latest design documents to the "as built" configuration drawings, to be used in the TUEC sampling program.
a.5. NCR's on Vendor Installed AMP Terminal Lugs s
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The action p'an does r.ct require the lug marsfacturer to
' prov~ide documented analyses to substantiate his change in position between the APC memo cf Septamber 2, 1981 (60* bendacceptable)and docume'nted telephone record of April 17, 1984 (90* be~nd acceptable).
2.
The action plan does not require the lug manufacturer or TUEC engineers to addrtss the mechanical strength and electrical charac-teristics of the identified " twisted" conditions identified on the NCRs.
3.
Other NCR's which identify terminal lugs bent or twisted. in EEcess of 60', which have been dispositioned as "It is our determination that these terminals do not pose an equipment serviceability problem and may be used-as-is" shbuld also be included in the action plan.
b.1. Flexible Conduit to Flexible Conduit Separation 1.
The results of the analyses to be submitted to the NRC staff in qualifying the flexible conduits as an acceptable barrier, shall include the acceptability of redundant flexible conduit,s in contact with each other.
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The analyses, as required by the IEEE Std 384-1974 (Section
' '5.6.2)/ Regulatory Guide 1.75, Revision 2 shall be based on tests performedtodeterminethe,flameretardantcharacter[sticsofthe wiring, wiring materials, equipment, and other materials internal to the control panels.'
3.
If the above' analyses can demonstrate the flexible conduit as an acceptable barrier, the G&H/TUEC design criteria, erection specifications, drawings, QA/QC procedures, and other related documents shall be corrected accordingly and identified in the action plan.
b.2. Flexible Conduit to Cable separation 1.
The results of the analyses to be submitted to the NRC staff in qualifying the flexible conduit as an acceptable barrier, shall include redundant cable in contact with the flexible conduit barrier.
2.
The analyses, as required by the IEEE Std 384-1974 (Section 5.6.2)/ Regulatory Guide 1.75, Revision 2, shall be' based on tests 1 performed to determine the flame retardant characteristics of 'the wiring, wiring materials, equipment, and other materials internal to the control panels.
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3.
If the above analyses can demonstrate the flexible conduit as an acceptable barrier, the G&H/TUEC design criteria, erection specifications, drawings, QA/QC procedures, and other related documents shall be corrected accordingly and identiffed in the action
- plan, b.4. Barrier Removal 1.
If the root cause is determined to have generic implication for the redundant field cables not meeting the six inch minimum separation requirement, the action plan shall prescribe the additional action.
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d.1. QC Inspector Qualifications d.2. Guidelines for Administration of QC Inspector Test 1.
TUEC must consider the results of the overall programatic review of QC inspection qualifications when responding to items d.1 and d.2.
l II. Civil / Structural Area b.
Concrete Comoression Strength
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1.
The action plan do s not take into account the fact that more
' than one strength of concrete may have been placed between January 1976 and February 1977. Bo,th4,000psiand2,500psyconcrete grades were used on'the project, If both are present in the tested
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concrete they must be analyzed separately.
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The action plan contemplates conversion of rebound numbers to compression strength by use of the calibration curve supplied by the manufacturer. Since there is a high degree of uncertainty associated with the' application of a general calibration curve to a particular set of materials, the statistical analysis should be carried out directly using the recorded a bound numbers.
3.
Paragraph 4.(5) mentions comparison testing of concrete placed outside the time frame in question. To eliminate age effects this concrete should match the age of the concrete in question as closely
. as possible. Preferably concrete placed before the end of 1977 should be used.
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The sampling plan stipulates that 50 placements from both the concrete in question and the concrete not in question will be tested. This number is adequate, but there is no mention of tiie number of tests to be run on each placement. The plan should state the number of test areas on each placement where concrete is in question and the number of test areas on each placement where it is not. As explained in Item,5, a sufficient humber of tests on each
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placement where concrete is in question should be performed to i
substantiate the quality of each individual placement.
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5.
Because the allegation being investigated is that some
' indi~vidual tests were falsified, the strength results.for the period in question should not be regarded as a single population. The mean values for-individual placements should be c'ompared with the mean of the concrete not in question at the 55 level of significance. The specific criteria to be used for judging the final acceptability of the overall test results should be delineated in the plan. Also identify remedial actions which would be followed if the test results fail to pass the acceptance criteria.
6.
Submit Q:-QP-2.5-7, " Determination of Strength of Concrete by Use of the Concrete Test Hammer" and QI-QP-13.0-5, "Verificat.fon of-CHncrete Test Hanner."
7.
As noted in Section 5, the program for perfbrming these tests should be subnitted to the NRC for staff review and acceptance.
8.
Paragraph 4.(7) refers to a term "significant variation." Please define the term more specifically in the context of action plan
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c.
Maintenance of Air Gap Between Contrete Structures 1.
Paragraph 4.(1) should indicate that QC inspections of the seismic gaps will be performed for all Category I structures.
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2.
Paragraph 4.(3) indicates that the original analyses were based
' on clear gaps, but that subsequently the design engineer evaluated the portions of the separation areas for the effects.bf the presence of rotofoam. Clarify what areas were evaluated and when these evaluations were performed. Submit these evaluations with the overall response to this issue.
3.
Paragraph 4.(3) and the Decision Criteria should also indicate that changes in seismic response (e.g., effects of loads transferred between buildin,'s and changes in seismic loads of structures) will be evaluated.
4.
Describe more fully w' hat is meant by the statement that "QC will doc'ument the debris characteristics on a 'best-effort' basis, using conservative estimations as needed."
5.
Submit the revised procedure QI-QP-11.0-3, " Concrete or Mortar Placement Inspection."
d.-
Seismic Design of Control Room Ceiling Elements 1.
Provide details of the new horizontal-seismic restraints discussed in Paragraph 4.(a)(1) and explain what is going to replace the gypsum panels as discussed in Paragraph 4.(a)(2).
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Describe the seismic analyses,' including the details of the dynamic models that will be used to evaluate the ceiling structures.
3.
It should be clearly demonstrated that the non-safety related conduit support system in the control room for conduit 2 inches or less is covered by the generic analyses discussed in Paragraph 4.(b) of Item I.c.
4.
The Standards /heceptance Criteria should be more explicit as to the analysis and design criteria that will be utilized in evaluating the ceiling structures -(Item II.d) and the non:afety-related.
' conduit (Item I c)
S.
With respect to item 4.(c), a more detailed discussion of the
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general approach to be used for evaluating the seismic design adequacy of other Category II structures, systems and components elsewhere in the plant should be provided. The discussion should include the modeling methods, analysis approaches, key assumptions and basis thereof, as well as the computer codes to be utilized in the evaluation. Also explain why only the architectural features throughout the plant and not all non-seismic related items will be evaluated to determine the adequacy of the Damage Study program.
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6.
The results of the reviews described in Paragraphs 4(c)(1) and 4(c)(2) to address the' adequacy of the treatment of Category II and non-seismicstructures,sys,temsandcomponentselsewbereinthe plant should be audited by an independent review team consisting of
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engineers not involved with the original evaluations. The details of these audits and findings should be submitted to the NRC for review. The TRT may then conduct an independent audit to confirm these findings.
III. Test Programs Area a.1 Hot Functional Testing (HFT) Data Packages 1.
The background section states that the technical review team (TRT) performed its review of the hot functional test data packages to ascertain the acceptability of the test results. This is not true. The TRT did not validate any test data; the teara only reviewed the test procedures d resultant data to detemine conformance with the CPSES FSAR, Chapter 14 commitments and NRC Regulatory Guide (RG) 1.68, " Initial Test Programs for Water-Cooled Nuclear Power Plants." Validation of test results'is being performed, on a sampling basis, by NRC Region IV. The revision to the action plan should clarify the scope of the TRT review.
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2.
Regulatory Position 3 Section C of RG 1.68 states that, te the s extent practical, the plant conditions during the (preoperational) tests should simulate the actual operating and emergency conditions
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to'whfch'the st'ructure, system, or component may be subjected.
It also states that, to the extent practical, the~ duration of the tests should be sufficient to permit equipment to reach its normal equili-brium conditions (e.g., temperaturer and pressures), and thus decrease the probability of failures, including "run-in" type failures, from occurring during plant operation. Explain the rationale for not meeting this regulatory position in the cases of ICP-PT-02-12,
Bus Voltage and Load Survey," 1CP-PT-34-05, " Steam Generator Narrow Range Level Verification," and ICP-PT-55-05, " Pressurizer Level Cofitrol."
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The action specified by NRC in our letter dated September 18,1984, is that all preoperational test packages should be reviewed to determine if there are other instances where test objectives were not met. (The TRT intended that the TUEC pay particular attention to RG l.68, Regul,atory Position 3 during this review.) TUEC's action plan (4.A.S.) states that the seven HFTs not included in the TRT review will be reviewed for compliance with test objectives. The next action (4.A.6) implies that only if an unspecified number of test objectives are identified as not having been satisfied during that review would a statistical sampling in accordance with MIL-STD-105, Table X-G-2 be conducted for the other 136 preoperational tests. This is not acceptable to the NRC The seven HFTs shall be added to the 136 remaining preoperational tests and a statistical.
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sample done on that total. Also, TUEC shall provide the basis for
\\ the statistical sample selected. In addition, RG 1.68 should be reviewedbythe.groupwhowillconductthereviewoffthe preoperational test packages to ensure that each member understands the concept which it ' advocates..TUEC shall prov.ide the rationale for selection of the review group members, a.3 Technical Specification for Deferred Tests 1.
Since it 'is no longer intended to defer certain preoperational tests until after fuel loading and since a special, test exception will be sought by TUEC from the NRC for snubber operability for testing after fuel load, the original issue as identified by TRT is no longer of concern. Revise 'the action plan to reflect this change.
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i a.4 Traceability of Ter.t Equipment 1.
The background section attributes the lack of traceability between the calibration of temperature measuring instruments and the monitored locations to personnel error. The TRT believes that the error was caused when the thermal expansion test procedure was revised to r'emove the instrument number from the dati. sheet. Startup Administrat.ive Procedure (SAP)-7 recognizes that tiaceability is required and provides optional methods to ensure this traceability.
However, when the thermi.1 expansion test procedure was revised, an o
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option was chosen which would not en'sure the required traceability.
Therefore, the TRT questions whether the person who revised the procedure and those who approved the revision adequately underst cd the need for traceability. The TUEC Action Plan shou'ld address this question. In addition, the action plan should include a commitment to review Unit.2 preoperational test procedures and Unit I and 2 initial start-up and plant operating procedures to ensure that similar errors do not exist and will not recur.
b.
Conduct of Containment Ir$tegrated Leak Rate Testing (CILRT) 1.
This is another example of where a preoperational test was conducted
'~' h the system in a configuration wh'ich did not simulate the actual -
wit plant operating and emergency conditions to the extent practical, as required by RG 1.68. Regulatory Position 3.
Con' sider the CILRT in t'he response to the comment III.a.1(2).
2.
The ' background section states that due to an oversight, the CPSES FSAR
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was not amended to reflect deviations from 10 CFR 50, Appendix J and ANSI N 45.4-1972 during the conduct of the containment integratad leak rate test, 1CP-PT-75-02. The action plan should be revised to explain how this oversight occurred and what the potential is for other similar oversights resulting in the FSAR' not being amended,
when deviations occurred. Also, address the TUEC procedure for
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documenting arid processing deviations from FSAR comitments to ensure that they are included in future amendments to the document.
c.
Prequisite Testing I
1.
Whila not specifically addressed by the TRT in its description of this issue TUEC should be aware that other completed Prerequisite Test Instructions were found, i.e., other than XCP-EE-1 and
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XCP-EE-14', where craft personnel had signed for verification of prerequisites in li6u of System Test Engineers. Other prerequisite tests were not addressed by TUEC in response to this issue.
The Action Plan should address all Prerequisite Test Instructions and include an assessment of th'e impact of any improper verification on -
subsequent testing.
d.
Preoperational Testing i
1.
At the October 19, 1984 NRC meeting. TUEC stated that the records retrieval system at CPSES is complex. Since the background section
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for this item states that a large number of design
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utilized by start-up, TUEC shall reassess the adequacy of the Action l
Plan for this item and document that reassessment in the revised l
Action Plan.
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