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UNITED STATES OF AMU 10,A
/26//f/ 9 NUCLEAR REGULATORY COPNISSION 3
BEFDRE THE ATOFTC SAFETY AND LICENSING BOARD In the Matter of TEXAS UTILITIES ILECTRIC
)
Docket Nos.~ 50-445 COMPANY, el al,.
50-446 (Comanche Peak Steam Electric
)
Station, Units I and 2)
)
NRC STAFF RESPONSE TO CASE'S REOUEST TUR ADMISSIDMS I.
Introduction On February'4,1985 Intervenor Citizens Association for Sound Energy (CASE) filed a Request for Adrissions perssent to 10 CJ.R. I 2.742. M 'In its filing, ~ CASES %ia-the 3taff ta M the. truth of:certain facts purportedly found by.the Staff's Technical hview" Team '(TNT) in connec-tion with its inspection and evaluation.of: Applicants': construction and
. quality assurance programs at Comanche Peak. Steam Electric Station (CPSES).
The admissians requested by CASE are based span a. series of letters issued by the TRT to Applicants a6tising h of.thee'of the TNT's
_1/
The Commission's procedural rules 1 provide thetia Tesponse to a request for admissions shall be filed "within a time designated by the presiding board or the Commis; ion," which is 1mt.to be less than ten days after receipt of service. 10 C.F.R. I 2.742(b).
Since CASE has not requested the. Board to establish a filing deadline.
and the Board has not done so sua sponte, there is currently no date by which the Staff's response to CASE's Request for Admissions must be filed. In the interest of avoiding undue delay, however, the Staff has elected to file its response to CASE.'s request at this time.
A B601020441 BS1113 q
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GARDE 8 5-59 PDR
. activi-tas and requesting them to submit additional infomation to enable the TRT to ecmplete its evaluation and reach a final position on the matters under consideration. See September 18 and November 29, 1984 and January 8,1985 Letters from Darrell G. Eisenhut, Director of Licensing, to Michael D. Spence, President. Texas Utilities Generating Cc=pany. These letters, however, do not represent the TRT's final posi-tion on the matters addressed therein. See e.g., Tr. 24,042 (Mr. Treby).
Rather, those letters merely memorialize matters discussed in meetings involving "TRT members and TUEC's personnel during the TRT's on-site
. activities." Safety Evaluation Report, Supplement No. 7 at J-5 (January 1985) ("SSER No. 7").
A case in point is the September 18, 1984 letter.
That letter was issued on the same day of a meeting " held 3 discuss potential safety concems and g request idditional infomation h the TRT t_o, complete its review. 3. (emphasis added); see also M. at J-6.
o Additionally, it should be noted that the TRT has stated unmistakably that the September 18,1984 letter does not represent its final position on the electrical / instrumentation, civil / structural, test program, or any other types of allegations discussed therein:
'The TRT noted at [the September 18,1984] meeting that the EAI findings, as well as the actions required of TUEC, could not be considered final l
until they were integrated with the results of.
the overall progransnatic review being conducted by the QA/QC Group.
l Safety Evaluation A7 art, Supplement No. 7 at J-8 (January 1985).
It is not until he process associated with preparing a written safety evaluation repo t on a particular subject is completed that the w
r.
TRT's position on that subject is expressed. 2/ Indeed, even when a SSER is issued on a particular subject, tt should not be considered final outil 1,.^m..imd with the reviews being conducted by the TRT's OA/QC group. See 35ER No. 7 at J-8.
It is worth noting again that the letters cited by CASE reflect only irreliminary views and assessserts of the TRT before such views and assess-ments had been published in a written safety evaluation report setting forth the. bases for-those conclusions. The ule purpose of those letters tes to inform AppTitants as soon as possible of the TRT's preliminary
-findings.to enable.them to commence corrective action without awaiting the actual Teceipt of an SSER.containing a more thorough and detailed
.esplanation of the bases forW TRT's findings. While the Staff believes
-theti the rfeus expressed in the: September 18 and November 29, 1984 and
.lanuary 8,1985 letters will zormspond to those in the applicable SSERs, it should be. emphasized that.ae'SSER describes the TRT's efforts and emplains its% dings in a fasirioniere m A nsive than any of the letters relied.upon by CASL :For-this reason-the conclusions expressed in the SSERuy not:cenform is:every respect to those in the letters.
-A review of 35ER E 7, which reflects the conclusions of the TRT's Ilectrical.and' Testing Groups. illustrates this point.
y The Staff, of tserse..m.1-that Applicants any avail them-selves of their right;toTespond to an SSER by challenging its findings and conclusions. Upon consideration of Applicants' pesponse it is possible tfut Staff might detamine that certain of the findings and conclusions contained in its SSER are erroneous and should be edified. In that case, the Staff would issue a new SSER setting forth the masons:and bases. underlying that determination.
i.
In responding to CASE's request for admissions. the Staff has been guided by the principles discussed above. In:other words, the Staff has answered those admissions involving matters with respect to which the TRT has expressed a position in a. published SSERfor actrission requests involving matters still.ander TRT review, the: Staff, pursuant 210 C.F.R.
I 2.742(b)(1), has indicated that it is unable.to ashrit er: deny the truth of the fact sought to be admitted.
II. NRC STAFF' RESPONSE TU SPECIFIC 'XDRISSTDR'REUUESTS 1.
The Technical' Review Team (TNT) found a lack sf awareness on the part of quality control (QC)-electrical inspectorstdocument in the inspection reports when the installationisf the " nuclear hunt-shvinkable cable insulatton sleeves" ens-mgrfmd to he y
_ STAFF RCSPONSE:
Adutt with the-foTlaring clarffication: The TRT myiewed QC inspection reports far-tuelvetlurtt spM:es:and found that six reports contained no indicattenhthe installatism:sf haut shrinkable sleeves was mquited is be ut+====md-The failure:1a-document this requirement indicated a lack of familiarity with the. applicable pro-cedure:nn the part of inspectica: personnel. :5ee SSER No. Tat J-29,3D.
2.
The TNT found'. inspection reports that did.neth that
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the aquired witnessing.3f splice installatism. mas dame.
l STAFF RESPONSE:
Adatt with tha fellowing clarfficatina: Of the twelve _ butt splice inspection reports avieted by the TNT, thme-did not indicate that the splices had been witwaad. See SSER No.'7.at.J-2D.
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l 3.
The TRT found a lack of splice qualification requirements and provisions in the installation procedures to verify the operability of those circuits for which splices were being used.
STAFF RESPONSE:
Admit with respect to installation procedures.
See SSER No. 7 at J-28, 29.
4 The TRT found selected cable teminations that did not agne with their locations or drawings.
STAFF RESPONSE:
Admit with the following clarification: The
-TRT inspected 380 cables, involving 1600 individual terminations, to detemine whether cable terminations confomed to applicable drawings.
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y The TRT found that six cables, g of which_ wee safety related_, wem not1:eminated in accordance with current drawings. See SSER No. 7 at'J-29.
5.
The TRT found cases where nonconformance reports '[NCRs) concerning vendor-installed terminal lugs in GE notor contal centers had been improperly clo g
STAFF RESPONSE:
- timtt with the following clarifi ion: M
[#ur #84 m voawsm verw e sus = sed 3r h dP4 Am#
Aoou sp-di4/M N TRT reviewed sixteen nonconfomances report (NCRs) documenting bent
(/WC)
TW W woanti teminal lugs. These NCRs were closed out on the basis ofta detemina-gg g tion that the bent terminal luas "did not, pose an equipment service-M l
Gre w s D e ability problem." SSER No. 7 at J-30. The TRT concluded that disposi-tioning this 1;ype of NCR in this manner was not adequate because,
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-6 among other things, "there was no reference to, or evidence of, an engineering evaluation, as required by the lug manufacturer, prior to a change in the acceptance criteria [.]" Jd.
6.
-The~TRT found, in numerous cases, that safety-related cables within flexible conduits inside main control room panels did notmeet the minimum separation requirements.
STAFF RESPONSE:
Admit See SSER No. 7 at J-42, 43, with the following clarification: The TRT noted, however, "that this type of
- conduit separation is W ii.i.ed by Section 5.6.2 of IEEE Standard 384 if such installation can 'be substantiated by analysis." Jd. at J-40.
~ 7.
The TRT'found in several cases, that separate sa.fety and
- nonsafety-related cables and safety and nonsafety-related cables within flexible conduits insidemin control room panels did not meet the mini-num separation Tsquirements. No evidence was found.that.justifind the lack of. separation."
STAFF ~ RESP 0NSE:
Admit SSER No. 7 at 4-42. 43. See also Staff Response to Admission Request 6, m.
8.
"The 7RT found that the existing'TUEC analysis substantiating the adequacy of* critaria for separation between zonduits and. cable
-trays had wt-been reviewed by the NRC staff.
STAFF RESPONSE:
Arbeit See SSER No. 7 at J-42, 43.
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9.
The TRT-found two minor violations of the separation. criteria' inside panels CPI-EC-PREB-09 and CPI-EC-PREB-03 concerning a barrier that had been runeved and redundant field wiring not meetingWninum separation. The devices involved with the barrier were FI-2456A. PI-2453A, PI-2475A, and IT-2450.: associated with' Train A; and FI-24571 :PI-2454A, w@
PI-2476A. and IT-2451.: associated { rain-5. ~The field wiring tes asso-ciated.with devices HS-5423 of Train B and HS-5574, nonsafety-telated.
STAFF RESPONSE:
.: Admit M.SSER No.'7 at.1-42.
These mere "the only two instances:of Class:IE panel-mounted devices in violation
-of the separation criteria which veguire mormctive action.' 'Id.
- 10. The TRT'found*t the. support h11stiourforeyelated conduits less than:nr equal to 2 inches ums-inconsistent wit $tsrismic requimments and could Pfad no evidence.that. substantiated the-:adsrpecy of the installation for iuonsafety ewlated:ronduit of any sim. (According to Regalatory Grfde 1.29 and F114103ection175.2.3, the: seismic' Category II and nonsetsuric items:shmald be designed is: sack a way thathr-failure would not adversely affimet the fari. tion of ssWelated components or cause injury to plant. personnel.)
STAFF' RESPONSE:
iAdmit with the'foT1 swing clarification: "The TRT's 71 ;;, em this issue as set forthda35ER No. 7 at Mstates, "The TNT concladus that-the installation #.the nonsafeterelated conduit in the control voeu appears to beinconststent with ther,.li.;
of RG 1.29.* 7he TRT.also: stated "that the md.Lility ~nt theinsta11ation will depend on TNT approual of TME's. analysis'of the.at _w of the
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. t.*tt+4 c.stNrt 1Weim_ M w As et t seisAsupportinstallationfornonsafety-relatedconduitsin{ area ~s'of the plant.,."* =- ^== + u e=3
" Id. at J-47.
- 11. The TRT found a lack of supportive docume'.tation regartHng personnel qualifications in the training and certification files. as required by preceduras and regulatory requirements.
STAFF RES20NSE:
Admit See SSER No. 7 at J-58.
- 12. The TRT found a lack of documentation for assuring that the
_ requirements for electrical QC inspector recertification were being-met. Specific example are:
One case of no documentation of a high school diploma or General Equivalency Diploma.
One case of no documentation to waive the remaining 2 months of the required 1. year experience.
One case where a'QC technician had not m d the required color vision. examination adm>
istered by a professional eye specialist. ':A makeup test using colored pencils was admis>.
istered by a QC supervisor was passed..and then a waiver tes given.
Two cases where the experience requirements to become a Level I technician were only l
marginally met.
One case of no documentation in the L.in;,
j and certification files substantfating that i
the person rat the experience requirements.
l l
STAFF RESPONSE:
Admit See SSER No. 7 at J-56.
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- 13. The TRT found a lack of guidelines and procedural requirements for the testing and certifying of electrical QC inspectors. Specific
~
examples are:
No time limit or additional training require-ments existed between a failed test and retest.
No controls existed to assure that the same test would not be given if an individual previously failed that test.
No consistency existed in test scoring.
No guidelines or procedures were available to control the disqualification of questions from the test.
No program was available for establishing iew tests (except when procedures changed). Ti.2 same tests had been utilized for the last ?
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14-17.
'Adrfssion Requests 14-17 related to certain alleged findings
{-4 of theTRT concerning Applicants' zonstruction activities in the civil /
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. structural area.
STAFF RESPONSE:
The Staff is _ unable to admit or deny the truth g9(O {
of any of the statements contained in CASE's requested admissions 14-17 q
because the TRT has not completed its evaluation of the civil / structural 1% - 2 k
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aspects of Applicants' construction program. As noted in Part I of this 13 g 4 C (
Response, the TRT's findings and conclusions with respect to these matters t k' )K T fi b.:
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0 will be published in an SSER. S! ca the SSER addrassing the items covered by the requested aduissions has not been cc.:pleted, the Staff is unable to admit or deny the truth of the statements made in those admission requests.
- 28. The TRT1ound that certain test objectives of Chapter 14 of theTSAR and Regulatory Guide 1. fib swi.-e.i2 for the conduct of
,,v iional testing-inrm not net.
~3TA M RESPONSE:
. Deny. De7RT:did not find that Applicants
-had failed to comply.with Chapter 14 uf-the CPSE3 75AR or RG 1.68.
-Rather,"the TNT found that three of Applicants':preoperational hot functinual tests (NFT)-did not achieve 1hrir stated objectives. See 33ER Mn. 7 at A73, 74, 76.
- 19. The TRT found.a.' deficiency in Test Precedure ICP-PT-02-12
" Bus Voltage and. load L..g in:that because acceptable voltages could 1 mot.he. achieved with the:specifind-transformer 1:aps, they were changed.
A:subumquent _._,;- _.1..v evaluation 1,;..d ste. ;ng to the original taps,: bat no vetest eas: performed.
STA F RESPONSE:
.Adrit wtth:the:tlarffication: set forth in 35ER No. 7 at A73,74.
~
K The 7ET found:n. deficiency h Test Prm edum ICP-PT-34-05,
" Steam' Generator Narrow Pange Level Verification" in that level detectors 3-LT-517, ~518 and' 529 wem uplaced with temporary equip-unt of a design.that ess:different from.that wtrich was to be eventually instaTled.
.n-STA F RESPONSE:
Admit with the clarification set forth in SSER No. 7 at J-74.
- 21. The TRT found a deficiency in Test: Procedure ICP-PT-li5-D5
" Pressurizer Level Control" in that hvel detector.3-LT-461 appeared to be out of calibration during the test and.ms luplaced^after.tfr-test. The retest approved by the Joint Testliroup..eas a cold calitrra-tion rather than a test consistent with the 1 original test ab.jective, whi.-h was to obtain satisfactory data under-hot: conditions.
STA F RESPONSE:
Adirit with the clarffication set forth in SSER No. 7 at J-74. 75.
- 22. The TRT Turted during a W of coupleted hot functionni.1mst data, tlat the Joint Test Grouo:did 1xrt approve 1hedsta aartilrafter cooldown from the test. The tests are not considered coupleta.until this approval is obtained. '.In order-tm complete-.the proposed post-fueling, deferred preoperational het Tunctional test..the Joint Test Group, sr a similarly qualified group, ausst: approve the-data: prior to proceeding to initial criticality. The TRT didwt find.any:ducument providing assurance that TUEC is coeurttted to de t!rts.
STAF 1tESPONSE:
Desy. Moreover.the.6. ant thatthe Joint Test Group (JTG) or:anothersimilar Jiody approve past-fueling. deferred preoperational test data is1so longer applicable because Applicants have indicated to the TRT that tho,se. tests which can be: performed ertthout emplacement of the reactor core will:be conducted priar to fuel loedtng.
See SSER No. 7 at J-76. The results1rf those tests:will be reviewed by 9
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the Station Operatica 7.av u C;m::ae (SCRC). See 555.'1 No. 7 at J-77.
Applicants have as:und the T'iT that the FSAR will be amended to pro 71de that the 50RC, not the JTG, is responsible for reviewing creoperational test data. Id.
- 23. The TRT found that in order to conduct preoperational tests at the mecessary temperatures and pressures after fuel load, certain limiting conditions of the proposed technical specifications cannot.be met, e.g.,
all snubbers will not be operable since some will not have been tested.
. STAFF RESPONSE:
Deny. The TRT found that Applicants' original plan to complete the remainder of its hot functional test program '(HFT) after fuel loading but prior to initial criticality " appeared technically sound and without safety implications." SSER No. 7 at J-75.
It should be moted..however, that Applicants subsequently altered their plans and decided to conduct prior to fuel loading those remaining preoperational tests which can be performed without emplacement of the reactor core. E.
~24.
The TRT found that dati, for the thermal expansion tests (which have not yet been approved by the Joint Test Group) did not. provide for traceability between the calibration of the measuring instruments and the1 monitored " locations, as required by Startup Administrative Procedure-7 (although the information was separately available in a personal log held by Engineering).
STAFF RESPONSE:
Admit with the clarification set forth in SSER No. 7 at J-72, 73. It should be noted, however, that.while
" problems were encountered during the themal expansion test, the TRT found that they had been properly documented in accordance with
. administrative. controls established for that purpose."
_Id_. atd-76.
- 25. TheWfound a deficient leak rate test in that apparently
'after repairing lasks focnd during the first two attempts, the third sttempt at a CILRT ass successful. It was successfully completed after three electrical penetrations were isolated because the leakage.through them could not be aad Though the leaks were subsequently Tepaired
- and individually tasted with satisfactory results, NRC approval was not
.nbtained to perform the:CILRT with these penetrations isolated. In addi-tion. leek rate calculations were perfomed using ANSI /ANS 56.8, which is n'aither endorsed:by the EC nor in accordance with FSAR couritments.
STAFF RESPONSE:
Admit with the clarification set forth in 35ER No. 7 at.MD. '83. 'The NRC, however, has reviewed and approved of
- App 11custs' CILIT-tast1aethodology and results.
Id,. at J-83.
d
- 26. The7RTM,=1n its aview of prerequisite. test records, j
-that craft personnele signinghverify initial conditions for tests h violation of startup ministrative Procedure-21, entitled: '" Conduct af 7esting" (Cp-3RP-21). This procedure requires this function.to be W by SystesTest Engineers. ~ 5tartup 1 management had issued a lumormate improperly authorizing traft personnel to perfom these veri-ficatinus on selected tests..
'9%
STAFF RESPONSE:
Adutt with the following. clarification:
Startup management had authorized craft to verify in e.wisite condi-tions only for two prerequisite test procedures ICP-EE-1 and XCP-EE-14.
See SSER No. 7 at J-87.
- 27. The TRT found that ' System' Test Engineers were not being provided with current. design tiforsation on a routine. controlled basis, and had to update their nun umterial when.they considered it appropriate.
STAFF RESPONSE:
Admit-with.the clarification set forth in SSER No. 7 at. J-94, 96. ThellT. heuever, m.snable.ts identify any problems resulting fnm Startup Test Engineers "havingD pursue design infohmation updates um their ewn-tritiative." ~ Id.:at.4-95.28-126,.
Admission Ihwpmate.2$.326 TelatE?tD'certafR alleged-findings of the TRT conce'rning-Applicants': quality assurana program and its: cons-truction activities in the anchamicalfpiping and c.6i.6 coatings area.
STAFF RESPONSE:
Unable-ta:ashrft er denyWhrumsons stated in STAFF RESPONSE tn asknissins 6 14-27.._ supra.
hetfully submitted, j
i
~di j
Gregory Emansel Staff l
Dated at Bethesda Maryland this 22nd day of February 1985 l
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101 Cahfornia Street. Swte 1000. San Frarcsco. CA 94t't 5894 415 397-5603 January 18, 1985 84042.022 Mr. Vince Noonan U.S. Nuclear Regulatory Comission 1920 Norfolk Avenue Bethesda, Maryland 20814 T
Subject:
Open Items Associated with Walsh/Doyle Allegations Texas Utilities Generating Company Comanche Peak Steam Electric Station Independent Assessmen'. Program, Phase 3 Job No. 84042
Dear Mr. Noonan:
As discussed during our meeting wi'.h the NRC staff on January 10, 1985, Cygna has assembled the attached list of open items associated with the Walsh/Doyle allegations and Cygna's Phase 1, 2 and 3 reviews. In addition, item 26 of the attached list has been added even though it was identified as a result of the Phase 4 mechanical systems review. Since it is concerned with piping classifi-cation, we thought it may relate in some way to the scope of your SSER.
Also attached is a schedule which graphically depicts the estimated response dates. Please note that the dates reflect milestones known to Cygna at this time and not necessarily item closeout. For example, one item entitled:
" sizing af pipe support hardware for rotational restraints," has a January 21, 1985 scheduled commitment from TUGC0 to supply Cygna with an evaluation of the problem. Cygna must then review the response which typically takes several weeks. Certain activity completion dates could be revised if the NRC staff indicates a preference to have specific items closed out prior to the scheduled p
dates shown.
We are currently in the process of reviewing the basis for closure of Phase 1, 2 and 3 items as well as the overall conclusions. In doing this, Cygna will be evaluating all discrepancies and observations together rather than solely within n
N a given phase. We believe this is a necessary and important effort since review results from later phases are clearly impacting the basis for resolution of pro-blems encountered in previous phases. A summary of conc 1"sions which are under l
review and which will possibly be revised as a result of this effort will be sent to you by January 25, 1985.
1 F01A-85-59 hly
_ _1 pp.
1 tt
aid ' /.1 iG'ln ;
Mr. Vince Noonan
. January'18, 1985 Page 2 If you have any questions or wish to discuss any of this information, please do not hesitate to call.
Very truly yours,
'1M/Wh~c d
N.H. Williams Project Manager NHW/ajb Enclosures cc: Mrs. J. Ellis Mr. S. Treby Mr. S. Burwell Mr. J.B. George Mr._D. Wade Mr. D. Pigott Mr. N. Reynolds
PHASES 1,2 AND 3 OPEN ITEMS LIST ESTIHATED DESCRIPTION CVGNA CROSS-REFERENCE STATUS RESPONSE !) ATE 1.
Ci nching of U-bolts.
IAP, Phases 1 and 2 Final Re-Cygna is currently reviewing Cygna letter to TUGC0 port, TR-83090-01, Rev. O.
TUGC0 response to Cygna ques-scheduled for 2/8/85.
Pipe Support Checklist General tions (TUGC0 letter dated Note 1.
11/1/84). Based on a prelimi-nary assessment of TUGCO's re-sponses, it appears additional information may be required.
1 In particular, no information has been supplied explaining how TUGC0 will extrapolate the analysis / test results to other pipe sizes and schedules. In addition, Cygna is evaluating the acceptability of cen-troidal stress information for the finite element mesh uti-lized by Westinghouse.
2.
Pipe support stabili ty.
IAP, Phases 1 and 2 Final Re-Cygna is currently evaluating Cygna letter to TUGC0 port TR-83090-01, Rev. D.
the pipe supports from all sunnarizing the results Pipe Support Checklist General phases to complete our as-of the review is sche-Note 1.
sessment of pipe support duled for 2/4/85.
- tability. This issue is tied IAP, Phase 3 Final Report TR-to Cygna's completion of the 84042-01, Rev. 1.
Pipe Sup-U-bolt cinching reviews.
i port Checklist General Notes 10, 12 a nd 16.
3.
Sizing of pipe support I AP, Phase 3 Final Report, TUGC0 performing analyses in TUGC0 scheduled response hardware for rotational T R-84042-01, Rev. 1.
response to Cygna Phase 3 by 1/21/85. Cygna 's re-restraints.
Observation PS-03.
view will be scheduled subsequent to receipt of TUGC0 analyses.
PHASES 1,2 AND 3 OPEN ITEMS LIST (CONTINUED)
ESTIMATED DESCRIPTION CfGNA CROSS-REFERENCE STATUS RESPONSE DATE 4
Punching effects in tube IAP Phase 4 review open item.
Cygna reviewing TUGC0 response Letter to.TUGC0 summa-steel around bolt holes.
to Cygna questions on the rizing Cygna concerns (See Figure 1.)
local effect in the tubesteel scheduled for 1/25/85.
wall (TUGC0 letter dated 11/8/84).
5.
Cumulative effects of IAP, Phases 1 and 2 Final Re-Cygna believes it is necessary Summary conclusions for individually insigni fi-port, TR-83090-01, Rev. O, to assess cumulative effects all phases will be pro-cant discrepancies.
"Methodol og y."
across all phases rather than vided in the Phase 4 only within a given phase.
report. Cygna letter to IAP, Phase 3 Final Report, Cygna is voiding selected, the NRC stating which TR-84042-01, Rev.1, " Method-previously documented conclu-conclusions are now open ol ogy."
sions (Phase 1, 2 and 3) since and which are now closed information obtained in later is scheduled for 1/25/85.
Transcript of January 10, 1985 phases affects the basis for Cygna/NRC meeting.
resolution of previously closed items.
6.
Corrective action pro-IAP, Phases 3 Final Report, The Phase 3 Quality Assurance Phase 4 report comple-gram.
TR-84042-01, Rev.1 Section reviews established that ade-tion date tied to clo-5.3.
quate corrective action sys-sure of all open items, tems were in place. Cyg na is reassessing these conclusions i
based on findings from all' phases of the technical revi ews.
7.
Design vert fication.
IAP Phase 4 review scope.
Part of the Phase 4 review Phase 4 report comple-scope.
tion date tied to clo-sure of all open items.
1 PHASES 1,2 AND 3 OPEN ITEMS LIST (CONTINUED)
ESTIHAT ED DESCRIPfIGN CVGNA CROSS-REFERENCE STATUS RESP 0.4SE ik11E 8.
Dynamic amplification IAP, Phase 2 Final Report, TR-Part of the Phase 4 review Phase 4 report coaiple-factor for cable tray and 83090-01, Rev. O, "Conclu-
- scope, tion tied to closure of conduit support design.
stons."
open items.
IAP Phase 4 review scope.
9.
Governing load case and IAP Phase 4 review scope.
Part of the Phase 4 review Phase 4 report comple-its effect on allowable scope.
tion date tied to clo-stresses for cable tray sure of all open items.
support design.
- 10. Accuracy of as-built IAP Phase 4 review scope.
Part of the Phase 4 walkdown.
Phase 4 report comple-drawi ngs, tion date tied to clo-sure of all open items.
- 11. Box frames with 0" gap.
Prefiled Testimony of Nancy H.
Cygna has additional questions Cygna letter to TUGC0 Williams dated April 12, 1984.
concerning TUGCO's choice of summarizing Cygna con-Doyle question 15.
formulae for calculating pipe cerns scheduled for sti f f ness.
1/25/85.
IAP, Phases 1 and 2 Final Report, TR-83090-01, Rev. O.
Pipe Support Checklist General Note 4.
i IAP, Phase 3 Final Report, TR-84042-01, Rev.1.
- 12. Richmond insert al-IAP, Phase 3 Final Report, TR-Cygna has reviewed the TUGC0 Cygna letter to TUGC0 l owabl es a nd bendi ng 84042-01, Rev. 1.
Pipe Sup-af fidavit on Richmond inserts summari zing Cygna con-stresses.
port Checklist General Note 6.
agai n and has further ques-cerns scheduled for ti ons.
1/28/85.
PHASES 1,2 AND 3 OPEN ITEMS UDT (CONTlNUED)
EST' MATED KSCRiPLIION CVGNA CROSS-REFERENCE
_ STATUS RESPONSE 04TE 13.
Inclusion of pipe support IAP, Phases 1 and 2 Final Re-A conclusive study of this ef-N/A mass in stress analysis.
port, TR-83090-01, Rev. O.
fect would be lengthy and is.
Pipe Stress Checklist General not authorized.
l Note 1.
j 14 Pipe support sel f-weight IAP, Phase 1 and 2 Final Re-This issue is under review by N/A j
exci tati on.
port TR-83090-01, Rev. O, the NRC staff. No further General notes attached to Cygna review is planned or individual pipe support authorized at this time.
checkli sts.
IAP, Phase 3 Final Report, T R-84042-01, Rev. 1.
Pipe Support Checklists General
, Note 7.
Meeting transcript between NRC and Cygna, July 3,1984.
- 15. P1pe support stiffness IAP, Phases 1 and 2 F1nal Re-This issue is under review by N/A used in stress analyses.
port TR-83090-01, Rev. O.
the NRC st.sff. No further General notes attached to Cygna review is planned or individual pipe support authorized at this tinae.
checklists.
IAP, Phase 3 Final Report, TR-84042-01, Rev.1.
Pipe Support Checklist General Note j
8 Meeting transcript between NRC j
and Cygna, July 3,1984.
1 t-l t
i PHASES 1,2 AND 3 OPEN ITEMS LIST (CENTINUED)
ESTINATED DESCRIPTION CVGNA CROSS-REFERENCE STATUS RESPONSE DATE l
l 16 Mass participation / mass IAP, Phase 3 Final Report, TR-TUGC0 has performed rear.alyses Cygna letter to TUGC0 is point spaci ng.
84042-01, Rev. 1.
On the pipe stress problems scheduled for one week
(
Ubservations PI-00-05 and and pipe support designs as after receipt of addi-l PI-09-01.
documented in their 12/7/84 tional information from letter to Cygna. Cygna has Gibbs & Hill.
checked a sample of the rean-alyses and has questions on the TUGC0 conclusions partic-ularly with regard to pipe support checks for adequacy.
Cygna has also requested ad-ditional information from Gibbs & Hill per 1/14/85 tele-con between L. Weingart and H.
Mentel.
- 17. Main steam " stability IAP, Phase 3 Final Report. TR-Closed from a pipe stress Same as item 16 above, b umpers".
84042-01, Rev. 1.
Observation sta ndpoi nt. Open from a sup-PS-02.
port standpoint since the re-view of these supports was part of item 16 above.
- 18. Rear bracket dimensions.
IAP, Phase 3 Final Report, TR-Closed by Phase 4 walkdown.
N/A 84042-01, Rev. 1.
Pipe Sup-port Checklists General Note 11.
N/A CC-1-009-007-A33R.
84042-01, llev.1. Pipe Sup-port Checklist PS-004.
PHASES 1,2 AND 3 OPEN ITEMS LIST (CONTINUED)
ESTIMATED DESCRIPTION CVGNA CROSS-REFERENCE STATUS.
RESPONSE DATE
~
20 Pi n-to-pin dimension on IAP, Phase 3 Final Report, TR-Closed by Phase 4 walkdowns.
N/A support CC-1-028-033-533K.
84042-01, Rev. 1.
Pipe Sup-port Checklist PS-026,
- 21. Bolting on support IAP, Phase 3 Final Report, TR-Closed by Phase 4 walkdown.
N/A MS-1-001-002-S72R.
84042-01, Rev. 1.
Pipe Sup-port Checklist PS-068.
- 22. Qualification of welds in IAP, Phase 3 Final Report, TR-Cygna has reviewed the Phase 2 Cygna letter to TUGC0 welded / bolted connec-84042-01, Rev. 1.
Pipe Sup-supports and found another addressi ng Cygna con-tions.
port lbservation PS-06 example of this type of con-cerns is scheduled for nection.
1/28/85.
~
23 Vert ftcation of cable Telecon attached to Cygna Cygna has addressed this as Cygna letter to NRC tray installation against letter 83090.021 to S. Bor-part of the Phase 4 scope and scheduled for 2/11/85.
latest drawi ng.
well, item 1.
will issue a letter to the NRC before issuing the Phase 4 report.
~_
24 Verification of cable Telecon attached to Cygna Cygna has addressed this as Cygna letter to NRC tray construction draw l etter 83090.021 to S. Bur-part of the Phase 4 scope and scheduled for 2/11/85.
Ings against design well, item 5, will issue a letter to the NRC drawi ng s.
before issuing the Phase 4 report.
N 25 Adequacy of the iterative Phase 4 design veri fication Cygna has addressed this as Cygna letter to MC design process.
reviews, transcript of 1/10/85 part of the Phase 4 scope and scheduled for 3/11/85.
Cygna/NRC meeting.
will issue a letter to the NRC.
before issuing the Phase 4 report.
8
- m i/,
=e PHASES 1,2 AND 3 OPEN ITEMS LIST (CONTINUED)
ESTIMATED DESCRIPTION CVGNo. CROSS-REFERENCE STATUS ESPONSE IMTE
- 26. Effect of nonsafety re-Cygna letter 84056.10 dated Cygna has addressed and closed N/A lated seismic Category II 7/30/84, question 3.
this issue for the Component piping on safety related Cooling Water System as part pipi ng (CPSES FSAR S,-c-Cygna letter 84056.023 dated of the Phase 4 review scope.
tion 3.2, subparagraph 3 8/21/84, question 2.
Review of generic implications "Other Classi fications.")
for other piping systems is TUGC0 letter to Cygna dated not authorized at this time.
8/11/84.
TUGC0 letter to Cygna dated 9/11/84 TUGC0 letter to Cygna dated 9/25/84.
Cygna Phase 4 (bservation MS-02-01.
e 4
0 FIGURE 1 o
PUNCHING EFFECTS IN TUBE STEEL (example) li
.i 23/4"O BOLT HEAVY HEX NUT 3 4
<[
m 1
I I
l 4
'i 8 x 12 x 1/2 T.S.
2 O
l P
4 l
1 m---
\\-.
s 4
OPEN ITEMS SCHEDULE mammmmmen (RESPONSE DATES) l i
1 wta ACTIVITT EnsimE: 01/18 01/25 af/01 W/05 02/15 N/22 03/01 03/08 03/15 83/22 83/29 04/05 94/12 94/19 04/26 05/03 4
1.
Sizing of pipe support hardware for rotational
O restraints.
4 i
2.
Punching effects in tee i
steel around bolt holes.
O (See Figure 1.)
- 3. Son frames with U" gap.
O a
4 Richmond lasert allomeles O
and bending stresses.
I !
5.
Mass partistpation/ mass 3
point spacing.
4 6 Pipe support stellity.e,
O I
7 Cinching of U4elts.
O 9
5.
Quellfication of welds in i
welded / bolted connec-O j j tions.
s j
9.
Vert fication of as4ullt t
i ~
cele tray hardware
-3 agalnst design drawing.
10 Vefication of cele tray constructler Wawings 3
agalast design drawings.
![
- 11. Adequacy of the iter (tpe e
3 design process.
- 12. Phase 4 review /open *.
I Itees.
3
(
- 13. Cusmalative effects of las dividually insignificant
~1 j
discrepancies.
14 Corrective action program.
-3 s
15 Design verification.
'16 Phase 4 Final Noyort.
g t