ML20136F657

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Forwards Comments on Comanche Peak Response Team issue-specific Action Plan for Incorporation in Rev. Resolution of All Matters Discussed Required Prior to NRC Approval of Plan
ML20136F657
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 01/24/1985
From: Noonan V
NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
To: Spence M
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
Shared Package
ML17198A292 List: ... further results
References
FOIA-85-59 NUDOCS 8502010314
Download: ML20136F657 (18)
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NUCLEAR REGULATORY COMMISSION

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Docket Nos:- 50-445, 50-446 M

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'TexasLUtilities Electric Company

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ATTN:

M.D. Spence, President. TUGC0 A'

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Subject:

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. Dear Mr. Spence.

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'On.0ctober 19'and 23, 1984, we met with you and. members of your staff, at yir request, to discuss the Program Plan and Issue-Specific Action Plans (the

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" 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 Technical Review Team assessment of certain.

onsite activities at Comanche Peak. These activities were in the electrical /f r trumentation, civil / strut.tural, and test programs areas.

By letter-dated November 21, 1984, the staff received. Revision ~1 to the

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Program Plan. We noted that-you have already incorporated into the revised

. Program Plan most of the general comments raised in the referenced meetings,

.such as, those on independence,'the need for. obtaining an external perspective ~,

identifying a ~ basis for selection of sample sizes, identifying root causes and consideration of all relevant infonnation on a particular area. -

to this letter provides additional coments on the Program Plan and its revision. Our detailed comments regarding the Issue-Specific' Action Plans are provided in Enclosure 2 to this letter.

(Youwillsoonbereceiving'theSupplementalSafetyEvaluationReports(SSER's) in the electrical / instrumentation', civil / structural, and test programs. areas.

The SSER's will provide further clarification and additional actions required as part of our further reviews.

Prior to approval of your plan, the NRC requires you. to resolve all the-matters. discussed herein. As discussed at these meetings, the-TRT will

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con _tinue'to assess the actions you are taking pursuant to the Plan, and cd(012-g@;uQ.

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2 revisions thereto. The staff would like to be briefed on the progress of.the entire Plan on a periodic basis, this may be accomplished by way of biweekly meetings'with the staff in Texas.

Sincerely, Vincent S. Noonan. Director Comanche Peak Project

Enclosure:

As stated 4

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COMMENTS ON COMANCHE PEAK RESPONSE TEAM PROGRAM PLAN AND REVISION 1.

In our review of the Senior Review Team (SRT) members, we agree with the SRT concept of involving both TUGC0 personnel and consultants; however, based on the information provided in your revision, we are uncertain about any previous association these consultants may have had with the Comanche Peak project. The SRT must be able to demonstrate a fresh management perspective in evaluating issues and implementing actions.

2.

Your revision discusses status reporting.

If any interim status reports on implementation of the Plan have been generated t'o date, the staff

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would like to be provided copies.

In addition, the staff would like to be briefed on the progress of the entire Plan on a periodic basis, this may be accomplished by way of biweekly meetings with the staff in Texas.

. COMMENTS ON COMANCHE PEAK RESPONSE TEAM ISSUE-SPECIFIC ACTION PLANS I.

Electrical / Instrumentation Area a.1. Heat Shrinkable Cable Insulation Sleeves 1.

When clarify:ng the construction installation procedures to identify the ccnditions which require actual installation of nuclear insulating sleeves, revision of procedure QI-QP-11.3-40 " Post Construction Inspection of Electrical Equipment and Raceways" should be considered to assure documentation of inspection of nuclear heat shrinkable insulating sleeves.

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 additior.al sample of twelve cables.

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Phase 2 of the action plan, irrespective of findings in Phase 1, which requires the identification of all drawings on which

. butt splices 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, i

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.B.

a.3. Butt Splice Qualification sn=

1.

Identify those cables and circuits in whi,ch butt splices exist in control panels.

2.

Section 4.A (paragraph 3) shou'ld be coordinated with action plan Item I.a.2, Phase 2 in verifying butt splices in appropriate panels.

3.

Section 4.B should be coordinated with action plan Item I.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 be found not staggered due to the

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W.>4 lack of provisions and requirements which were not included in the appropriate installation procedures.

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

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The NRC staff does not agree sith TUEC's position of acceptable conditions based on operability.

In this issue operability is not

, the concerri, but conformance of hardware to the "as built" configuration drawings and documents.

3.

Acceptable conditions, in the action phn?c-using cable /

conductor terminations of a sizd larger, should be supplemented to incl de the requirement for a good connection to be established.

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The actiEn' plan shall identify ~all the latest design documents

" to the "as built" confiseration drawings, to be used in the TUEC sampling program.

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a.5. NCR's on Vendor Installed AMP Terminal Lugs '

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The action plan does not require the lug manufacturer to provide documented analyses to substantiate his change in position between the APC memo of September 2, 1981 (60' bend acceptable) and documented telephone record cf April 17, 1984 (90' bend acceptable).

2.

The action plan does not require the lug manufacturer or TUEC engineers to address 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 excess 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" should 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 conduits 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 3

performed to determine the flame retardant characteristics of the

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wiring, wiring materials, equipment, and other materials ' internal to the control panels.

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b' 2. Flexible Conduit to Cable Separation

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The resu'Its 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.

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The analyses,sas required by the IEEE Std 384-1974 [Section 5.6.2)/ Regulatory. Guide 1.75 Revision 2, shall be based on tests y performed to determine the flame 're~tardant characteristics of the

wiring, wiring materials, equipment, and other materials internal to the control panels.

3.

If the above analyses can demonstrate the f,lexible 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.

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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.

d.1.-'QC Inspector Qualifications d.2. Guidelines fer Administration of QC Inspector Test 4

1.

TUEC must-consider the results of the ove.rall programmatic

' review of QC inspection qualifications when responding to items.d.1 and d.2.

II. Civil / Structural Area 1

b.

. Concrete Compression Strength 1.

The action plan does not take into account the fact that more.

than one strength of concrete may have been placed between January 1976 and February 1977. Both 4,000 psi and 2,500 psi concrete grades were used on the project, If both are present in the tested concrete they must be analyzed separately.

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,1 2.

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 rebound 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.

4.-

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 the

- 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 number of tests on each placement where concrete is in question should be performed to substantiate the quality of each individual placement.

5.

Because the allegation being investigated is that some

. individual tests were falsified, the strength results for the period

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in question should not be regarded as a single population. The mean values for' individual placements should be compared with the mean of the concrete not in question at the 5% 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 QI-QP-2.5-7., " Determination of Strength of Concrete by Use of the Concrete Test Hammer" and QI-QP-13.0-5, " Verification of Concrete Test Hammer."

7.

As noted in Section 5, the program for performing these tests should be submitted to the NRC staff prior to performing these tests.

8.

Paragraph-4 (7) refers to a term "significant variation." Please define the term more specifically in the context of action pla'n-II,b.

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 s

the portions of the separation areas for the effects of the presence of-rotofoam. Clarify what areas were evaluated and when these evaluations were performed. Subnit 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

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between buildings and changes in seismic loads of structures) will be evaluated.

4.

Describe more fully what is meant by the statement that "QC will document 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."

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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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2.

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 / Acceptance 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 nonsafety-related conduit (ItemI.c).

5.

With respect to item 4.(c), a more detailed discussion of the 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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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-seismic structures, systems-and components elsewhere in the plant should be audited by an independent review team consisting of l

engineers not involved with the original evaluations. The details of these audits and findings'should be submitted to the NRC for review. The TRT will then conduct an independent audit to confinn these findings.

III. Test Programs Area a.1 Hot Functional Testing (HFT) Data Packages 1.

The background section states that'the technical review team

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-(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 team only 1-reviewed the test procedures and resultant data to detennine conformance with the CPSES FSAR, Chapter 14 comitments 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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i Regulatory Position 3, Section C of RG 1.68 states that, to the 2.

extent practical, the plant conditions during the (preoperational) tests should simulate the actual operating and emergency conditions to which the structure, 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., temperatures 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 Control."

3.

The action specified by NRC in our letter dated September 18, 1984, is tha't all preoperational test packages should be reviewed to

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determine if there are other instances where test objectives or prerequisite conditions were not met.

(The TRT intended that the TUEC pay particular attention to R.G.1.68, Regulatory Position 3 during this review.) TUEC's action plan (4.A.5.) states that the seven HFT's 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 w

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the NRC. The seven HFT's shall be added to the 136 remaining pre-operational tests and the statistical sample done on that total.

Also, TUEC shall provide the basis for the statistical sample selec-ted.

In addition, RG 1.68 should be reviewed by the group who will conduct the review of the preoperational test packages to ensure that each member understands the concept which it advocates. TUEC shall

- provide'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 thermal expansion testing after fuel load, the origina.1 issue as identified by TRT is no longer of concern. Revise the action plan'to reflect this change.

a.4 Traceability of Test 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 remove the instrument number from the data sheet.

Startup Administrative Procedure (SAP)-7 recognizes that traceability is required and provides optional methods to ensure this traceability.

However, when the thermal expansion test procedure was revised, an J

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l option was chosen which would not ensure the required traceability.

Therefore, the TRT questions whether the person who revised the procedure and those who approved the revision adequately understood the need for traceability. The TUEC Action Plan should address this aspect.

In addition, the action plan should include a cannitment to review Unit 2 preoperational test procedures and Unit 1 and 2 4

initial start-up and plant operating procedures to ensure that similar errors do not exist and will not reoccur.

1 b.

Conduct of Containment Integrated Leak Rate Testing (CILRT)

I 1.

This is another example of where a preoperational test was conducted with the system in a configuration which did not simulate the actual plant operating and emergency conditions to the extent practical, as required by R.G.1.68, Regulatory Position 3.

Consider the CILRT in the response to the comment III.a.1(2).

2.

The background section states that dus to an oversignt the CPSES FSAR was not amended to reflect deviations from 10 CFR 50, Appendix J and ANSI N 45.4-1972 during the conduct of the containment integrated leak rate test, ICP-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 e

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j i i documenting and processing' deviations from-FSAR commitments to ensure that they are included in future amendments to the document.

4 c.

Prequisite Testing 1.

While 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 XCP-EE-14, where craft personnel had signed for verification of prerequisites in lieu 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 the impact of any improper verification on subsequent testing.

d.

Preoperational Testing 1.

At the October 19, 1984 NRC meeting, TUEC stated that the records retrieval system at CPSES is complex. Since the background section for this item states that a large number of design documents are utilized by start-up, TUEC shall reassess the adequacy of the action plan for this item and document that reassessment in the revised action plan.

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