ML20141C936

Part 21 Rept Re Containment Spray Sys Recirculation Lines. Initially Reported on 860311.Matter Under Investigation to Determine Remedial Course of Action.Staff Will Be Kept Informed of Progress

ML20141C936
Person / Time
Site:	Comanche Peak, Fort Calhoun, 05000000
Issue date:	03/17/1986
From:	Derienzo P GIBBS & HILL, INC. (SUBS. OF DRAVO CORP.)
To:	Westerman T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
REF-PT21-86, REF-PT21-86-135-000 PT21-86-135, PT21-86-135-000, NUDOCS 8604070348
Download: ML20141C936 (12)

Text

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Gibbs S Hill. inc. -

l 11 Pem Piaza New Wrk. New Wrk 10001 212 764 Teen -

Domestic 127636/968694 Intematonal 428813< 234475 A Oram Canpany March 17, 1986 Mr. Thomas F. Westerman, Q' [_(( @ [i5 IlM E b s

Enforcement Officer U.S. Nuclear Regulatory Commission MN1 I 9liM6 Regional Administrator, Region IV j~

Parkway Central Plaza Building s 611 Pyan Plaza Drive, Suite 1000 - - -

Arlington, Texas 76011

Subject:

Notification of Potential Defects Relating to the Rules of 10CFR21 This letter is to confirm our telephone conversation of March 11, 1986, in which I notified you of a potential defect under 10CFR21, associated with the containment sprav system recirculation lines of the Comanche Peak Steam Electric Station (CPSES). A description is presented in the attachment to this letter.

I have informed the appropriate of ficial of the licensee of CPSES, Texas Utilities Generating Company, that we so notified you.

I have also informed the licensee of Fort Calhoun Unit No. 1, Omaha Public Power District (OPPD), Omaha, Nebraska, for which G&H performed the engineering and design.

We are currently investigating this matter to determine a remedial course of action. We will keep your staf f informed of our progress.

In addition to the above item, and as I so informed you in our telephone conversation, I am enclosing a description of four (4) additional items which are under investigation as potential defects under 10CFR21 rules. The distinction in these four (4) 8604070348 860317 DR ADOCK0500gg85 .

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Gibbs S Hill. Inc.

Mr. Thomas F. Westerman March 17, 1986 U.S. Nuclear Regulatory Page 2, 1986 Commission items is that we have not as yet concluded from our investigation that they are, indeed, reportable defects under the rules of 10CFR21. I intend to keep your staff informed of the final disposition on each of these items when we complete our investigation.

Very truly yours, GIB S & HILL, JD s/INC.A

. GCv/

/

.' Paul P. eRienzo,

/ Vice P esident /

PPD /NNK:paf / Quality Assurance Attachments cc: J. Beck - TUGCO R. Andrews - OPPD Dra&5

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'4 OPD-1 Rev. 3 Page 31 of 37 Date: 3/17/86

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APPENDIX V REPORT OF NONCONFORMANCE OR DEFECT UNDER 10 CFR PART 21 Evaluation Number: 86-01 Date:3/13/86 TO  : Director, Office of Inspection and Enforcement United States Nuclear Regulatory Commission Region IV - Arlington, Texas 76011 FROM: .Vice President, Quality Assurance Gibbs & Hill, Inc.

11 Penn Plaza New York, N.Y. 10001 Facility Name and Location: Comanche Peak SES Units 1 & 2-Glen Rose, Texas Licensee: Texas Utilities Generating Co. (TUGCO)

Docket Number: 50-445 and 50-446 Date: 7/20/73 License Type: Construction Permit 126 & 127 Date: 12/19/74 Constructor: (If Applicable) Not Applicable Construction Subcontractor: (If Applicable) Not Applicable Component Vendor: (If Applicable) Not Applicable Component Subvendor: (If Applicable) Not Applicable G&H Design: (If Applicable) Containment Spray System Recirculation Lines

s OPD-1 Rev. 3 Page 32 of 37 Date: 3/17/86 Description of Failure to Complv or Defect:

The containment spray system recirculation lines are classified as non-nuclear safety, but are seismically. supported. If these lines fail in an accident, there is a possibility that the containment spray pumps would runout, overload their motors and trip. The potential defect is whether these lines have been designed in accordance with NRC Reg. Guide 1.26.

Date Information Obtained: March 7, 1986 This was reported to NRC - Region IV, by telephone, on 3/11/86.

Description of Safetv Hazard:

Failure of this piping prior to or durf.ng containment spray system operation could prevent the proper operation of the containment sprav system pumps. Lacking fluid, these pumps miaht run-out on their curves during operation, causing automatic trips. ,

Defective Basic Component Component Spray System recirculation lines are classified as non-nuclear safety.

Number:

-In use:

At

-Supplied for Use:

At:

-On Order:

For:

Other Facilities:

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v OPD-1 Rev. 3 Page 33 of 37 Date: 3/17/86 Corrective Action Bv:

Organization - Gibbs & Hill (in coordination with TUGCO)

Individual - Chief Mechanical Engineer Corrective Action Dates:

(If obtainable)

Advice to Purchaser or Licensee:

Upon completion of our investigation

/

? As- L M, GAH VTce PresVdent,~ Date Quality Assurance

/(Designated Responsible Officer)

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March 13, 1986 PRELIMINARY REPORT OF POTENTIAL NONCONFORMANCE OR DEFECT UNDER 10CFR21 This preliminary report is prepared in conjunction with G&H Evaluation Number 86-01, dated 3/13/86. The report describes four (4) items associated with the Comanche Peak Steam Electric Station as indicated below. Further investigation is needed to determine whether they must be reported as defects under 10CFR21.

These items are as follows:

1) Air Cooling of Containment Pressure Instruments The safety function of these instruments is to indicate containment pressure. in normal operation or in the event of a containment high prescere incident, they do not require cooling. Cooling is required in case of a break in a high energy line outside the containment, in the same area where they are located. This cooling is supplied by air from a non safety source.

2) Radiation Detectors in the Component Cooling Water System This detector may be required to alert the presence of radioactivity in the component cooling water system as may occur from the rupture of a pressure component it services.

This detector is not nuclear safety grade. We are examining the consequences of such an event on personnel and public safety.

3) Service Water Discharge Lines The classification of this piping outside buildings is group G (non-nuclear safety), whereas the rest of the service water system is safety class 3. The consequences of a failure in this portion of the system have not been fully established.

The concern is that a break in the Group G lines not compromise the service water system's ability to act as an ultimate heat sink.for the safety cooling water systems.

4) Acceptance Test Procedure for the Instrument Air System.

The acceptance test procedure does not contain requirements for testing the air operated valves, as required by Regulatory Guide 1.80. We are investigating whether the pre-operational test of the instrument air system performed by TUGCO did indeed test the air operated valves.

1 .

y Tolophone Convorsation Rocerd D:ta:3/11/86 Tim e:5 Uup.m.

P.P. DeRienzo . G&H Call by: / of (Nemel (Cowenyl An swer by: Tem Westerman

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NRC-Region IV of (Nome) (Co w enyI 2323 Co n t r a c t N o:

Subject d i s c u s s e d: CPSES - Reporting of Potential Defects Under 10CFR21 SUMM ARY OF DISCUS $10N. DECISIONS AND COMMITUCNTS.

I. G&H would like to make NRC aware of a potential defect which appears to be reportable under 10CFR21. This items pertains to the safety classification of containment spray system recirculation lines. These lines are non-nuclear safety, but are seismically supported. The classification of these lines may not be in conformance with NRC Reg. Guide 1.26. If these lines failed in a seismic event there is a possibility that the containment spray pumps could run out, overload their motors and trip. This item will be further investigated to develop a remedial solution.

II. In addition to the above item, several other items are currently under investigation by G&H before a final decision is made as to whether they are reportable under 10CFR21. We are, therefore, advising you that these items are potentially reportable under 10CFR21.

These items are as follows:

F-43410 68

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1) This item pertains to air cooling of containment pressure instruments. This cooling is affected by air from a non safety source. The safety function of these instruments is to indicate containment pressure. In normal operation and during containmant high pressure incidents, they do not require cooling. Cooling is required in case a break in a high energy line occurs outside containment in the same area where they are located.

2) This item refers to the radiation detectors in the component cooling system. Under certain accident conditions, this detector may be subject to a high temperature excursion. This detector is not nuclear safety grade and may not be able to function under this condition. Further investigation is recuired to access its performance and the consequences of an accident as has been described.

3) This item refers to the quality classification of service water discharge lines outside of buildings.

They are group G (non-nuclear safety) , whereas the rest of the service water system is safety class 3. The consequences of a failure in this portion of the system is under investigation. The concern is that the intended function of the service cooling water system be assured in the event a break occurs in the discharge lines.

4) This item refers to the acceptance tests procedure for the instrument air system. It does not contain requirements for testing the system air operated valves, as required by Regulatory Guide 1.80. It is not certain that pre-operational systen test performed by TUGCO operations actually tested the air operated valves. We will continue our investigation into this matter.

The foregoing items were brought to our attention by a G&H Engineer working on CPSES. They were subject to evaluation by our staff, but there is a need for further investigation.

DISTRIBUTION Mr. T. Westerman - NRC Region IV

-(. .

. Tolopheng Convorsatien Rocord 02,J/12/86 y;,J,1:00a.m.

0 P.P. G&H Call by: DeRienzo / ' of (Name) (Cygyon y)

An swer by: Ed Powell ,g TUGCO - Dallas (None) (copy,i

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Co n t r a c t N o:

Subject d i s c u s s e d: Recortina of Potential Defects Under 10CFR21 for CPSES SUW W ARY OF DISCUSSION. D ECISIONS AND COWWITWENTS.

Called John Beck (TUGCO's VP for Nuclear and QA). In his absence Ed Powell took the call.

I. G&H would like to make TUGCO aware of a potential defect which appears to be reportable under 10CFR21. This items pertains to the safety classification of containment spray system recirculation lines. These lines are non-nuclear safety, but are seismically supported. The classification of these lines may not be in conformance with NRC Reg. Guide 1.26. If these lines failed in a seismic event there is a possibility that the containment spray pumps could run out, overload their motors and trip. This item will be further investigated to develop a remedial solution.

II. In addition to the above item, several other items are currently under investigation by G&H before a final decision is made as to whether they are reportable under 10CFR21. We are, therefore, advising you that these items are potentially reportable under 10CFR21.

These items are as follows:

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F 4241048

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Page 2

1) This item pertains to air cooling of containment s

pres'ure instruments. This cooling is affected by air from a non safety source. The safety function of these instruments is to indicate containment pressure. In normal operation and during containment high pressure incidents, they do not require cooling. Cooling is required in case a break in a high energy line occurs outside containment in the same area where they are located.

2) This item refers to the radiation detectors in the component cooling system. Under certain accident conditions, this detector may be subject to a high temperature excursion. This detector is not nuclear safety grade and may not be able to function under this condition. Further investigation is required to access its performance and the consequences of an accident as has been described.

3) This item refers to the quality classification of service water discharge lines outside of buildings.

They are group G (non-nuclear safety), whereas the rest of the service water system is safety class 3.. The consequences of a failure in this portion of the system is under investigation. The concern is that the intended function of the service cooling water system be casured in the event a break occurs in the discharge lines.

4) This item refers to the acceptance tests procedure for the instrument air system. It does not contain requirements for testing the system air operated valves, as required by Regulatory Guide 1.80. It is not certain that pre-operational system test performed by TUGCO operations actually tested the air operated valves. We will continue our investigation into this matter.

The foregoing items were brought to our attention by a G&H Engineer working on CPSES. Thev were subject to evaluation by our staff, but there is a need for further investigation.

DISTRIBUTION Mr. E. Powell - TUGCO - Dallas

T. .

Tolophone Convers@ tion Rocord Est3:

1 3/12/86 Tim e:

11:00a.m.

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P.P. DeRienzo -

G&H Call by: of (Name) (Cogony)

Jim Fisicaro OPPD-Omaha Nebraska An swer by: Richard Jaworski ,(

(Namel (Cowany?

Co n t r a c t N o: gj; Subject d i s c u s s e d: Mapnrtinn n( pnton64ni nofacts finder 10CFR21 for CPSES for Potential Impact on Ft. Calhoun Unit 1 SUM M ARY OF" DISCU SSION. DECISIONS AND COMMITMENTS.

Called Dick Andrews (OPPD-Operation Manager). In his absence Rich Jaworski (Section Manager) and Jim Fisicaro (Licensing Manager) took the call.

G&H would like to make OPPD aware of certain 10CFR21 Items which we have just reported to the NRC on Comanche Peak. Since G&H was also the A/E for Ft. Calhoun we bring this matter to OPPD's attention for their assessment and separate notification of the NRC.

I. G&H would like to make OPPD aware of a potential defect which appears to be reportable under 10CFR21. This items pertains to the safety classification of containment spray system recirculation lines. These lines are non-nuclear safety, but are seismically supported. The classification of these lines may not be in conformance with NRC Reg. Guide 1.26. If these lines failed in a seismic event there is a possibility that the containment spray pumps could run out, overload their motors and trip. This item will be further investigated to develop a remedial solution.

II. In addition to the above item, several other items are currently under investigation by G&H before a final decision is made as to whether they are reportable under 10CFR21. We are, therefore, advising you that these items are potentially reportable under 10CFR21.

These items are as follows:

• Yh

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Page 2

1) This item pertains to air cooling of containment pressure instruments. This coo'ing is affected by air from a non safety source. The safety function of these instruments is to indicate containment pressure. In normal operation and during containment high pressure incidents, thev do not require cooling. Cooling is required in case a break in a high energy line occurs outside containment in the same area where they are located.

2) This item refers to the radiation detectors in the component cooling system. Under certain accident conditions, this detector may be subject to a high temperature excursion. This detector is not nuclear safety grade and may not be able to function under this condition. Further investigation is required to access its performance and the consequences of an accident as has been described.

3) This item refers to the quality classification of service water discharge lines outside of buildings.

They are group G (non-nuclear safety), whereas the rest of the service water system is safety class 3. Tro consequences of a failure in this portion of the " stem, is under investigation. The concern is that the intended function of the service cooling water system be assured in the event a break occurs in the discharge lines.

4) This item refers to the acceptance tests procedure for the instrument air system. It does not contain requirements for testing the system air operated valves, as required by Regulatory Guide 1.80. It is not certain that pre-operational system test performed by TUGCO operations actually tested the air operated valves. We will continue our investigation into this matter.

The foregoing items were brought to our attention by a G&H Engineer working on CPSES. They were subject to evaluation by our staff, but there is a need for further investigation.

DISTRIBUTION Mr. J. Fisicaro - OPPD Omaha Nebraska Mr. R. Jaworski - OPPD Omaha Nebraska