ML20150B166

Responds to NRC Re Open Items & Unresolved Issues Noted in Insp Rept 50-445/87-22.Clarifications to Insp Rept Statements Also Encl

ML20150B166
Person / Time
Site:	Comanche Peak
Issue date:	03/11/1988
From:	Counsil W, Woodlan D TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
TXX-88309, NUDOCS 8803160207
Download: ML20150B166 (17)

Text

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1UELECTRIC w mi.m c.co.nsu Harch 11, 1988 i

herunsw ske Presadme U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NO. 50-445  :'

RESPONSE TO NRC INSPECTION REPORT N0. 50-445/87-22 Gentlemen:

TV Electric has reviewed your letter dated January 12, 1988, concerning the inspection conducted by Messrs. A. Singh and D. Kelley and NRC consultants <

during the period October 19, 1987 through October 23, 1987. This inspection covered activities authorized by the NRC Construction Pennit CPPR-126 for  !

CPSES Unit 1. Included in your inspection report were nine open items and four unresolved issues.

Per your request, we hereby respond to the Open Items and Unresolved issues in Attachment I to this letter. Additionally, we have included in Attachment 2 clarifications to statements made in the inspection report.

Very truly yours,

.0 W.G.Couns(1 By F R. Woodlan Docket Licensing Manager JOS/grr Attachment c-Mr. R. D. Martin, Region IV l Resident Inspectors, CPSES (3) i 8803160207 880311 PDR ADOCK 05000445 Q DCD a neth c%w Street LB81 Ekilas, Tenas 75.'01

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", Attachment 1 to TXX-88309 March 11, 1988 Page 1 of 13 OPEN ITEM (445/8722-0-01)

An inspector reviewed the installation of the RCP oil collection system. The inspector looked at two of the four RCPs and verified that all external potential leakage areas were adequately covered and would drain oil into a separate collection tank. The design drawings were reviewed and the inspector confirmed that each collection tank was designed to hold all of the oil inventory f rom its associated pump. During the inspection the applicant stated that seismic analysis for the RCPs had not been completed to verify that the system was seismically qualified. This item is considered open pending completion of the analysis by TV Electric (445/8722-0-01).

RESPONSE

(445/8722-0-01)

Seismic qualification of the React.or Coolant Pump Lube Oil System is in progress. Westinghouse is seismically qualifying the internal portions of the Reactor Coolant Pump Lubricating Oil Collection System. Impell is addressing the seismic qualification of the remaining portions of the Reactor Coolant Pump Lube Oil System and Lube Oil Collection Pans and determining their adequacy using Calculation 0210-063-0069. The analysis determining the adequacy of the piping and collection tanks is being Jerformed by SWEC using calculation 16345-ME(S)-014. SWEC PSE is preparing t,e pipe stress analysis calculations required for the seismic qualification of the piping and collection tants using Calculaduns 15454-NP(S)-RC-1-349 through 352. All engineering portions of the Reactor Coolant Pump Lube Oil Collection System are scheduled for completion by July 31, 1988. Any design modifications necessary to support the seismic qualification of the Reactor Coolant Pump Lube. Jil Collection System and Lube Oil Collection Pans are scheduled for completion by October 1, 1988.

Attachment 1 to TXX-88309 March 11, 1988 Page 2 of 13 OPEN ITEM (445/8722-0-02)

During this inspection several barriers separating redundant trains of safe shutdown equipment were identified by the inspector as not being three-hour-ri+ed. Specifically, unrated steel hatches were located in fire area

b. ..daries. The applicant presented an analysis which stated that due to low combustible loading on either side of the hatches, automatic suppression on at least one side of the hatch and a one hour fire resistive coating on both sides of the hatch, it was not likely that a fire would propagate through the hatch. The inspector reviewed the analysis and found it acceptable. However, it was identified that this was a deviation f rom Section 0.1.j of Appendix A to BTP APCSB 9.5-1 and must be identified as such in the FSAR. The applicant committed to identify these unrated steel hatches in a future FSAR amendment.

submittal by the applicant of an FSAR This item isaddressing amendment considered thisopen pending(445/8722-0-02).

deviation

RESPONSE

(445/8722-0-02)

An upcoming amendment to the CPSES FSAR will identify these unrated steel hatches as a deviation to Section 0.1.j of Appendix A to BTP APCSB 9.5-1.

This discussion will be in FSAR Section 9.5.1.6.2.

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. Attachment 1 to IXX-88309 March 11, 1988 ,

Page 3 of 13 t

OPEN !iEM (445/8722-0-03)

. Appendix A to APCSB 9.5-1 Section 0.l(j) states that "Penetrations in fire l barriers, including conduits and piping, should be sealed or closed to provide '

a fire resistive rating at least equal to that of the fire barrier itself.

Door openings should be protected with equivalent rated door frames and a

hardware that have been tested and approved by a nationally recognized

laboratory." During the inspection, the inspector expressed concern that the method of sealing conduits four inches in diameter and smaller was not in accordance with rated configurations and had not been identified as a deviation from staff guidance. The applicant stated that conduits with either suppression or detection on both sides of the penetration would only be sealed on one side while conduits with no detection or suppression on at least one side would be sealed on both sides at the first opening. The inspector was concerned that this plan would allow for only one seal outside of the barrier in locatit;/s where there was only detection on both sides on the barrier with !

no suppression on either side. The applicant agreed to revise their position r

, and committed to seal conduits four inches and smaller on both sides at the first opening regardless of the presence of detection or suppression. This -

item is considered open pending the completion of the seal installation (445/8722-0-03).

RESPONSE -

(445/8722-0-03)

, The commitment to seal canduits four inches and smaller was not recognized by

! 10 Electric as havinc occured during the Fire Protection Program inspection in -

i October, 1987. TV t:Iectricisreviewingthiscommitmentandwillprovidea response by April 29, 1988.

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Attachment 1 to TXX-88309 March 11, 1988 Page 4 of 13 OPEN ITEM (445/8722-0-04)

During this inspection a number of modifications to fire doors, primarily for security hardware, were observed. Although the doors and frames contained labels which demonstrated compliance with testing criteria for Underwriter's Laboratory, the inspector was concerned that these modifications would degrade l the performance of the door under fire conditions. The applicant presented documentation from Underwriter's Laboratory concerning how security modifications could be made without jeopardizing the rating of the door.

However, these guidelines may not have been implemented during modification of the plant fire doors. The applicant committed to review all fire doors presently installed to determine if modifications comply with guidance provided by Underwriter's Laboratory. Where compliance cannot be established, the applicant committed to bring the door into compliance or replace the door with one that conforms to the guidelines. The applicant also committed to ensure that all future modifications will conform to the guidance established by Underwriter's Laboratory. This item is considered open pending the completion of applicant's review of this issue. (445/8722-0-04)

RESPONSE

(445/8722-0-04)

The guidelines provided in Underwriter's Laboratories, Inc. letter dated September 7, 1984, have been implemented. Ins)ection attributes have been provided and added to specifications for fire Jarriers per DCA 67,208 as part of the "Post Construction Hardware Validation Program" to assure compliance to the guidelines in safety related buildings. This is implemented through Field Verification Method CPE-SWEC-FVM-EE/ME/IC/CS/086. ,

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Attachment I to TXX-88309 March 11, 1988 Page 5 of 13 '

OpEN ITEM (445/8722-0-05)

The areas identified in the 84-44 inspection as lacking lights had been provided with lights and therefore open item 445/8444-0-04 is considered closed. New areas requiring lights had been identified by the applicant resulting from changes in the safe shutdown analyses. As noted in Section 6.1.2 of this report, areas were identified by inspectors where additional emergency lights may be required. Pending completion of TV Electric's evaluation identifying locations requiring additional lights, including resolution of the emergency lighting issues discussed in Section 6.1.2 of this report, this item is considered open (445/8722-0-05).

RESPONSE

(445/8722-0-05)

Impell Calculation 0210-063-0034 will be revised by May 27, 1988, to address additional lighting required as a result of the revision of the Safe Shutdown Analysis. Required changes in lighting design will be identified in Deficiency Reports.

Deficiency Report # P87-05230 was issued to identify a need for an 8-hour battery pack emergency lighting unit at valve 1-HV-8112, discussed in Section 6.1.2 of HRC inspection report 87-22. Other valves discussed in Section 6.1.2 (1-88080, 1-FCV-618, 1-HCV-606, 1C1-650, and ICl-6S1) are valves necessary to achieve during Cold Shutdown. Equipment required to attain cold shutdown does not require emergency lighting, since cold shutdown procedures are less time critical and may be accomplished using onsite capability such as additional manpower, battery powered portable hand lights or establishing onsite power.

OCA 64,191, Revision 1, will include required new lighting. Implementation of this DCA is scheduled for July 31, 1988.

Attachment 1 to TXX-88309 March 11, 1988 Page 6 of 13 OPEN ITFM (445/8722-0-06)

Section E.4 of Appendix A to BTP APCSB 9.5-1 states that "The use of halon fire extinguishing agents should as a minimum comply with the requirements of NFPA 12A and 12B, Halogenated Fire Extinguishing Agent Systems - Halon 1301 and Halon 1211." During this inspection, the inspector was concerned that the Halon system provided in the Cable Spreading Room may not be in compliance with NFPA 12A. The applicant indicated that the review of the system against the requirements of NFPA 12A had not been performed. Therefore, the applicant needs to perform a review of the Cable Spreading Room Halon system against the requirements of NFPA 12A. Any deviations identified in this review will be required to be submitted to the staff for evaluation. The NRC considers this item open pending applicant completion of the evaluation and HRC review of the results (445/8722-0-06).

RESPONSE

(445/8722-0-06)

NCR-87-00748 was initiated on October 14, 1987 to identify a nonconformance of the Cable Spreading Room Halon System. A design modification (DMRC-87-0231) has been issued to upgrade the Cable Spreading Room Halon System to comply with applicable specifications and sections of NFPA 12A. This work is scheduled for construction completion by July 15, 1988. Following the modification a full functional concentration test will be conducted to ensure concentrations are within guidance criteria established by NFPA 12A. Impell's NFPA 12A Code Compliance Review is scheduled for completion August 5,1988.

4 Attachment 1 to TXX-88309 March 11, 1988 Page 7 of 13 OPEN ITEM (445/8722-0-07)

Regarding the section in the procedure involving repairs, attachment 6 for the >

emergency air supply hock up to RHR valves 1-FCV-618 and 1-HCV-606 referenced actions to close instrument air valves 101-650 and 1C!-651 which were difficult to locate and poorly labeled. There also did not appear to be 8-hour emergency lights in the area. The need for TVEC to complete their assessment of locations where emergency lighting is required is addressed in Section 4.3 of this report. The issue of the poorly labeled valves is considered an open item pending further review by the staff (445/8722-0-07).

RESPONSE

(445/8722-0-07)

TV Electric Operations has initiated a new sign for these valves on an "Identification Aid Installation Request". Pennanent "identification Aids" for valves 1C1-650 and 101-651 will be prepared and installed by April 29, 1988. Procedure STA-618, "Installation and Control of Permanent and Temporary Signs and Identification Aids" is used to provide identification of equipment in the plant.

Attachment 1 to TXX-88309 March 11, 1988 Page 8 of 13 OPEN ITEM (445/8722-0-08)

The applicant has '.eveloped modifications which will enable local operation of the diesel generators. These are the subject of Design Change Authorization DCA 61,447. DCA 61,447 was initiated to resolve the consequences of uncoordinated 125 VDC circuits EG 104509, EG 145211, and EG 130661. This DCA, when implemented, will require the installation of branch circuit fuses or the installation of Thermo-Lag protection. Pending completion of the modification and review by the NRC, this item is considered open (445/8722-0-08).

RESPONSE

(445/8722-0-08)

NCR 87-02812 was initiated on November 16, 1987. This NCR identified that the installed Gould A25X30 fuses did not comply with the design which required Bussman BAN-30A fuses. As the Gould A25X30 fuses installed are the desired branch circuit fuses discussed in the audit open issue to resolve the problem, the NCR has beeq dispositioned "Use As Is". DCA 61,447, originally issued to implement installation of Gould A25X30 fuses will be cancelled. Design documents will be revised per procedure to include the use of Gould A25X30 fuses.

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Attachment 1 to TXX-88309 March 11, 1988 Page 9 of 13 OPEN ITEM (445/8722-0-09)

a. The_ applicant analysis of protection of associated circuits related to safe shutdown was found to be substantially completed. The analysis resulted in the need for a r. umber of modifications, many of which have not been completed. One area where a significant amount of work remained to be done was installation of Thermo-Lag. Until the analysis is completed and the staff reviews the results, this item is considered open (445/8722-0-09).

b. The applicant identified circuits which were not completely analyzed to account for ampacity effects due to the increased operating temperature resulting from the Thermo-Lag wrap. The applicant indicated that Revision 4 of the CPSES FSSA Calculation No. 152 will address this issue and could result in further circuit modifications or Thermo-Lag changes.

The common bus concern cannot be satisfactorily resolved until Revision 4 of the FSSA and the final Therno-Lag report, ECF-M1700, have been completed. The issue of ampacity effects due to increased operating temperatures resulting from Thenno-Lag wrap will remain open subject to completion of TV Electric's analysis. This item is considered part of Open Item (445/8722-0-09).

RESPONSE

(445/8722-0-09)

a. The revisian of the analysis is scheduled to be available for NRC review by May 1, 1988. Applicable DCAs will be initiated by June 1, 1988 to l :plement any identified modifications.

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b. The Thermo-Lag Removal Program at CPSES has addressed cables identified to have ampacity problems due to Thermo-Lag wrap. Impell Calculation 0210-142-C102 "Thermo-Lag Removal Detailed Analysis" identified sections of Thermo-Lagged raceways which were potential candidates for Thenno-Lag removal. Impell Calculations 0210-063-0077, 0210-063-0079 and EPM Calculation P257-169 raviewed the 66 cables which originally had been identified as ampacity issues and through Thermo-Lag reduction, decreased the list to 21 ampacity cables requiring analysis. SWEC Electrical is currently completing analysis of ampacity effects due to Thenno-Lag wrap (E.C.D. April 30,1988). Following completion of this l analysis DMRC 190, TV Electric will complete the necessary plant l modifications by October 23, 1988.

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Attachment 1 to TXX-88309 March 11, 1988 Page 10 of 13 UNRESOLVED ISSUE (445/8722-U-01)

A number of stairwell walls were identified during the inspection where the inspector considered the justification was not adequate to support two hour rated construction. The applicant presented an evaluation which was conducted to determine the rating of fire area and stairwell bG'Jndaries. This evaluation was used to justify the fire rating of those boundaries which were not built specifically to the specifications of an independent testing organization. Where specific installation criteria of a recognized approval agency was not followed, the evaluation was used to determine if criteria were met or exceeded in such items as wall thickness and material type. The inspector identified six stairwell walls that could not be directly related to the installation criteria established by a recognized approval agency. The applicant has committed to take actions to resolve this issue. Pending actions taFan by the applicant to resolve this issue and NRC review of those actions, this item is consiaered unresolved (445/8722-U-01).

RESPONSE

(445/8722-U-01)

DR # C-87-414 was initiated on October 14, 1987 by SWEC Civil / Structural identifying the six stairwell walls requiring field verification of construction by opening the walls. Impell Fire Protection has identified the requirements necessary to adequately disposition the Deficiency Report.

Verification of hidden construction attributes and dispositioning of the deficiency report will be performed by SWEC Civil / Structural. This in formatioi: will be reflected in a revision to Impe11 Calculation 0210-063-0043 which will establish an equivalent rating for these fire area boundary walls. The CPSES FSAR Section 9.5.1.6.2 will be revised in an upcoming amendment to identify these walls as deviations to BTP APCSB 9.5-1 Appendix A.

4 Attachment 1 to TXX-88309 March 11, 1988 Page 11 of 13 UNRESOLVED ISSUE (445/8722-U-02)

...The applicant presented a revised listing of manual actions... The list indicated that some revisions to Table 2 were necessary and that some actions had been deleted. The new listing of actions would be presented in a previously planned Revision 4 of Calculation No. 152.

The issue of the adequacy of manual actions which must be taken in the same

-area as the postulated fire remains unresolved pending TV Electric's revision to Calculation No. 152 and NRC review of the document (445/8722-U-02).

RESPONSE

(445/8722-U-02)

Calculation No. 152, Revision 4 is scheduled to be available for NRC review by May 1, 1988. It will contain a revised listing of manual actions by fire area, which will easily identify actions required in the same area as the fire. Justifications for the adequacy of these actions will be provided.

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Attachment I to TXX-88309 March 11, 1988 Page 12 of 13 UNRESOLVED ISSUE (445/8722-U-03)

The applicant attempted to address the concern raised by the team regarding the feasibility of the manual actions inside containment by preparing, durirg the inspection, a calculation (ref. Appendix A, A.6) intended to show that time for rupture of the PRT rupture was overly conservative and that the rupture disk would not burst at all. The team did not have time to review-this calculation as it was presented on the evening prior to the exit meeting and because the actual Westinghouse calculations are not provided in the WCAP.

This item remains unresolved pending the NRC review of the calculation (445/8722-U-03).

RESPONSE

(445/8722-U-03)

A clarification to the information given the audit team on the subject of spurious Safety Injection is required. Since the inspection, the calculation has been revised. The revised calculation will be available for review March 17, 1988. The results of the revised calculation indicate the following:

Time for rupture of the PRT rupture disk, as given in WCAP-ll331, remains overly conservative, Per the revised calculation, the PRT rupture disk still does not rapture prior to blowdown, The pressurizer could now go water solid during the transient, assuming no additional mitigating operator actions are taken, and Operator actions inside containment required in current procedures, can still be completed prior to the postulated PRT rupture during final depressurization of the primary system to RHR cut-in. The pressurizer level conditions and swell due to the steam generator dry-out are major factors contributing to the phenomenon.

. l Attachment 1 to TXX-88309 March 11, 1988 Page 13 of 13 J

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UNRESOLVED ISSVE (445/8722-U-04)

The control circuit for the accumulator isolation valves 1-8808A, B, C and D are not electrically isolated from the control room. The applicant intends to-utilize jumpers to maintain control or manually. operate the valves during hot shutdown. The inspection team considers this action a hot shutdown repair

-which is not consistent with staff guidelines. Further information is needed to resolve this concern (445/8722-U-04).

RESPONSE

(445/8722-U-04)

The CPSES procedure ABN-803A provides for manual actions to close these valves. The manual actions are completed prior to RHR cut-in. Jumpers are not used to close these valves for achieving and maintaining hot shutdown.

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5 to TXX-88309 .

March 11, 1988 Page 1 of 3 ,

IR 87-22 Description Discussion Clarification / Comments Section Section 4.1 "

... or are constructed Actual Uniform Building Code requirements The Actual Uniform _

page S of 8-inch-thick reinforced are for 6-inch-thick reinforced concrete. Building Code concrete in accordance with requirements reflect the Uniform Building Code ..." the design criteria used at CPSES.

Section 4.1 The previously approved The previously approved deviation included The previously approved page 7 deviation associated with the HVAC fire dampers. A program to replace deviation is no longer remaining dampers still HVAC fire dampers has been instituted. necessary.

applies since they cannot be TU Electric has determined through analyses mounted completely inside the that fire dampers mounted adjacent to tornado barrier due to interference pressure relief dampers provide protection with tornado pressure relief equivalent to the fire barrier in which they dampers. are installed. These analyses were reviewed ~

during the inspection.

Section 4.4 "

. . .all sprinkler systems NFPA 13 upgrade applies to safety related are in compliance with areas of CPSES where the Fire Hazards Analysis NFPA 13." identifies a requirement for suppression.

Section 6.3 The inspection report The following is a list of major devices See CPSES FSAR page 19 and indicated a listing of controlled from the Hot Shutdown Panel. Section 7.4 Table 7.4-1 20 equipment on the Hot Shutdown Those devices designated with an "(A)"

Panel as being required for are associated with alternate shutdown.

alternate shutdown. .

(A) Main Steam Isolation Valve 1HV2333A (A) Main Steam Isolation Valve luV2334A (A) Main Steam Isolation Valve IHV2335A (A) Main Steam Isolation Valve 1HV2336A Turbine Driven Auxiliary Feedwater Pump (A) Motor Driven Auxiliary Feedwater' Pump 1 Motor Driven Auxiliary Feedwater Pump 2

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Attachment'2 to TXX-88309 March 11, 1988 j Page 2 of 3 ..*-

IR 87-22 Description Discussion Clarification / Comments-Section Section 6.3 (A) Steam Generator 1 PORV 1PV2325 (continued) (A) Steam Generator 2 PORV IPV2326 (A) Steam Generator 3 PORV IPV2327 (A) Steam Generator 4 PORV IPV2328 (A) Service Water Pump 1 Service Water Pump 2 (A) Diesel Generator 1 ,

Diesel Generator 2 (A) Centrifugal Charging Pump 1 '

Centrifugal Charging Pump 2 (A) Pressurizer Level Control IFCV121 Valve (A) Letdown Orifice Isolation 1-8149A Valve (A) Letdown Orifice Isolation 1-81498 Valve (A) Letdown Orifice Isolation 1-8149C Valve Backup Heater Group A Backup Heater Group B i (A) Component Cooling Water Pump 1 Component Cooling Water Pump 2 -

(A) RHR Pump 1 RHR Pump 2 -

Charging Pump Isolation 1-8106 ,

Valve (A) Pressurizer PORV PCV455A IPCV445A (A) Steam Generator Blowdown IPV5180 Heat Exchanger Isolation Valve

_ to TXX-88309 March 11, 1988 Page 3 of 3 ,,

IR 87-22 Description Discussion Clarification / Comments Section Section 6.3 The following valves are not controlled from the Hot (continued) Shutdown Panel. As noted before, those valves associated with alternate shutdown are designated with an "(A)".

(A) Main Steam Isolation Bypass IHV2333B Valve (A) Main Steam Isolation Bypass IHV23348 Valve (A) Main Steam Isolation Bypass IHV23358 Valve (A) Main Steam Isolation Bypass lHV2336B Valve (A) Letdown Isolation Valve ILCV359 Letdown Isolation Valve ILCV460 Control room Manual Reactor Trip Backup Heater Group C (A) Pressurizer Block Valve 1-8000A Pressurizer Block Valve 1-8000B

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(A) Accumulator Isolation Valve 1-8808A (A) Accumulator Isolation Valve 1-88088 (A) Accumulator Isolation Valve 1-8808C (A) Accumulator Isolation Valve 1-8808D (A) Charging. Pump Isolation Valve 1-8105