ML20150D652
| ML20150D652 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/31/1984 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20150D634 | List: |
| References | |
| FOIA-87-847 NUDOCS 8803240451 | |
| Download: ML20150D652 (17) | |
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i NT0L REVIEW MANAGEMENT REPORT * !
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I December 1984 l 1
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- The changed portions of this report are noted by bars in the right margins next to the affected lines. These bars have been drawn manually and, there- !
fore, will not appear in copies transmitted electronically. For this reason, i annotated copies will be sent to all addressees as followup to the copies I transmitted electronically. {
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LICENSING STATUS OF COMANCHE PEAK UNIT 1 v
Comanche Peak Steam Electric Station Unit 1 is in the final stages of the operating license review process. The Construction Permits for Units 1 and 2 were issued on December 19, 1974. Texas Utilities docketed their application for operating licenses on April 25, 1978. The Final Environmental Statement was issued September 24, 1981. The Safety Evaluation Report (SER) was issued on July 14, 1981. Because of the large number of outstanding issues identified in the SER, the staff recommended delaying the ACRS review. SER Supplement No. I was issued on October 16, 1981, and the ACRS meeting was held on November 13, 1981. The ACRS, by letter dated November 17, 1981, supported issuance of an operating license. The latest SER supplement was issued on November 13, 1984.
The activities listed below, particularly the hearing matters and allegations, have the potential for impacting the licensing decision date.
The staff conducted a Caseload Forecast Team site visit during the week of March 19,1984, to obtain a more current estimate of the fuel load date.
During this visit the applicant advised that his current projection for a fuel load date for Unit 1 is September 1984. The staf f's preliminary assessment was that this projected date is optimistic. On May 7,1984, the Applicant met with the NRC staf f and provided new information in support of a late September 1984 fuel load date, and updated the earlier data provided in March. The staff concluded that the applicant's projected schedule was achievable, but it ellowed little contingency for delays. The applicant has been submitting a bi-weekly status report on progress in meeting their projected schedule. The September 24, 1984 status report submitted by the applicant forecast a mid-to-late October 1984 fuel load date. By a letter dated October 9,1984, the applicant advised the ASLB that it had revised the sequence of precritical testing for Comanche Peak Unit I and that a license to load fuel will not be required l prior to the completion of these tests. The applicant estimated that approximately l three months would be required for that effort.
On July 13, 1984, the staff issued a Special Review Team Report that resulted from the special review conducted during the period April 3-13, 1984 at the Comanche Peak site. The purpose of the review was to: 1) evaluate the current implementation of the applicant's management control of the construc-tion, inspection and test programs, 2) provide an in-depth understanding and background information to the NRC management team established by the Executive Director for Operations, and 3) obtain information necessary to establish a management plan for resolution of all outstanding. regulatory actions. The Special Review Team found during this limited review that the applicant's management control over the construction, inspection, and testing programs is generally ef fective and is receiving proper management attention. The Special Review Team concluded that the applicant's programs are being sufficiently controlled to allow continued plant construction while the NRC completes its review and inspection of the facility.
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O LICENSING STATUS OF COMANCHE PEAK 1 U On September 18, 1984, the Technical Review Team issued a request for additional information identified by its evaluation of the technical issues at Comanche Peak, including "allegations." This letter was limited to the Technical Review Team's findings in the general areas of electrical / instrumentation, civil /
structural, and test programs. Additional requests will be issued in other areas as the reviews are completed.
FSAR Review The staff FSAR review is essentially complete. The principal items that need resolution are:
(1)* Review of Cygna Independent Assessment Program, (2) Conformance of fire protection with Appendix R, including safe shutdown methodology, (3) Seismic and dynamic qualification of equipment, (4) Technical Specifications, in the view of the staff, the only item (asterisked above) having a potential for delaying the applicants' fuel load date is the Cygna Independent Assessment Program. The progress in the other three items identified above, combined with m the slippage in the fuel load date, has removed them as a potential cause for delay. Seven of the items listed previously have been resolved.
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3 The major FSAR open item is the staff's review of the Cygna Report, an Independent Assessment Program performed at the Staff's request. The i staff concluded, as a result of the Construction Assessment Team (CAT) inspection, that some form of added assurance that the plant has been designed and constructed in accordance with the application was necessary.
The staff requested that the applicants consider conducting a program which would provide the staff with that added assurance. The Cygna review consisted of a broad review of the design control programs of the applicants and the architect-engineer, a review of the implementation of design analysis, design change control and design interface controls, a review of the design of a l
portion of the residual heat removal system including piping and pipe support, and verification of the correct use of design and construction documents by a visual inspection (walkdown) of a spent fuel pool cooling loop. The staff review of this item is being expedited consistent with hearing schedule demands.
The onsite emergency plan review has been completed on the applicant's revised (Rev. 8) emergency plan dated May 2,1984, and all EP-related items in the SER have been resolved. The only remaining item on which the staff may report later is the supplemental finding on the adequacy of offsite plans, which is expected from FEMA by December 15, 1984.
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G U LICENSING STATUS OF COMANCHE PEAK 1 Qudity Assurance / Quality Control Area Numerous quality assurance / quality control (QA/QC) issues are outstanding at Comanche Peak. NRC inspections have identified QA/QC problems in design and construction. The overall QA/QC program is the subject of litigation in the hearing and numerous QA/QC allegations have been made.
A Construction Appraisal Team (CAT) inspection was conducted at the Comanche Peak site during the period January-March 1983. The CAT found two notewcrthy deficiencies. One involved a breakdown in the work and quality control for the construction of the heating, ventilation, and air conditioning (HVAC) system. There were numerous deficiencies in HVAC equipment installation and QC inspections. The CAT found evidence of poor welding in many HVAC supports.
QA audit and surveillance activities failed to identify these deficiencies.
The second major deficiency involved the design change control system and program for assuring that the field installation conformed to the latest design document.
The CAT found the design change control system to be cumbersome and found a large number of design changes at Comanche Peak. There was not an adequate program in place at the time of this inspection to ensure that proper inspections were completed. The Applicant has made commitments to conduct a final p reinspection to assure that the components conform to final design documents.
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b The NRC staff will verify the adequacy of tne reinspection program by audit, Numerous hearing issues regarding design and construction adequacy remain unresolved (see Hearing, below). One critical issue concerning construction adequacy is containment liner coating (painting). The Brookhaven National Laboratory conducted preliminary testing on the containment liner coatings.
The initial report to the staff was completed in late April with a draft evaluation submitted to the staff on June 13, 1984. The applicants also responded to the allegations in a letter dated June 22, 1984. The staff has reviewed these responses and prepared a request for additional information.
The Applicant responded to the questions in writing by letters dated August 10, 14, and 21, 1984. In the meantime, the applicants submitted studies on the performance of the containment sump with entrained paint particles and other debris in an effort to show that failure of all of the paint inside containment would not compromise performance of the emergency core cooling system.
Further, the applicants are proposing to change the classification of coatings to nonsafety-related, i.e. , removing it from the list of items subject to the quality assurance requirements of 10 CFR 50 Appendix B. The staff is currently evaluating the latest submittal. Staf f acceptance of the applicants' studies on the containment sump performance could resolve the painting issue without impacting the fuel load date.
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( LICENSING STATUS OF COMANCHE PEAK 1 Q)
Many allegations can be classified as being relevant to both construction adequacy and construction QA. This overlap is attributable to the dual nature of the concerns. There are specific concerns about the adequacy of as-built hardware and structures, as well as a more generic concern with the adequacy of the construction QA/QC program. Most of the active 01 investigations relate to construction QA/QC allegations. In response to the numerous allega-tions, the Project Director assembled a Technical Review Team (TRT) on-site on July 9,1984. The TRT consists of over 50 technical experts drawn from the NRC (NRR and Regions), national laboratories and consulting organizations.
The TRT was on-site investigating the allegations until October 1984. On September 18, 1984, the TRT met with the applicant to present its conclusions on the general areas of electrical / instrumentation, civil / structural, and test p rog rams . The applicant was also issued a letter requesting additional information needed to resolve the TRT findings. Additional letters and meetings will be forthcoming as the TRT completes its review.
Hearings Comenche Peak has been in a heavily contested hearing for three years. All but one contention have been dismissed. The remaining contention questions the ability of the Applicants' Quality Assurance / Quality Control Program to
['N prevent deficiencies in the design ano construction of the plant. The Licensing
(') Board has admitted many allegations of design and construction deficiencies into the hearing as relevant to this contention. The allegations may be categorized into three general areas: (1) design adequacy and design quality assurance; (1.) construction adequacy (i.e., the technical / safety significance of the specific allegation); and (3) construction quality assurance.
The major issues remaining to be resolved are:
(1) Pipe support design and design QA concerns ("Walsh/Doyle Concerns")
(2) Applicants' Plan to resolve issue (1), above (3) Adequacy of A500 steel with reduced material properties (4) Cygna Independent Assessment Program (5) Welding (6) Protective coatings adequacy (7) NRC staff inspections of rooms turned over to plant operations staff (8) Transamerica DeLaval diesel generators (9) Various document control deficiencies (10) Intimidation of QC inspectors and craf tspersons a
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- f'T LICENSING OF COMANCHE PEAK 1 O The vast majority of allegations in the design adequacy / design QA category were raised by intervenor's witnesses Mark Walsh and Jaci. Doyle, and concern the design of pipe supports. The ASLB suggested (by its Decereber 1983 Memorandum and Order) that an independent design review be conducted. Applicants have responded by proposing a plan ("Applicants' Plan") to address the ASLB's concerns with pipe support design and design QA. This bifurcated effort consists of a partially "in-house" ef fort coordinated by Ebasco Services, Inc. ,
and a limited independent effort by Cygna Energy Services. The AS*.B the staff, and the intervenor, CASE, provided their comments to the Applicants on their Plan. Applicants submitted a "Supplemental Plan" responding primarily to the Board's comments. The staff and the intervenors submitted their comments on this supplement.
During the hearing session on April 27, 1984, the ASLB accepted the applicant's plan as supplemented. During June 1984, the applicants submitted numerous motions for Summary Disposition on the concerns investigated by the "in-house" effort coordinated by Ebasco Services, Inc. The staff is currently preparing responses to each of these motions. One of the motions for summary disposition related to the adequacy of the upper lateral restraint for the steam generators.
The applicant's consultant met with the staff on November 13, 1984, and stated that the modified NASTRAN computer code used in the analysis of the upper p I lateral restraint has some limitations, but these limitations do not affect t the adecuacy of the restraint for the Comarche Feak plant. A submittal placing the results of the applicant's analysis in perspective will be provided in the near future.
Closely related to the design adequacy / design QA issues is the Independent Assessment Program (IAP) conducted by Cygna Energy Services. A draft IAF report (the "Cyg.ia Report") was issued in November 1983. Testimony by Cygna and the intervenor witnesses was completed in hearings in late April-early May 1984. The staff is preparing an SSER and affidavits addressing the prior testimony by Cygna and the intervenor witnesses in anticipation of completing the hearing record relative to the IAP. Cygna has recently submitted its "Phase 3" independent assessment of Comanche Peak and Cygna's "Phase 4" review is in progress. The staff has contracted with EG&G Idaho to review the Cygna Phase 3 ,
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l The staff has scheduled completion of all actions related to the ASLB hearing by mid-January 1985. ;
On August 7, 1984, the Applicant filed a Mot _ ion For Authorization to Issue a License to load. Fuel and Conduct Certain Precritical Testing. The Motion l requested the ASLB authorize the Director of NRR, upon making findings on all applicable matters specified in 10 CFRS50.57(a), to issue to Applicants a license to load fuel and conduct certain precritical testing activities for <
Comanche Peak Unit 1. Following the filing of responses by the remaining '
parties, the Board issued an Order (August 24, 1984) finding that because of the broad QA/QC contention, the Board needed to make 10 CFR $50.57a findings i s
w) with respect to four identified plant systems. The Board requested that !
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e (O LICENSING STATUS OF COMANCHE PEAK 1 U applicants submit additional information to several questions posed by the Board. On September 13, 1984, the applicants submitted additional information regarding the Goard's Order. On November 2, 1984, the staff responded to the applicants' supplemental information, indicating that it would be more expedi-tious to complete the ongoing evidentiary presentation of design and QA issues, and make any necessary full power a_nd low power findings on the basis of such evidence, rather than undertake another separate and parallel evidentiary con-sideration of the same design and QA issues limited to fuel loading and precriti-cality testing.
A special, separate hearing board has been constituted to address intimidation /
harassment issues for which the initial decision is expected in December 1984.
On July 9, 1984, the intervenor CASE, supported by legal assistance from the Government Accountability Project (GAP) and Anthony Z. Roisman, started taking depositions from members of the staff, employees of the applicants, and present and former construction workers relating to intimidation of quality assurance / quality control personnel at Comanche Peak. Personnel from the Office of the Executive Legal Director have represented the staff in this effort. Over 70 depositions have been taken on this matter.
The staff has retained the services of a multi-disciplinary team coordinated A by EG&G Idaho, Inc. to review the evidence on intimidation. A report (September 1984) has been issued, in which the EG&G team concluded there was no pervasive climate of intimidation at CPSES.
Hearings on intimidation have been held on September 15-26, October 1-3, November 19-21 and November 26-28, 1984. Additional hearings are necessary to present the staff testimony on this matter, including the results of the EG&G Report.
NRC Inspections
- 1. Normal Inspection Items There are a number of normal inspection items that remain to be completed (percent completion for each item is included)
Electrical and instrumentation installation (100%)
As-built verification (100*4)
Preoparational test procwores review (100%)
Preoperational test witnessing (100%)
Preoperational test results review (85%)
Preoperational test program implementation (100*.)
Operational staf fing inspection (90%)
Plant procedures (100%)
Operating procedures (50*4)
Emergency procedures (100%)
Operational QA program (100%)
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Fire protection (85%)
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Physical security (100%)
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. ,. l A LICENSING STATUS OF CO M NCHE PEAK 1 l l
Additional contractor and staff resources have been obtained in order to complete the inspection ef fort prior to the scheduled fuel load date.
- 2. Retesting The applicant re-ran approximately 25 preoperational tests to confirm system readiness subsequent to various modifications and design changes.
Many of these tests were witnessed by the NRC and test results are being evaluated as appropriate. Systems involved include safeguards systems, reactor protective system, service water, component cooling water, and the diesel generator. The applicant has requested, and the staf f has accepted, deferral of certain preoperational tests which the applicant planned to perform after fuel load but prior to criticality. However, due to available time, the applicant is presently performing these deferred tests.
- 3. Open Inspection Items Construction and preoperational testing inspection program line items include verification of SER commitments, followup on construction assessment team findings, resolution of unresolved items, resolution of items of noncompliance, followup on reports made pursuant to 10 CFR 50.55(e) and 10 CFR 21, inspection procedure completion, and inspector followup items.
In addition, there are issues arising from the Licensing Board hearing which mau require resolution through special inspections. At present, (AV) the backlog of inspection line items has been eliminated, and the program is now essentially current.
One outstanding open area remains in the construction inspection program involving the inspection by the staff of rooms, areas and systems, primarily related to piping and pipe supports, that have been final inspected by the Applicants and have been turned over by the construction forces to operations. Completion of this effort is a commitment by the staff to the Licensing Board and will be completed prior to the finding of readiness for fuel load. Turnover inspections have been completed for the fuel handling building, cable spread room, and the containment building. The final turnover inspections of the safeguards and auxiliary buildinns began July 16, 1984, and ended September 28, 1984, and the report is in preparation.
A fire protection team inspection was performed during the week of October 29, 1984, and the report is in preparation.
- 4. Radiation Protection and Radwaste There are open items in six categories that must be closed prior to fuel load. These are: post-accident sampling system capability, surveillance program for radwaste systems, radiation worker training program examinations and certifications, and the review of ventilation system as a possible post-accident radiation source. At the present time, these items are O
t well along in resolution and should be closed prior to the anticipated fuel load date: review of ventilation system as a possible post-accident
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(~'% LICENSING STATUS OF COMANCHE PEAK 1 'wY radiation source, high energy noble gas monitoring of gaseous effluents, sampling and analysis of high range particulates and iodine plant effluents, high range containment radiation monitor calibrations,. quality assurance surveillance of radwaste activities and testing of plant ventilation charcoal adsorbents. At the present time, these items are well long in resolution and should be closed prior to the anticipated fuel load date.
The apparent increase in the number of open items from the last report is a result of the transfer of open items from the emergency preparedness program.
- 5. Emergency Preparedness An emergency preparedness appraisal and followup appraisals were con-ducted in September-October 1983 and April 1984, respectively. Twenty-eight significant deficiencies (Appendix A items) were identified in the areas of administration and organization (staff augmentation times),-
emergency facilities and equipment (completion of equipment installation) and training (staff training on new equipment installation and dose assessment). A second followup appraisal was conducted on August 6, 1984 and the applicant conducted a successful shif t augmentation drill on September 20, 1984. Currently, nine items remain to be closed before fuel load. The applicant has indicated that all significant deficiencies, f including the incomplete dose assessment, will be corrected by fuel load.
(qv) A full participation exercise was conducted December 14, 1983, and the FEMA evaluation report was issued on July 16, 1984. A second full participation exercise was conducted on November 14, 1984, but neither the NRC nor the FEMA reports have been issued. An emergency preparedness inspection was conducted during the week of November 13, 1984, to review open items and to inspect the applicant's implementation of the Emergency Plan during the November 14, 1984 exercise.
- 6. Physical Security All open items have been resolved and the physical security inspection has been completed.
Allegations There are currently 528 allegations on Comanche Peak being pursued by the staff. These allegations can be generally categorized into the following areas:
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/~3 LICENSING STATUS OF COMANCHE PEAK 1 O Area No. of Allegations Electrical 49 Civil / Structural 45 Mechanical / Piping 137 f QA/QC Deficiencies 132 Coatings 62 Test Programs 18 Intimidation / Harassment 31 Vendor / Generic 18 Independent Assessment Program 7 Miscellaneous J9 Total 528 The onsite review of these allegations has been in progress since July 9,1984 i and was completed in October. The staff is evaluating these issues which I
will be documented in an SSER.
The intimidation of QC coating inspectors has resulted in escalated enforce-ment action for which two proposed civil penalties were issued. The appli-I cant's responses to the proposed civil penalties are currently under review.
The applicant's response to the Williams case is being reviewed. NRC action on the Atchinson case is being. delayed pending a review by the Court of Appeals on the Department of Labor decision. The Dunham case was reviewed /
for potential enforcement action.
Enforcement action has been deferred until completion of the Department of Labor adjudication. The Department of Labor has ongoing proceedings for other former Comanche Peak employees. The outcome of these proceedings may require subsequent action by the NRC.
01 Investigation The Office of Investigations (01) has completed investigations regarding the '
Comanche Peak facility in the areas of welding, QC, electrical, inspections, intimidation, and procedures, construction practices. management, NCR's, coatings, pipe hangers, firings, The Licensing Board issued an order (September 17,1984) directing 01 to release the reports on these allegations to the Board and parties under protective order. 01 filed a response to the Board on October 25, 1984, in which 01 suggested that the staff is in a better position to evaluate the significance and relevance of tne unreleased 0! reports. The Licensing Board adopted 01's suggestion in a November 2,1984 order which directed the staff to submit a schedule for advising the Licensing Board of the relevance of the 19 unreleased 01 reports.
The Office of Investigations, is actively pursuing investigations in other O areas such as QC, welding, records and document control. Results of these investigations may reveal additional technical issues requiring evaluation.
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PACF 3 PLANT - COMANCHE PEAK, UNii 1 ,
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FSAR Responsible SSE9 Schedule **
Confi rma to ry. Issues Organization Ca teoo ry inpui Issuo Comments
- 1. Starr review of WECAN computer MEB/DE 1 12/84 12/84 Undergoing starr review p rog ram incomplete
- 2. Dynamic ana lysi s for asymmetric MEB/DE 1 12/84 12/84 Undergoing starr review loads on the reactor coolant system
- 3. TMl Action Plan items (SER Section 22)
(a) II.E.4.2 Containment isola- LQB/DE 1 12/64 12/84 Unde rgo i ng starr review, lation dependability Will require additional (purge va lve info rma tion f rom appl icant operabi l i ty ana lysi s for LOCA-related dynamic loads)
(b) II.E.1.1 Recommendation CL-3 ASB/DS1 1 12/84 12/84 Cnnri rma tn ry aud i t by Region IV veri fication by test starr required to resolve of the capaoility of the turbine-d riven auxi l ia ry reedwa ter ( AFW) pump to operate for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> without AC power (c) ll.D.1 Performance testing RSB/DSI 1 12/84 12/84 Undergoing starr review or HWR and PWR relier and safety valves 4
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Technical Spec I r i ca t i_on_s l O rga n i za t ion Categg_g Irlp_uj Issue Commenn 1 Heatup and cooldown curves MTEB/DE 1 12/84 12/84 Awaiting inrormation from l applicant
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DATE* /;,/ 4//e/ ACTION CONTROL FORM - REGION IV NO. f/-1Jo
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g ACTION PKG, 5520 Entry and File Copy
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SUBJECT:
42 # arm W74ma RM M 4htw l1 fl U N .
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REVIEWED SY: -1M . (copy to R. Martin as applicable) 0' ,
ASSIGNED RESPONSIBILITY FOR COORDINATION AND/OR PREPARATION OF REPLY.
MANHOURS (ESTIMATED IN 1/2-HOUR M boM i ASSIGNEE:
INCREMENTS)
COPY TO:
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DIVISI0ft/BPjdiCH COPY DISTRIBUTION: MANHOURS (ESTI!iATED IN 1/2-HOUR ItiCREMENTS)
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Secretarial REQUESTED DUE DATE: /P 3 ///
ACnlAL DUE DATE: _
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CORRECTED DUE DATE: _
DATE ACTION COMPLETED:
m TOTAL %4HC'OS 1
REMARKS:
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ENCLOSURE
(
- f. larch 5, 1987 l
Note to: Christopher Grimes, Director Comanche Peak Projects Staff Office of Special Projects From: Lawrence J. Chandler Special Litigation Counsel Ofnce of General Counsel
SUBJECT:
LICENSING BOARD INQUIRY ON DRAFT STAFF REPORTS ABOt1T COMANCHE PEAK QA/QC On March 2,1987, we received a telephone call from Peter Bloch, Chairman of the Licensing Board for Comanche Peak. He indicated that after reviewing the Staff's February 17, 1987 response to CA SE's Motion to Compel, the Licensing Board wishes to know whether the Staff or OIA are aware of other undisclosed draft trend reports or draft reports written by the Staff regarding the adequacy of the QA/QC program at Comanche Peak, i
We interpret this inquiry as asking whether the Staff is aware of any draft reports, evaluations or asseasments (including, but not limited to "trend reports") regarding the adequacy of the QA/QC program (or a portion of the program) at Comanche Peak, which have not been issued by the Staff for one reason or another.
In addition to Staff members in IE, NRR and Region IV who are currently or wers forcierly assigned some responsibility with regard to Comanche Peak '
such that they might have knowledge of such material, OIA should be contacted to determine whether, in the course of its recent efforts at Region IV, it identified any documents that might be responsive to the Board's inquiry (other than the "trend report" already discussed in OIA Report 86-10). I l
The OGC attorney who is coordinating .the Staff's response is Geary. 8. l Mizuno. Ile may be reached at x28505. Please let Mr. Mizuno know, by March 9,1987, approximately how long this effort might take.
I Lawrence J. Chandler '
Special Litigation Counsel cc: James G. Keppler c}1 4
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