ML20151C825

Interim & Final Deficiency Repts CP-85-36 Re Train C Conduit Supports.Initially Reported on 871105.Design Validation Process Completed for Unit 1.Unit 2 Corrective Actions Will Be Submitted Upon Completion of Unit 1

ML20151C825
Person / Time
Site:	Comanche Peak
Issue date:	04/08/1988
From:	Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
CP-85-36, TXX-88305, NUDOCS 8804130207
Download: ML20151C825 (2)

Text

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Lo # TXX-88305 Fi e # 10110 C C 903.9 7t# ELECTRIC Ref. # 10CFR50.55(e)

, April 8, 1988 I- mm.. c. co a Enecoun Vue heuJent U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washingt.>n, D.C. 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 TRAIN "C" CONDUli SUPPORTS SDAR: CP-85-36 (FINAL REPORT-UNIT 1)

(INTERIM REPORT-UNIT 2)

, Gentlemen:

On November 5, 1987, we notified you by our letter, logged Txx-6928, of a deficiency involving Train "C" conduit supports which we deemed reportable under the provisions of 10CFR50.55(e). This report provides cause and im)lication discussion and the preventive and corrective action completion j scledule for this issue.

The cause of this deficiency was the failure by the responsible design organization to adequately incorporate the necessary engineering criteria and regulatory commitments (Reg. C-uide 1.29) into design documents and associated construction procedures required to implement the design of the Train "C" conduit supports. This deficiency is limited to Train "C" conduit (including conduit junction boxes (SDAR: CP-85-29)) less than or equal to 2" in diameter, Currently, we are implementing the Train "C" Corrective Action Program (CAP) for the Unit 1 and Common Areas. The design validation process has been completed with the following results:

1. All validation procedures are in place for the resolution of all related CPRT issues (Issue Specific Action Plan 1.c). These reviewed and finalized with third party concurrence (procedures have been except for minor editorial and efficiency enhancement revisions which are ongoing as the program continues).

2. All DIRs (51) which resulted from the third party's review of Impell's Train "C" Validation Procedures have been re:olved.

3. All complex (unique) supports have been evaluated and modifications identified and validated.

O 8804130207 880409 PDR S ADOCK 0500o445 \O DCD 400 hrth Ouw Street i B Si ikilss. Tew 73MI

TXX-88305 April 8, 198B Page 2 of 2 To date, approximately 104,000 conduit supports have been evaluated in Unit 1 and Common Area. This represents approximately 96's of all Train "C" conduit supports less than or equal 2" in diameter. This effort has resulted in 2

approximately 670 modifications. The Post Construction Hardware Validation Program (PCHVP) for these conduit supports has been implemented concurrently with the design validation process. The remaining 4,000 supports are currently being field verified under the PCHVP Program.

To prevent recurrence of this deficiency, Design Basis Document (DBD)

DBD-CS-093, "Seismic Adequacy of Train 'C' Conduits (Two Inch Diameter and Less)," has been issued to provide the design basis and descriptive technical information for the seismic acceptability evaluation of the Train "C" (two inch diameter and less) conduit. The criteria in 080-C5-093 are being used to prepare detailed project procedures for implementation of the evaluation program.

Project Instruction PI-0210-053-013 "Train 'C' Conduit Maintenance Program,"

has been established to provide a review of all new construction activities which would affect previously validated areas. Construction procedure ECP-198 has been developed to provide guidance for the future installation of Train "C" conduit supports.

Corrective actions for Unit 2 are currently being formulated and will be submitted upon completion of the Unit 1 and Common Area activities.

Corrective actions for Unit 1 and Common Area are currently scheduled for completion commensurate with the schedule for the PCHVP.

This is our final report for Unit I and Common Area activities related to Train "C" conduit supports.

Our next report for Unit 2 activities will be submitted no later than August 31, 1989.

1 Very truly yours,

, $4AM W. G. Counsil DAR/grr c41r. R. D. Martin, Region IV Resident inspectors, CPSES (3) l l

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