ML20151P006
| ML20151P006 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/21/1988 |
| From: | Edgar G NEWMAN & HOLTZINGER, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Bloch P, Jordan W, Mccollom K Atomic Safety and Licensing Board Panel |
| References | |
| CON-#288-6115 OL, NUDOCS 8804260065 | |
| Download: ML20151P006 (12) | |
Text
.
NEWMAN Sc }lOLTZINOEn, P.C.
..Ca.
E..a~
.... c.1. c c 1. ~.
u+c W_ t.at. s
. t oss, ~ a...
~ a. s.E E,...
A E ta w Ma D'# S WA&MINGTON O C 20036 s a.x.
4-4..
88 APR 21 P3 Lfts9 ' " '
.f t....,.
- r.n'La.
=a==>***
A, s
Cav O W sita.ng sat =6 tt % a Sata DovGgalG GDtE%
(pa$G Jonhlo%.
h l' (
,4,, dea 4ht C ST hQ$
[
RaSQg(TNhthMa%
4 00CX f i,m '4,h," [,
- r. f'natust t 4 wct' r awot, so-~ t s t oa "~
- wcD sawt3 3 was gt d A fil Loatm 3 wggTgre u C =at 6 a s,a. s t a aw a Gut tawa=
serrate e ustmast.
E DeanO s Twowt
- ER*06 m patTEagom samt53. kCoa.R sahtt avam v i.o-. i a L E N sA0.ek. van a s'wuoNS u t v4 P Ga. :-~,,
ao t 1 seto-o, u C.u a t s f Cnas.t.3 C..t at.Da 0. s4 M E a k.
s
.e g. v.. -, t
=a C.
.3E s:or,a -a.-a.
a[0 g aata.%
RCDt#T N=Strim Apri1 21, 1988 (EE EC *
~a=o. ia
- * ~ '
., ~ ~
w.<os.<,E..a~
scii;,< i:
~,-...!
Peter B.
Bloch, Esq.
Dr. Kenneth A. McCollom Chairman Administrative Judge Atomic Safety and Licensing 1107 West Knapp Board Stillwater, OK 74075 U.S. Nuclear Regulatory Commission Elizabeth B. Johnson Washington, D.C.
20555 Oak Ridge National Laboratory P.O.
Box X, Building 3500 Dr. Walter H. Jordan Oak Ridge, TN 37830 881 West Outer Drive Oak Ridge, TN 37830 Re:
Texas Utilities Electric Company, et el.
Docket Nos. 40-455-OL and 50-446-OL
Dear Administrative Judges:
As described in TU Electric's March 29, 1988 letter to the Board, TU Electric has been responding to certain questions from the NRC Staff arising from the December 9, 1987 public meeting.
In the March 29, 1988 letter, we committed to provide the Board with any further responser to Staff questions that arose from the meeting.
In accordarce with that commitment, the attached letter is enclosed for your information.
Respectfully submitted, N
George L. Edgar
/ rad Enclosure cc:
Service List 0804260065 800421 ADOCK 0500 5
gDR
4
~~'
Ourt RECSVED surus EE Lo$ee10068 e Txx.88373 AFR.1SB.3
=.
.=
ri C
C 10010 c1o
_ N D'. '.' A N & H TllNG[7"F,P April 14, 1988
?$0..<NY,Y U. S. Nuclear Regulatory Comission Attn: Document Control Desk Washington, D. C.
20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 RESPONSES TO NRC STAFF REQUESTS
REFERENCES:
(1) Letter from W. G. Counsil to the NRC, logged Txx 88135, dated February 1, 1988 (2) Letter from W. G. Counsil to the NRC, logged Txx-88254, dated March 16, 1988 Gentlemen:
During the public meeting between the NRC staff and TU E1petric on December 9, 1987, and in the letter from S. Ebneter of the NRC staff to W. G. Counsil of TV Electric dated January 22, 1988, the NRC staff requested additional information relating to the CPRT or CAP programs.
As of my letter to the NRC dated February 1, 1988 (Reference 1), we have responded to all but two of the NRC items. My letter to the NRC dated March 16, 1988 (Reference 2) provided a response to the ites relating to the nature (root causes) of the deficiencies and weaknesses that occurred in the design process in the past.
Enclosed as Attachment A "Program for CPSES Unit 2" is TV Electric's response to the NRC staff's last item, a request for an explanation of the applicability of the CAP to the CPSES Unit 2.
We received an extension in submitting this response from the Office of Special Projects.
The NRC staff has also requested an explanation of the significance of the I
deviations from design requirements identified, but not deemed insignificant, by the CPRT in the performance of ISAP VII.c.
As stated in the Collective Significance Report (CSR), these deviations encompass approximately one fourth of the deviations identified, or approximately one half percent of all ISAP Vll.c inspection and documentation review points.
The requested explanation is enclosed as Attachment B, "Conservatism in CPRT's Evaluation of Deviations."
m was on.< surers is si peum Tem ?nci
t i
o Txx.88373 April 14, 1988 Page 2 of 2 Please let us know if we can provide any additional information that would be useful to the NRC staff in its continuing review of the CPSES.
i Very truly yours,
[
dN W. G. Counsil JDS/grr c - Mr. R. D. Martin, Region !Y Residentinspectors,CPSES(3) i f
D t
i l
l l
1 4
1 q
ll l
I i
l l
i 9
l i
1 n
t
-_._.-_-,_._._..__._________.______.J
Attachment A to Txx.88373 April 14, 1988 Page 1 of 3
)
PROGRAM FOR CPSES UNIT 2 At the meeting on December 9, 1987, between representatives of TV Electric and NRC Staff, the NRC Staff requested an explanation of the applicability of the Corrective Action Program (CAP) to CPSES Unit 2, including an explanation concerning corrective actions that are applied directly to Unit 2 and corrective actions that are incorporated as part of the formal constructicn management process given the current construction status of Unit 2.
TV Electric announced on March 18, 1988, that construction of Unit 2 is being temporarily suspended for about one year beginning in April 1988. Although TV Electric has not finalized the details of ita program for the review of the existing design and hardware of Unit 2 and for the completion of the design and construction of Unit 2, the basic features of the program, including the application of corrective actions from the CAP, are described as follows.
The CPRT program included investigation and analysis of the hardware of both Unit I and Unit 2.
Thus the findings of the CPRT and the resolution of these findings, as well as the resulting corrective and preventive actions taken or comitted to by TV Electric under the CAP, will be addressed on CPSES Unit 2.
To the extent that corrective actions tiave been or are being taken with respect to hardaare of Unit 1, equivalent actions with respect to the corresponding hardware of Unit 2 will take into account the lessons learned in the Unit 1 program.
To the extent that corrective or preventive actions relating to hardware for Unit I are of a programatic nature, such as changes in installation specifications, construction procedures or 0C inspection procedures, such enhancements of TV Electric's programs have been and will be applied to the completion of the construction of Unit 2.
Although the design validation performed under the CAP focused on the design-of Unit I and Common, portions of the design of Unit 2 have also been revieaed in varying degrees dependent upon the disciplines involved.
Fcr example, substantial effort related to the design of Unit 2 has been expended in the specific reviens that were undertaken first, such as pipe stress and pipe supports, cable trays and conduits, including both the reviews by CPRT under the relevant 05APs and reviews performed by the CAP engineering contractors.
Moreover, since the designs of Unit I and Unit 2 are largely similar, as discussed below, much of the design af Unit 2 will be facilitated by the availability of the technical methodologies, procedures and experience gained in the implementation of the CAP for Unit 1 and Common.
The Design Basis Documents (DB0s) that were developed under CAP are applicable to corresponding systems, structures and components of Unit 2.
Procedure ECE-0C-17 (Rev. 4), which governs the preparation and review of DB0s, outlines a typical table of contents (Exhibit C) for a 0B0.
Under that outline, Section 8 of the typical 0B0 identifies any Unit 1/ Unit 2 differences.
- Thus, current 030s will be reviewed and revised to identify the differences, if any, that may exist between Unit I and Unit 2 relating to each 0B0. Upon completion of such review and revision, each 0B0 will be suitable for the review and completion of the design of Unit 2.
In reviewing and completing the design documentation for Unit 2 (i.e.,
calculations, specifications and drawings), full use will be made of the effort completed for Unit 1.
For example, many calculations and specifications validated or developed for Unit I are likely to be equally valid for Unit 2.
Accordingly, reviews will be conducted to detennine the
Attachment A to TXX-88373 April 14, 1988 Page 2 of 3 1'
l aspects of Unit 2 that are distinguishable from Unit 1, and in the absence of l
such unique features, the Unit 1 calculation or specification will be used for l
Unit 2.
Nevertheless, in some instances, such as ASME stress reconciliation, I
specific calcul'ations will be required and produced for Unit 2.
Since Unit I and Unit 2 are not duplicate plants, the drawings for Unit 2 will have to be reviewed against the DBDs, except for those components determined to be identical to components in Unit 1, including many procured items.
Throughout i
the process, all lessons learned in the design validation of Unit I will be fully applied. For example, design modifications identified for Unit 1 have been or will be reviewed for their applicability to Unit 2.
Where applicable, the corresponding design change and hardware modification will be implemented for Unit 2.
The results of the design review and conipletion efforts for Unit 2 will be reflected in the final design documents, which will be prepared in accordance with existing TV Electric design control procedures.
Accordingly, there is no need for or plan to produce DVPs or PSRs for Unit 2.
The review and completion of the Unit 2 design will be performed using the same relevant technical methods, technical procedures and TV Electric design Y
control procedures used for Unit I and Common.
Thus, the review and completion of the design of Unit 2 will be performed in accordance with clearly specified and current design criteria, methodologies, procedures and 0A audits and reviews.
TV Electric will also review the existing hardware of Unit 2.
However, the details of the review for Unit 2 will vary from the Unit 1 program based upon the current status of construction and QC acceptance of hardware and upon the applicability of lessons learned from the implementation of pCHVP for Unit 1.
It is likely that fewer additional inspections will have to be perfomed for Unit 2 than for Unit 1 because of its less advanced completion status and because of lessons le. ned from Unit 1.
For example, in some instances, as modifications have been or are being made in the design of Unit I under the CAP, corresponding changes have been or will be made in the design of Unit 2, the related construction work is then completed in accordance with the modified design and QC inspections are performed under current practices and procedures.
Under such circumstances, no additional inspection would be required.
Similarly, in instances where design validation of Unit 2 does not result in any modifications and OC inspections of construction have been or will be performed under current practices and procedures, there would be no need for additional inspections, in addition, where the implementation of the PCHVP for specific attributes of Unit I systt's, structures or components demonstrates that the installed hardware complies with the design or that it is unnecessary to conduct 100'4 inspection or walkdowns and that validations can be completed through engineering evaluations, engineering evaluations could also be used for Ltnit 2, in the absence of any features distinguishing the two units.
Attachm:nt A to TXX-88373 April 14, 1988 Page 3 of 3 Enhancements already embodied in TV Electric's Engineering and QA Departments will provide additional assurance that the review and completion of the design and construction of Unit 2 will fully comply with licensing comitments and QA requirements. for example, the Engineering Assurance (EA) Section of CPE, established in March 1986, maintains design control procedures and provides the necessary training in their use, and conducts technical evaluations and surveillance of engineering activities to assure technical adequacy and compliance with design control procedures and licensing cognitments.
The QA Department created a Technical Audit Group in January 1987 with the responsibility for conducting in-depth technical audits to assess the quality of the CAP design validation program and PCHVP activities, as well as CAP actions in response to CPRT findings and recomendations. Although this separate group within the QA Department will be dissolved as the CAP is completed, its functions will be assumed by the permanent audit and surveillance sections within the QA Department with expanded capabilities, including transferred personnel from the Technical Audit Group or acquired personnel with the requisite education, experience and training.
In addition, TV Electric will conduct a preoperational test program for Unit 2 in accordance with the requirements of FSAR Section 14.2 and the appropriate provisions of Reg. Guide 1.68, Revision 2 (FSAR Appendix 1A(B)).
Since these TV Electric programs will be fully ef fective to assure regulatory compliance-during the review and completion of the design and construction of Unit 2, there is no need for or plan to use the additional layers of external overview or confirmatory programs that were applied to Unit 1 (i.e., CPRT, TAP, Cygna and EFE).
Attachment B to TXX-88373 April 14, 1988 i
Page 1 of 3 CONSERVATISM IN CPRT'S EVALVATION OF DEVIATIONS The Collective Significance Report (CSR) and the Collective Evaluation Report (CER) sumarize.d the results of the self-initiated evaluation of the quality of construction of CPSES, Units 1 and 2, performed by the Comanche Peak Response Team (CPRT).
The results of this evaluation are reported in the Results Report for ISAP Vll.c and demonstrate a high degree of conformance with design requirements. Only two percent of the inspection and documentation review points were found to deviate f rom design or documentation requirements, while 98 percent were in conformance.
Further, of the two percent found to deviate in some manner, the CPRT determined that more than three-fourths of these were insignificant.
The NRC Staff has requested an explanation of the significance of the remaining approximately one-half percent of the total ISAP VII.c inspection and documentation review points for which identified deviations were not deemed insignificant by the CPRT.
This is addressed herein.
The CPRT evaluated each of the jeviations between as-built hardware and applicable design requirements to assess its potential safety significance, and placed each deviation into one of the following classifications:
Insignificant - a deviation that had a negligible effect on the ability of an item to perform its intended safety function, or a deviation involving an incomplete document for which supplemental information provided evidence that the hardware was of acceptable quality.
Hotable - a deviation that had a nonnegligible effect on the ability of an item to perform its intended safety function or had a nonnegligible effect on the ability of the reviewed documentation to provide evidence of hardware qualitj.
Construction Deficiency - a deviation that, if left uncorrected, could have resulted in the loss of capability of an item to perform its intended safety function.
Unclassified Deviation - a deviation that was not evaluated for safety significance, because it was judged to be more expeditious to proceed directly to a root cc e and a generic implications analysis and to specification of cc.rective actions.
Of the four classifications, only construction deficiencies were identified by the CPRT as being safety significant.
Insignificant and notable deviations were deemed to be not safety significant.
As stated, unclas',ified deviations were not evaluated for safety significance.
to TXX-88373 April 14, 1988 Page 2 of 3 The CPRT's definition of a construction deficiency, as applied in the evaluation of the safety significance of deviations. was conservative.
For example, the approach taken to implement the definition would have resulted in the identification of construction deficiencies for items that did not satisfy Code-allowable limits but that would not have f ailed under design loading conditions, it would also have included deviations that would have resulted in failure of an item (such as a particular attachment clip), but not in failure of a structure, system or component.
Similarly, a deviation on a pipe support could have been classified as a construction deficiency even though adjacent pipe supports would prevent the associated piping system from becoming overstressed under design loading conditions.
Thus, the existence of a construction deficiency, identified through such a conservative evaluation, is not sufficient to imply that the safety of the plant would have been adversely affected if the deficiency had been left uncorrected.
In 15AP Vll.c, the CPRT perfonned inspections and documentation reviews of random samples of as-built safety-related items in CPSES Units 1 and 2 that encompassed more than 535,000 inspection points and more than 95,000 documentation review points. As stated above, of these the vast majority, approximately 99.5%, were either in conformance with design requirements (approximately 98%) or constituted insignificant deviations (approximately m 1.5%).
The remaining 0.5% included notable deviations, unclassified deviations and construction deficiencies.
The notable deviations were evaluated by the CPRT to be not safety significant.
The deviations that were classified as construction deficiencies or unclassified deviations constitute approximately 0.25% of all inspection and documentation review points, while the construction deficiencies themselves constitute approximately 0.06%.
A s.-
this demonstrates, a very small fraction of the ISAP Vll.c inspection and review points (0.06 to 0.25 percent) were found to have deviations with potential safety significance.
This is a relatively small percentage given the breadth of the sample and the conservative threshold established by the CPRT to declare a deviation to be safety significant.
In order to further illustrate the conservatism in the CPRT classification of deviations, the TV Electric Project performed separate evaluations of all CPRT identified hardware related construction deficiencies and unclassified deviations (including but not limited to those from ISAP Vll.c) to determine whether the found conditions, had they been left uncorrected, could have precluded achieving or maintaining a safe plant condition.
The Project evaluations detennined whether components would actually fail, not just exceed design allowables, and recognized that component failure would not be safety significant if analysis demonstrated no adverse impact on either a system function or redundancy required to reach a safe shutdown condition.
The Project determined that the found conditions underlying more than three-fourths (50) of the associated CPRT findings, each consisting of one or more deviations, would not have prevented achieving or maintateing a safe plant condition.
The remaining 7 findings could not be definitively categorized without extensive, unwarranted expenditure of resources for further detailed analyses or tests, or because insufficient data were available to further characterize deviations that had already been corrected.
These indeterminate evaluations did not need to be completed because those already completed had demonstrated that th? CPRT designation of "safety-significant" is conservative and does not necessarily constitute a determination of an unsafe plant condition.
Attachment B to TXX-88373 April 14, 1988 Page 3 of 3 It is important to emphasize that corrective and preventive action has been taken for each of the CPRT findings, whether or not the Project determineo that the underlying conditions, if left uncorrected, could have precluded achieving or maintaining a safe plant condit:on.
The results of the separate Project evaluations of the safety significance of the CPRT findings did not affect the determination of corrective and preventive actions. As described in the Results Report for 15AP Vll.c, all deviations identified by the CPRT were processed as nonconformances in accordance with site procedures, in addition, for those deviations detennined to be construction deficiencies, evaluations were conducted to detennine the root causes and generic implications.
Based on these reviews and analyses the CPRT recommended corrective and preventive actions.
The CPRT evaluated the insignificant and I
notable deviations for any indication that additional construction deficiencies might exist.
This lea to the classification of deviations as adverse or unclassified trends for which root cause and generic implications analyses were also performed with corrective actions being recomended as appropriate. Finally, unclassified deviations were treated like construction deficiencies or trends, as if they were known to be safety-significant.
- Thus, in no case was an identified deviation allowed to remain without disposition by TV Ele..ic and, in all cases with potential safety significance, additional corrective action was recommended.
These corrective actions are" typically being implemented in the Post Construction Hardware Validation Program (PCHVP) as part of the Corrective Action Program (CAP).
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
)
Docket Nos. 50-445-OL
)
50-446-OL TEXAS UTILITIES ELECTRIC
)
COMPANY et al.
)
)
(Application for an (Comanche Peak Steam Electric
)
Operating License)
Station, Units 1 and 2)
)
)
CERTIFICATE OF SERVICE I,
Thomas A.
Schmutz, hereby certify that the fore-going letter was served this 21st day of April 1988, by mailing copies thereof (unless otherwise indicated), first class mail, postage prepaid to:
- Peter B. Bloch, Esquire
- B.
Paul Cotter, Jr., Esq.
Chairman-Chairman Atomic Safety and Licensing Atomic Safety and Licensing Board Board Panel U.S.
Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555
- Alan S. Rosenthal, Esq.
Assistant Director for Chairman Inspection Programs Atomic Safety and Licensing Comanche Peak Project Division Appeal Panel U.S. Nuclear Regulatory U.S.
Nuclear Regulatory Commission Commission P.O. Box 1029 Washington, D.C.
20555 Granbury, TX 76048
- /
Asterisk indicates service by hand or overnight courier, i
W -4
- Juanita Ellis Robert D. Martin President, CASE.
Regional Administrator, 1426 South Polk Street Region IV Dallas, TX 75224 U.S. Nuclear Regulatory Commission William R.
Burchette, Esquire 611 Ryan Plaza Drive Heron, Burchette, Ruckert, Suite 1000
& Rothwell Arlington, Texas 76011 Suite 700 1025 Thomas Jefferson St.,
N.W.
Dr. Kenneth A. McCollom Washington, D.C.
20007 Administrative Judge 1107 West Knapp
- William L.
Clements Stillwater, Oklahoma 74075 Docketing & Service Branch U.S.
Nuclear Regulatory Joseph Gallo, Esquire Commission Hopkins & Sutter ashington, D.C.
20555 Suite 1250 1050 Connecticut Avenue, N.W.
- Billie Pirner Garde Washington, D.C.
20036 Government Accountability Project
- Janice E. Moore, Esquire Midwest office office of the General Counsel 104 E.
Wisconsin Avenue - B U.S. Nuclear Regulatory Appleton, W1 54911-4897 Commission Washington, D.C.
20555 Susan M.
Theisen, Esquire Assistant Attorney General
Environmental Protection Division Suite 600 P.O. Box 12548 Washington, D.C.
20005 Austin, Texas 78711-1548 Lanny A.
Sinkin Robert A.
Jablon, Esquire Christic Institute Spiegel & McDiarmid 1324 North Capitol Street 1350 New York Avenue, N.W.
Washington, D.C.
20002 Washington, D.C.
20005-4798 Nancy Williams
- Elizabeth B. Johnson CYGNA Energy Services, Inc.
Oak Ridge National Laboratory 2121 N. California Blvd.
P.O.
Box X Building 3500 Suite 390 Oak Ridge, Tennessee 37830 Walnut Creek, CA 94596
- Dr. Walter H. Jordan David R.
Pigott 881 West Outer Drive Orrick, Herrington & Sutcliffe Oak Ridge, Tennessee 37830 600 Montgomery Street San Francisco, CA 94111 l
l l
- Robert A. Wooldridge, Esquire Worsham,.Forsythe, Sampels
& Wooldridge 2001 Bryan Tower, Suite 3200 Dallas, Texas 75201
- W.
G.
Counsil Executive Vice President Texas Utilities Electric -
Generating Division 400 N. Olive, L.B.
81 Dallas, Texas 75201 Thomas A.
Schmutz V
Dated:
April 21, 1988 4
- - _ _ - -.., -.,, _ _.. _ _ __