ML20154C213

Supplemental Deficiency Rept CP-83-08 Re ASME Documentation for Welded Brackets on Valves Supplied by Fisher Controls. Initially Reported on 830423.NRC Concerns Re Details of Analysis Resolved & Replacement of Valve Brackets Scheduled

ML20154C213
Person / Time
Site:	Comanche Peak
Issue date:	09/09/1988
From:	Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
CP-83-08, CP-83-8, TXX-88676, NUDOCS 8809140277
Download: ML20154C213 (2)

Text

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=2 Log i TXX-88676

, L- 2 File # 10110  ;

903.9 1 1UELECTRIC R*'U""50'bb(')

l w n = c. co a September 9, 1988 I nm.,- tv, n,,a ,

V. S. Nuclear Regulatory Commission Attn Document Control Desk

Washington, D. C. 20555 j i

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)  !

) DOCKET N05. 50-445 AND 50-446 CONTROL VALVE BRACKETS I

50AR

CP-83-08 (SUPPLEMENTAL REPORT) l Gentlemen:

3 k j

On April 23, 1983, we provided notification via our report logged TXX-3657 of I i a deficiency which we considered to be reportable involving ASME documentation i j for welded brackets on valves supplied by Fisher Controls. In our latest report (logged TXX-88526 dated June 22,1988) we stated that the brackets that {

l were in use as snubber attachment points on safety related Fisher Control valves would be replaced in order to improve the quality of bracket welds. We -

] also stated that an as-built inspection of the welds had been performed using i ,

Nuclear Construction Issues Group visual Weld Acceptance Criteria (VWAC), and  ;

that based on the inspection results, a worst case anaissis had demonstrated "

that the welds would not have failed during a seismic event. Based on the -

results of this analysis, we concluded that the condition described in 50AR CP83-08wasnotreportablepursuant10CFR50.55(e).

i  !

in discussions subsequent to issuance of TXX-88526, NRC inspectors expressed j

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8 concern that the presence of protective coatings on the subject welds may have masked significant structural defects during the VWAC inspections. To address l t

these concerns, TV Electric removed the protective weld f.oatings on selected  !

2 worst case (based on the anticipated load and previous inspection results) j valve brackets, re-inspected the welds using AWS 0.1.1 criteria, and re-j analyzed the bracket welds,  :

TV Electric also conducted a load test on a {

i bracket that had been welded over raised lettering on the valve actuator  :

1 casting, j

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TXX-88676 September 9, 1988 l Page 2 of 2 l ,

The analysis and load test results indicate that the sutCect brackets would ,

have performed their intended function during a postulated seir.mic event. NRC inspectors' concerns, regarding details of the analysis, have been addressed i

! and resolved with the inspectors. Records of the analysis and test results <

l are available for the NRC inspectors' review. TV Electric considers that I

these results substantiate our previously stated position that the condition

! described in SDAR CP-83-08 is not reportable per 10CFR50.55(e).

l Currently, replacement of the Unit 1 valve brackets is scheduled for completion by December 16, 1988. Replacement of the Unit 2 brackets is i scheduled for completion prior to Unit 2 fuel load. Not all brackets attached to these valves are in use. As part of the replacement actiYities, the unused l brackets will be removed to prevent future use.

Very truly yours, 1

/, / .WXO W. G. Counsil JCH/grr L

I c-Mr. R. D. Martin, Region IV '

Resident inspectors, CPSES (3) l l

l I