ML20154C213
| 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 R*'U""50'bb(')
1 1UELECTRIC l
w n = c. co a September 9, 1988 I
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V. S. Nuclear Regulatory Commission Attn Document Control Desk Washington, D. C.
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SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES) i
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DOCKET N05. 50-445 AND 50-446 CONTROL VALVE BRACKETS I
50AR: CP-83-08 (SUPPLEMENTAL REPORT) l Gentlemen:
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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
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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
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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).
in discussions subsequent to issuance of TXX-88526, NRC inspectors expressed j
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concern that the presence of protective coatings on the subject welds may have l
8 masked significant structural defects during the VWAC inspections.
To address these concerns, TV Electric removed the protective weld f.oatings on selected t
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-2 j
analyzed the bracket welds, TV Electric also conducted a load test on a
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bracket that had been welded over raised lettering on the valve actuator i
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l 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 these results substantiate our previously stated position that the condition I
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 brackets will be removed to prevent future use.
Very truly yours, 1
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.WXO W. G. Counsil JCH/grr L
I c-Mr. R. D. Martin, Region IV Resident inspectors, CPSES (3) l l
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