ML20199H496
| ML20199H496 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Comanche Peak |
| Issue date: | 03/22/1985 |
| From: | Shao L NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM) |
| To: | Noonan V NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM) |
| Shared Package | |
| ML17198A302 | List:
|
| References | |
| FOIA-85-299, FOIA-85-59, FOIA-86-A-18 NUDOCS 8607030337 | |
| Download: ML20199H496 (7) | |
Text
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~535 MEMORANDUM FOR: Vincent S. Noonan, Director Comanche Peak Project FROM:
L. Shao, Group Leader Civil / Mechanical Groups Comanche Peak Project
SUBJECT:
REVIEW OF STAFF DPAFT RESPONSE TO CASE'S REQUEST FOR ADMISSIONS The Civil / Structural staff has reviewed the subject draft response to CASE's request for admissions. Please be advised that we am providing concurrence to the draft with the correction of typographical errors as marked on the enclosure.
L. C. Shao, Group Leader Civil / Mechanical Groups
Enclosure:
As stated cc:
D. Eisenhut J. Scinto G. Mizuno S. Treby C. Poslusny C. Haughney D. Jeng DISTRIBUTION R. Minogue D. Ross G. Arlotto L. Shao 8607030337 860623 PDR FOIA GARDE 86-A-18 PDR jm.. 7e q
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_BEFORE THE ATOMIC _ SAFETY AND LICENSING BOARD 90 In the Matter of
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I TEXAS UTILITIES ELECTRIC h
Docket Nos. 50-445
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COMPANY, g M.
50-446 i
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l Station, Units 1 and 2)
J g6 SUPPLEMENT TO NRC STAFF RESPONSE TO CASE'S REQUEST FOR ADMISSIONS i
On February 4, 1985, Intervenor Citizens Association for Sound Energy (CASE) filed a request for admissions in which it asks the Staff to admit certain facts purportedly found by the Staff's Technical Review j
Team (TRT) during the course of its review and evaluation of Applicants' construction and quality assurance / quality control activities at Comance l
Peak Steam Electric Station (CPSES).In its March 1, 1985 Response the i
Staff indicated that the TRT's findings and conclusions regarding the matters within its jurisdiction are set forth in applicable Supplemental Safety Evaluation Reports (SSER). See Staff Response at 2-3.At the time the Staff's initial response to CASE'S Admission requests was filed j
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only SSER No. 7, concerning Electrical / Instrumentation and Test Program issues had been published.
Subsequently, the Staff issued SSER No. 8, which addresses Civil / Structural issues. ' Consequently, the Staff is'now in a position to respond to CASE admission requests 14-17 which relate to these matters.
The Staff's responses are set forth below.
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-a-o quencies of the supported masses determined to assess the influence of the seismic response spectrum at the control room ceiling elevation would have on the seismic response of the ceiling elements.
/C STAFF RESPONSE: Admit as explafned in SSER No. 8 at(7kB4, 85.
Respectfully submittad, i
s e.
Gregory Alan Berry Counsel for NRC Staff Dated at Bethesda, Maryland this day of March 1985.
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DE C ] 91965 i: Ell 0RANDU!: FOR: Vincent Nonnan, Project Director Comanche Peak Technical Review Team 1
FR0ft:
L. C. Shao, Group Leader Civil / Mechanical Group Comanche Peak Technical Review Tean
SUBJECT:
"COR:ENTS ON ACTION ITEMS IDENTIFIED BY.ELLIS[
OF CASE DURING NOVEMBER 7, 1984 MEETINC"
REFERENCE:
Hemorandum from Vince Noonan to Distributior., " Transmittal of Action Items as Delineated in Transcript of Meeting With J. Ellis on November 7,1984,* dated Decen6er 7,1984.
4 l
We have reviewed the above referenced memorandun and the transcript of the subject meeting with emphasis on the completeness of the action items listed in Enclosure 2 to the memo and clarity of issue characterization. We offer the following coments:
p 1.
Enclosure.J to th referenced meno may not have listed all issues raised byQ. Elli f CASE during the November 7, 1984 meeting.
Specifice.11ty,se n additional issues not included in Enclosure 2 are listed in Attachment I to this memorandum for A. Vietti's infomation and follow up. We suggest that Attachment I be appended to Enclosure 2 for ease of oudfuture tracking work.
7 2.
We have also marked up Enclosure 2 as Attachment II with names to further clarify task assignments.
We have completed a scoping review of fJ. Ellis[ December 4,1984 3.
letter and attachments (ider.tified as item 19 of Enclosure 2 to the referenced memo). The review resulted in identification of thirteen (13) civil /strveture related issues which are listed in Attachment III.
We intend to follow up on these issues as we,D. Ellis's/ December 411 i
Attachments I and II.
Issues identified int
, 1984 letter which are related to Mechanical and Piping area are being evaluated and will be disposed in a separate menorandum.
In view of the fact that some seventeen (17) issues in the civil / structural area have been identified by CASE during the meetings (see Attachments I and
- 11) and eight (8) additional issues have been raised in the CASE letter dated 3
Dccember 1,1984 (see Attachment III), the civil / structural staff needs ad(itioRa1 Jupport of resourcf1_to timaly resolve the issues. The additional resources needed are:
D 1.
A full time NRC, staff with cjy11/ structural _ background inr annenvimately
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DEC19 E64 V. f:oonan
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High priority implementation of a pmposed Bf;L Technical Assistance Program forwarded to C. Poslusny of your office on November 16, 1984 (seeAttachmentIV).
Your prompt action in providing the requested resources will be appreciated.
Original Si;;neJ by L C. Shao L. C. Shao Civil / Mechanical Group Leader Comanche Peak Technical Review Team
Enclosure:
As stated cc:
R. P gsnen A. Victti C. Poslusny D. Jeng S. Hou DISTRIBtJTION:
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OFFICIAL RECORD COPY
Attachment I,
Action Items Transcript Pages Responsibility
- 20. Were Richmond inserts installed 109 L. Shao/D. Jeng in 2500 psi concrete (line9thru15) 21.
In Damage Study Program was a 110 L. Shao/D. Jeng 2 to 1 (rise to run) projectile (line23 thru 24) range considered.
- 22. Why was some concrete that was 86 L. Shao/D. Jeng committed to be retested not.
(line4-9)
In particular Reactor #2 cavity wall.
23.
CASE questions validity of 101 L.Shao/D. Jeng Schmidt hammer tests (line12) 24, Where was 2500 psi concrete used 93 L. Shao/D. Jeng (line 4 thru 8)
- 25. General cracking of concrete 159 L. Shao/D. Jeng (line 20 of page 159 thru line 11 ofpage160)
- 26. At a doorway between the Contain-134 L. Shao/D. Jeng ment and Safeguards building no (line 12 thru 19) gap exists, the buildings are integrally attached.
l
J gMM; DISCLOSE g
Trar. script Responsibility Action Items Pages 1.
Review for information discussions 9.90,106 N. Livemore on 04/Qc failures in areas of:
Civil / Structural Niscellaneous Electrical 33-35 Test Programs 66 l
2.
Look at the designed and installed 25.76-77 R. Bangart supports for HVAC system ducts in containment. (Specifically.
vertical and laterals) 3.
Determine the temperature equipment 28 R. LaGrange inside containment is qualified to withstand.
1 l
4.
Investigate C58 procedure for reviewing 59-64 A. Vietti/CSB j
containment integrated leak rate testing 5.
Investigate inspections and reports 78-79 A. Vietti/VIB i'
Bohnson Co.
issued by the VIB on CP vendor 6.
NCR E-81-00088, dated 3/25/81 79 J. Calvo (AE-55)(documentprovided) 7.
Case Exhibit 658 (AE-56) 81 A. Vietti/J. Calvo (LocatingthroughpDR) 8.
Check if when CP used 2500 psi concrete 87.91 L. Shao/D.ren[
i strength six did the analysis reflect 2500 psi or 4000 psi i
9.
Visit plant site to see what actions 114 L. Shao/D. Ten $
the applicant has in progress on 4
the control room ceiling Action /Infomation
- 10. Check if Sibbs 8 N111 osed a 115-119 L. Shao/D. Terso/
1.5 factor in all static load calculations (ifnotwhydidn't
- b. 7*a5/ P.T. h u e/ F. Ri'd[*
Cygna notice in their review.)
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l Transcript Responsibility Action Items Pages Action /Information o
- 11. Check if in containment allowable 119-122 L. Shao/D. Terso/b. Ten 3/
stresses go beyond yield for cable tray supports.
(TUvsedageneric p,1y,,,jp,g.,gg, 4
l design with allowable stresses for i
the auxiliary building contrary to FSAR connitments.) (Cygna did not l
address)
Action /Information
- 12. Check if when TU attached their cable 124 L. Shao/D. Terso/D.Te3 trays to the support and structural steel, they drilled a hole through the flange of the channel which reduces the section modules which has not been accounted for in calculations. Check some of the cable tray supports in the field.
(Cygna did not address) i
- 13. LiviIer Plate 127 L. Shao/ D.Ln3
- 14. NCR on a 10 CFR 50.55(e) that 138 L. Shao/b. Ten 3/S. Ho[
TU did not report. (Information transmitted from Gagliardo to etg,y;,y*
L. Shao) i
- 15. Crack in the basemat (AC-44) 148-166 L. Shao/r.Teng*
(documentation duringmeeting)provided
- 16. Specific problems with concrete 167-169 L. Shao/D. Ten $ s (documentation provided durin9 meeting) 6 g, t,4%,
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- 17. Minimum wall violation for piping 171 L. Shao/S.go/
(AP-29) (documentation provided at meeting)
- 18. ANI Reports 174 H. Livermore/
(documentation provided at meeting)
L. Shao (if needed)/S A J l
19.
PackagefromN.E111shceived L. Shao/1).Te.ng /3,gm,
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12/4/84 u Then "*'a* added by O,..)/5+rAr4 Sh an 4e da<.b +aA 4Wgn*M6.
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3 Attachment III 1
Action Items in the Civil / Structural Area Identified from CASE 12-1-84 Letter The following is a list of concerns identified from the CASE 12-1-84 Letter and Attachments.
The Attachments are pages VII-16 through 23 and XXVII-42 through 48 of CASE's Proposed Finciings and Fact and Conclusions of Law NCR's were s)ubmitted as supporting information by CASE.(Walsh/Doyle All The following 1
Action Item M
Comments 1.
Schmidt hammer testing 3 of letter New Item. (This item CASE wants to know:
is related to AC-52
- 1) Under whose direction discussed in C/S tests are conducted Category No. 3).
- 2) Credentials and ability of individuals performing tests
- 3) Involvement of NRC in testing 2.
NCR C-82-00523 Separate New Item Reinforcing Steel missing Attachment from the Unit 1 containment wall Elev. 820'-8 3.
NCR C-520 XXVII-42 New Item Inadequate concrete cover over rebar 4.
NCR C-669 XXVII-42 This NCR was previously missing reinforcing steel addressed in C/S in Unit i reactor cavity Category No. 6 No action required 5.
NCR C-809 XXVII-43 This NCR was previously 6-#10 additional bars addressed in C/S omitted from a beam in Category No. 6 Auxiliary Building No action required.
6.
NCR C-810 XXVII-43 This NCR was previously 9-#9 and 2-#4 assessed in C/S additional bars omitted Category No. 6.
around elevator shaft No action required.
door in Unit 1.
Action Item PaSe Comments 7.
NCR C-811 XXVII-43 This NCR was previously 46-#9 bars omitted from addressed in C/S wall in excess letdown heat Category No. 6.
exchange room.
However, additional information is provided by CASE.
C/S category No.
6 may need revision I
because of the new information.
8.
NCR C-1314 & DCA-5080 XXVII-44 New Item 57-#5 dowels were bent and 10-#5 dowels broken off at concrete.
9.
Is there a potential tie in XXVII-44 New Item i
between NCR C-669 and NCR C-1314 with the base mat crack in Unit 17
- 10. CASE states the above XXVII-44 New Item examples of omitted rebar are only a sampling of such deletions. They appear to have a general concern that no analyses were performed justifying these omissions.
- 11. CASE lists four allegations XXVII-46 These allegations have made which were investigated been addressed in C/S in IE Report 79-25: AC-32, categories 4, 6 and 12.
AC-33, AC-38 and AC-39.
- 12. CASE expresses a concern VII-23 Previously addressed about unauthorized cutting in C/S Category 15.
of rebar.
No action required.
13.
CASE also discusses the XXVII-45 New Item omission of shear tie reinforcement at the inter-section of the done and wall in the Unit 2 containment.
They cite this as another example of QA/QC failure.
14.
In the discussion of the XXVII-47 Previously addressed in allegation (AC-38) about C/S Category 6.
The missing shear tie reinforce-assessment may need ment in Unit 1, CASE does not revision because of CASE accept the conclusion that the concerns.
alleger was probably referring to the above mentioned incident in Unit 2.
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UNITED STATES NUCLEAR REGULATORY COMMISSION 5
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I MEMORANDUM FOR: Joseph Scinto, Deputy Director G
l Office of the Executive Legal Direct
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FROM:
Vincent S. Noonan, Project Director p
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Comanche Peak Technical Review Team
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SUBJECT:
COMANCHE PEAK TECHNICAL REVIEW TEAM (TRT) AND REGION IV INPUT TO THE STAFF'S RESPONSE TO TEXAS UTILITIES 50.57(C) MOTION TO LOAD FUEL AND CONDUCT CERTAIN i
PRECRITICAL TESTING l
Enclosed are allegations and issues still under evaluation by the TRT in the Civil / Structural, Mechanical / Piping, Electrical / Instrumentation, Test Programs, and QA/QC areas affecting systems that may be needed for fuel load and the precritical testing requested by the applicant. There are no outstanding issues in the TRT Coatings area that would affect the systems needed for fuel load and precritical testing requested by the applicant.
Also enclosed is the status of Region IV room inspections as they relate to the applicants motion.
/
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,r ect Director manche Pe ech ical Review Team cc:
E. Case D. Eisenhut R. Martin, Region IV J. Gagliardo R. Wessman A. Vietti R.C. Tang P. Matthews L. Shao J. Calvo R. Keimig H. Livennore R. Bangart r-I h
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4 Allegations and Technical Issues Still Under Evaluation By the TRT in the Civil / Structural Area Affecting Systems That May Be Needed for Fuel Load and the Precritical Testing Requested By the Applicant 1.
Interaction of Seismic Category I Buildings and Systems Housed Within Them The TRT investigated the requirements to maintain an air gap between concrete structures. The TRT reviewed available inspection reports and
.related documents, made on field observations, and had discussions wi.th i
TUEC engineers.
The TRT found a lack of supportive documentation that an air gap has been provided between concrete structures. TUEC has not adequately demon-t strated complia'nce with FSAR Sections 3.8.1.1.1, 3.8.4.5.1 and 3.7.B.2.8, which require separation of Seismic Category I buildings to prevent seismic interaction during an earthquake. Accordingly, by letter dated September 18, 1984, TUEC has been required to perform inspections and provide the results of analyses to demonstrate that Seismic Category I structures, systems, and components are safe in the as-built condition.
s In response to the NRC letter of September 18, 1984, the applicant has developed a program to resolve the NRC staff concerns which the staff is currently evaluating. The staff met with TUEC in public meetings on October 19 and 23,1984,.to discuss the staff's coments on the i
applicant's proposed program plan to resolve this issue, and is currently
),
preparing a letter to TUEC documenting these specific coments.
I Since a thorough assessment of this issue has not been completed as yet, it is inappropriate to consider fuel load and the precritical testing requested by the applicant at this time.
2.
Seismic Design of Control Room Ceiling The TRT investigated the seismic design of the ceiling elements installed in the control room.
This review revealed that TUEC had not adequately' den.anstrated that the suspended ceiling, lighting fixtures and non-safety related conduit over the control room (which are classified seismic' Category II or Non-Seismic by TUEC) are appropriately designed such that their failure would not adversely affect the functions of safety-related components in the control room er cause injury to operators. Accordingly, by letter dated Septemper 18, 1984, TUEC has been required to provide further analyses and evlluations to justify their design.
In addition, TUEC has been-L required to provide the results of an analysis which demonstrates that i
the foregoing problems are not applicable to other Category II and non-seismic structures, systems and components elsewhere in the plant.
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In response to the NRC letter of September 18, 1984, the applicant has developed a program to resolve the NRC staff concerns which the staff is currently evaluating. The staff met with TUEC in public meetings on October 19 and 23, 1984 to discuss the staff's coments on the applicant's proposed program plan to resolve this issue, and is currently preparing a letter to TUEC documenting these specific comments.
Since a thorough assessment of this issue has not been completed as yet, it is inappropriate to consider fuel load and the precritical testing requested by the applicant at this time.
Allegations and Technical Issues Still Under Evaluation By The TRT in Hechanical/ Piping Area Affecting the Systems That May Be Needed For Fuel Load and The Precritical Testing Requested By The Applicant.
The TRT evaluation of allegations and issues in the Mechanical / Piping area is still ir. progress. The staff is planning to have a public meeting with the applicant to identify requests for additional information in the Mechanical / Piping area in late November 1984. The TRT review of the following allegations and issues would require action by the applicant before proceeding with the fuel load licensing process.
1.
Plug Welds The TRT is evaluating alleged unauthorized and undocumented plug welds that were fabricated in pipe and cable tray supports and base plates located throughout the plant including the South Yard Tunnel and Unit 2 Cable Spreading Room.
t 2.
Piping Systems Between Seismic Category I and Non-Seismic Category I Building The TRT is evaluating an issue identified in the April 1984, CPSES Special Review Team Report that the affects of seismic interactions have not been considered, contrary to the FSAR Section 3.7.B.2.8 comitment.
3.
Skewed Welds On Pipe Supports The TRT is evaluating alleged lack of written QC inspection procedures for the examination of certain types of skewed welds on pipe supports initially identified in ASLB Hearings on July 30, 1982, by 4.
Cutting Of Bolts On Steam Generator Lateral Supports The TRT is evaluating an allegation that some anchor bolts in the steam r
zation[nfuringinstallation~ofthebeamsbecausetherewasconcreteinthe genera or upper lateral supports were shortened without proper authori-
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hole.
5.
Temporary Supports During Piping Installation l
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The TRT, while evaluating an allegation that a main steam line was forced,
t into place using the main polar crane in Unit 1, identified additional concerns regarding:
- 1) the effects of settlements at temporary supports during flushing of the main steam line; and 2) the adequacy of temporary 3
supports in general.
Allegations and Technical Issues Still Under Evaluation By The TRT l
in the Electrical / Instrumentation Area Affecting Systems That May Be Neoled for Fuel Load and the Precritical Testing Requested By The
, Applicant 1.
Electrical QC Inspector Training / Qualification Deficiencies j
The TRT examined QC electrical inspector training and certification.
files, and requirements for testing program, on-the-job training and recertification program.
The TRT found a lack of supportive documentation regarding personnel qualifications in the training and certification files, as required by procedures and regulatory requirements, and also found a lack of documentation for assuring that the requirements for electrical QC i
inspector recertification were being met. Accordingly, by letter dated September 18, 1984, the staff requested additional infomation from TUEC.
In response to the NRC letter of September 18, 1984, the applicant has developed a program to resolve the NRC staff concerns which the staff is currently evaluating. The staff met with TUEC in public meetings on October 19 and 23, 1984, to discuss the staff's conenents on the applicant's proposed program plan to resolve this issue, and is currently
+
preparing a letter to TUEC documenting these specific coments.
These deficiencies identified with the electrical QC inspections have generic implications to other construction disciplines. The implications i
of these findings are being further assessed as part of the TRT overall 4
programmatic review of QC inspector training and qualification.
It is inappropriate to consider fuel load and the precritical testing requested by the applicant at this time, due to the uncertainty regarding the qualification and training of inspectors involved in inspecting systems needed for this activity.
l 2.
Conduit Support Installation i
Deficiencies in Selected Seismic Category I Areas 1
r-The TR" examined the nonsafety.related conduit support installation in selecti k! seismic Category I areas of the plant. The support installation
[-
for nolisafety-related conduits, less than or equal to 2 inches, was inconsistent with seismic requirements, and no evidence could be found that substantiated the adequacy of the installation for nonsafety-related conduit of any size. Evidence could not be found that substantiated,the
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failure would not adversely affect the function of safety-related components or cause injury to plant personnel.
The safety significance of the loss or uncertainty about the operability of these systems is that the lack of analysis makes the quality of the supports indeterminent and consequently their behavior during a seismic i
event could not be predicted. The TRT concludes that the conformance of the seismic support system installations with Regulatory Guide 1.29 had l
not been demonstrated. Accordingly, by letter dated September 18, 1984,
.the staff requested additional information from TUEC.
In response to the NRC letter of September 18, 1984, the applicant has developed a program to resolve the NRC staff concerns which the staff is currently evalu.ating. The staff met with TUEC in public meetings on October 19 and 23, 1984, to discuss the staff's coments on the applicant's proposed program plan to resolve this issue, and is currently l
preparing a letter to TUEC documenting these specific coments.
These problem areas identify a potential generic implication to all I
seismic Category I areas of the plant.
It is inappropriate to consider fuel load and the precritical testing requested by the applicant at this time, due to the uncertainty of operability of the systems needed for this activity.
3.
Electrical Equipment Separation Deficiencies iI-The TRT review concerned with the separation criteria between separate cables, trays and conduits in the control room and cable spreading room; and the compatibility of the electrical erection specifications with i
regulatory requirements.
After reviewing documentation and inspecting random samples of separation l
l between safety-related cables, trays and conduits and between them and nonsafety-related cables, trays and conduits, the TRT found:
(1) numerous cases of safety-related cables within flexible conduits inside i
main control room panels, which did not meet minimum separation requirements; (2) several cases of separate safety /nonsafety cables and separate safety cables within flexible conduits, inside main control room panels, which did not meet minimum separation requirements; and (3) existing TUEC's analysis substantiating the adequacy of the criteria for separation between rigid conduits and open/ ladder cable trays had not I
been reviewed by the NRC staff. Accordingly, by letter dated September l
18, 1984, thd staff requested additional information from TUEC.
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In res nse to the'NRC letter of September 18, 1984, the applicant has b
develo d a program to resolve the NRC staff concerns which the staff is currently evaluating. The staff met with TUEC in public meetings on i
October 19 and 23, 1984 to discuss the staff's coments on the j
applicant's proposed program plan to resolve this issue, and is currently preparing a letter to TUEC documenting these specific coments.
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! The safety significance of the loss or uncertainty about the operability of these systems is the apparent lack of separation that could result in i
the loss of redundancy when the installation is challenged by design basis events. This could possibly cause loss of capability to achieve safe shutdown depending on the circumstances surrounding the event and the circuits involved.
These problem areas have potential generic implications in all safety-related control panels and cabinets.
It is inappropriate to consider fuel load and the precritical testing requested by the applicant at this time, due to the uncertainty of operability of the systems needed for this activity.
4.
Electrical Cable Termination Deficiencies The TRT inspected random samples of safety-related terminations, butt splices inside panels, and vendor-installed terminal lugs in ITE Grinnel switchgear and motor control centers, and reviewed documentation relative to the installations.
The TRT found: (1) lack of awareness of QC electrical inspectors to acknowledge requirements for nuclear heat-shrinkable cable insulation sleeves; (2) selected inspection reports did not indicate the required witnessing of splice installation; (3) absence of splice qualification requirements in procedures; and (4) selected cable termination installations were in disagreement with as-built drawings. Accordingly, by letter dated September 18, 1984, the staff requested additional h
information from TUEC.
J In response to the NRC letter of September 18, 1984, the applicant developed a program to resolve the NRC staff concerns which the staff is i
currently evaluating. The staff met with TUEC in public meetings on October 19 and 23, 1984 to discuss the staff's comments on the applicant's proposed program plan to resolve this issue, and is currently preparing a letter to TUEC documenting these specific coments.
The implied safety significance of the loss or uncertainty about the operability of these systems is that the lack of witnessing of the installation, disagreement of the installation with as-built drawings, or improperly dispositioned NCRs, could place the quality of installation in question.
Furthermore, the absence of qualification requirements, or 1;
provisions to demonstrate operability cast doubt on the adequacy of the butt splice 1,nstallation.
t r-i These ' oblem areas have potential generic implications to all safety-p relate panels, switchgear cabinets, motor control centers, and r
temin tion cabinets.
It is inappropriate to consider fuel load and the precritical testing requested by the applicant at this time, due to the uncertainty of operability of the systems needed for this activity.
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Allegations and Technical Issues Still Under Evaluation By The TRT In The j
Test Program Area Affecting Systems That May Be Needed For Fuel Load and The Precritical Testing Requested By The Applicant l
The TRT review of completed Hot Functional Test data packages which had been reviewed and approved by the Joint Test Group (JTG), revealed that t
TUEC had not met the objectives of three of the 17 test data packages reviewed. Accordingly, TUEC was instructed, by letter dated September 18, 1984, to review all complete preoperational test data packages to ensure there are no other instances where test objectives were not met, or prerequisite conditions not satisified.
t In response to the NRC letter of September 18, 1984, the applicant has developed a program to resolve the NRC staff concerns which the staff is currently evaluating. The staff met with TUEC in public meetings on October 19 and 23, 1984 to discuss the staff's comments on the applicant's proposed program plan to resolve this issue, and is currently preparing a letter to TUEC documenting these specific comments.
Since a thorough assessment of this issue has not been completed as yet, it is inappropriate to consider fuel load and the precritical testing requested by the applicant at this time.
In addition, the TRT is currently investigating the board's concerns about startup quality assurance (Board Memorandum dated October 1, 1984) i and is scheduled to respond in late November.
Allegations and Technical Issues Still Under Evaluation By the TRT In the Quality Assurance / Quality Control (QA/QC) Area Affecting Systems That May Be Needed For Fuel Load and The Precritical Testing Requested By The Applicant The TRT evaluation of allegations and issues in the QA/QC area is still in progress. The staff is planning to have a public meeting with the t
applicant to identify requests for additional information in the QA/QC area in late November. The TRT review of the following allegations and issues would require action by the applicant before proceeding with the fuel load licensing process.
1.
Management Comitment to QA/QC The TRT is evaluating alleged management directives to not report problems, intimidation of inspectors, and unqualified QA/QC supervisory personnel. While no specific technical issue was identified from the r-indivi ual allegations, a collective concern from these allegations was g
identi ied relative to QC inspector training and qualification, and the applic t's comitment to an effective QA program.
2.
parts Interchanged In Diaphram Valves The TRT is evaluating an allegation that numerous diaphram valves were j
disassembled and subsequently reassembled interchanging certain parts.
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As-Built Verification l
The TRT is evaluating the results of an as-built verification effort I
conducted as an input into the total QA/QC assessment in that it is used i
to measure the effectiveness of the applicant's QA/QC program for work performed prior to the TRT's review. The TRT perfonned inspections on
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completed hardware using the final as-built drawings of the hardware.
Open Items In The Region IV Walkdown Inspections Affecting Systems That
- May Be Needed For Fuel Load and the Precritical Testing Requested By -The
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Applicant 4
The staff has completed inspection of the Cable Spread Room, Fuel Building, Containment Building, and Safeguards and Auxiliary Buildings.
The staff concludes that inspection of the Cable Spread Room and Fuel 1
Building did not reveal matters that would affect system operability for
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the systems and components required for fuel load and the precritical testing requested by the applicant.
As part of the inspection of the Containment Building, the staff identified a violation related to the as Built Design Documentation Program that may affect system operability for the systems and components i
required for fuel load and the precritical testing requested by the j
applicant.
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i A review of the licensee's program for verification and control of design If documents was conducted. Specific drawings and diagrams were selected by the manager, nuclear operation and TUGC0 Nuclear Engineering for updating prior to fuel loading. The inspection was conducted to detennine (1) adequacy of procedures governing the generation and com as-built design documents (drawings and specifications)pletion ofand (2) the i
schedule for completion of the as-built drawing documentation. The inspection of document control resulted in findings that the actual i
status of certain design drawings could not be determined and that some design drawings available for use by the control room were out of date.
These findings were cited as a violation of Criterion V to Appendix B of 10 CFR Part 50.
The staff concludes that while the Unit I containment building inspection did not identify violations which specifically indicate progransnatic weaknesses in the applicant's program relative to the operability of systems necessary for fuel loading and precritical testing, a violation j
concerning trie as-Built Design Documentation Program was identified for r-which the NRC staff. position is indetenninate until the applicant's i
respongetotheviolationisevaluated.
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Finally, the results of room inspection of the Safeguards and Auxiliary i
Building are still under evaluation. Consequently, the NRC staff i
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. position is indetenninate until the inspection report is issued and the applicant's response is evaluated.
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