ML20204F616

Submittal of First Progress Rept Re Comanche Peak Review Team Activities,Per ASLB 860606 Memorandum & Order. W/Certificate of Svc.Related Correspondence

ML20204F616
Person / Time
Site:	Comanche Peak
Issue date:	07/30/1986
From:	Gad R ROPES & GRAY, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
References
CON-#386-162 OL, NUDOCS 8608040249
Download: ML20204F616 (15)

Text

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!r Filcd: July 30, 1986.

%TLD Connt ih15YD N OW ~1 A10:yg UNITED STATES OF AMERICA hh[;',7 ~~ -

NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of )

) Docket Nos. 50-445-OL ,

TEXAS UTILITIES ELECTRIC ) 50-446-OL COMPANY et al. )

) (Application for an (Comanche Peak Steam Electric ) Operating License)

Station, Units 1 and 2) )

)

APPLICANTS' FIRST PROGRESS REPORT Pursuant to the Board's " Memorandum and order (Progress Report and Notice of Available Documents)"

entered June 6, 1986, the Applicants' submit herewith their first " Progress Report."

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1. CPRT Milestones - Accomplished The Senior Review Team ("SRT") has approved and issued seven Results Reports, as set forth in Attachment 1. The notice to CASE of the availability of the Working Files for each of these action plans has been issued, and the responses to the Board's 14 Questions has been provided for one (I.a.4 - Agreement Between Drawings and Field Terminations). It is expected that responses to the Board's 14 Questions for the balance of the seven issued Results Reports will be filed shortly.

Two action plans (IV - Protective Coatings and VII.b.5 - Electrical Raceway Support Inspections) have been deleted.

Two additional action plans have been or will be issued shortly (VII.a.9 - Receipt and Storage of Purchased Materials and III.a.5 - Preoperational Test Data Package Acceptance Criteria).

Thus there are a total of 53 action plans (ISAPs and DSAPs), of which 9 have been deleted or completed.

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2. CPRT Milestones - To Be Accomplished Completion of the CPRT Program Plan is considered to consist of the following milestones:

Issuance of Results Reports for the Issue Specific Action Plans (I.a.1 though VII.b.5);

Issuance of the Collective Evaluation Report for the Testing Program; Completion of the Action Plan VII.c hardware re-Inspections; Issuance of the Results Report for Action Plan -

VII.c; Issuance of the Collective Evaluation Reports for the QA/QC and Quality of Construction Program (CPRT Program Plan Appendix B);

Issuance of the Results Reports for the Discipline Specific Action Plans; Issuance of the Collective Evaluation Report for the Design Adequacy Program (CPRT Program Plan Appendix A); and Issuance of the overall Collective Significance Report for the CPRT Program.

The CPRT does not work to a project schedule in the normal sense in which the term is used. The CPRT Project Director collects and collates information from the CPRT Review Team Leaders ("RTLs") and Issue Coordinators ("ICs") with respect to progress, which information is used by the Project Director and the SRT for planning purposes.

The following information may be helpful to the Board: .

The milestones set forth above are expected to be accomplished essentially in the order listed.

There are 30 action plans that at the moment are viewed as likely to be completed in the period from the present through October 31, 1986. These are:

I.a.1 Heat Shrinkable Sleeves I.a.2 Insp. Rprts. Butt Splices .

I.a.5 NCR's on AMP Terminal Lugs I.b.1 Flex / Flex Separation I.b.2 Flex / Cable Separation I.b.4 -Barrier Removal I.d.1 QC Inspector Qualifications I.d.2 Admin. of Inspector Tests I.d.3 Craft Personnel Training

• II.a Re Steel in Cavity II.c Air Gap II.d Control Rcom Ceiling II.e Rebar in Euel Handling Bldg.

III.a.1 HET Data Packages III.a.4 Traceability of Test Inst.s III.a.5 Preop Package Acceptance Criteria III.c Prerequic i te Testing V.a Skew (  :. elds in NF Supports V.d Plug .. elds V.e Install. of Main Steam Piping VI.a Insulation / Shield Wall Gap VI.b Polar Crane Shim VII.a.2 NC and CA Systems VII.a.5 Periodic Review of QA Program VII.a.6 Exit Interviews VII.a.7 Housekeeping and Sys. Clean.

VII.a.8 Fuel Pool Liner VII.b.1 Onsite Fabrication VII.b.3 Pipe Support Inspections IX Piping and Supports DSAP

These action plans are listed in numerical order, which does not represent an expectation that they will be completed in that order. In addition, it is also expected that by October 31st the physical re-inspections being performed under Action Plan VII.c will be con.;1eted.

By the end of the year, it is expected that five other action plans will be completed. These are:

I.c Conduit Supports '

V.b Shortening of Anchor Bolts VII.a.1 Material Traceability VII.a.3 Document Control VII.b.4 Hilti Bolts / Inspection These action plans are listed in numerical order,.which does not represent an expectation that they will be completed in that order. The Results Report for Action Plan VII.a.9 is expected to be issued during the first quarter of 1987.

The Collective Evaluation Report for the Testing

, Program is expected to be issued by the end of 1986.

The Action Plan VII.c Results Report is expected to be issued by the end of 1986. The Collective Evaluation Report for the QA/QC Program (CPRT Program Plan Appendix B) is expected to be completed within

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F approximately two months after issuance of the Action Plan VII.c Results Report.

The Discipline Specific Action Plans and the Design Adequacy Program Collective Evaluation (CPRT Program Plan Appendix A) are presently expected to be i completed in early to mid-1987. The final report of the SRT should follow four to six weeks thereafter.

This schedule does not take into account any possible implications of the matters discussed in " Corrective Action Schedule," infra.

In each case, " completed" with respect to an action plan refers to the approval of a results report by the SRT.

This information is provided with certain l caveats. These schedules are not the sort of firm schedule the Board may have had in mind when it issued l

its memorandum; such schedules do not exist and will not be created for the CPRT Program. Some of these dates may slip for a number of reasons including some conscious decisions.

3. Decisions Affecting Schedule In the first instance, the schedule for the completion of CPRT Action Plans is affected by what the RTL and IC for each action plan find. The action plans are investigatory in nature and define conditions under which investigations may be expanded. Such expansion cannot be foreseen or predicted, and the foregoing schedule includes no allowance for any expansion that may be required. In addition, TUGCO may decide for -

l whatever reasons to undertake additional investigations or comprehensive corrective actions on its own (with overview by CPRT), of which examples are the piping and pipe support program and the cable tray support-program. The foregoing schedules contain no allowance for the effect of any such additional undertakings by TUGCO.

Schedules are also affected by competing demands upon personnel. Resource conflicts are not totally avoidable; they have the potential for affecting when action plans are completed. On the other hand, if serial litigation of results reports eventuates, these potential resource conflicts are expected to ameliorate

as the process proceeds.

4. Corrective Action Schedule As is set forth in the Program Plan, corrective actions are the province of the CPSES project. Thus, completion of corrective actions is not, except to the extent set forth in CPRT Program Plan Appendix H, a prerequisite to completion of the CPRT program.

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Similarly, until action plans are completed, no complete catalog of the corrective actions that may be required can be formulated.

As the Board is aware, however, certain corrective actions are presently on-going. These' include:

1. Pipe Supports. The status of this work is described in the TUGCO Letter #TXX-4844 (6/9/86), a copy of which is attached. As the Board is aware, the Stone & Webster " Generic Technical Issues Report" has recently been made available, and the program is expected to be completed by the end of 1987.

2. Cable Tray Hangers. The work on this program is expected to be completed by the end of 1986.

3. Conduit Supports. The work on this program is expected to be completed by the end of 1986.

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4. HVAC and Duct Supports. The work on this program is expected to be completed early in the first quarter of 1987.

In addition, as the Board has earlier been made aware (see the SEC Report on Form 8-K of July 11, 1986, of which copies were provided to the Board and to CASE), a number of design problems have surfaced recently as a result of the various investigations now ongoing at CPSES. The Applicants are currently considering the development of comprehensive corrective action plans to resolve these preliminary findings and their implications. Stone & Webster Engineering gorp.

has been requested by the Applicants to develop preliminary action plans, which prior to implementation will be reviewed by the CPRT -- the Design Adequacy Program RTL and the SRT.

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5. Conclusion - Procedural Suggestions Recognizing that the Board has issued one ruling on the subject and expects to rule again following submissions due in the future, the Applicants feel constrained to observe that the foregoing information fully confirms the necessity of serial litigation of completed aspects of the CPRT program if wholly needless delay in the completion of the Operating License proceeding is to be avoided. ,

Given the history of CPRT, the issue specific action plans, which were created first and implemented first, will be completed first as the foregoing information reflects. At the other end of the spectrum, the Design Adequacy Program was added last, and implementation of that program could not begin until the scope development process had been completed.

The personnel involved in the issue specific (i.e., for the most part TRT-generated) action plans will have completed all of their duties except those that may be required for litigation long before the Design Adequacy Program is finished: at best, the Design Adequacy Program will not be completed until six months to one year after the issue specific action plans have been 1

o completed. If the intervenor's proposal were to be adopted there is a virtual assurance of significant demobilization-remobilization problems for large aspects of the CPRT organization, and the resulting impact on the quality of the evidence that the Applicants will be able to present to this Board will inevitably be negative. It simply isn't possible to send people away for six months to a year, or more, and then ask them to come back to testify about what they .

once did. Either the people won't be able to come back because of whatever new matters they are engaged in or, if they are available, they won't be and cannot be expected to be as familiar with the specific issues and the details of investigative materials as they were when they left.

The next Progress Report will be issued September 30, 1986.

Nicholas S. Reynolds William A. Horin BISHOP, LIBERMAN, COOK PURCELL & REYNOLDS 1200 Seventeenth Street, N.W.

Suite 700 Washington, DC 20036 (202) 857-9800

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Robert A. Wooldridge WORSHAM, FORSYTHE, SAMPELS &

WOOLDRIDGE 2001 Bryan Tower, Suite 3200 Dallas, TX 75201 (214) 979-3000 Roy P. Lessy, Jr.

WRIGHT & TALISMAN, P.C.

1050 Seventeenth Street Washington, DC 20036-5566 (202) 331-1194 Thomas G. Dignan, Jr.

R. K. Gad III ROPES & GRAY 225 Franklin Street '

Boston, MA 02110 (617) 423-6100 f g ,

By ( i

.' m-R. K. ad III s

??mfra CERTIFICATE OF SERVICE jggg7, Al0:12 I, Robeirt K. Gad III, one of the attorney h's.;hblicants herein, hereby certify that on July 30, 1986, I made service of the within " Applicants' First Progress Report" by mailing copies thereof, postage prepaid, to:

Peter B. Bloch, Es. quire Mr. James E. Cummins Chairman Resident Inspector Administrative Judge Comanche Peak S.E.S.

, Atomic Safety and Licensing c/o U.S. Nuclear Regulatory Board Commission U.S. Nuclear Regulatory P.O. Box 38 '

Commission Glen Rose, Texas 76043 Washington, D.C. 20555 Dr. Walter H. Jordan Mr. William L. Clements Administrative Judge Docketing & Services Branch 881 W. Outer Drive U.S. Nuclear Regulatory Commission Oak Ridge, Tennessee 37830 Washington, D.C. 20555 Chairman Chairman Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555

• Stuart A. Treby, Esquire *Mrs. Juanita Ellis Office of the Executive President, CASE Legal Director 1426 S. Polk Street U.S. Nuclear Regulatory Dallas, Texas 75224 Commission Washington, D.C. 20555

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Renea Hicks, Esquire Ellen Ginsberg, Esquire Assistant Attorney General Atomic Safety and Licensing Environmental Protection Division Board Panel P.O. Box 12548, Capitol Station U.S. Nuclear Regulatory Commission Austin, Texas 78711 Washington, D.C. 20555 Anthony Roisman, Esquire Mr. Lanny A. Sinkin Executive Director Christic Institute Trial Lawyers for Public Justice 1324 North Capitol Street 2000 P Street, N.W., Suite 611 Washington, D.C. 20002 Washington, D.C. 20036 Dr. Kenneth A. McCollom Mr. Robert D. Martin Administrative Judge Regional Administrator 1107 West Knapp Region {V Stillwater, Oklahoma 74075 U.S. Nuclear Regulatory Commission Suite 1000 611 Ryan Plaza Drive '

Arlington, Texas 76011 Ms. Billie Pirner Garde Geary S. Mizuno, Esq.

Citizens Clinic Director Office of the Executive Government Accountability Project Legal Director 1901 Que Street, N.W. U.S. Nuclear Regulatory Commission Washington, D.C. 20009 Maryland National Bank Bldg.

Room 10105 7735 Old Georgetown Road Bethesda, Maryland 20814 Elizabeth B. Johnson Administrative Judge Oak Ridge National Laboratory P.O. Box X, Building 3500 Oak Ridge, Tennessee 37830 Nancy Williams Cygna Energy Services, Inc.

101 California Street Suite 1000 San Francisco, California 94111

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Robert K. G d III

• Federal Express i

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HP No. H .me Rev Date R.T. Leader RRS t .il SHT Hpp' CHSE ikat Board 14 IV Serveillance Pro. For Coatings Deleted llelet ed VII.b.5 Elec. Raceway Support Inspect' Deleted Delet ed II.b Concrete Compressive Strength 3 01/24/06 H. Levin SRT Hpproved 02/20/86 04/04/86 I.a.4 Dwgs/ Terminations 4 01/24/06 Mallanda/lLinsel SRT fipproved 03/13/86 04/04/86 06/05/06 III.d Preop Testing 4 02/27/06 J. Rushwick SRT Opproved 03/13/06 04/04/86 VII.b.2 Valve Disassembly 1 01/24/06 J. Hansel SRT fipproved 03/19/06 04/04/86 1.b.3 Conduit / Cable Tray Separation 4 01/24/06 J. Hallanda SRT Hpproved 03/26/86 04/04/86 VII.a.4 Hudit Pro. EL Fksditor Qual's 1 01/24/06 J. Hansel SRT Opproved 04/18/06 06/04/06 I.a.3 Dutt Splice Qualification 4 01/24/06 Mallanda/ Hansel SRI ftpproved 04/30/86 06/04/06 I.a.4 Dogs / Terminations - Revised 4 01/24/06. Hallanda/ Hansel SWI Hpproved 06/25/86

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