ML20205L815

Permittees Further Responses to M Gregory Interrogatories & Request for Production of Documents (Set 5).* Certificate of Svc Encl.Related Correspondence

ML20205L815
Person / Time
Site:	Comanche Peak
Issue date:	03/30/1987
From:	Eggeling W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Gregory M GREGORY, M.
References
CON-#287-2940 CPA, NUDOCS 8704020199
Download: ML20205L815 (12)

Text

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. UNITED STATES.0F AMERICA ,

NUCLEAR PEGULATORY COMMISSION 88CgTED U

before the ATOMIC SAFETY AND LICENSING BOARD OFFICE CF EECiETAsv 00CKETitlG A SUv;Cf.

BR A N::4

)

In the Matter of )

)

TEXAS UTILITIES GENERATING )

COMPANY et al. ) Docket No. 50-445-CPA

)

(Comanche Peak Steam Electric )

Station, Units 1 and 2) )

)

)

PERMITTEES' FURTHER1 RESPONSES TO "MEDDIE GREGORY'S INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS (SET 5)"

Pursuant to 10 CFR SS 2.740, 2.740b and 2.741, the Permittees respond herein to "Meddie Gregory's ,

Interrogatories and Request for Production of Documents (Set 5)."

The Permittees have ignored the definitions and -

guidelines in the paragraphs labelled "a" through "e,"

inclusive, as contained in the document entitled "Meddie Gregory's Interrogatories and Request for 1

By agreement of the parties, the Permittees will continue to respond to these Interrogatories as their investigation with regard to each issue is completed.

8704020199 870402 -

PDR ADOCK 05000445 G PDR 3 50'

Production of Documsnts (Sat 5)," insofer no tha scm3 are contrary to the Rules of Practice.

i Interrogatory 1:

When did Applicants first receive notice of the issues identified by the.MRC's TRT Reports and SSERs, and in what form did that notice come (i.e., NCR, IR, audit report, memorandum, consultant's report, etc.)?

Interrogatory 2:

For each item identified in Interrogatory 1, identify what response was taken to the problem and by whom.

Interrogatory 3:

If the answer to Interrogatory 2 is that no action was taken, explain the reason that no action was taken. If that reason is because Applicants relied on a "second opinion," identify the individuals or organizations who provided that opinion.

Interrogatory 4:

Identify how each " finding" identified in Interrogatory 1 was integrated into consideration of the subsequent findings by others. (For example, how were the findings by the NRC in 1978 and 1979 integrated into Applicants' response to the findings by the Management Analysis Corporation (MAC)?)

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PERMITTEES' RESPONSES (ISSUE: BUTT-SPLICE QUALIFICATION):

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At page J-28 of SSER 7 dated January 1985, the TRT found:

' The practice of butt-splicing cables in panels was allowed on a limited basis, as specified in Section 8.1.5.2.4 of Amendment 44 to the

. I Final Scfsty Analyais Rsport (FSAR). Tho NRC ,

• steff reviewed Texas Utilities Electric l Company's (TUEC's) justification for permitting butt-splices inside panels (correspondence from M. Srinivasan, NRC Power Systems Branch to B.J. Youngblood, NRC Licensing Branch, July 30, 1984), and concluded that the practice is acceptable on a limited basis, subject to'the following conditions:

• That adequate provisions be included in the installation procedures to verify operability of those circuits for which splices are being used, That the wire splices used are qualified for anticipated service conditions, and That splices are staggered within the panel so that they are not adjacent to each other in the same wire bundle and pressing against one another.

The TRT went on to find "the splices to be in conformance with all the procedural requirements set forth by TUGCO (but these requirements] did not include the three conditions for acceptability stated above." -

(SSER 7, page J-29)

Permittees believe that the TRT letter of 9/18/84 was their first notice of this issue. The genesis of -

this issue, however, was Design Change Authorization (DCA) 14801 which authorized the splicing of cable conductors in termination cabinets. (Revision 1 to this DCA was issued on 10/26/82 to add the statement "do not heat shrink these splices"). The type of butt-splice used by TUGCO in termination cabinets or control panels at Comanche Peak Steam Electric Station  ;

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is tho AMP Pre-Insulatcd Environmsntal Saal (PIES) splice.

On 7/27/83, the NRC was contacted by TUGCO to determine any potential conflict between the FSAR and Regulatory Guide 1.75 concerning the use of splices in Class lE panels. (Texas Utilities Services Inc.

I Conference Memorandums, TCO 549 and TCO 550). On 8/24/83, TUGCO received a letter from the NRC in which it was indicated that the NRC Senior Resident Inspector, Construction, was aware that splicing of conductors in Class 1E panels had been authorized by site engineering. The letter noted that action to clarify this issue had been initiated by earlier conference calls to the NRC (i.e. TCO 549 and TCO 550).

In October 1983, FSAR Amendment 44 was issued by TUGCO to address the exception to IEEE 420-1973 on the I use of splices in Class lE panels. On 9/14/84, the NRC approved the ESAR Amendment 44 subject to conditional requirements such as staggering of splices, -

qualification of splices for expected service and verification of circuit operability. These requirements were provided in the NRC evaluation, "The Safety Evaluation of Field Splices Inside Control Panels." This guidance from the NRC was received by TUGCO after the installation of the subject splices.

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On 9/18/84, however, the NRC letter to TUGCO notified TUGCO of the TRT finding. Subsequently, the CPRT was formed and ISAP I.a.3 (Butt-Splice Qualification) was issued to address the TRT finding with regard to butt-splices.

(ISSUE: HEAT-SHRINKABLE INSULATION SLEEVES):

At page J-29 of SSER 7 dated January 1985, the TRT found:

the lack of awareness of where the heat-shrinkable sleeves should be installed, as reflected in the QC inspection form, when the high percentage of missed and/or improperly documented inspections requiring witnessing, indicated that craft and inspection personnel lacked familiarity with these procedural requirements.

Permittees believe that the TRT letter of 9/18/84 was their first notice of this issue. Prior to this time, at Comanche Peak Steam Electric Station, heat-shrinkable insulation sleeves were typically -

installed over certain types of electrical connections in order to provide electrical insulation, including an environmental seal. The criteria for the use of such

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heat-shrinkable insulation and environmental sealing materials (600V) was included as part of Design Change / Design Deviation Authorization (DC/DDA) 2409 Appendix B, issued by Gibbs & Hill, Inc. to i

Sp cification 2323-ES-100 in August, 1978. Thic criteria was later incorporated into the craft procedure (EEI-8 RI) which was used to control the installation of 600V heat-shrinkable materials.

(7/03/79)

Design Change Authorization (DCA) 7463 was issued on 5/06/80 to clarify Detail 18B and add Detail 18D to 1

Drawing 2323-EI-1701. These details authorize splicing of field run conductors to vendor supplied device pigtails utilizing uninsulated AMP splice connectors which are then insulated with heat-shrinkable materials. On 5/29/80, DCA 7463 Revision was issued.

This DCA authorized alternative butt-splice connectors to Detail 18. The alternative connectors authorized were AMP 52979 and 52980 Pre-Insulated Environmentally Sealed (PIES) splice connectors. -

DCA 7463 Revision was the first documentation issued to authorize the use of PIES splices to terminate conductors and was also used to indicate that -

J heat-shrink tubing is not required when using the PIES connectors.

On 4/16/81, DCA 9985 was issued to consolidate DCAs including DCA 7463 concerning Detail of Drawing 2323-EI-1701. Instructions contained in this DCA clearly illustrated the engineering position of not l

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installing haat-chrink tubing over tho PIES splica.

Accordingly, at Comanche Peak Steam Electric Station, inspection reports of butt-splice installations that were made using the PIES splice connectors would have the " witness" heat-shrinkable cable sleeve installation attribute marked N/A (Not Applicable) because said sleeves were not required nor were they installed.

On 6/08/84, QC Procedure QI-QP-11.3-28, Revision 21, " Class 1E Cable Terminations," was issued which identified specific applications where heat-shrinkable insulation sleeves should be used. However, this Procedure did not specifically state that AMP PIES splices were not to be included in the class of connections requiring installation of heat-shrinkable insulation sleeves. As this was the procedure in effect during the TRT inspection and since the '

butt-splices inspected by the TRT were AMP Pre-Insulated Environmental Sealed (PIES) splices, the TRT expressed a concern over the apparent lack of awareness of where heat-shrinkable insulation sleeves are required.

On 9/18/84, the NRC letter to TUGCO notified TUGCO of the TRT finding. Subsequently, the CPRT was formed and ISAP I.a.1 (Heat-Shrinkable Cable Insulation Sleeves) was issued to address the SSER finding with e

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• 1 sleeves are required. " .

(ISSUE: FLEXIBLE CONDUIT TO FLEXIBLE CONDUIT '

SEPARATION)

At page J-42 of SSER 7 dated January 1985, the TRT stated that they:

could find no evidence that an analysis was performed to support the practice that allowed certain separate safety- and nonsafety-related: ,

flexible conduits inside control room panels to be in direct contact with each other or to be separated by less than 1 inch, as required by Section 5.6.2 of IEEE Standard 384.

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t Permittees believe that the TRT letter of 9/18/84 was -

their first notice of this issue, to wit: the need for analysis to qualify SERVICAIR flexible conducts as

" barrier." IEEE 384-1974, "IEEE Trial-Use Standard Criteria for Separation of Class lE Equipment and Circuits," . '

l. .g IEEE 420-1973, "IEEE Trial-Use Guide for Class lE Control '

Switchboards for Nuclear Power Generating Stations,".and Regulatory Guide 1.75, Revision " Physical Independence of Electric Systems," are generally accepted as the documents ,

, governing the electrical separation requirements. All are applicable to the CPSES Project. Additionally, all indicate that within electrical panels and cabinets, " metallic conduit" is an acceptable separation barrier in lieu of

! physical separation. As a result, rigid metallic conduit has i

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, barrier inside electrical panels.

After obtaining IEEE 323-1974 and IEEE-344-1975 j environmental and seismic qualification data for the SERVICAIR flexible metallic conduit and after discussions ,

with the' supplier of the control boards (Reliance Electric

' Company), TUGCO issued design change documents (LCA-6330 1-dated 10/2 /80) at Comanche Peak specifying the use of SERVICAIR fle):ible metallic conduit as a barrier.

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I Initiall), the use of SERVICAIR flexible metallic

( cor.duit was limited to the main control boards. Their use Y,was expanded in October 1980it o include all panels'. supplied' by Reliance Electric Company'(procured under Purchase i

i order CP-0605 to Specification 2323-M'S 605) . This includes s

l their use in the control room control boards and vertical

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! ventilation-panels. In November 1980,' Design Change s

s Authorization (DCA-9086, Rev. 1) was issued to the -

- Electrical Erection Specification 2323-ES-100. It listed

SERVICAIR flexible conduit as metallic conduit, thereby -

2 allowing its use as a separation b'ar:-ier in all electrical l panels. Permittees believed SERVICAIR flexible metallic conduit to be an acceptable barrier in accordance with all-

<pplicable standards and therefore undertook no specific effort to provide the analysis to qual'ify this material as a i

barrier.

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On 9/18/84, however, the NRC letter to TUCCO notified TUGC0 of the TRT finding. Subsequently, the CPRT was formed and ISAP 1.b.1 (Flexible Conduit to Flexible Conduit s

Separation) and ISAP 1.b.2'(Flexible Conduit to Cable Separation) were issuedcto address the SSER finding with regard to demonstrating the adequacy of SERVICAIR flexible metallic conduit as a barrier.,

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00CKETED USNRC c CERTIFICATE OF SERVICE I, William S. Eggeling, hereby certify that on March N, W830 All :39 I made service of the within document by mailing copies ggggpoK5 00CKETING A SEgyggg, postage prepaid, to: BRANCH P e'te r B . ' ' loch, Esquire 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 Ms. Billie Pirner Garde Administrative Judge Midwest Office 881 W. Outer Drive 3424 N. Marcos Lane Oak Ridge, Tennessee 37830 Appleton, WI 54911 Chairman Chairman Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Board Panel ,

U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission R

Commission Washington, D.C. 20555 .

Washington, D.C. 20555 Lawrence J. Chandler, Esquire Mrs. Juanita Ellis 3 Office of the Executive President, CASE l Legal Director. 1426 S. Polk Street U.S. Nuclear Regulatory Dallas, Texas 75224

,' Commission -

Washington, D.C. 20555

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4 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 IV Stillwater, Oklahoma 74075 U.S. Nuclear Regulatory Commission Suite 1000 611 Ryan Plaza Drive Arlington, Texas 76011 Elizabeth B. Johnson Geary S. Mizuno, Esq.

Administrative Judge Office of the Executive Oak Ridge National Laboratory Legal Director P.O. Box X, Building 3500 U.S. Nuclear Regulatory Commission Oak Ridge, Tennessee 37830 Washington, D.C. 20555 Nancy Williams Cygna Energy Services, Inc.

101 California Street .

Suite 1000 San Francisco, California 94111

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William S. Eg ing e