ML20206H003
| ML20206H003 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/13/1987 |
| From: | Gad R ROPES & GRAY, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | GREGORY, M. |
| References | |
| CON-#287-3079 CPA, NUDOCS 8704150218 | |
| Download: ML20206H003 (30) | |
Text
_ _ __ _ _ _ . _ _ _ _ _ _ _ _ _ ______ -
3079 ,. eocea m
- l UNITED STATES OF AMERTCA NUCLEAR REGULATORY COMMICSION OgK ED before the s
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ATOMIC SAFETY AND LICENSING BOARD %7 APR 13 P4:15
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OFFICE TJ 'iU r U hY 00CKf.iliJi > "Fi '
EF t.01 .
)
In the Matter of )
)
TEXAS UTILITIES GENERATING ) Docket No. 50-445-CPA COMPANY et al. )
)
(Comanche Peak Steam Electric )
Station, Units 1 and 2) )
)
a )
PERMITTEES' FURTHER1 RESPONSES TO "MEDDIE GREGORY'S INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS (SET 5)"
Pursuant to 10 CFR 55 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 Production of 1
By agreement of the parties, the Permittees are !
continuing to respond to these Interrogatories as their investigation with regard to each issue is completed. ,,
i g4thQ f50 5 G
- . . ~ .
i Documsnto (Sot 5)," insofar ca tha namn cro contrary to tha Rules of Practice.
s Interrogatory 1:
When did Applicants first receive notice of the issues identified by the NRC'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)?)
PERMITTEES' RESPONSES (TRT ISSUE: BARRIER REMOVAL)
,At page J-42 of SSER 7 dated January, 1985, the TRT found:
The missing barrier (used to separate redundant devices in auxiliary feedwater panel CP1-EC-PRCB-09) and the field wiring not being aspnrated by the required 6 inchas (insido panni
- cpl-EC-PRCB-03) were the only two instances of Class lE panel mounted devices in violation of the separation criteria which require corrective i
action.
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Permittees believe that the first notice of this issue, .
namely barrier removal and/or electrical separation criteria, was in April 1983. At this time, the NRC Construction Appraisal Team (CAT) conducted a site audit and found multiple instances where the six inch separation between redundant train wiring within control panels had not been maintained.
TUGCO responded to the electrical separation issue of the CAT report in a letter dated May 17, 1983 as follows:
Since construction activities are continuing in the area of cable pulling and terminations, internal separation matters are addressed by the QC punch list on an in-process basis. Some items, not identified on a daily basis, will be verified by QI-QP-11.3-40 during post construction verification.
Statements concerning the use of other than Service Air Company stainless steel flex conduit for separation were made by the. CAT Inspectors. The manufacturer of the control board has used material of micarta and in some cases, square 6x6 metal wireway, for barriers. Engineering specifications allow for any suitable material to be used as a j barrier for separation matters.
No corrective action is required.
In October, 1983, the NRC conducted a Region IV follow-up inspection to the CAT inspection and found that the Post Construction Verification Program (QI-QP-11.3-40) utilizing RFICs, NCRs, DCAs, irs and Trend Reports continually identified and addressed separation criteria ,,
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probicmo. Tho progrcm wac found to provida adsquate controls and critoria to assure that violations are promptly identified and properly tracked to close out deviations.
s Overall, the Post Construction Verification Program was found to be a controlled, planned and effective means of
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addressing problems that exist in areas of high construction activities. -
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On July 13, 1984, the NRC conducted the Special Review Team (SRT) audit which included a review of QI-QP-11.3-40.
This NRC review examined post construction inspection of electrical equipment and raceway procedure for compliance to the electrical separation criteria. To guarantee that internal electrical separation in panels was being adhered to, several panels for which QI-QP-11.3-40 " inspection" was essentially complete were examined. These panels were located in the cable spreading room and control room. The examination showed that internal separation was satisfactory even though work was still in process.
On 09/18/84, the NRC letter to TUGCO stated two TRT findings relative to the separation criteria inside panels CP1-EC-PRCB-09 and CP1-EC-PRCB-03, one concerning the missing barrier and one concerning inadequate cable-to-device separation. These findings were confirmed to be deviations from the Project separation criteria.
Nonconformance Reports E-84-100526 and E-84-100524 (10/09/84) were issued to address these deviations. The barrier material was replaced and the field cables were
rcworked to resolvo the ssparation violations. In addition, the CPRT was formed and ISAP I.b.4 (Barrier Removal) was issued to address the TRT findings regarding barrier removal and field wiring not being separated by the required six (6) inches.
(TRT ISSUE:
HOT FUNCTIONAL TESTIhG (HET) DATA PACKAGES)
At page J-13 of SSER 7 dated January, 1985, the TRT found:
three HFT data packages were approved by the TUEC Joint Test Group (JTC) that failed to meet all of the objectives stated in the test procedures.
Yet at J-76 to J-77, of SSER 7, the TRT stated:
It appeared that the overall objectives of the CPSES Unit 1 preoperational test program were being satisfactorily met, thus providing reasonable assurance that the plant is properly designed and constructed and that its operation will not pose a threat to public health and safety. While some of the allegations had valid bases, none were considered to have safety significance or generic implications.
Permittees believe that the TRT letter of September 18, 1984 was their first notice of this issue. Following notification by TRT of this issue on September 18, 1984,
. CPRT was formed and ISAP III.a.1 was issued (Hot Functional Tes,' ting (HFT) Data Packages) to address the TRT findings as stated in SSER 7. The objective of ISAP III.a.1 was to satisfactorily resolve.the concerns posed by the three '
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potentially deficient test date packagas identified by tha TRT and also to provide reasoncble assurance that the CPSES preoperational testing program was and is being accomplished
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according to applicable NRC requirements and regulations.
(TRT ISSUE: TERMINATIONS NOT IN .
CONFORMANCE WITH CURRENT DRAWINGS)
At page J-30 of SSER 7 dated January, 1985, the TRT found:
Concerns exist relative to safety-related cable terminations which are not in conformance with current drawings.
More specifically, at page J-29 of SSER 7 the TRT stated:
. . . the TRT selected 380 cables, involving 1600 individual terminations, and inspected them in detail with respect to drawing requirements. This inspection revealed that six cables (five of which are safety related) were not terminated in accordance with current drawings. These six cables are:
- 1) E0139880 in panel CP1-ECPRCB-14
- 2) E5110040 in panel CP1-ECPRTC-16
- 3) E0118262 in panel CP1-ECPRTC-16
- 4) NK139853 in panel CP1-ECPRCB-02 (non-safety)
- 5) EG104796 in panel CP1-ECPRTC-27
- 6) EG021856 in panel CPX-ECPRCV-01 Permittees believe that the TRT letter of 09/18/84 was their first notice of this issue for five (5) of the subject cables, namely, E0139880, ES118262, NK139853, EG104796 and EG021856.
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Crblo EB139880:
The TRT notified TUEC that the panel identified for this conductor should be CP1-ECPRCB-04. Thie cable was s
terminated-correctly, but the color code cable on the
_. drawing had not been correctly reflected in the condu,ctor termination details. The conductor color code assignment .cn1 l the drawing was changed as a result of DCA-7025 Revision 10 issued on 05/21/82 for Westinghouse pre-fab cables and included cable E$139880.
On 09/18/84, the NRC letter to TUGCO notified TUGCO of the TRT finding. On 07/17/85, corrected drawing El-0171-04 Rev.CP4 was issued and all other drawings with this same type of cable were checked to ensure this condition did not exist elsewhere. Also, the CPRT was formed and ISAP I.a.4 (Agreement Between Drawings and Field Terminations) was issued to address the TRT finding of nonconformance of terminations with drawings.
Cable E0118262:
This cable was terminated correctly. After termination, drawing El-0172-16 Rev.CP1 was issued on 02/21/84 and as a result of a drafting error, this drawing reflected cable EW118262 as having two green conductors.
On 09/18/84, the NRC letter to TUGCO notified TUGCO of the TRT finding. On 09/22/84, drawing El-0172-16 Rev.CP4
was approved which corrscted the drawing error and Inspnction Report E-1-0054828 documented the termination of cable E0118262 origin end to be consistent with the drawing.
Also, the CPRT was formed and ISAP I.d.4 (Agreement Between Drawings and Field Terminations) was issued to address the TRT finding of nonconformance of terminations with drawings.
Cable NK139853:
The drawing for this non-safety cable had the orange and yellow-orange pair of conductors designated as " spare," but the conductors were left terminated. However, the corresponding vendor-side conductors had correctly been lifted from the terminal block and thus there was no functional deviation.
On 09/18/84, the NRC letter to TUGCO notified TUGCO of the TRT finding. Inspection Report ER-ET-1-0054546 (09/28/84) verified the "as installed" condition of cable NK139853 destination end. The subject conductors were removed from the terminal blocks. Also, the CPRT was formed and ISAP I.a.4 (Agreement Between Drawings and Field Terminations) was issued to address the TRT finding of nonconformance of terminations with drawings.
I Cable EG104796:
Cable EG104796, a two conductor cable, was installed on 06/03/82. During the TRT inspection, the cable was found to i
have conductore interchangad on the terminal points.
Although this connection has no polarity requirement and therefore the interchange had no effect on the circuit's operability, it did conflict with the urrent drawing El-0172-27 Rev.CP3.
On 09/18/84, the NRC letter to TUGCO notified TUGCO of.
the TRT finding. On 09/28/84, NCR E84-100503 was issued and cable EG104796 was reworked. Inspection Report ET-1-0054829 documented the rework and confirmed compliance with drawing El-0172-27 Rev.CP3. Also, the CPRT was formed and ISAP I.a.4 (Agreement Between Drawings and Field Terminations) was issued to address the TRT finding of nonconformance of terminations with drawings.
Cable EG021856:
In March, 1984, Design Change Authorization (DCA) 19948 was issued that resulted in the designation of cable EG021856 as a " spare." On 06/08/84, drawing El-0174-13 Rev. CPI was issued, but DCA 19948 was not incorporated into the Revision, thus, cable EG021856 destination end was still shown as terminated.
On 09/18/84, the NRC letter to TUGCO notified TUGCO of the TRT finding. On 09/24/84, drawing El-0174-12 Rev.CP2 was issued which correctly incorporated DCA 19948 and I deleted cable EG021856 from the drawing. Also, the CPRT was
- formed and ISAP I.a.4 (Agreement Between Drawings and Field 1
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Terminations) was iagusci to address tha TRT finding of nonconformance of terminations with drawings.
Cable E0110040: <
s Permittees believe that the first notice of the issue
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for cable E@l10040 was through internal review during the time period between June 4, 1984 and September 16, 1984.
The cable was found to be terminated properly in conformance with the current drawing at the time the termination was made (IR ET-2796 on 04/09/80 as per drawing El-0172-16 Rev. 7). On 02/21/84, drawing El-0172-16 Rev.CP1 was issued and this Revision inadvertently changed the color shown for one conductor from green to black with no change indication being made on the drawing.
On 06/04/84, drawing El-0172-16 Rev.CP2 was issued containing the same error with regard to cable E$110040.
However, by 09/16/84, when drawing El-0172-16 Rev.CP3 was issued, the drawing error related to the termination of cable E110040 had been detected and corrected.
On 09/18/84, the NRC letter to TUGCO confirmed the TRT l
finding. Subsequently, the CPRT was formed and ISAP I.a.4 l l
(Agreement Between Drawings and Field Terminations) was issued to address the TRT finding on nonconformance of terminations with drawings.
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(TRT ISSUE: PREREQUISITE TESTING)
At pages J-87 and J-13, respectively, of SSER 7 dated January, 1985, the TRT stated as folloWW:
. . . [T]he TRT review found that craft personnel verified and signed for initial conditions on some prerequisite test data --
sheets, contrary to Section 4.10.9 of CP-SP-21, " Conduct of Testing," which -
requires that this be done by the STE
[ System Test Engineer]. Further investigation revealed a memorandum issued by the Lead Startup Engineer on March 31, 1983, countermanding this requirement of CP-SAP-21. The subject of the memorandum (SIM-83084) was "ETG Personnel Schedule Change," but it also indicated that craft personnel (ETG) [ Electrical Test Group] may verify prerequisite conditions for Prerequisite Test Instructions XCP-EE-1 and 7
XCP-EE-14. Issuing such a memorandum in lieu of executing a properly approved change to CP-SAP-21 is in violation of CP-SAP-1, "Startup Administrative Procedures Manual,"
Section 4.4.2.1, which requires a permanent or interim change to be approved and issued
- to all manual holders in accordance with l CP-SAP-1. It appears that as a result of
, the memorandum, 24 of the 35 tests reviewed by the TRT had prerequisite conditions improperly verified by craft support personnel. Fifteen were XCP-EE-14, but nine ,
were XCP-EE-24, " Fixed Battery Pack Operated i Emergency Lighting Units," which were not l authorized by the memorandum.
. . .[T]he TRT found that TUEC startup management authorized, by memorandum, test support craftsmen to verify initial conditions for certain prerequisite test procedures in violation of Startup Administrative Procedure CP-SAP-21, " Conduct of Testing." This instruction also appears
, to be a violation of 10 CFR 50, Appendix B, Criterion V.
Permittees believe that Test Deficiency Report 2594 dated March 30, 1984 was their first notice of this issue.
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TDR 2594 stated that psrsons other than the assigned System Test Engineer had signed the " applicable prerequisite complete" sign-off blank for Prerequisite Tests for Battery Pack Lighting (XCP-EE-24). As specified'by TDR 2594, the required corrective action was to instruct all testing personnel as to the raquirements of Startup Administrative Procedure 21, Revision 2, " Conduct of Tecting" and to specifically instruct them that the assigned System Test Engineer will sign for " applicable prerequisites complete."
The corrective action was approved by the Lead Startup Engineer. This action effectively rescinded SIM 83084.
Following notification by TRT of this issue on September 18, 1984, TUEC formed the CPRT and issued ISAP III.c (Prerequisite Testing) to address the TRT findings as stated in SSER 7.
(TRT ISSUE: UNAUTHORIZED CUTTING OF REBAR IN THE FUEL HANDLING BUILDING)
At page K-162 of SSER 8 dated February, 1985, the TRT l stated:
The TRT investigated an alleged instance of unauthorized cutting of rebar associated with the installation of the trolley process aisle rails in the Fuel Handling Building. The claim is that during installation of 22 metal plates in January 1983, a core drill was used to drill about 10 holes approximately 9 inches deep. The TRT reviewed the reinforcement drawings for the Fuel Handling l Building and determined that there were three i layers of reinforcing steel in the top reinforcement layer of the slab. This reinforcement layer censisted of a No. 18 bar 12 -
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running in the onst-wast direction in tha first and third layers, and a No. 11 bar running the north-south direction on the second layer. The review also revealed that the layout of the reinforcement and the trolley rails was such that the east-west reinforcement would interfere with the drilling of holes along only one rail location.
However, if 9-inch holes were drilled, both the first and third layers of No. 18 reinforcement would be cut. Design Change Authorization No. 7041 was written for authorization to cut the upp'ermost No. 18 bar at only one rr location, but did not reference authorizatior cut the lower No. 18 ^
bar. DCA-7041 also ste that the expansion bolts and base plates may be moved in the east-west direction to avoid interference with reinforcement running in the north-south direction. The information, described in DCA-7041, was substantiated by Gibbs & Hill calculations. If the ten holes were actually drilled 9 inches deep, then the allegation that the reinforcement was cut without proper authorization would be valid.
Accordingly, TUEC shall provide:
- 1. Information to demonstrate that only the No.
18 reinforcing steel in the first layer was cut, or
- 2. Design calculations to demonstrate that structural integrity is maintained if the No.
18 reinforcing steel on both the first and third layers was cut.
Permittees believe that the first notice of this issue was NRC letter 50-445/83-27 to TUGCO (September 29, 1983).
In this letter, the NRC reported to TUGCO the results of their interview on September 1, 1083, with a Brown & Root millwright who alleged that he had cut rebar, without authorization, while installing trolley rails in the Fuel )
Handling Building.
The NRC letter identified this issue as being an unsubstantiated allegation, therefore, no action was taken by TUGCO.
Nevertheless, the TRT letter of 09/18/84 to TUGCO identified a concern regarding cutting of the rebar and .
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, required that action bn takan to ensure that if unauthorized cutting did take place, it would have no effect on the structural integrity of the Fuel Handling Building.
Subsequently, the CPRT was formed and DSAP II.e (Rebar in the Fuel Handling Building) was issued to address the TRT
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concern regarding the cutting of rebar in the fuel handling building.
(TRT ISSUE: SEISMIC DESIGN OF CONTROL ROOM CEILING ELEMENTS)
At pages K-84 and K-85 of SSER 8 dated February, 1985, the TRT found:
. . . not all items in the Cor.crol Room ceiling fall under the seismic Category I or II designation.
Specifically, these items are the suspended drywall, acoustical, and louvered ceilings. These components, designated as nonseismic, do not i satisfy the provisions of Regulatory Guide 1.29, l since they were not designed to accomodate seismic effects.
At pages K-160 and K-161 of SSER 8 further elaboration was presented:
The TRT investigated the seismic design of the ceiling elements installed in the control room. The following matrix designates those ceiling elements present in the control room and their seismic category designation:
- 1. Heating, Ventilating and Air Conditioning Seismic Category I
- 2. Safety-Related Conduits Seismic Category I
, 3. Nonsafety-Related
- Conduits Seismic Category II
- 4. Lighting Fixtures Seismic Category II
- 5. Sloping Suspended Drywall Ceiling Non-Seismic
- 6. Acoustical Suspended Ceiling Non-Seismic .
- 7. Lowarsd Sunpandad Ceiling Non-Seismic According to Regulatory Guide 1.29 and FSAR Section 3.7B.2.8, the seismic Category II and nonseismic items should be designed in such a way that their failure would not adversely aYfect the functions of safety-related components or cause injury to operators.
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For the nonseismic items (other than the sloding suspended drywall ceiling), and for nonsafety-related conduits whose diameter is 2 ,
inches or less, the TRT could find no evidence that the possible effects of a failure of these items had been considered. In addition, the TRT determined that calculations for seismic Category II components (e.g., lighting fixtures) and the calculations for the sloping suspended drywall ceiling did not adequately reflect the rotational interaction with the nonseismic items, nor were the fundamental frequencies 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.
j The history of the ceiling and wall design in question dates back to 01/09/79 with the issuance of Gibbs & Hill letter GTN-33023 to TUGCO. An attachment to this letter was j a Design / Engineering Change Request (N-338) which revised
! the lower ceiling in the control room (above the control I
board) to include acoustical tile above the louvered ceiling
) in lieu of plaster and also provided for gypsum board in lieu of plaster for the sloping fascia wall connecting the lower and upper ceilings. On 06/14/79, Gibbs & Hill reissued the architectural drawings for the construction of thd control room ceiling.
Permittees first had notice that this design of the control room ceiling might present a seismic concern on
, September 3, 1980, when the TUGCO Project Civil Engineer -
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telephonad Gibbs & Hill inquiring about ceiling compliance with Regulatory Guide 1.29 (per Project Civil Engineer's 3
log). The following month, on October 7, 1980, TWX-12537 was generated from TUGCO to Gibbs & Hi 1 requesting an engineering justification for the nonseismic classification of the suspended ceiling and gypsum walls in the control room. The transmittal and receipt of this document i
precipitated several telephone conversations between TUGCO and Gibbs & Hill in regard to the ceiling design compliance with Regulatory Guide 1.29.
On 02/12/81, Memo CPP-4512 from TUGCO Project Civil Engineer to TUGCO Engineering Manager was generated which proposed to strenghten and supply back-up support to the l existing gypsum sloping wall. This proposal ("CPSES-Seismic I
Qualification of Control Room Ceiling and Gypsum Wall") was transmitted to Gibbu & Hill via TUGCO Memo CPPA 11410 on 07/22/81. TUGCO's memo requested the comments and' concurrence of Gibbs & Hill with the described proposal in
. which: (1) the suspended acoustical and louvered ceilings in the Control Room are considered acceptable in their as~-built conditions and; (2) the gypsum wall is to be additionally supported in two identified areas. In responsa to the request, Gibbs & Hill issued a letter (GTT-7965) on 08/07/81 to,TUGCO which stated concurrence with the aforementioned proposal, but acknowledged a lack of current substantiating documentation.
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Following a meeting between CPSES staff'and TRT staff on i
07/31/84 in which the question of seismic design adequacy in regard to Regulatory Guide 1.29 was raised, TUGCO initiated '
a written response to File (CPPA-40224' dated 08/03/84) which addressed the requests of the TRT staff and justified the architectural wall and ceiling systems in the Control Room j as being in compliance with the intent of Regulatory Guide l.29.
Subsequently, the NRC letter of 09/18/84 formally reiterated to TUGCO the TRT concerns regarding the control room ceiling. Following receipt of the letter, the CPRT was formed and ISAP II.d (Seismic Design of Control Room Ceiling Elements) was issued to address the TRT concerns regarding 4
control room ceiling seismic design adequacy.
(TRT ISSUE: AIR GAP BETWEEN CONCRETE STRUCTURES)
At page K-77 of SSER 8 dated February, 1985, the TRT found:
1 1 Based on the review of available documents, on field ,
1 observations, and on discussions with TUEC engineers, 1
the TRT cannot determine whether an adequate air gap has been provided between concrete structures. Field investigations by B&R QC inspectors indicated unsatisfactory conditions due to the presence of debris in the air gap, such as wood wedges, rocks, clumps of concrete and rotofoam. The disposition of the NCR
- ' ' relating to this matter states that the " field investigations reveal that most of the material has been
- removed." However, the TRT cannot determine from this report (NCR C-83-01067) the extent and location of the debris remaining between the structures.
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Bessd on discussions with TUEC cnginsoro, it is tha TRT's undarstanding that field investigations were mads but that no permanent records were maintained. In addition, it is not apparent that the permanent installation of elastic joint filler material
("rotofoam") between the Safeguards Building and the Reactor Building, and below grade for the other concrete structures, is consistent with the seismic analysis assumptions and dynamic models used to analyse the
-. buildings, as these analyses are delineated in the Final Safety Analysis Report (FSAR). The TRT, therefore, concludes that TUEC has not adequately demonstrated .
compliance with FSAR Sections 3.4.1.1.1, 3.8.4.5.1, and 3.7.B.2.8, which require separation of Seismic Category I buildinge to prevent seismic interaction during an earthquake.
TUGCO had committed in the FSAR to provide separation between buildings to prevent unacceptable seismic interaction during an earthquake. To meet this commitment, CPSES has been designed, in a fashion similar to other nuclear plants, by providing an air space between buildings wide enough to allow for building movement during seismic j l
activity. Certain components (e.g., fire or environmental !
l seals) are by design allowed to span this gap. Elastic foam (equivalent to the term "rotofoam" cited by the NRC) forming material is also allowed in the gap below grade in the design.
As construction commenced, an elastic foam was used by Brown & Root as the concrete forming material. After pouring, the foam forming material was left in place. This practice cohtinued until 1977, when it came to the attention of,'Gibbs & Hill. Construction had been given Engineering approval to leave foam in place for pours below waterstops due to inaccessibility for removal attempts. The approval was provided in Field Problem Action Request (FPAR) 110 --
(Esbruary 13, 1976). Construction interprated ths Enginaaring response as a generic approval (i.e., for all elevations) and continued the practice of leaving foam in place. When Gibbs & Hill learned of this practice in September 1977, it informed the Project that this deviated
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from the design concept. Permittees believe that this was their first notice of the issues underlying the TRT finding regarding air gaps between seismic structures.
TUSI memo TUS-5019 (November 2, 1977) instructed Construction to remove the foam forming material so as to maintain the design air gap between the buildings in most locations.
Elevations at which foam was required to be removed were identified and Halliburton Services was contracted to effect removal.
The inspection and documentation of this activity was assigned to Broun & Root QC. Brown & Root QC developed a temporary procedure CP-QCI-2.4-9, " Inspection of Elastic Joint Filler Material Removal," which was limited to delineating the inspection and documentation requirements for verifying the Halliburton work effort. This procedure referred to TUSI memo TUS-5019 as defining the guidelines and scope of the removal effort and, hence, the scope for this one-time inspection. A checklist was attached to this procedure to document the inspections performed.
As a result of TUS-5019, slip-forming, an alternative method of forming concrete, was thereafter used to form the structural concrete in most locations. Because most base l
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l mats and lower walls ware alrecdy poursd, this chenga primarily affected walls more than 10 feet above grade.
A Gibbs & Hill memo was issued on January 30, 1978, stating that the gap areas identified'in TUS-5019 were inspected by a TUSI Civil Engineer and a Gibbs & Hill Field
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Engineer, with the conclusion that the removal of foam for the identified areas was acceptable. The Brown & Root Site 1
Quality Control Manager issued a memo on February 19, 1978 (IM-12939), to the Construction Manager stating that Brown &
Root had also conducted inspections of the seismic gap between the Auxiliary Building and Containment Building #1 i
i to determine the effectiveness of the foam removal effort by Halliburton. This memo, contrary to the TUSI and Gibbs &
Hill inspection report, concluded that the foam removal efforts were incomplete and that further removal or engineering evaluation was required. A written reply to j
1 this memo was requested to define actions and schedule, After a reasonably exhaustive search, neither a written nor oral response from Construction management was found. The inspections referred to in IM-12939 are not the same as those done by Brown & Root QC under QC inspection procedure CP-QCI-2.4-9. Since the locations referenced in IM-12939 are different from those addressed in the two checklists whi,ch have been identified with CP-QCI-2.4-9, it is clear
- th'at these inspections were in addition to those conducted pursuant to CP-QCI-2.4-9.
Subacquant to IM-12939, tha QC proceduron ware rsvised to ensure that the seismic gap was in accordance with the design drawings at the time of concrete pouring. i (QI-QP-11.0-3) However, CPSES QA insdection reports subsequent to the removal. effort have identified foam forming material and other types of debris in areas where the design drawings require air gaps. (IR-C-7705,-06,-07,'
IR-C-0319, 0320). These reports -were attached to an NCR (C-83-01067) in April 1983 and sent to Civil Engineering for disposition. Civil Engineering closed out the NCR with a technical analysis which concluded that the 'naterials that are remaining in the air gap are of such size and nature l that they pose no structural or seismic concern to the adjoining buildings.
On 9/18/84, the NRC letter to TUGCO confirmed the TRT's concern regarding this issue. Subsequently, the CPRT was formed and ISAP II.c (Maintenance of Air Gap Between Concrete Structures) was issued to address the concern. In addition, on 10/16/84, QI-QP-11.0-3 (Rev.5), TUGCO prepour inspection procedure was revised to include reinspection criteria of seismic gaps to satisfy ccmmitments under ISAP !
II.c. Also, NCR C-83-01067-RI (Unsatisfactory Inspection i Reports) was reopened (6/21/85) to be addressed under ISAP II.,c. !
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(TRT ISSUE: GAP BETWEEN REACTOR PRESSURE VESSEL REELECTIVE INSULATION AND THE BIOLOGICAL SHIELD WALL)
At page K-180 of SSER No.8, the TRT stated as follows:
A significant construction deficiency report, submitted pursuant to 10 CFR Part 50.55(e), on August 25, 1983, documented that unacceptable
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cooling occurred in the annulus between the.RPVRI and the shield wall during hot functional testing, )
apparently because of the existence of an ,
inadequately sized annulus gap and possibly because of the presence of construction debris in the t annulus. TUEC corrected the situation by I modifications to allow increased air flow for proper heat dissipation and by removal of the construction debris. TUEC representatives indicated that testing to verify the adequacy of :
the cooling flow will take place when additional !
hot functional testing is conducted. Information l gathered by the TRT during the in'restigation l indicated that a design change in the RPVRI support '
ring (i.e., locating the ring outside rather than inside the insulation) resulted in a limited clearance between the RPVRI and the shield wall.
The TRT review of the 50.55(e) report revealed that TUEC failed to: (1) address the fundamental issue of the design change impact on annulus cooling flow, and (2) determine whether Unit 2 was similarly affected.
Permittees believe that the TRT letter of November 29, 1984, was their first notice of this issue. In summary, the TRT concern is that TUEC's 50.55(e) report of the test A deficiency regarding inadequate cooling did not include a determination of the underlying cause of the deficiency and did not include a determination of a potentially similar effect on Unit 2.
,The March 1973 original Westinghouse specification for th'e RPVRI required that the RPVRI structural steel support ring be contained inside the insulation. Per procedure, Westinghouse issued drawings for Construction regarding i
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Wastinghousa's plan for constructing tha support ring.
However, in the drawing issued for Construction by Westinghouse, the support ring is shown to exist outside the boundary of the insulation. No desigd change document or revision to the Westinghouse specification relative to the locationofthesupportoutsidetheinsulationboundrhhas been identified. This deviation from the Westinghouse specification was not communicated as a deviation to Gibbs &
Hill, and no evaluation was done to consider the impact of
{ the outside support ring on air flow and cooling efficiency 4
j between the reactor pressure vessel and the biological shield wall.
In April, 1983, TUGCO Startup identified inadequate cooling in the reactor cavity during Hot Functional Testing (HFT) and recorded it as a test deficiency. A meeting was held at CPSES on April 20, 1983, to discuss TDR-908 and appropriate disposition. CDA-17,367 was issued on May 16, 1983, to identify action taken to resolve TDR-908. A retest of air flow and cooling efficiency was conducted with unsatisfactory results. On May 26, 1983, TDR-1221 was I
- issued regarding the deficiency identified during the i
retest.
3 On July 28, 1983, TUEC orally reported the test l i
def,1ciency to NRC. On August 25, 1983, TUEC initiated its fo'rmal report of the test deficiency as a 50.55(e) item by
- submitting an interim report (TXX-4033). This was followed by submittal of another interim report (TXX-4042) on i
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Scptembar 6, 1983. On Ssptsmbar 26, 1983, TUEC submitted its completed 50.55(e) report (TXX-4054) regarding the deficiency.
i Westinghouse issued Field Change 8otice (FCN)
TBXM-10,609 on September 27, 1983, which documented the unacceptable condition. Westinghouse issued procedure MP 2.7.1/TBX-3 on October 1, 1983, which described the
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following equipment modifications to be made: (1) drilling holes in the support channel to facilitate air flow; and (2) installation of a flow restrictor at the top of the reactor vessel insulation (FCN TBXM-10,612).
Westinghouse completed hole drilling in the support channel between October 4 and October 14, 1983.
Installation of the flow restrictor and BMI tube vertical restraints was completed the week of October 24, 1983.
Confirmatory air flow tests were completed during the week of October 31, 1983, with acceptable results. On November 18, 1983, Westinghouse transmitted a letter to TUGCO which summarized the efforts undertaken to correct the reactor cavity cooling problem.
Following notification by TRT of their concern regarding the RPVRI on November 29, 1984, TUEC formed the CPRT and issued ISAP VI.1 (Gap Between Reactor Pressure Vessel Reflective Insulation and the Biological Shield Wall) to address the TRT finding as stated in the November 29, 1984 TRT letter and subsequently in SSER No. 8.
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. r (TRT ISSUE: IRREGULARITIES IN FUEL POOL LINER CCCUME"TATIO")
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At page 0-281 of SSER 11 dated May, 1983, the TRT found:
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Based on the TRT review of about 200 fuel pool travelers, TUEC was unable to maintain an effective and controlled QC program 'for fuel pool liner fabrication,.
installation, and inspection. Typical pool traveler irregularities were:
- 1. There was apparently a routine practice during construction of the fuel pool that allowed craft personnel to complete a portion of the inspection report forms prior to the actual inspection. Craft personnel entered the word " SAT," dated the entry, and left blank only the space for the QC
, inspector's signature. It appeared that the craft
,' ', personnel were judging the inspection results prior to inspections.
- 2. The date accompanying the signature.for visual examination of an inside weld was changed to a date that appeared to precede the examination.
- 3. Entries by the same inspectcf for two different inspections did act appear to match in that one entry appeared to be written by another person.
- 4. The procedure number for a dye penetrant inspection was changed by an inspector different from the one who conducted the inspection.
- 5. The date for a dye penetrant, inspection was changed by an inspector other than the one who performed the inspection.
6.
Fuel pool travelers were found with missing QC ,
signoffs for fitup and cleanliness. No proof could be found that some of the required weld fitup and cleanliness inspections were ever performed.
- 7. The TRT review disclosed the following irregularities with traveler entries in addition to those listed above.
(a) Date changes after the fact (b) Signoffs for functions out of sequence (c) Corrections after the fact (d) Changes to first party inspector date signoffs (e) Missing signatures
)
Permittees believe that their first notice of a potential issue with regard to fuel pool liner travelers might exist was on March 17, 1983, with issuance by TUGCO of
Nonconformance Rsport (NCR) M-83-00795. This report idsntified that "a random review of stainless steel liner travelers, for Reactor II Cavity Liner Welds has found required fit-ups/ cleanliness inspections of inside (watar i side) welds cannot be verified as being performed. The ;
~ i quality of welds is indeterminate." This NCR was dispositioned as "use-as-is" with the notation that, "
" subject welds are seam welds utilized to provide leak tightness of the liner. Acceptability of welds shall be based on vacuum box and hydrostatic tests." TUGCO QA verified the disposition and closed the NCR with the action being documented on the NCR (03/23/83).
The NCR was reopened as Revision 1 on 03/28/83 to delete the reference to the random selection, leading to the inference that only the listed welds were affected and therefore an investigation would not be required. The disposition and justificatica emained unchanged.
Revision 2 of this NCR was issued on 08/08/84 deleting Weld 1225 (a plate-to-embed weld) from the listing of welds affected. (Revision 3 was eventually issued on 04/30/85 changing the justification of the disposition based upon the declassification of the Reactor Cavity liner by Revision 4 of Specification 2323-SS-18, Gibbs & Hill Specification for the, construction and inspection procedures used for fuel pool liner erection and welding.)
Following the issuance of NCR M-83-00795, several other Nonconformance Reports regarding fuel pool liner
e documantation ware issusd by TUGCO prior to the publication
. . of the NRC-TRT findings. All of these Nonconformance Reports were eventually closed by TUGCO QA following verification of their disposition. THe following list identifies the subject NCR's, their date of issue and a brief description of the nonconformance: ..
NCR M-83-OO907 03/28/83 Premature Signoffs of Inspections NCR M-83-01000 04/07/83 No Evidence of Particular Inspection Being Performed NCR M-83-01135S 04/21/83 Lost Travelers NCR M-83-01188 04/26/83 Premature Signoffs of Inspections NCR M-84-00647 02/24/84 Vacuum Box Inspection Marked 'Not Applicable' on Traveler i
NCR M-84-00668 02/27/84 i
Missing Weld Documentation NCR M-84-00669 02/27/84 j Vacuum Box Inspection Marked 'Not Applicable' On 4
Traveler NCR M-84-00670 02/27/84 Vacuum Box Inspection Marked 'Not Applicable' On Traveler NCR M-84-00682 02/28/84 Vacuum Box Inspection marked 'Not Applicable' On Traveler i NCR M-84-01969 07/05/84 ;
No Evidence of Particular Inspection Being Performed NCR M-84-200037 07/30/84 Missing Weld Documentation i' NCR M-84-200038 07/30/84 Vacuum Box Inspection Marked 'Not Applicable' On Traveler NCR M-84-200039 07/30/84 Vacuum Box Inspection Marked 'Not Applicable' On i Traveler NCR M-84-200093 08/23/84 Missing Weld Documentation
,'On 01/08/85, the NRC letter to TUGCO confirmed the TRT concerns regarding fuel pool traveler irregularities for I l
fabrication, installation and inspection. Following the 1
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formation of the Comanche Peak Responsa Tecm (CPRT), En
.- Issua-Specific Action Plan (ISAP) VII.a.8 (Fuel Pool Liner Documentation) was issued to address the TRT findings
. s regarding fuel pool liner plate record anomalies.
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4 00LKETED CERTIFICATE OF SERVICE LkNHC I, R. K. Gad III, hereby certify t' hat on April ,
g ge service of the within document by mailing copies thereof, postage prepaid, to: OFFICE F EE.JE iA10 00CKETING s bVid.
BisANCH Peter B. Bloch, 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 i Administrative Judge Midwest Office 881 W. Outer Drive 3424 N. Marcos Lane
! Oak Ridge, Tennessee 37830 Appleton, WI 54911 i 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 Lawrence J. Chandler, 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 l 1
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Renea Hicks, Esquire Ellen Ginsberg, Esquire Assistant Attorney General Atomic Safety and Licensing Environmental Protection Division Bodrd 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.
Suite 600 Christic Institute 1401 New York Ave., N.W. 1324 North Capitol Street Washington, D.C. 20005 Washington, D.C. 20002 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 Service), Inc.
101 California Street Suite 1000 l San Francisco, California 94111 I
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R. K. Gad II,F "
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