ML20206U753
| ML20206U753 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/19/1985 |
| From: | Denise R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Noonan V NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM) |
| Shared Package | |
| ML19284C882 | List:
|
| References | |
| FOIA-85-59 NUDOCS 8607110119 | |
| Download: ML20206U753 (21) | |
Text
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- w PlUCLEAR REGULATO3Y COMMISSICTJ
\ f i, 'l 'c RIGloN IV
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{k k.yJ. / [ PARKWAY CINTRAL PLAZA DUILDING 611 RYAN PLA;'A OnlVE. SUITE 1CCO
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A 3 Li p,9Io 'J.,T E.%". 7CC11 er r. A 0 cca MEP.05ANCUM FOR:
V. S. Nconan, Cirector, TRT FRCM:
R. P. Cenise, Directcr Division of Reactor Safety anc Projects, RIV TELEPHONE CALL BETWEEN V. S. N0ONAN AN J. ELLIS ON FEBRUARY I,
SUBJECT:
1985, DISCUSSING REACTOR COOLANT PUMP MOTOR FAILURE AND CUTTING SPENT FUEL POOL LINER On March 6,1985, a memo was forwarded in response to a noteThe fromfollowing V. S. Noonar.
to D. M. Hunnicutt, above subject, dated February 6, 1985.
provides additional information.
- 1. Ms. Ellis asked if the TRT was aware that the reactor coolant pump motor which failed some months ago, failed a second time soon after the initial event.
PRP0NSE: On
.nere has been only one reactor ccolant (RC) pump failure at CPSES.
October 28, 1984, while filling and venting, the Unit 1 RC system,This No. 4 ::
pump motor trippad due to a phase A and B overcurrent condition.
overcurrent condition was a:parently caused by a stator winding insulati:-
breakdown. A piece of metal resemcling a washer could have caused the insulation breakdown. This puma motor failure was considered by the applicant to be an isolated incident on a nonsafety-related component.
This failure was discussed with Ms. Ellis during a meeting at the DFW Airport Hilton Hotel on November 7, 1984.
The "second failure" Ms. Ellis cculd be referring to occurred on January 4, 1985. This was not a failure cf a RC pump motor, but, rather, was a seal During the plant cooldown leak on No. 2 RC pump shaft seal assembly.
that followed the het plant tests (mini-HFT) conducted in November an December 1984, an cperater observed excessive leakage coming frcm a seal. Ucon disassembly and inspection of all three seals on No. 2 RC pump, the applicant notad a degradation of the "dcuble Delta seals" The applicant checked(No.
tre2 seal was the worst case. See figure 1 and 2).
seal ring assemblies on all RC pumps for similar problems and is investi-The NRC gating the cause with assistance form the pump seal vendor.
l Resident Inspectors are fellcwing this proolem to ensure the corrective l
actions are adequate. If appropriate, the applicant will issue a l 10 CFR Part 21 report.
The only other recent pump failure that occurred during the mini-HFT was Train A Residual Heat Removal (RHR) pump. Apparently, The a rumor was RHR pump faile.-
started that this was a RC pump, which was not true.
due to loss of suction cn Decroer 1,19S4, while the operator was on the line during Thermal Expansion testi";
attempting to placa the m 0Thc icis of suction was caused by an automatically of piping supports. The applicant is centrolled, motor opera 2d suction valve being snut.
l 8607110119 860624 PDR FOIA CARDE85-59 PDR ' en p i - - - -_ ____._,m,. , m_ __ _
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l V. S. Noonan 2 investigating the cause of the valve being shut. Possibilities include spurious centrol signals, operator error, or other control circuit problems. The failure occurred when the upper wear rings Thiscame into stalled the contact and friction heating welded the partsThetogether.
NRC Resident Inspectcrs are pump and the motor tripped (See figure 3).
folicwing this investigation.
- 2. Ms. Ellis indicated that she had heard that the utility was cutting spent fuel pool liners in Unit 2 for the purpose of looking at the concrete.
She indicated that she could not substantiate this allegation but wondered whether, (if it is true), the TRT should review this and whether board notification was necessary.
RESPONSE
In August 1982, applicant personnel made preparations toWhile pour removing the concrete annulus around the reactor vessel for Unit 2.
the expanded metal framework frcm the reactor side of compartment ccncrete walls, a void in the concrete at the bottom of the stainless steel lir.er The applicant docum.arted wall for compartments 1 and 4 was cbserved.
this void en NCR C-52-01202. The recair of the icentified void re:Lirec removal of a porticn of tha stainless steel liner; therefore, final disposition of NCR C-82-01202 was delayed until a later time due tc During the late emphasis to complete construction activities for Unit 1.
1984, applicant rescurces were made available to accomplish work related to the concrete void.
To fully evaluate the extent of voids and confirm repairs, three areas of the liner were removed and concrete excavated by applicant personnel.
To assure full definition of the suspect area, a grid pattern of li-inch diameter prebe holes and greut holes was used The applicant reviewed the grid pattern results and compared the grid pattern results in These reviews indicated compartments 2 and 3 to ccmpartments 1 and 4.
that voids do not exist in ccmpartments 2 and 3.
The repair precedure (DCA-20S56) recuired that the total extent of :ne concrete voids be determined and repairs be made to the identifiec to concrete voids. Twenty-five bags of grout (1 cubic yard) were use:The CCA make the repairs. The repairs are dccumented on greut card 261.
incicates that the voids were not extensive (28 scuare feet by E incnes
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General Ccreents Applicants 10/S/84 Plan places the sar.e individuals in char;e of correcting the problets who initially helped cause or allowed the preb'.e s to develop to begin with.
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ITI" SU'!EER II.b -- Concrete Compression Strencth ---
Pages 1 '.: The specific alle;stions set forth by the Technical Refiew Tean
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. w'.*.5. cold wea.'..er c-..c. e .e . . c". .. '.... c. .' e v esn5 9/12/53 letter to the 3 card from NRC Staff Ccunsel, attaching ccpies of Inspettien Reports 77-01 and 77-04, regardin; cold weather concrete curing. See also semd Inspection Report S3-24/S3-15, by then-v-.- -
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(2) A review of NCR's referenced in CASE Attachment D indicates that the Applicants' concrete is not in compliance with the original design.
(3) A review of NCR's (CASE Attachment D) indicates that the quality and compressive strength of the concretc at Comanche Pe is indeterminate at best, and in some instances appears to be deficient. This review calls into question the quality of all of Applicants' concrete.
(4) .It appears that the field cure cylinder for concrete pour #201-5781-001 for the Reactor #2 cavity wall of 2/13/76 was 3559 psi-lbs. (below Applicants' stated design strength of 4000 psi-lbs.)
and the two standard (or labor'atory-tested) cylinders indicated a.
strength of 4257 and 4219 psi-lbs. (which is under Applicants' claimed actual strength of 4500 psi to 5000 psi).
It also appears that this concrete was never retested.
(5) On many of the Nonconformance Reports (NCR's) or Deficiency and Disposition Reports (DDR's, the predecessors to NCR's) discussed in Attachment D, there are numerous concrete pours which had field cured cylinder compressive strenghts less than the 4000 psi which the Applicants claim is their design strength.
(6) At one point Brown & Root informed Texas Utilities that they would retest each concrete pour which was listed on the deficiency report, the attached documents indicate that thev did not.
In fact, on DDR No. C-449, for example, they only retested 6 pours out of 20; there is no indication that they ever retested 3
J the others; on DDR No. C-457, they retested 2 out of 16; on DDR No. C-499, they retested 17 (plus one additional second retest of one pour) out of 39; on DDR No. C-529, they retested 14 (plus additional second retests of three pours) out of 22 (a larger percentage than they tested on any of the other pours involved in documents which are discussed); and on NCR C642, they retested 8 out of 20.
(7) On CASE Attachment D, there is a listing for several DDR's (or NCR's) which shows not only those field-cured cylinders which tested oelow 4000 psi-lbs., but also (marked by **) those standard (or laboratory-tested) cylinders which tested below 4000 psi-lbs.
It is important to note that in no instance were concrete rebound hammer tests done for the concrete where both the field-tested and the standard (or laboratory tested) concrete showed to be below 4000 psi-lbs. All of the concrete rebound hammer retests were done for concrete pours where the standard (or laboratory tested) concrete initially showed to be 4000 psi-lbs. or above.
(8) Applicants did not promptly and effectively institute action to correct the cause of the problem.
Further,.despite the number and extent of the problems identified on the DDR's, all of them were marked: " Reportable Deficiency: No."
On NCR C642, Revision 0 was not available for file, which indicates a breakdown in document control.
4
6
- C642R1 was issued to delete the requirement for a Corrective Action Report (CAR) to be written up; C642R2 was issued to add back the requirement for a CAR. A review of that CAR, S-8, was totally inadequate and did not identify the root cause or correct the real problem.
(9) Applicants appear to be assuming that a sister pour near one which N
.was deficient is a good pour (based on the initial field and ,
1 laboratory tests similar to those which indicated that the other pour was deficient) and they use it as a comparison for the deficient pour. How can they be certain that the tests for the supposedly good pour are correct and those for the deficient pour -
are incorrect? How do they know that it is not the other way around; i.e., that the tests for the deficient pour are correct and the tests for the good pour are incorrect? If this were in fact the case, it could mean that instead of the retests showing y
that both pours are good, it actually means that both pours are 3 deficient. ,
(10) There is enough variation of results within the same group of I
comparison tests to call into question the accuracy of the tests. I I
(11) There are documents in the record which indicate that there were i also extensive problems with the water meters which were used to I f
measure the amount of water which went into the concrete pours; !
this could have an adverse impact on the quality of the concrete.
(12) Applicants stated that they reviewed a representistive sample of {
test reports of concrete used at CPSES and also they they reviewed 5
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.. . _ _ _ _ _ _ _ _ _ a
b NCR's regarding concrete, and that from their review, they concluded that test conditions are representative of conditions at CPSES. There was not any documentation to support Applicants' statements, and it is unknown what test reports and NCR's they reviewed, but the ones which Mr. Walsh reviewed certainly did not lead him to the same conclusion as reached by Applicants.
(13) The testing procedures used to certify the concrete at Comanche Peak were not in conformance with established codes. This is especially important since these were retests done of concrete pours where field-tested concrete cylinders tested out at less than desired.
The retests which were done apparently used a concrete rebound hammer test to verify that concrete which appeared to be defective or weaker than desired was, in fact, adequate. This test was a rebound test and would fall under ASTM designation C805-79 (see Attachment E heesee). This ASTM specification states at paragraph 3.2:
"This method is not intended as an alterative for strength determination of concrete." (Emphasfe idded.)
ASTM C805-79 also stated in paragrant 2.3' "The rebound number determinec Ly c..r. method may be used to assess the uniformity of concrete in situ, to delineate zones or regions (areas) of poor quality or deteriorated concrete in structures, and to indicate changes with time in charactistics of concrete such as those caused by the hydration of cement so that it provides useful information in determining when forms and shoring may be removed."
6
9 it appears that Arplicants have used a concrete rebou-i :es:
to c,ualify substandard concrete to justif:- coor concrete ir :he l
field.
t (14) Even if one were to accept the concre:e rebound test as an acceptable method for retesting the strength of the concre:e (which woul'd be contrary to ASTM C805-79), AST:1 also sets f;rth certain specific criteria for testing and reportinz, several of which Applicants have not cet. (Mark 'Jalsh did net. have tire to 3
go into detail regardinz these in his Affidavit, but attached sc e documents, Attachments I, F, and G, to his Affidavit, whier centained soma infor ation in this re;2rd.)
(if) There are also sc e addi:icnsi cau:icns and drawbachs re;;rcin; the,dse of concrete rebcund tests which :t e discussed in nttachnee.ts c, c , and u.
n & .or l,x4 exacpae:
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(a) The tests cust not be recarded as a substitute f:r standard contressien tests.
(b) The cethod should be used f:r cercarative purposes.
(c) T'ae method tes ts enic the surf:ce and does no: :_ve a good indicarica cf the actu21 strenz:S of the cencr2te.
(d) The results of the tests are affe::ed bv 3 w de zarie:-
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of conditiens, such as the :e af the tes sce;..cr, i n -:
surface and internal moisture condition of the ::acrete, the type of coarse a;;regate, the type of cemen:, *ne type of m',c, the carbonatic n the cancr m '
the C X C: Je4 .T f t ', *, e , 1 " f J. ; 5 .' 3 O .' J ~ , t: , ,
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i 4 i shape, and rigidity of tes: specimens, whether er no:
1 the same test hanner is used for the tests, hancer tyre, etc. Much of this infor:a: ion is not indicated.cc the i concrete-rbound hammer tes: reports referenced-in' CASE Attachment D hereto.
i (16) Once Applicants discovered that there was the possibility of deficient or defective concrete, what they should have done :o test it was to drill a core sample for each pour and tes that.
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I (17) Mark Walsh stated that his brief review of the docu=ents referenced in CASE At:achment 3 ' - r , coupled with the s: ate:ents cade in AST.: CS05-79 and c:har documents whi:5'.S attached, have raised doubts in his mind, no: only regarfine the Rich =cnd inserts, but also regarding the quality of all of :he iI concrete at Comanche Peak.
There are other more acceptable and reliable =ethods available ::
retes: the concrete a: Co anche Peak. For fur:her information regardinc this, CASE Attach en: D and supporting documen:s for it, contact CASE
?residen: Juani:a Ellis.
In additien, there are other documen:s anc informa: ion whi:t rs. El is would like to discuss cth the Technical Revier Te.: 's expert or 00 ::::: .
id '
I portions of CASE's Answer to Acplicants' Statemen: >f j ( See e--
7 taterial Facts Relating to Richmonci Inserts As To Which There Arr=
- 2: '
llaterial Facts. In the form of Affidavit of CASE Witness idark Walv I 9 / l l /M . ans.vr 3, paces 13-:?: CAS: At:achten: 9 thereto, Sutra r-S.ilec rec. Docueent s Recar.d i - - t'.3n. r et.- Nura at t'.smane ne Pe ak ; an- ,
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l Attachment E thereto, ASTM C805-79, " Standard Test Method for Rebound Number I
of Hardened Concrete.")
l ITEM NUMBER II.c -- Maintenance of Air Gap Between Concrete Structures It is CASE's understanding that there was an area between buildings, where the Safeguards Building connects with the Containment Building, at a door, where e.here was nc1J30. (If necessary, CASE believes it can obtain affidavit (s) regarding this.)
The TRT should also be certain that the area between Category I and Category Ij[ structures are checked. If Category II structures are not designed as seismic Category I, they could possibly fall into Category I structures under seismic conditions; so they must also be reanalyzed.
ITEM NUMBER II.d -- Seismic Design of Control Room Ceiling Elements This was an allegation sent by CASE on 3/11/83 to the NRC's Office of Inspection and Enforcement (see :t- '-f ,, :f Inspection & Enforcement (I&E) Report 50-445/83-24, 50-446/83-15, the inspection / investigation of this and other matters by then-NRC Senior Resident Inspector - Construction at Comenche Peak, Robert Taylor item 10, pages 8 and 9 of Appendix).
l Page 3 of 10, paragraph 3: Why was it originally constructed as non-seismic i
! and non-safety related? Who created this philosophy? And where else in the l plant has that same philosophy been used?
l 9
Page 4 of 10, ' paragraph 2: Was the evaluation for this particular item and all items under consideration for item II.d in compliance with FSAR section 3.7B.3.5 (;_pr ::- '-3), which requires a 50% increase in load above the peak for the response spectra curve (i.e., 1.5 times the peak) to take into account multimodal response. Assurance of this is necessary because the Applicants neglected to consider this 50% increase in the design of the cable tray supports, as evidenced by the testimony of Cygna Energy Services in the May 1-2, 1984, operating license hearings (contact CASE for transcript pages). In addition, Applicants had allowed their cable tray supports to be overstressed, even without including the 50% increase. Also, Applicants have made inappropriate assumptions in their analyses. One of the inappropriate assumptions is that cable tray supports are always rigid in the vertical direction (i.e., a natural frequency above 33 hz.). The importance of the cable tray supports to the ceiling is that the same group of engineers qualified both structural appertenances.
Page 5 of 10, paragraph 4(a): Applicants state:
"The present design of the ceilings was predicated on the position that failure of architectural features with small masses would not be adverse to the occupants of the control room."
What Applicants are saying here is that they deliberately designed the
( ceilings with the idea that it was all right for the individual members (such as lighting fixtures, parts of the ceiling itself, etc.) to fall o'n the control room operators, but that this would be all right because the
" architectural features" have "small masses."
10 1
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Obviously, the Applicants have not defined what are "small masses." A small mass could be a dust flake, from which there would be no injury to the control room operators. But a "small" mass might also be a piece of gyp board falling on a control room operator or a lighting fixture falling on a control room operator. These two items could also be (and apparently were) considered "small tssses" by the Applicants. These two "small" masses could be sufficient to injure and incapacitate the control room operator.
It should also be noted that Applicants' present position is certainly not what was indicated in the inspection / investigation report done by then-NRC Senior Resident Inspector - Construction at Comanche Peak, Robert Taylor (see ser; ---- ':? ;f I&E Report 50-445/83-24, 50-446/83-15), item 10, pages 8 and 9 of Appendix, especially page 9, second paragraph). It should al'so be noted that Mr. Taylor stated in his report that (item 17, page 17 of Appendix): .
"The SRIC met with one or more of the persons identified in paragraph 1 of this report at frequent intervals during the inspection period to discuss the licensee's position and proposed actions on a significant number of issues which occurred during the period."
Further, if the report had been inaccurate, the Applicants should have called this to the attention of Mr. Taylor and the NRC Staff.
Page 5 of 10, item 4(a)(1), first paragraph: When was this " initial evaluation" made? It appears that it was first done for Applicants' Program Plan in answer to the TRT Report. Obviously, it should have been done before they put up the control room ceiling to begin with. It also appears that Applicants propose -- apparently without having done any analysis or l
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notion, in the interest of ex:ediency. They shoule perf3r calculati:ns and analyses before takin; their fix. And CASE should be allcwed to have CASE Witness *1 ark Walsh, who is the individual who first becught this :o CASE's attention, review such calculations and analyses.
Another question is: Of all the hundreds or thousands of people who have kone through, or worked near or in the control roon since that ceiling has been up, why didn't anyone else besides Mr. Walsh recognize the design faults? Or did others notice it, only to be told it was none of their business, or were they intimidated and afraid to centien it because they
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Page 6 of 10, iten (2): L.ns: is a ":::al seis.ictlly cualified sloped
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c e illn;" Wasn't that wha: :ney were supposed to have had before? The :RC Technical Review Team should require that Applicants submit the design before they allow Applicants precure or install this latest " f i:< . " Further.
CASF. Witness Mark Walsh shoul- be pr:vided wi:5 the desi;n and allowed c
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"!en-Category I e:uin.cn: and cen onents located in s isnic CatcJort i buildines are inzes:icated by analysis or testing, or both, to ensure that undar the p escribe; earth:uake lea:inz, structural integetty 13 maintained, and ta ens e r.' :!:: :ne: do not adversely affect the in t e:::i t . a r er >r m i L . . .'r H:". of ane :esi:nat ed seisnic Cat xtor' '.
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the pen for the response spectra curve (i.e., 1.5 tines :ne peak) :: :ake into account culticodal response. As discusse d in the precedin:, assurance of this is ne:essary because the Applicants neglected to consider this 50f, increase in the design of the cable tray supports, as evidenced by :he testimony of Cygna Energy Services in the May 1-2, 19 8!. , cperating license hearings (contact CASE for transcript pages). In addition, Applican:s had allowed their cable tray supports to be overstressed, even withcut including the 5% increase.
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re; rd Page S cf 10, iten (b): This nee:s : be specifically : nsidered 1 to this particular iten, rather than assumin; tha: it will all be taks. c:re of thrcu;h sete eeneric "fix."
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COMMENTS ON APPLICANT'S PROGRAM PLAN AND ACTION PLANS (October 8, 1984)
General Plan [u _
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(Page 3 of 15)
I. Personnel Qualifications / Testing: This is being do#d e in compliance with existing CPSES QA provisions--when the QA/QC portion of the TRT review has not yet been done by the NRC.
IV.A (page 4 of 15): "The personnel assignments to this project reflect the importance that TUEC has attributed to its successful conduct and completion."
But on page 7 of 15 in titis section, they have put VEGA in charge of QA/QC--and TOLSON in charge of protective coatings! And (on page 4 they put MERRITT in charge of the whole sheebang as Program Manager!
He of T-Shirt Incident and Lipinsky memo fame. . .) r r 1r g 4 e y v--i n m 6 - m+ ; ;).
In addition (page 8 of 15) McBay is in charge of Issue I.c/II.d--
and Vega is in charge of Issue I.d.l.
NOTE: On page 10 of 15 they say that the assignment of these persons to theid tasks was based on "the need to utilize eersonnel with demonstrated ability to make objective evaluations and decisions" TOLSON? VEGA? McBAY? MERRITT?
ITEM NUMBER I.c - Electrical Conduit Supports A N ce m c -%, p./
fIWeneeddiscoveryonmanyitemslistedinthissectionthatareapplicable to ongoing items at issue in the other portion of the hearing--but of which we were unaware of their existance until now. These items include:
k - All documentation associated with the Damage Study Program. (Page 1 of 4) f g
- All documentation associated withhabl seismic /non-seismic interaction study performed "in 1983" including the walkdown of 287 rooms.
- A copy of Engineering Instruction CP-EI-4.0-36 " Control of Seismic and N@ Non-Seismic Component Interaction Evaluations)" (ALL REVISIONS) .
- A copy of Engineering Instruction CP-EI-4.0-53 " Maintenance of Damage i
k Study Analysis" (ALL REVISIONS).
) - A copy of DCA-4693 delineating support requirements for 2" and under N 4 diameter conduit (ALL REVISIONS).
$g - A copy of all summary documents (4.a on page 2 of 4) , seismic analyses y4 (4.b, page 3 of 4) (both original generis analysis and any later revisions)
( and all documentation of the sampling program to verify field installation ,
j (4.b, page 3 of 4).
A - Conv of Reg. Guide 1.29 (All revisions)
- CASE objects to the sampling program proposed"by~ Applicant as being in-sufficient response to the concern.
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Comments on 10/8/84 Program Page 2 ITEM NUMBER I.d.1 -QC Inspector Qualifications
- 1. The NRC envisions a two-tier approach: if the qualifications, etc. are OK per procedure for a particular inspector, then his work is OK-but if it is not per procedure, then all of his inspections should be reviewed for adequacy and impact.
TUEC proposes a three-tier approach to qualify otherwise unqtGalified (per pro-cedure inspectors) outside of the procedures by a SPECIAL EVALUATION TEAM--who are not identified by name in the program plan. This list of their evaluation criteria (page 5 of 8 under Phase II) includes "Other considerations deemed appropriate by the SET)"--which could. include anything and probably will! TUCC's assurance of " expertise" is hardly enhanced by putting such personnal as TOLSON and VEGA in charge of the program parts to begin with--and CASE assumes that similarly " experienced" personnel will be on the SET. This way, TUEC hopes te keep any hardyare/ documentation reviews to a bare minimum (page 6 of 8, A, 3rd para.)
- 2. The NRC required an evalaution of ALL electrical QA/QC inspectors.
Applicant only commits to evaluation of every non-ASME electrical inspector Applicant (without proof) claims that the ANI has previously revived all ASME electrical training /certifica. tion records (page 4 of 8, 2nd para-graph af ter Example 5 paragraph; also 4. A first paragraph) . (Curiously in 4.A TUEC commits to reveiseing certifications for ALL electrial ins _p.ectors NC_LO.GERN ON SITE, but only non-ASME for those currently on s1 C Is this (directed against potential CASY witnesses???) WE NEED DISCOVERY RE ANI re ASME ,
(QA/QC inspector checks of certification / training, etc.
4 7{ -
- 3. The review of all inspector files (Phase I) will be done by TUGC0 Audit group (page 6 Of 8, item C)--a group not known in the past for great work.
- 4. (Page 7 of 8, D, 3) Note that VEGA is Issue Coordinator for this item---
not guaranteed to elicit confidence-especially since he is now in charge of QA--and was previously in charge of AUDITS.
ITEM NUMBER I.d.2 - QC Inspector Tests NOTE: Team leader for this item is VEGA.
(page 2 of 2) TUEC only comdits to FUTURE tests under revised procedures (4, 2nd paragraph) . This is not suffic Q --all past testyneedtobereviewed to any revisions. FRC x;;1d ;;; i- listed this-itti.pf -they did not tidnk :Lt :h: existin3 guccarues 4 e-not inadequa'ter I
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Comments on 10/8/84 Program Page 3 ITEM NUMBER II.a - Reinf orcing Steel in Reactor Cavity - % 4 g .
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We need discovery on:
- The analysis of "asbuilt" reactor cavity which will be performed - M /k d-(page 2 of 3, 4-Scope) by Gibbs & Hill (considering all applicable / mp /)/
loading combinations) . . _
NOTE: It is important that no cales apparently were done at the time of approval of the addition of rebar to the next higher level to ensure that the "fix" was OK-THIS IS APPALLING " ENGINEERING".
- All documentation on all frilitarices of reinf orcement omission in all saf ety-related Class I structures (page 2 of 3, under Expanded Review)-
including all documentation and engineering cales, etc. supporting all dispositions. --- -. ._
p h ysc.p l m 1(
ITEM NUMBER II.b - Concrete Comoression Strength Q ; p- ' A b Y-(SEE m.m.C FAe3 E = -JJm"A)
ITEM NUMBER II.c - Maintenance of Air Gap B etween Concrete Structures
/
- 1. Defineo" inaccessible areas" (page 2 of 6, under 3, 3rd paragraph) and define " conservative estimates" (same) .
- 2. Define "best-eff ort' ba sis" (page 2 of 6, 4.1) . M /#
~
- 3. {We neeci disco [ery on item 4.3 (page 3 of 6): .1 All documentation regarding the re-evaluations to be performed "using similar methodology with revised stiffness (or_ spring values) based on actual debris characteristics and locations". This evaluation will
" determine the changes in frequency from the original mode and evaluate (interaction effects." (Also what changes in compoents, piping, etc. result.) j 4 ] This sounds like a big mess--since they have not outlined the allegedly 4 y,y "similar" methodology, nor given the " revised values" (for two different types of values, yet!)--to produce calculations that will change the
,j ig,/ l seismic I
calculations for possibly many components and piping (4.3, last
(/'Y* h/ sent enc e) .
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Comments on 10/8/84 Program Page 4 ITDI NUMBER II.c (continued)
Also, 6 the proper personnel to do e visual examination are engineers, not QC personnel who may not be trained to know what should and should not be there (e.g. , concrete).
ITDi NUMBER II.d - Seismic Design of Control Room Ceiling Elements (SEE . M : $& U u
ITEM NUMBER II.e - Rebar in the Fuel Handling Building (LCneed discovery on the design cales to be performed that will "denonstrate (that structural integrity wilQ maintaine. . ." (page 2 of 3, 4 - Scopt e . .
T M ns / wp / pl ITEM III.a.3 - Technical Specification for Deferred Tests M IW M' T P' o f Te need discovery on be authorization to defer the seven (7) preoprational '
tests by NRR--including the technical rationale, calculations, etc. for so doin;;. l I
i We also need discovery on the special test exceptin to the technical specification l for snubber operability (page 1 of 2, 3-Backg,round). [ CASE lEdTiled-a motion f or
'M c~ontention last f all (1983) regarling the punch list and the themal expansion tests and the cases of snubber f ailure during hot functional tests--and this all points to data that could allow our contention in at this time--or at least point out that they still have problems with snubbers in the hot funcitonal/ thermal expansion tests.
TR rk CM& lv
(*MME C0hTENTION)
I'7
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Comments on October 8,1984 Program Page 5 ITEM NUMBER III.a.2 - JTG Approval of Test Data yg Need aiscovery onia11 documentation regarding def erred preopeational test completed as it is done.
We also need all information on thermal expansion test with the goal of completion at the 30% testing plateau (pre ascension to 50% power). This is crucial inf ormation (see III.a.3) regarding our proposed contention (disallowed last fall)--and also for rate hearings. Something is drastically wrong with snubbers--since in the .
August ,1984 meeting on site (between TRT and TUEC) regarding some motions for summary dispostion, the TEUC personnel referred to a new " snubber reduction program, We want to know WRAT is going on, WHY, and if the FIX is permissible from an en-gineering .(and cost) standpoint. (Why did they put in snubbers in the first place if they didn't need them? And why take them out if you do need them? Or is it not 4 possible to .)fix the snubbers s,o that they will work during actual plant operation c . etc . etc GENERAL OBSERVATIONS ON PROGRAM PLAN:
- 1. Where the NRC denands 100% reinspectfAjs, TUEC decides for itself that it will do a " random sampling" of only a limited number of items in question.
J,s
- 2. Where NRC gives a set plan, TUEC adds at least one or sometimes more steps to dilute the force of the NRC plan (eg. QC inspector review of training) .
6 JS
- 3. TUEC blandly admits to not having calculations in many engineering cases. $^/)
z and promises to " generate them" NOW. Th A., py/ p yt./ 2.. N *
/ c c.f A. h a - n , G y . g ,
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4 TUEC claims to have "found" documentation that the NRC TRT did not see or d (f or scxne reason) did not use. E:jj
- 5. TUEC downplays the significance of any item under discussion and asserts that it will prove that no problen is safety-related.
Mi'
- 6. All cover sheets f or each iten .were signed off (prepar[, reviewer, program sh manager and senior review team member) on the same day, October 5,1984-- ,
While individual issue coordinators could well have had a due date of October '
5-it does not seem that a thorough review of all such plans could have been reviewed by the review team leader (if he had several to review)--and especially that all could have been " reviewed" in depth by the program manager or the senior review team member ON THE SAME DAY. This shows that shallow
" rubber-stamping" that will occur in this impressive-on-paper "def ense-in ,
depth" levels of review.
- 7. NOTE: Whoever signed the " Senior Review Team" on most issue cover sheets did so in a color of ink that did not repooduce--we can't read the signatures and need legible copies of all cover sheet's.
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MEMORANDUM OF CALL Previous editions usabfe lh <f/;E c E C ALLb
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