ML20210E448
| ML20210E448 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/03/1987 |
| From: | Eggeling W, Powell L ROPES & GRAY, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | GREGORY, M. |
| Shared Package | |
| ML20210E454 | List: |
| References | |
| CON-#187-2467 CPA, NUDOCS 8702100307 | |
| Download: ML20210E448 (8) | |
Text
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w UNITED STATES OF AMERICA 00CKETED
' NUCLEAR REGULATORY COMMISSION UNC before the 87 FEB -9 A10:36 ATOMIC SAFETY AND LICENSING BOARD GFri:.
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In the Matter of
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Docket No. 50-445-CPA
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TEXAS UTILITIES GENERATING
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COMPANY et al.
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(Comanche Peak Steam Electric
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Station, Units 1 and 2)
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PERMITTEES' INITIAL 1 RESPONSES TO "MEDDIE GREGORY'S INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS (SET 5)"
Pursuant to 10 CFR $$ 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,"
i inclusive, as contained in the document entitled 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.
8702100307 870203 PDR ADOCK 05000445 G
PDR d503 e
"M ddie Grsgory's Interrogatorios end Rcquest for Production of Documents (Set 5)," insofar as the same are contrary to the Rules of Practice.
l 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 identifie'd 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 tha NRC in 1978 and 1979 integrctsd into-Applicants' response to the findings by the Management Analysis Corporation (MAC)?)
PERMITTEES' RESPONSES (Issue:
Terminal Lug NCRs)
At page 2 (Enclosure 1) of the NRC TRT letter dated 9/18/84, the TRT found:
cases where nonconformance reports (NCRs) concerning vendor-installed terminal lugs in the GE Motor Control Centers had been improperly closed.
The TRT made these findings more specific in January 1985 in
'#~
SSER 7:
(1)
The disposition block of the NCR form stated that many of the lugs were " determined not to pose an equipment serviceability problem."
However, there was no reference to or evidence of an engineering evaluation, as required by the lug manufacturer prior to a change in the acceptance criteria on NCR E-84-00972.
(2)
Only the " bent" condition of the lugs was addressed by both the vendor representative and TUEC Engineering.
Neither the mechanical strength nor the electrical characteristics were ever addressed with respect to " twisted" lugs.
The TRT determined that these NCRs were improperly dispositioned in that the full scope of the identified problem was not addressed and the "use-as-is" dispositions were not adequately justified. (Page J-30)
Permittees believe that the TRT finding was their first notice of this issue.
However, we have also determined that...
tha Permittsas might ba said to have hed notica of a relatsd concern when TUGCO QA/QC issued the first NCR relevant to this TRT finding on 3/29/84.
At that time, while replacing 4
a G.E. thermal overload relay, it was noted that bending of J
terminal lugs (beyond 90 degrees) would be required for proper installation on the relay.
Because this appeared to exceed the manufacturer's criteria for field lug bending, as established in Vendor letter 16,624, NCR-E84-OO972 was generated.
Shortly thereafter, TUGCO QC inspection revealed excessive bending of the lugs on the ITE Gould-Brown Boveri switch gear.
In some instances the bending was in excess of 60 degrees.
Thus, NCRs E-84-OlO66 through E-84-01081 were issued.
In response, AMP Product Corporation, the lug l
vendor, was contacted. 'J00? Product Corporation instructed TUGCO that terminal lugs could be bent two times to a total of 45 degrees or one time to a total of 90 degrees.
According to the vendor, additional bending up to 120 degrees could also be acceptable depending on the length of the conductor to be supported, the susceptibility of the termination to vibrations, and whether rebending was required once the lug was bent beyond 45 degrees.
Although lugs may be bent up to 120 degrees, AMP stated, they would no longer maintain their full mechanical strength, but they would maintain their electrical characteristics.
(CPPA 38,241 telephone conversation documentation 4/17/84).
s - -
b With.this information, TUGCO Enginaering datorminsd that the terminal lugs on the G.E. overload relay could be bent in excess of 90 degrees, as allowed under the AMP Product Corporation criteria.
Thus, NCR-E-84-00972 was dispositioned.
With regard to the ITE Gould-Brown Boveri bent terminal lugs, TUGCO Engineering decided that they would be replaced if they were bent beyond 90 degrees or showed signs of fatigue (i.e.,
flaking,-cracking or other physicial discontinuities).
With this criteria, TUGCO Engineering proceeded to evaluate the disposition of each of the nonconforming conditions defined by NCRs E-84-01066 through E-84-01081. (4/17/84).
It was believed at that time that this adequately e
identified and addressed all problems associated with bent '
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or twisted terminal lugs, and these problems were considered by TUCCO Engineering to be resolved.
[
On 9/18/84, however, the NRC letter to TUGCO notified j
TUGCO of the TRT finding.
Subsequently, the CPRT was formed and ISAP I.a.5 ("NCR's on Vendor Installed AMP Terminal Lugs") was issued to address the SSER findings with regard to NCR dispositioning for both bent and twisted terminal lugs.
(Issue:
Conduit / Cable Tray Separatie-)
At page 3 (Enclosure 1) of the NRC TRT letter dated 9/18/84, the TRT found: !
a that tha existing TUEC entlynic substantiating tha adequacy of the criteria for separation between conduits and cable trays had not been reviewed by the NRC staff.
The TRT specified its finding in January 1985 in SSER 7, they found:
no evidence that the existing G&H analysis for establishing the criteria for a 1-inch separation between rigid conduits and cable trays, as stated in G&H Electrical Erection specification 2323-ES-100, had been evaluated by the NRC staff for Comanche Peak.
This analysis should have been referenced in the FSAR. (Page J-42)
We believe this finding was the Permittees' first notice of this precise issue, which is confined to a concern regarding a lack of NRC Staff evaluation.
However, we have determined that Permittees' first notice of the potential existence of the concerns underlying the TRT finding might '
be considered to have bsen on 11/7/83, during a Gibbs & Hill in-house review of DCA 15,917.
DCA-15,917 (originally issued on 1/25/83) authorized a reductidn of separation criteria between a safety related conduit directly above an enclosed cable tray.
During the i
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in-houce review, a design reviewer questioned the separation criteria for open cable trays and conduits which had existed prior to the issuance of DCA-15,917.
The DCA was thus returned to the Engineering Department to provide additional l
analysis.
The Engineering Department did so.
Two days I
later, an interoffice memo providing the reasoning which i
j supported the DCA was sent to the design reviewer.
I ___
A (11/9/83).
On 11/22/83 the dasign reviewar asnt en 3
interoffice' memo to the Engineering Department stating the reasoning with regard to his objection to the DCA.
On 1/17/84,-the Gibbs & Hill Engineering Department transmitted EE-863 to the G&H Chief Electrical Engineer for his use in final dispositioning of the concerns involving DCA-15,917.
EE-063 explained the engineering judgment interpreting IEEE 384-1974a which justified the separation criteria of the DCA.
This analysis utilized the parameters and assumptions of the NRC funded Sandia Cable Tray Fire Test Report No. Sand. 77-1125C.
Upon review of the design reviewer's objections and
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EE-863, the Chief Electrical Engineer gave final approval of DCA-15,917 (1/23/84).
As of this date, Gibbs & Hill
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believed that its analy51s regarding the r.eparation criteria between rigid conduits and cable trays was justified.
It was not until the 9/18/84 TRT letter to TUGCO, which notified TUGCO of the TRT finding that the sufficiency of the Gibbs & Hill analysis was thought to be in any way in issue.
Subsequently, the CPRT was formed and ISAP I.b.3
(" Conduit to Cable Tray Separation") was issued to address and resolve the TRT's concern.
l 2
IEEE 384-1974 and Regulatory-Guide 1.75, Rev. 1, were the standards that CPSES committed to in the FSAR with regard to general separation criteria.
These standards do not, however, directly address the separation between rigid conduits and open cable trays.
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.FEB 3 '87 14: 26 LICEt45E TUGC0 PAGE.02 s
SIGNATURE I,
L. Ed Powoll, being first duly sworn, do depose and say that I am Manager, Administration of the Generating Division of TU Electric, that I
am familiar with the information contained in the CPSES
- files, that I have assisted in the preparation of the foregoing answers, and that the foregoing answers are true, except insofar as they l
are based on information that is available to TU Electric but not within my personal knowledge, as to which I, based l
on such information, believe them to be true.
/
\\
4.cK % \\
L. Ed Powell Sworn to'before me this JJ day of February 1987:
0.~ m Notary PudI1c My Commission Expires:
_3/s&/fo As to Objections:
1 Thomas G. Dign @' Jr R. K. Gad III W William S. Eggeling Kathryn A. Selleck Ropes ir Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100
.