ML20211A096

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Applicant Fourth Progress Rept.* Senior Review Team Approved & Issued 28 Results Repts (Representing 27 Action Plans). Notice to Case of Availability of Working Files for Action Plans Also Issued
ML20211A096
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 02/10/1987
From: Selleck K
ROPES & GRAY, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
References
CON-#187-2510 OL, NUDOCS 8702190089
Download: ML20211A096 (36)


Text

_

W 25/0 TE

' February 109((((T Filed:

'87 L FEB 17 P5 :01 GFF:X- ?

^h*

UCCdl1:f!C : '!%4i is-qe UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION'.

before the~

i ATOMIC SAFETY AND LICENSING BOARD i

)

In the Matter of

)

50-445-OL.

)

Docket Nos.

TEXAS UTILITIES ELECTRIC

)

50-446-OL COMPANY et al.

)

I

)

(Application for an-(Comanche Peak Steam Electric

)

Operating License)

Station, Units 1 and 2)

.)

)

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

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

l 1.

CPRT Milestones - Accomplished The Senior Review Team ("SRT") has approved and issued 28 Results Reports (representing 27 Action Plans), as set forth in Attachment 1.

The notice to DOhKO$0hok45

')b nDu m

A

o N'

CASE of the availability of the Working Files for all of these action plans has been issued and-the responses to the Board's 14 Questions have been provided for all but 12 of them (as indicated on that exhibit).

It is expected that responses to the Board's 14 Questions-for

.the balance of the issued Results Reports will be filed shortly.

I As noted on the attachment, two Action Plans have q

been deleted.

Thus'there are a total of 53 action plans (ISAPs and DSAPs), of which 30 have been deleted l

or completed.

2.

CPRT Milestones - To Be Accomplished As set forth in the "First Progress Report,"

completion of the CPRT Program Plan is considered to consist of the following milestones:

1.

Completion of the Action Plan VII.c hardware re-inspections; 2.

Issuance of the Results Report for Action' Plan VII.c; 3.

Issuance of the Collective Evaluation Report for the Testing Program; 4.

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

5.

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

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6.

Issuance'of the Results Reports for the Diucipline Specific Action Plans; 7.

Issuance of the Collective Evaluation Report for the Design Adequacy Program (CPRT Program Plan Appendix A);.and 8.

Issuance 'of the overall Collective Significance Report for the CPRT Program.

As noted in prior Progress' Reports, the CPRT does

' not work to a project schedule in.the normal sense in which the term is used.

Nonetheless, the.following information may be helpful to the Board:

The milestones set forth above are expected'to be accomplished essentially in the order listed except that it is expected that issuance of'the Results Reports for the hardware-inspection TRT-based action plans and the Results Report for Action Plan VII.c will be issued more or less simultaneously.

The presently expected date for issuance of the Results Report for Action Plan VII.c is April 30, 1987.

Any remaining Action Plans other than the DSAPs are expected to be completed, and the Collective Evaluation Reports for the Quality of Construction,1 Construction QA/QC, and Testing Programs are expected to be issued, during the second quarter of 1987.

a

4' With' respect to design, please see the letter of

.the Chairman'of'the SRT to Mr. Counsil,' dated February 4,

1987, copy attached.

It is expected'that the:

completed CPRT Results Reports on[ design topics willibe completed in the. third quarter of 1987.

In each case, " completed" with respect to an action

plan refers to the approval'of a'Results Report by the-SRT.

As noted in prior Progress Reports, the foregoing

'information is provided with certain caveats.

These schedules are not the sort of firm schedule the Board may have had in mind when it issued its memorandum; such schedules do not exist and will.not be created for the CPRT Program.

Some of these dates may slip for a number of reasons including some conscious decisions.-

The next Progress Report will be issued March 31, 1987.

Nicholas S.

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

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

_4_

Robert A.-Wooldridge WORSHAM, FORSYTHE, SAMPELS &

WOOLDRIDGE 2001 Bryan Tower, Suite 2500 Dallas, TX 75201

~(214) 979-3000-Roy P.

Lessy, Jr.

WRIGHT & TALISMAN, P.C.

1050 Seventeenth Street, N.W.

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

R. K. Gad III-Kathryn A.

Selleck ROPES & GRAY 225 Franklin Street Boston, MA 02110 (617).423-6100 By Kathfyn A.

Selleck i 4

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filELECTRIC John W. son he Fre4Jmr February 4. 1987 Mr. W.G. Counsil Executive Vice President TU Electric Skyway Tower /400 N. Olive Street Dallas, Texas 75201

Dear Mr. Counsil:

There have been some significant developments in the TU Electric,.

Corrective Action Prograus for CPSES that prompt the FRT to refocus CPRT activities reisted to CPSES design adequacy.

As you know, the CPRT's Design Adequacy Program (DAP) included a major element of self-initiated investigation of CPSES design adaquacy.

It was originally the SRT's intent that the results of this initial investigative phase would form the basis for CPRT recommendations related to the need for corrective actions and additional investigatory efforts related to design adequacy.

During the past few months, TU Electric has made a series of decisions regarding Corrective Action Programs for CPSES based on a number of considerations, including the preliminary results of the DAP investigative phase.

It is the SRT's understanding that the resulting Corrective Action Programs defined by TU Electric will constitute a 100%

design verification of the safety-related aspects of CPSES (other than NSSS design), and that these programs will be implemented by major architect / engineering firms that have had no previous design responsibility for those portions of the original design that they are now verifying.

This commitment by TU Electric provides an alternative means for achieving the design adequacy-related objectives of the CPRT Program Plan from that originally envisioned and obviates the need for For completion of all of the specific elements contained in the DAP.

example, since the Corrective Action Programs cover all of the design activities that were addressed by the DAP on a sampling basis, there is i

no logical need to rely on trending or generic implications analyses to identify areas of potentially deficient design requiring further investigation.

400 North Olae Street L 8. 81 Da!!u. Texu U201

,_,, x, m 4

b Recognizing these developments, the SRT believes that a shift in the focus of CPRT activities related to CPSES design adequacy is appropriate at this time.

It is the consensus of the SRT that the focus of future CPRT design-related activities should be on SRT-directed, specific i

- overviews designed to assess the effectiveness of the implementation of the corrective Action Programa defined by TU Electric with particular.

~

emphasis on achievement of CPRT Program objectives.

Included in this set of directed activities will be specific evaluations of the effectiveness of the establishment and implementation of progranaatic improvements to preclude recurrence of past CPSES design problems.

4 As currently envisioned by the SRT, CPRT overview activittee will j

consist of the following elements:

1)

DAP overview efforts in the areas of large bore piping / pipe supports and cable tray / conduits will continue to be conducted 1

in accordance with the Program Plan; results of this overview I

will be reported in DSAP Results Reports.

2)

As directed by the SRT, review the TO Electric Corrective i

Action Programs for the purpose of determining whether such programs have captured all known, open technical issues 1

and that there is a commitment to resolve them.

3)

As directed by the SRT, reviews will.be conducted to evaluate the adequacy and effectiveness of implementation of contractor (e.g. the SWEC Engineering Assurance Program) and TU Electric preseems notablichod to ensure the quality nf the Design Basia l

Consolidation Program (DBCP) and other design-related corrective action programs.

i i

4)

As directed by the SRT, reviews will be conducted to assess the adequacy of selected end products of the DBCP and other design-related corrective action programs.

5)

As-directed by the SRT, reviews will be conducted of the adequacy of (including effectiveness of implementation) TU Electric programs and procedures to manage and control design-related activities, with particular emphasis on actions taken to preclude recurrence of past problems.

c In order to do an adequate evaluation of TU Electric corrective action and management programs, as they relate to design, the SRT aust identify causes of suspected design discrepancies.

It is our current view that the following causes should bound all suspected design discrepancies at CPSES. Our scrutiny of the corrective action and asnagement programs will emphasize these areas o

Design Consitaant Control o

Code Compliance Procedures i

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Organizational Interf ace Procedures (internal and external) g o

Design Change Control Procedures

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o Design Verification Procedures o

o Procedure Implementation

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o Technical Audits of Design Contro1 o

Technical Audit Corrective Actions, Training and Personnel Qualification ql o

Exceptions to Revision 3 of the Program Planivill be noted in the Results Report or Collective Evaluations as they are published.

)

f E A)./d i hnW. Beck [ Chairman Senior, Review Team, CPRI JWB/ led

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z-h ANNOTATED BIBLIOGRAPHIES

.R AVAILABLE DOCUMENTS Pursuant with the Board's Order of June 6, 1986, the Applicants submit the attached annotated bibiiographies of available documants for the time period of November 26, 1986 - January 25, 1987. The principals that were utilized, the documents that are annotated and the document sources are consistent with the guidelities and procedures that were used by Applicants in previous annotated bibliographies.

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10 CFR 50.55(e)

During the period of November 26, 1986 to January 25,

1987, Applicants issued 49 letters to the NRC concerning 44 items which had previously been identified as potentially~ reportable under the provisions of 10 CFR 50.55(e). The letters are catagorized as follows:

A. 30 letters

-Interim Report - Evaluation to determine report-ability is continuing.

B. 13 letters - Interim Report - Item determined to be report-able, evaluation / corrective action continuing.

(See listing below)

Date letter No.

SDAR No.

Su)iect 777T5/86 1xx-sii7 ce-se-as Large sore piping and Supports This letter is a follow-up report on a reportable item under the provisions of 10 CFR 50.55(e).

It notifies the NRC that continuing engineering evaluation has not identified any additional instances which are considered reportable, however, evaluation is continuing.

Date Letter No.

SDAR No.

Subject TT773/86 Txx-sizo ce-es-7z Smali Bore Piping and Supports This letter is a fol19, 90 report on a reportable item under provisions of 10 CFR So.55(e) involving the scope of plant modification resulting from the project's pipe support reverification program.

It notifies the NRC that continuing engineering evaluation has not identified any additional instances which are considered reportable, however, evaluation is continuing.

Date Letter No.

SDAR No.

Subject 717T5/86 Txx-eia7 CP-se-11 Component Cooling water Pump Inpeller Linear Indications This letter is a follow-up report on a reportable item under the provisions of 10 CFR 50.55(e). Inspections of the Unit 1,

Train A, CCW pump impeller have revealed that rework is required. The i

Train B impeller will be inspected following the availability of Train A service water. Upon completion of the inspection, the extent of the required work will be determined and the repair will be scheduled as required.

g letter No.

S)AR No.

Subject 12/05/86 TXX-6138 C)-85-31 Electrical Raceway Support System On August 27,

1985, the NRC was notified of a

deficiency involving the Unit 1

Electrical Raceway Support System.

Specifically, due to additional weight imposed by the installation of Separation Barrier Material (SBM) and Radiant Energy Shield (RES) Material without.a complete interdisciplinary review and design

analysis, the structural integrity of the raceway is indeterminate. This letter informs the NRC that this issue is being reported under the provisions of 10 CFR 50.55(e) and required information as to description, safety implications and corrective action for the issue is provided.

.QLtjt letter No.

SDAR No.

Subiect 12/10/86 TXX-6146 CP-86-53 Seismic Design of Conduit On October 21,

1986, the NRC was notified of a

reportable deficiency involving the seismic design of conduit under the provisions of 10 CFR 50.55(e). This letter is an interim report submitted to status corrective action implemented to date.

Date letter No.

SDAR No.

Sub.iect T77T2/86 TXX-6153 CP-85-42 Thermolag on Conduit Supports On October 26, 1986, the NRC was notified that the deficiency involving the possible adverse effect of the substitution of rectangular and oversized preformed sections of thermolag on conduit installations is reportable under the provisions of 10 CFR 50.55(e).

This letter is an interim report submitted to status correctise action implemented to date.

.EiLt.g letter No.

SDAR No.

Subject 12/18/86 TXX-6168 CP-86-54 Original Design of Control Room Ceiling On October 3,

1986, the NRC was notified of a reportable item involving the design and installation of the control room ceiling. This letter is an interim report submitted to status the..

implementation of corrective action. Quality control verification of construction activities concerning the control room ceiling will be complete upon closure of outstanding inspection findings.

Date letter No.

SDAR No.

Subjec<

Tl7Tb/86 TXX-6175 CP-86-18 Safety Chilled Water Chiller Units On May 21,

1986, the NRC was notified of a reportable item involving difficulties in starting and operating the safety chilled water chiller units. This letter informs the NRC that detailed review is continuing of vendor specifications and updating of the list of components serviced by the component cooling water system. The supplier (YORK) is also continuing the evaluation of the installation of the chiller flow control valves with regard to a
standby, non-operating safety chiller.

Westinghouse is also continuing to evaluate the impact of the 40 degree Farenheit CCW temperature on NSSS components.

Date Letter No.

SDAR No.

_ Subject 12/19/86 TXX-6177 CP-86-62 Polar Crane Support Structure On October 3,

1986, the NRC was notified of a

deficiency involving the misinterpretation of the polar crane load cases which were deemed reportable under the provisions of 10 CFR 50.55(e). This letter is an interim report submitted to status corrective action implemented to date.

Date letter No.

SDAR No.

Subject 01/06/87 TXX-6201 CP-86-82 Cable Tray Hangar Splice Welds On December 8,

1986, the NRC was notified of a

deficiency involving certain welds which are used to splice cable tray hangars channel sections end to end to form posts. This letter informs the NRC that this deficiency is reportable under the provisions of 10 CFR 50.55(e) and provides the required information concerning description, safety implication and corrective action for the deficiency.

Date Letter No.

.SDAR No.

Subject 01/08/87 TXX-6206 CP-86-36 Large Bore Piping and Supports On June 9,

1986, the NRC was notified of a reportable item involving the scope of plant modifications resulting from the project's pipe support reverification program. This letter informs the NRC that engineering evaluation is continuing and has not identified any additional instances which are considered reportable.

Date Letter No.

SDAR No.

Subject TI779/87 TXX-6207 CP-86-72 Small Bore Piping and Supports On June 9,

1986, the NRC was notified of a reportable item involving the scope of plant modifications resulting from the project's pipe support reverification program.

This letter informs the NRC that engineering evaluation is continuing and has not identified any additional instances which are considered reportable.

Date

. Letter No.

SDAR No.

_ Subject TI")Tl/87 IXX-6235 GP-86-19 Instrumentation Installations On March 21, 1986, the NRC was notified of a reportable item involving the installation of steam service pressure transmitters. This letter was submitted to status the corrective actions for this reportable item under the provisions of 10 CFR 50.55(e).

J C.

3 letters - Final Report - Deficiency not reportable (See-listing below)

Date letter No.

SDAR No, Subject Tl7I3/86

'TXX-6132 CP-85-26 Upper Lateral Restraint Embedment Design This letter is a final report of a potentially reportable item under the provisions of 10 CFR 50.55(e). The deficiency involves the design / analysis of the steam generator upper lateral beam anchorage. Evaluations were performed for LOCA loading under a design bounding assumption where the steam generator compartment platforms are considered removed (resulting in higher pressures in the upper portion of the compartment).

Based on the evaluations performed, this letter ' informs the NRC that it has been concluded that in the event this issue had remained undetected, no condition adverse to safety would

exist, therefore, this issue is not reportable.

Date Letter No.

SDAR No.

Subject Tf775/86 TXX-6140 CP-86-80 Torque Values for J.C.

White Tubing Restraints On November 7,

1986, the NRC was notified of a

deficiency involving the recommended torque values for J.C.

White tubing restraints. The torque values for these restraints have not been reficcted in the project specifications and procedures or implemented during the installation process. This letter is a final report and informs the NRC that an evaluation has concluded that the vendor's minimum torque requirements have been met when these bolts were installed per project specifications. The letter states that project specifications and procedures will be revised to specifically implement the manufacturer's requirements. This revision will replace the terms " snug tight" and "in a secure manner" which meet the intent of project requirements, but cannot be verified. The letter concludes that in the event this issue had remained undetected, no condition adverse to safety would exist, therefore, this issue is not reportable.

Date letter No.

SDAR No.

Subject 12/23/86 TXX-6180 CP-86-17 Minimum Concrete i

Coverage l

On March 21,

1986, the NRC was notified of a

deficiency concerning the minimum concrete coverage required for reinforcing steel in the walls and floors necessary to maintain a three-hour i

fire rating. This letter is a final report and informs the NRC that our evaluation of the subject walls and floors indicated

.that-po s t u'l a ted temperatures would not adversly affect the structural capacity of the reinforced concrete elements. It has been concluded that CPSES design ~is in compliance. with Uniform

. Building Code (UBC)- and this issue is not. reportable under the provisions of 10 CFR 50.55(e).

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i D.

3 letters - Final Report - Deficiency is Reportable and Corrective Action Taken (see listing below)

Date Letter No.

SDAR No.

Subject 01/16/87 TXX-6220 CP-86-70 Elevated lemperature Effects on Instrument Supports & Tubing This letter is a final report of a deficiency regarding elevated temperature effects on instrument supports and tubing.

The required information as to description of the deficiency, safety implications and corrective action are provided.

Date letter No.

SDAR No.

Subject 01/21/87 TXX-6228 CP-86-77 Instrument Tubing Minimum Wall Thickness This letter is a

final report of a

deficiency involving specification of minimum wall thickness in instrument tubing which may not meet the stress allowables required by the ASME B&PV

Code,Section III.

The required information as to description of the deficiency, safety implications and corrective action is provided.

Date letter No.

SDAR No.

Subject 17771/87 TXX-6230 CP-86-16 Fire Effects on Instrument Tubing This letter is a final report of a deficiency involving the detrimental effects of low melting point metals on stainless steel instrument tubing during a fire. This letter provides the required information as to a

description of the deficiency, safety implications and corrective action. l l

CPRT s

The following correspondence was issued by TUGC0 to the NRC concerning CPRT during the time period of November 26, 1986 lanuary 25, 1987:

Date Letter No.

Subject 12/02/86 TXX-6102 Response to CASE's Comments on Welding in CPRT Program Plan This letter transmits the CPRT responses to the CASE comments on welding contained in their August 14; 1985 letter, " CASE's First Critique of Applicants' Comanche Peak Response Team (CPRT) Plan".

Date letter No.

Subject TT/T8/86 TXX-6159 Small Bore Piping and Pipe Supports

. Generic Issues Report This letter transmitted copies of the "Small Bore Piping and Pipe Supports Generic Issues Report" prepared by Stone and Webster Engineering Corporation for TUGC0 as part of the CPRT piping and pipe supports requalification effort.

Date Letter No.

Subject 77773/86 IXX-6184 CPRT Results Reports This letter transmitted the following Results Reports:

VII.a.7 Housekeeping & System Cleanliness I.b.1 Flexible Conduit to Flexible Conduit Separation I.b.2 Flexible Conduit to Cable Separation DJdgL Letter No.

Subject 12/23/86 TXX-6148 Documents for Evaluation and Resolution of Generic Technical Issues for HVAC Ducts & Duct Supports This letter transmitted documents prepared by EBASCO Services Incorporated for TUGC0 as part of the CPRT cable tray and conduit support program initiated by Texas Utilities...

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Date Letter No.

Subject 01/16/87 IXX-6223 CPR' Results Repor.ts This letter transmitted.the following Results R.eports:

I.a.1 Heat-Shrinkable Cable Insulation Sleeves I.b.4 Barrier Removal II.c Maintenance of Air Gap Between Concrete Structures:

VII.a.3 Document Control V.d Plug Welds 1

4

RESPONSES TO NRC INSPECTION REPORTS /

i NOTICE OF VIOLATION / NOTICE OF DEVIATION The following correspondence was issued by Applicants (TUGCO) to the NRC Region IV concerning inspection reports during the period of November 26, 1986 - January 25, 1987:

ate letter No.

Subiect 2/86 TXX-6134 Inspection Report Nos.

50-445/85-18 & 50-445/85-15 NOV Item

.'s - 0JT waivers for inspectors' certifications.

NOD Item C

Insufficient information regarding incorrect checklist entry and justification for the entry.

This letter transmitted a sepplemental response.

In part, the response stated:

NOV Item A - Applicants continue to disagree that this is a violation. In all cases, the conditions regarding OJT were met as evidenced by the L-III proficiency demonstration and Certifying Authority signatures. Procedures have been revised to eliminate the need for minimum OJT and 0JT waiver to avoid further misunderstanding of their intent or use.

N00 Item C - The reason for the deviation is an inadvertent error or entry by the discipline engineer. The engineer did, however, provide the required justification for the entry. A reinspection found the flange locations, in question, to be within allowable tolerance.

Date Letter No.

Subject 1T7T6/87 TXX-6200 Revised Corrective Action Date This letter transmitted a

revised date for completion of corrective action regarding NOV 446/8509-V-02.

Date Letter No.

Subject

'NT7T9/87 IXX-6173 Inspection Report Nos.

50-445/86-01 & 50-446/86-01 NOV Item A.1 - Insufficient information regarding failure to.

implement procedure requirements for DRs for non-ASME components.

NOV Item A.4

- ' Insufficient information regarding tagging of nonconforming items on NCRs.

NOV Item A.6 - Insufficient information regarding restriction of initial response to CPRT activities only.

N0D Item B - Provide documented actions to prevent recurrence of initial stated examples.

N00 Item C -

Provide information as to whether surveillance and/or audits have addressed activities of QA/QC engineer applicable to deviation, 445/8601-D-18.

This letter transmitted a supplemental response.

In part, the response stated:

NOV Item A.1 - Applicants' initial response only addressed the failure to initiate NCRs for items falling under the ASME Section XI program since this was the only activity identified through Applicants' review of the QA/QC Coordinators' DR/NCR log initiated for all ERC DRs generated for non-ASME components.

NOV Item A.4 The intent of the tagging criteria was not to identify items installed or functioning properly since the NCR provides adequate control of those items. Tagging criteria is now contained in work procedures to require " hold tags" on deficient items if:

a) Item is not installed, or b) Correction of the deficiency without QC witness would preclude proper reinspection.

NOV Item A.6 - Applicants' initial response was restricted to CPRT related activities because of the limiting nature of controlling IPC procedure, IPC-P3. Quality engineering evaluation of the 53 out-of-scope three-part memos initiated by IPC determined that 30 documented nonconforming conditions should have been documented on' individual NCRs. Those conditions have been documented on NCRs issued on or before 04/30/86.

N0D Item B - Documentation of action to prevent recurrence is contained in appropriate ERC files.

N0D Item C - ERC QA surveillance number II-85-20 specifically addressed the work activities of the QA/QC engineer applicable to this deviation.

Date Letter No.

Subject TT7T2/87 Txx-6089 Inspection Report Nos.

{

i 50-445/86-03 & 50-446/86-02 i

NOV Item A - Improper field design changes.

NOV Item B - Adherence to quality control procedures.

NOV Item C - Adherence to quality control procedures.

NOV' Item D.1 - Adherence to quality control procedures.

NOV Item D.2 - Adherence to quality control procedures.

NOV Item E - Inadequate quality control program.

NOV Item F - Inadequate quality control measures.

NOV Item G.1 - Inadequate quality control program.

NOV Item G.2 - Inadequate quality control program.

NOV Item H - Inadequate quality control measures.

NOV Item I - Adherence to quality control procedures.

N0D Item A - Deviation from QA/QC procedures.

N0D Item B - Deviation from QA/QC procedures N00 Item C - Deviation from QA/QC procedures.

NOD Item D - Deviation from QA/QC procedures.

N0D Item E.1 - Deviation from QA/QC procedures.

NOD Item E.2 - Deviation from QA/QC procedures.

N00 Item E.3 - Deviation from QA/QC procedures.

This letter transmitted a response' to the above items. In part, the response stated:

NOV Item A The DCA in question was revised to delete the specifics regarding wire size reduction.

Procedure CP-CPM 6.3 will be revised to require that a review of the DCA be conducted prior to the traveler being issued to ensure that if the DCA does contain specifics they are incorporated into the traveler.

NOV Item B - Formal classroom training was initiated in February 1986 and completed in May 1986 to resolve inconsistent IR l l.

rI completion by QC inspectors.

NOV Item C - NCRs were initiated for each of the nonconforming conditions identified in this violation. QC inspectors involved with acceptance of.the discrepant installations identified have been made aware of their errors.

NOV Item D.1 - The isometric drawing in question has been revised-to show the 3/8" HKB. With the dispositioning of NCR M-86-201023, recurrence of this violation will be prevented.

NOV Item D.2

- A revision will be made to QI-QP-11.21-1 as corrective action to prevent recurrence of this condition.

For each specific-discrepancy noted in the NOV Item E

violation, a NCR or Deficiency and Disposition Report (DDR) has been issued for evaluation and disposition.

Several other procedure revisions and retraining efforts were-identified torthe NRC to be taken to prevent recurrence.

NOV Item F - NCR M-80-00161 was revised in April 1986. A review of a random sample of NCRs has been conducted to determine the safety significance of actions resulting from completed dispositions of NCRs. This review has provided a high degree of assurance of the adequacy of the dispositions of NCRs at CPSES.

NOV Item G.1 - A series of nonconformance reports were listed as being i ssued as a

result of the conditions noted in this violation. Revision 06 of Procedure QI-QP-11.10-2A was issued on 02/24/86 and QC personnel were trained to this procedure revision.

NOV Item G.2 - Nonconformance Reports were initiated to address the dimensional discrepancies. Each of the QC inspectors involved with acceptance of the discrepant installations identified have been made aware of their errors.

NOV Item H

This alleged violation is under evaluation.

Applicants expect to send a report by February 20, 1987.

NOV Item I - This violation consists of three parts.

Part 1 - All TUGC0 Operations NCRs have been reviewed and no significant adverse trends. were identified.

Trend analysis performed on 1985 NCRs was reported to the appropriate levels of management by the 1985 Quality Assurance Annual Report.

Part 2 - Recently issued NE0 procedures now clearly define the site guidelines for deficiency and nonconformance reporting.

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Part 3 - STA-404 was revised in June 1985 to document the review for nonconforming conditions by providing a "Yes/No NCR required" block on the DR form.

N0D Item A Corrective action has been completed with the issuance of Rev. 3 to QI-019 and with the reinspection of all affected packages as of May 30, 1986.

N00 Item B - Applicants deny the alleged deviation. The ERC QA/QC discipline engineer did in fact review QI-QAP-11.1-28 Revision 3 for applicability in developing the QI-029 inspection checklist.

The engineer concluded that inspection for excessive grinding of base metal through paint is not a recreatable characteristic of the welding attribute.

N0D Item C - Applicants deny the alleged deviation. The surface of the subject weld was inspected per packages I-S-PWRE-006 and I-S-NPBW-014.

Weld surface irresclarities were noted by the inspectors and the attribute rejected in each package.

N00 Item D - Applicants deny the alleged deviation. A subsequent review of this package by ERC has revealed that a deviation does not exist. The ERC engineer correctly N/A'd these attributes.

~

NOD Item E.1 - Corrective action has been taken in regard to this violation.

Additionally, TUGC0 has undertaken a complete HVAC support reverification program for Unit I and common. The DAP analysis is currently in process and is expected to be completed by June 1987.

N0D Item E.2 - ERC Deviation Report number I-S-HVDS-075-DR5 was prepared to document the undersized weld.

N0D Item E.3

- Deviation Report number I-M-LBCO-148-DR-3 was prepared on August 28, 1986, to document the existence where the minimum separation criteria was not met. A NCR was generated as a result of the DR to disposition the above conditions.

Date Letter No.

Sub:ect 4

NT7T6/87 TXX-5186 Inspection Eeport Nos.

50-445/86-14 & 50-446/86-11 NOV Item A

Failure to segregate nonconforming items in warehouse.

NOV Item B.1 - Permanently installed equipment not protected from welding and grinding activities.

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NOV Item B '. 2 Failure to implement ' color coding / identification requirements.

NOV Item B.3 Failure ~to implement color coding / identification requirements.

NOV-Item B.4 - Loose conduit' connectors.

NOV Item B.5 - Lack of end protection for unlanded _ conductors.

NOV Item B.6 - Failure to implement color coding requirements.

NOV Item C

~

Lack of procedures to' address process control fo'r drilling holes in solid _ bottom-cable trays to facilitate installation of fittings and/or cable TY-RAPS.

This letter transmitted a response to the above' items. In part,-

the response stated:

NOV Item A - A NCR was issued to identify the damage to the items specified.

Items have been segregated by relocation to the QA 1

hold area pending NCR disposition. Warehouse.and QC _ receiving j

personnel will be retrained in the requirements of the applicable-receiving and inspection procedures.

i NOV Item B.1 - The permanently installed equipment in question will be inspected for damage and appropriately dispositioned. In a meeting on July 24-25, 1986, the use ' of disciplinary measures in the event of a similar violation - was discussed. A project directive was issued concerning the protection of permanent plant equipment which defined disciplinary actions to be taken.

NOV Item B.2 - NCRs were written to identify and correct the discrepant conditions.

NOV Item B.3 NCRs were written to identify and correct the discrepant conditions.

NOV Item B.4 - The cited violation of loose connectors (not-hand tight) was found to exist for only one instance rather than two.

A NCR was issued, dispositioned, work completed and the conduit in question was satisfactorily reinspected. A review - of other i

completed IE flexible conduit connectors was performed and no additional nonconformances.were identified.

NOV Item B.5 Applicants deny this alleged violation. The intent of this procedure is to provide protection to the cable end prior to, during and after construction pulling activities. It is not-the intent to provide conductor end protection for unused conductors within a terminated cable..

i' NOV Item B.6 - NCRs.were. written to identify and. disposition.the discrepant conditions. Work has-been completed-on these NCRs and the cables satisfactorily reinspected.

NOV Item C - Pevisions!have been mad'e to appropriate construction and inspection procedures to provide criteria for installation and verification of completed installation.

JLt o Letter No.

Sub.iect C1/I9/87 TXX-6212 Inspection Report'Nos.

50-445/85-14 & 50-446/85-11 4

NOV Item D - Failure to follow procedures concerning maintenance 4

i of duplicate copies of engineering documents.

I This letter. transmitted a response to the.above item.

In.part, the response stated:

NOV Item D - Engineering Instruction TNE-AD-4-6 was created to specifically control the transmitted and duplicate retention of

^

pipe support calculations -and measures to assure accountability.

g /87 Letter No.

Subj ect 01/22 TXX-6213 Inspection F;eport -Nos.

l 50-445/86-06 & 50-445/86-04 NOV Item A(2) - Overflowing of electrical cable from cable trays.

This letter transmitted a response to the above ' item.

In part, the response stated:

NOV Item A(2) - Corrective actions have been taken to prevent the improper cable installation identified in the NOV. Revisions to Inspection Instructions and Construction Procedures have been made to address the specific requirements of the electrical erection specification.

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TUGC0 INTERNAL AUDIT 0F ENGINEERING AND CONSTRUCTION ACTIVITIES The following internal audits were conducted. Reports were issued during the time period of November 26, 1986 - January 25, 1987:

Number: TCP-86-42

Title:

Permanent Plant Records Vault Scope: The scope of the audit consisted of the evaluation of the operation of the QA Permanent Plant Records Vault.

Number: TCP-86-43

Title:

Piping Systems As-Built Scope: The scope of the audit was to evaluate the adequacy and verify the implementation of the Piping As-Built Verification Program.

Number: TCP-86-44

Title:

Cable Spread Room (U2) As-Built Scope:

The original scope of this audit was to evaluate the adequacy and implementation effectiveness of TUGC0 Nuclear Engineering's Field Verification Nethod (FVM) TNE-FVM-CS-05, Rev.

O for As-Builting of the structural steel framework in Unit 2 Cable Spread Room.

During the pre-audit entrance

meeting, the audit team was informed that no As-Builting activities were on going based upon the reassignment of this task responsibility from Gibbs & Hill, Inc. to Stone & Webster Engineering Corp. (SWEC). As a result, the objectives of the scheduled audit could not be accomplished as originally intended. Consequently, the scope was altered to assess program status, for audit rescheduling purposes, and to assure that no As-Builting activities were proceeding during the transition period and re-establishment of approved procedures for conducting the task.

Number: TCP-86-45

Title:

Engineering /QC: HVAC Scope: The scope of the audit was performed to verify that proper 4

programs / procedures have been established by participating organizations to complete

design, installation and as-built verification of Unit 1 and 2 HVAC systems.

Number: TI 07

Title:

Design Control Scope:

The scope of the audit was performed to verify that affected organizations had initiated / revised programs and procedures as necessary to implement the requirements of NE0-3.03, Revision 1 " Preparation, Review and Disposition of-Plant Design Modifications",

and verify that a

program had been established by.

affected organizations to complete design modifications which were initiated prior to the issuance of NE0-3.03, Revision 0.

i '

MISCELLANE0US The following additional correspondence was issued by TUGC0 to the NRC during the time period of November 26, 1966 - January 25, 1987:

Date Letter No.

Subject Tf/64/86 TXX-6143 TUGC0 Commitments from CYGNA & SWEC Meeting This letter transmitted copies of information requested during the meeting of November 13-14, 1986 between CYGNt and Stone and Webster Engineering Corporation.

Date letter No.

Subject 12/08/86 IXX-6126 NRC Request f or Additional Information Concerning MSIV Bypass Valves This letter (with attachments) provided additional information concerning the TUGC0 request on May 17, 1985, to allow the use of manual operators on the main steam isolation valve (MSIV) bypass valves. The correspondence also provided comments on the proposed technical specification revision and on the related FSAR changes provided by Amendment 56.

Date Letter No.

Subject

'T77Fb/86 1xx-else Meeting notice This letter transmitted notice of a forthcoming meeting between CYGNA and SWEC to discuss Piping System and Pipe Support Corrective Action Program.

Date Letter No.

Subject 12/T6/86 TXX-6157 Supplemental Information on Containment Coatings Performance This letter transmitted TUEC's response to the NRC Staff's request for supplemental information regarding the CPSES Coating Performance Program.

a Date Letter No.

Subiect TT)T]/86 TXX-6185 FSAR Amendment This letter transmitted FSAR changes scheduled.for a future FSAR Amendment resulting from testing and analysis performed to justify the separation between instrumentation and control cables and raceways at CPSES.

j,,jLQ Letter No.

Subject 12/19/86 TXX-6162 FSAR Amendment vescription This letter transmitted a description of Amendment 61 to the CPSES FSAR.

Date letter No.

Subject TT7I2/86 TXX-6182 Transmittal of Documents This letter transmitte'd copies and pertinent comments concerning the following documents:

CPSES Design Basis Consolidation Program Plan

  • Civil / Structural Generic Issues Report Date Letter No.

Sub.iect 12/23/86 TXX-6191 Generic Issues Report This letter transmitted copies of the Electrical Generic Issues Report prepared to resolve the specific design issues raised by design reviews including the third party review by TERA Corporation.

at letter No.

Subject 1/86 TXX-6189 Follow-Up Report Regarding Allegations This letter transmitted information that the allegation involving cans of trash in the containment wall (refererce NRC letter 4 A-019 of May 30, 1986) is being investigated and evaluated.

he letter No.

Subiect 01/02/87 TXX-6147 Pipe Support Base Plate Designs Using Concrete Expansion Anchor Bolts This letter transmitted information to revise TUGC0's submitted l,

4 responses to IE Bulletin 79-02 (Pipe Support Base Plate Designs Using Concrete Expansion Bolts) Revision 0 through 2.

jlL(g Letter No.

Subiect 01/06/87 TXX-6174 Generic Technical Issues Report This letter transmitted copies of

" Generic Issues Technical Report Evaluation and Resolution of TERA Equipment Qualification Issue Resolution Reports" prepared by Impell for TUGC0 to resolve seismic and environmental concerns identified by TERA.

Date Letter No.

Subject TT7T6/87 IXx-6214 ACRS Presentation This letter transmitted additional information regarding TU Electric's presentation to the Advisory Committee on Reactor Safeguards.

Date letter No.

Subject 177T6/87 ixx-ezii Generic issues Report This letter transmitted copies of the Instrumentation and Control Generic Issues Report which has been prepared to resolve the specific design issues raised by design reviews including the third party review by TERA Corporation.

Date Letter No.

_ Subject E 9/87 IXX-6229 Meeting Notice This letter transmits notice of a forthcoming meeting between CYGNA and EBASCO to discuss cable tray support.

O OTHER On behalf of Texas Utilities, Robert A. Wooldridge _has submitted various documents to the Board for their information.

These documents include the following for the time period of November 26, 1986 - January 25, 1987:

12/09/86 Notice of meeting between CYGNA and SWEC.

12/09/86 Information from the November 13-14, 1986 meeting between CYGNA and SWEC.

12/19/86 Copies

.o f Small_ Bore' Piping and Pipe Supports Generic Issues Report.

12/22/86~

Copies of CPSES Design Basis Consolidation Program Plan and Civil / Structural Generic Issues Report.

12/22/86 Approved Results Reports VII.a.7, I.b.1 and I.b.2.

12/23/86 Copies of Electrical Generic Issues Report.

12/23/86 Documents for Evaluation and Resolution of Generic Technical Issues for HVAC Ducts & Duct Supports.

01/05/87 Copies of Generic Technical Issues Report Evaluation and Resolution of TERA Equipment Qualification Issue Resolution Reports.

01/16/87 Copies of Instrumentation and Control Generic Issues Report.

01/16/87 Approved Results Reports I.a.1,I.b.4, II.c, VII.a.3 and V.d.

The following reports were issued by the CPRT Overview Quality Team (0QT) during the time period of November 26, 1986 - January 25, 1987:

12/08/86 Internal memo from J.F.Streeter to J.W. Beck transmitting the CPRT 0QT Progress and Status Report. This report includes a summary of the 00T meeting held October 13-17, 1986 and a progress and status report of 00T activities.

12/19/86 Internal memo from J.F.Streeter to J.W. Beck' transmitting the CPRT 0QT Progress and Status

. ~..

-t Report. This report i ncludes a summary 'of the- 0QT meeting held December 'l-5, 1986:and a progress and status report of.0QT activities.

The following consultant reports have_

been received by engineering for the time period of November 26, 1986 - January 25, 1987:

(SEE ATTACHMENT A)

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ATTACHMENT A l

LETTER f DATE NAME OF REPORT SWTU-0182 11/20/86 Executive summary report for October 1986 IM-T-0210-052-181 11/28/86 Transmittal of Impell report 01-210-1521 Train C Conduit damping justification IMT-0884 12/15/86 Final issue report of the equipment qualification generic issue report CVT-0217 12/16/86 St:ne & Webste'r corrective action program monthly report for November 1986 SWTU-0399 12/19/86 Electrical generic issues report EB-T-1656 12/22/86 Transmittal of documentation for cable tray hangers ~

design verification program SWTU-0397 12/19/86 Civil / Structural generic issues report IMT-0994 12/29/86 Generic technical issue report. Evaluation and resolution of TERA Equipment Qualification Issue Reports:

DAP-E-EIC-503 (Environmental) and DAP-E-M-500 (Seismic)

CVT-0222 12/15/86 Impact of construction deviation on stress requali-fication NE-2819 12/04/86 Vendor manual review study i_

EB-T-1533 01/12/87 System interaction Program Generic Technical Report WPT-8683 01/06/87 Comanche Peak Inspection and Evaluation Report for Steam Generator Upper-Support Beam Anchor Bolts EB-T-1647 12/15/86 Evaluation and Resolution of Generic Technical. Issues for HVAC Systems (Including ducts and duct supports) 01/16/87 Instrumentation and Controls Generic Issue Report 12/05/86 Small Bore Piping and Pipe Support Generic Issues Report 12/15/86 Impact of construction Deviations on Stress Requalification Program

- Page 25 -

4 00LKEiEr USNhC CERTIFICATE OF SERVICE,87 FE817 P5 :01' I,_Kathryn A.

Selleck, one of the attorneys for the Applicants GFI v.

Y.

sw.

herein, hereby certify that on February 1@,0C198J g made service of the within Applicants' Fourth Progress Report and Annotated Bibliographies, by mailing copies thereof, postage prepaid, to:

Peter B. Bloch, Esquire Mr. James E.

Cummins Chairman Re.sident 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 Nancy Williams Administrative Judge Cygna Energy Services, Inc.

c/o Carib Terrace 101 California Street, Suite 1000 552 North Ocean Blvd.

San Francisco, California 94111 Pompano Beach, Fl.

330G2 Chairman Chairman.

Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.

20555 Washington, D.C.

20555 Stuart A. Treby, Esquire Mrs. Juanita'Ellis Office of the Executive President, CASE Legal Director 1426 S.

Polk Street U.S. Nuclear Regulatory Dallas, Texas 75224 Commission 7735 Old Georgetown Road Room 10117 Bethesda, Maryland 20814 l

1 i

't 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 Joseph-Gallo, Esquire Executive Director Isham, Lincoln & Beale Trial Lawyers for Public Justice 1120 Connecticut Avenue, N.W.

2000 P Street, N.W.,

Suite 611 Suite 840 Washington, D.C.

20036 Washington, D.C.

20036 Dr. Kenneth A. McCollom Mr. Lanny A.

Sinkin Administrative Judge Christic-Institute 1107 West Knapp 1324 North Capitol Street Stillwater, Oklahoma 74075 Washington, D.C.

20002 Ms. Billie Pirner Garde Mr. Robert D. Martin Midwest Office Regional Administrator, 3424 N. Marcos Lane Region IV Appleton, WI 54911 U.S.

Nuclear Regulatory Commission Suite 1000 611 Ryan Plaza Drive Arlington, Texas 76011 Elizabeth B.

Johnson Geary S.

Mizuno, Esquire-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 Maryland National Bank Bldg.

Room 10105 7735 Old Georgetown Road Bethesda, Maryland 20814 Kathfyn A.

Serleck

_ _ _.