ML20211D111
| ML20211D111 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/15/1986 |
| From: | Selleck K ROPES & GRAY, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| References | |
| CON-#486-1191 OL, NUDOCS 8610220108 | |
| Download: ML20211D111 (11) | |
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V i(4 I 00CKETED USNflC Filed:
October 15, 1986
'86 0CT 20 Alli19 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the a i,...
ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
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TEXAS UTILITIES ELECTRIC
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Docket-Nos. 50-445-OL and COMPANY, et al.
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50-446 OL
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(Comanche Peak, Steam
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Electric 'tation,- Unit 1)
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)
APPLICANTS' CPRT ISSUE HISTORY I.a.5 and I.b.3 In response to the Board's requests of August 8 and September 2, 1986; and the Applicants' undertakings in response thereto,2 the Applicants hereto append the history of issues determined to have some validity by the CPRT in 4
2 As set forth in their filings of August 22, September 12 and October 6, 1986.
8610220108 861015 PDR ADOCK 05000445 PDR G
030)
's Q
its Results-Reports Nos. I.a.5 and I.b.3.2 l
Respectfully submitted,
/ A'
) du' 4
Thomas G.
Dignan, Jr.
R. K. Gad III t
William S.
Eggeling Kathryn-A. Selleck Ropes & Gray r
225 Franklin Street i
Boston, MA 02110 (617) 423-6100 t
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As no'ted in Applicants' Response to Board Memorandum of
~8/8/86 (Assistance to the Board), filed _on October 6, 1986, Applicants will continue to supply chronological
~
. histories as completed.
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Page 1 of 3 ANNOTATED HISTORY ASSOCIATED WITH CPRT ISAP I.a.5 Date Description 07/81 While in the process of terminating the Unit 1 charging pump motor, it became evident that bending the cable terminal lugs was required to effect proper installation. TUGC0 Electrical Engineering contacted Amp Special Industries to discuss bending of their product.
07/28/61 TUGC0 received Amp's letter (VBR-16,513) confirming the previous telephone conversation with TUGC0 Engineering concerning the bending of 4/0 two (2) hole NEMA short barrel AMPOWER terminal connectors to a 45 degree angle.
08/25/81 Upon receipt of the vendor's letter (VBR 16,513) TUGC0 Engineering developed the Construction Operation Traveller EE 81-127-4901 incorporating the information received to accomplish bending the lugs for the Unit 1 charging pump motor terminations.
08/61 As a result of fielo questions addressing bending of other lugs which were outside the criteria set forth in Amp's letter (VBR 16,513) again TUGC0 Engineering contacted Amp and requested additional information to increase the angle of bend in the lugs to 60 degrees.
09/02/61 TUGC0 received Amps letter (VBR 16,624) confirming the previous telephone conversatica with TUGC0 Engineering allowing field bending of Amp loose piece terminal lugs (i.e. AMPOWER, Solidstrand, PIDG, and Plasti-Grip), a maximum of 60 degrees one time.
This letter would later become the standard from which all terminal lug bending criteria evolved.
03/29/84 While replacing a G.E. thermal overload relay, it was noted that the Amp lugs would have to be bent from 90 degrees to approximately 120 degrees to be installed on the relay.
Because this violated the previous Amp criteria for field bending a Nonconformance Report (NC2-E84-00972) was generated.
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Page 2 of 3 Date Description Shortly thereafter, during a TUGC0 CC inspection of ITE Gould-brown Eoveri switchgear. it was noted that some of the vendor installed Aap terminal lugs were bent in excess of 60 degrees and/or twisted.
04/84 NCRs E-84-01066 through E-84-01081 were issued to document the bent and/or twisted condition of the Amp terminal-lugs in the ITE Gould-brown Boveri switchgear.
04/17/S4 In responding tc the NCRs, Amp was again contacted and the new and existing situation (including the criteria established in 1981p were discussed.
Amp responded that a terminal lug could be bent.two (2) times-to a total of 43 degrees or one (1) time to 40 degrees.
Further, Amp stated that bending of more than 90 degrees and up to and including 120 degrees is acceptable if the product user evaluated each specific application by considering (1) the length'of conductor to be supported by the termination, (2) the susceptibility of the termination to vibrations. (3) once bent beyond 45 degrees and rebending is required the termina! should be discarded. This telephone conversation was documented on (CPPA 38,241) which was sent to Amp for review.
In dispositioning NCR-E-84-00972, it was determined that'the component configuration dictated that the terminal lugs on the G.E. thermal overload relay had to be bent in excess of 90 degrees to be installed.
With regard to the ITE Gould-Brown Boveri bent terminal lugs, TUGC0 Engineering decided that the terminal lugs in question would be replaced if they were bent in excess of 90 degrees or if the terminal lug showed signs of fatigue (i.e.,
flaking, cracking or other physical discontinuities).
With this criteria, engineering then proceeded to evaluate and disposition each of the nonconforming conditions defined by NCRs E-84-01066 through E-84-01081.
07/13/84 NRC Special Review Team (SRT) conducts site review. During this review the NRC conducted inspector interviews, receiving an allegation from inspector A-2, that.
" Wrote recent NCR (not yet evaluated) on G.E. Motor Control Centers.
Compression lugs have bends as much as 180 degrees (more than normally done done by Site Construction).
Don't think G.E. can violate requirements and may be a problem elsewhere in G.E. MCC's".
Page 3 of 3 Date Description At the conclusion of the interviews the NRC summariced "although some concerns were expressed requiring Curriter review, those concerns did not appear to be excesstve in number or serieur, and would be ucrmally ex1ected during the interview process."
09/18/8A The NRC notified TUCCO, by letter (D.G. Eisenhut-to !!.D.
. Spence Docket numbers 50-443 and 30-446) of their findings from the Technical Review Team (TRT) Audit. TCGC0 subsequently formed the Comanche Peak Response Team (CFRT).
a 4,
ANNOTATED HISTORY 4
ASSOCIATED WITH CPRT ISAP I.b.3 Date Description INTRODUCTION TUGCO in the CPSES ESAR committed to the IEEE Standard 384-1974 and Regulatory Guide 1.75, Revision 1.
These documents govern the separation criteria for Class 1E safety related raceways.
Although very specific criteria are provided in the standard and regulatory guide for separation between redundant cable trays, the same specificity is not provided for separation between conduits and open cable trays.
Since specific criteria was not provided, Gibbs and Hill developed criteria for separation of conduit and open cable trays which meet the intent of the above standards.
i The issue raised by the NRC-TRT. involved separation between conduit and open cable trays, specifically the one-inch separation specified for certain configurations.
The NRC-TRT-felt that the analyses supporting the separation i
criteria should have been referenced in the FSAR and evaluated by the NRC staff.
TUGCO Licensing is currently reviewing the FSAR amendment which will be submitted to the NRC.
This amendment addresses the justification of the separation criteria for conduits and cable trays.
02/19/75 Gibbs & Hill Inc. transmitted a document titled
" Criteria for Separation of Class 1E Equipment and' Circuits" (GTN-2441).
This document established separation criteria necessary to maintain the physical independence of circuits and electrical. equipment and was based upon Regulatory Guide 1.75 and IEEE 384-1974.
GTN-2441 depicts pictorinlly the separation criteria of a conduit directly below or to the i
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Date Description side of an open cable tray with a clearance of one inch.
11/16/79 DCA-6132 replaced Section No. 4 of Electrical Erection Specification 2323-ES-100 Revision No.
1.
This section provided the necessary information for assisting the contractor in field routing of conduit, use of tolerances for tray installation and routing of cables in free air without violating the separation criteria.
This DCA specifie'd separation criteria for all configurations of open cable trays and conduits.
01/30/81 Gibbs & Hill Inc. transmitted Revision No. 2 of Specification 2323-ES-100 incorporating the above listed D.C.A.
(GTN-51481) 01/25/83 DCA-15,917 was issued authorizing a reduction in the separation criterion for a safety-related conduit directly above an enclosed cable tray
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from four inches to one inch.
The above reduction in separation to one-inch is in accordance with IEEE 384-1974 and Regulatory Guide 1.75, Revision 1.
11/07/83 During a G&H in-house review of DCA-15,917 the design reviewer questioned the adequacy of the interpretation of IEEE 384-1974 which specified the required separation criteria standards.
Although the change made in DCA-15,917 was in compliance with the standard and regulatory guide, the reviewer questioned the' separation criteria for open cable trays and conduits, which had been in existence prior to the issuance of the DCA.
The design reviewer marked the "in-house" Change Verification Check List for CMCs and DCAs rejected on 11/07/83 in the " design review complete" section of the form.
This form was then returned to the Engineering department (who had previously approved this DCA o
Date Description on 10/26/83) to provide additional analysis to support approval or disapproval.
It should be noted that the G&H job engineer had not signed the final disposition.of this check
-list and the CPSES field would be. advised once the final disposition was made.
11/09/83 The G&H Engineering department. responded to the design reviewer with an interoffice memorandum which provided the reasoning which supported their position for approval of DCA-15,917.
11/22/83 The G&H design reviewer transmitted an internal office memorandum to the engineering department stating the reasoning which supported his rejection.
01/17/84 The G&H Engineering department transmitted a comprehensive memorandum (EE-863) to the G&H Chief Electrical Engineer for his,use in the final dispositioning of the design reviewer's concerns which were stated in his memorandum of 11/22/83.
The memorandum of 01/17/84 defined in detail the basis for the interpretation (engineering judgment) of IEEE 384-1974 which was used to justify the separation criteria for the specific conduit to cable tray configuration.
This memorandum also included a detailed analytical analysis specific to the raceway configuration under discussion.
This analysis utilized the pertinent parameters and assumptions in the Sandia Cable Tray Fire Test Report No.
Sand 77-1125C.
Sandia Labs Reoort Abstract The NRC funded an analytical analysis and physical modeling of various cable tray and cabling configurations which were subjected to electrically initiated fires.
This study confirmed the suitability of design standards in Regulatory Guide 1.75 and IEEE 384-1974..
U Date Description 01/23/84 Gibbs & Hill I.O.M.,
this memo from the Chief Electrical. Engineer provides the justification for the approval of DCA-15,917 and eliminated the concerns raised by the earlier rejection by the design-reviewer.
09/18/84 The NRC notified TUGCO by letter (D.G. Eisenhut to M.D.
Spence Docket numbers 50-445 and 50-446) of their findings from.the Technical Review Team (TRT) Audit.
TUGCO subsequently formed the Comanche Peak Response Team (CPRT).
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9 CERTIFICATE OF SERVICE I,
Kathryn A.
Selleck, one of the attorneys for the Applicants herein, hereby certify that on October 15, 1986, I made service of the within document by mailing copies thereof, postage prepaid, to:
Peter B.
Bloch, Esquire Mr._ James E. Cummins Chairman Resident Inspector Administrative Judge Comanche Peak S.E.S.
Atomic Safety and Licensing c/o U.S.
Nuclear Regulatory Board Commission U.S. Nuclear Regulatory P.O.
Box 38.
' Commission Glen Rose, Texas 76043 Washington, D.C.
20555 Dr. Walter H.
Jordan Mr. William L. Clements-Administrative Judge Docketing & Services Branch 881 W.
Outer Drive U.S.
Nuclear Regulatory Commission Oak. Ridge, Tennessee 37830 Washington,.D.C.
20555 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
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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 i
Suite 1000 611 Ryan Plaza Drive Arlington, Texas 76011 Elizabeth B.
Johnson Geary S.
Mizuno, Esquire Admini.strative 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 Nancy Williams Cygna Energy Services, Inc.
101 California Street Suite 10C0 San Francisco, California 94111 k
/ bd Kathryn/A. Selleck /