ML20212F078

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Reiterates Commitments Made at 851001 & 860530 Meetings Re All Phases of Independent Assessment Program.Cites Util Failure to Fulfill Most Commitments.Piping Procedure Submitted
ML20212F078
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 08/01/1986
From: Stuart R
CYGNA ENERGY SERVICES
To: Spence M
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
84056.103, NUDOCS 8608130221
Download: ML20212F078 (7)


Text

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o Ces gg COO 90 NATION 101 California Street, Suite 1000. San Francisco. CA 94111-5894 415/397 5600 S o J/Im/

August I,1986

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[O-84056.103 Mr. M. D. Spence President Texas Utilities Operating Company Skyway Tower 400 N. Olive Street, L.B. I Dollas, Texas 75201

Subject:

May 30,1986 Management Meeting Summary Texas Utilities Generating Company Comanche Peak Steam Electric Station Independent Assessment Program - All Phases

Dear Mr. Spence:

The purpose of this letter is to reiterate the commitments made at two separate management meetings between TUGCO and Cygno, including respective counsel. At the first of these meetings, held on Octobe: 1,1985, commitments were ogreed to by both Cygna and TUCCO in the interest of effectively and efficiently supporting the ASLB proceedings. Specifically, Cygno committed to document all open items requiring resolution prior to the issue of the Phase 4 report within approximately two weeks of the meeting date. Cygna fulfilled that commitment in several letters transmitted between October 9th and 30th. Cygna was also requested to transmit all questions relative to the CPRT plan as soon as possible. Accordingly, we distributed a thorough set of questions and comments on October 6,1985. TUGCO committed to resolving the open items and establishing a meeting schedule for Cygna to discuss their concerns with the various CPRT disciplines over several months. The CPRT corrective actions were to serve as the basis for resolution of Cygna findings. Neither of the TUCCO commitments were fulfilled as of July 30,1986.

A subsequent meeting was held on May 30,1986 to re-establish a schedule for the Phase 4 report, TUGCO's response to Cygna findings, and Cygna/CPRT meetings. To this end, the following commitmmts were made:

1.

TUCCO will respond to all open items within 60 days. Some mswers may refer to specific aspects of the CPRT plan.

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SonORADON Mr. M. D. Spencer 84056.103 August I,1986 Page 2 2.

Cygno/CPRT meetings will be scheduled md conducted within 60 days.

At these meetings, Cygna will be able to clarify any questions relative to the CPRT efforts os they pertain to Cygna findings.

3.

TUGCO will provide the relevant technical procedures referenced in the CPRT plan as soon as possible.

4.

Cygna will issue the Phase 4 report which details the resolution of each individual finding offer all open items and issues are rescIved with the CPRT.

One CPRT piping procedure was received on July 31,1986. No other commitments have been fulfilled.

At the last meeting Cygno also questioned the schedule for resolution of outstanding design control issues such as the adequacy of the historical document control system.

TUGCO responded that the collective significance of procedural breakdowns would not be addressed until the conclusion of the CPRT corrective actions. The target date for this is Spring 1987. No agreement was reached relative to how the Cygno design control issues would be addressed in the Phase 4 report or whether they should be assessed in a report to be prepared upon the conclusion of the CPRT program. This completes the substance of the agreements made to date.

In the interest of keeping all parties informed a list of activities completed or in progress over the lost 10 months is attached. This some stxnmary was provided in response to i

CASE discovery request on July 3,1986 (Reference Cygna letter 84056.102).

We look forward to receiving TUGCO's responses and establishing a meeting schedule with the CPRT.

l Very truly yours, Richard J. Stuart President cc: Service List (Attachment 2)

Enclosure RJS/om

August 1, 1986-84056.103 Mr. M.D. Spence ATTACHMENT 1 The following is a brief summary of Cygna's activities for the past year related to the Comanche Peak Independent Assessment Program.

A.

Database of Findings A database of all findings from the four phases of the IAP has been compl eted.

B.

Probable Cause Evaluation For each of the findings, a preliminary probable cause grouping has been assigned based on the information available to Cygna as of this date. These groupings have been incorporated into the database for use in a cumulative effects evaluation.

C.

Observation Updating All observations from Phases 1, 2, and 3 are currently being updated to reflect information obtained since the last issuance and to refer to related Phase 4 findings as appropriate. This activity is not complete and awaits the receipt of further documentation.

D.

Review of Relevant CPRT Documents Project team personnel are reviewing documents related to the CPRT activities as they pertain to the Cygna findings. In October,1985 Cygna documented and transmitted certain questions related to the revision of the CPRT Plan received by Cygna on 7/9/85. Cygna expects to meet with CPRT review teams in the future in order to close out Cygna findings. To date the CPRT procedures and criteria necessary l

to resolve the Cygna issues have not been received.

1

August 1, 1986 84056.103 Mr. M.D. Spence E.

Review of Relevant ASLB Documents Cygna has continued to review documents transmitted from the NRC, ASLB, CASE, and TUGC0 for relevance to the Cygna review scope and findings. Listings of these documents sorted by subject area have been transmitted to TUGC0 on a continuing basis. The latest listing was dated April 23, 1986.

F.

Review Issues List (RIL)

Cygna is continuing to update the RIL which is a sununary overview of the key findings and open issues from all four phases of the IAP.

G.

Supplemental Walkdowns Cygna project personnel conducted select supplemental field verifications during 6/85 The walkdowns were performed to confirm certain data and to reconcile outstanding questions arising from Cygna data and responses received from TUGC0 and Giobs A Hill since the first set of Phase 4 walkdowns.

H.

Special Studies In order to evaluate the design significance of certain cable tray and conduit support findings and evaluate the reasonableness of selected TUGC0/Gibbs A Hill responses, Cygna is performing some analyses. These analyses include:

(1) buckling of single angle braces, (2) base angle connection behavior, (3) thermal loadings on conduit supports, (4) NPSI pad evaluation, (5)' punching shear evaluation of tube steel, (6) cabic tray dynamic amplification factor evaluation, (6) torsion of unistrut sections.

I.

Preparation of Phase 4 Final Report The following activities have been ongoing in preparation for the issuance of the Phase 4 work:

1.

Over 200 checklists are being finalized.

2.

Observations are being prepared to the extent possible without interfacing with CPRT personnel on the resolutions.

1 2

August 1, 1986 84056.103 Mr. M.D. Spence 3.

The list of documents reviewed has been finalized.

However, some additions may be required as new information is received.

4 The Review Scope and Methodology sections have been drafted.

5.

The Program Review Matrices have been drafted.

6.

The Design Review Criteria documents are undergoing independent reviews by Cygna personnel.

7.

The Work Instruction for conducting the design review is being revised to reflect the current methodology, since changes have taken place as a result of the CPRT effort.

The final report cannot be completed until Cygna receives responses which are necessary to close Cygna's open items, and resolution is reached with the CPRT relative to Cygna's findings.

J.

Responses to CASE Discovery Requests Cygna has prepared detailed responses on CASE's discovery requests regarding pipe support stability submitted on 3/24/86 and 6/20/86.

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e August 1, 1986 84056.103 Mr. M.D. Spence ATTACl#ENT 2 Mrs. Juanita Ellis President, CASE 1426 S. Polk Dallas, Texas 75224 Nicholas S. Reynolds, Esq.

Bishop, Liberman, Cook, Purcell & Reynolds 1200 Seventeenth Street, N.W.

Washington, D.C.

20036 Robert Wooldridge, Esq.

Worsham, Forsythe A Sampels 2001 Bryan Tower Dallas, Texas 75201

. Ms. A. Vietti-Cook.

U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, Maryland 20014 Peter R. Bloch, Esq.

Chairman, Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission 4350 East West Highway, 4th Floor Washington, D.C.

20814 Stuart A. Treby, Esq.

Office of the Executive Legal Director U.S. Nuclear Regulatory Commission 7735 Old Georgetown Road Rethesda, Maryland 20814 William Counsil Texas Utilities Generating Company Skyway Tower 400 N. Olive Street, L.B. 81 Dallas, Texas 75201 P R J:S-LIST

August 1, 1986 84056.103 Mr. M.D. Spence Mr. Jack Redding Texas Utilities Generating Company 400 North Olive Street, L.B. 81 Dallas, Texas 75201 or c/o Oatel Services Corp.

7910 Woodnont Avenue Suite 208 Rethesda, Maryland 20814 Mr. David R. Pigott Orrick, Herrington A Sutcliffe 600 Montgomery Street San Francisco, CA 94111 Ms. Ellen C. Ginsburg Atomic Safety and Licensing Board 4350 East West Highway Bethesda, Maryland 20814 Mr. V. Noonan U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, Maryland 20814 Dr. Walter H. Jordan 881 W. Outer Drive Oak Ridge, Tennessee 37830 Dr. Kenneth A. McCo110m 1107 West Knapp Stillwater, Oklahoma 74075 P R J:S-LIST