ML20212H793

Forwards Comments Re Review of Three Isaps Re Hot Functional Testing,Receipt & Storage of Purchased Matl & Onsite Fabrication Forwarded w/860513 Ltr

ML20212H793
Person / Time
Site:	Comanche Peak
Issue date:	07/31/1986
From:	Noonan V Office of Nuclear Reactor Regulation
To:	Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
NUDOCS 8608140187
Download: ML20212H793 (6)

Text

31 JUL 1986 Dockst Nos.

50-445 9 1 JUL M and 50-446 Mr. William G. Counsil Executive Vice President Texas Utilities Generating Ccmpany Skyway Tower,t. B 81 400 North Olive Street Dallas, Texas 75201

SUBJECT:

REVIEW 0F NEW OR REVISED ISAPs We have completed our review of the three ISAPs forwarded with your letter of May 13, 1986.

ISAP III.a.1 (Rev. 4), Pot Functional Testing Data Packages, is considered to be responsive to the issue as presented. The staff has no coments.

ISAP VII.a.9 (Rev. 0), Receipt and Storage of Purchased Material and Equipment, does not address all of the original concerns which led to this ISAP in that it does not provide for detailed assessment of compliance of vendor items and components with procurement document requirements. We understand that this ISAP will be revised.

ISAP VII.b.1 (Rev. 2), Onsite Fabrication, is considered to be responsive to the issue sub. ject to the comments contained in the enclosure to this letter. The NRC staff will examine your response to these comments as part of its inspection program for the CPRT Program Plan.

Sincerely, Vincent S. Noonan, Director PWR Project Directorate #5 Division of PWR I.icensing-A

Enclosure:

Distribution:

Comments on ISAPs Docket FTlesA OEl.D NRC POR ~ ~

JPartlow cc: See next page 1.ocal PDR BGrimes PD#5 R/F EJordan T. Novak ACRS (10)

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50-445 and 50-446 Mr. William G. Counsil Executive Vice President Texas Utilities Generating Company Skyway Tower,l.. B. 81 400 North Olive Street Dallas, Texas 75201

SUBJECT:

REVIEW 0F NEW OR REVISED ISAPs We have completed our review of the three ISAPs forwarded with your letter of May 13, 1986.

ISAP III.a.1 (Rev. 4), Hot Functional Testing Data Packages, is considered to be responsive to the issue as presented. The staff has no comments.

ISAP VII a.9 (Rev. 0), Receipt and Storage of purchased Material and Equipment, does not address all of the original concerns which led to this ISAP in that it does not provide for detailed assessment of compliance of vendor items and components with procurement document requirements. We understand that this ISAP will be revised.

ISAP VII.b.1 (Rev. 2), Onsite Fabrication, is considered to be responsive to the issue subject to the comments contained in the r

enclosure to this letter. The NRC staff will examine your response to these comments as part of its inspection program for the CPRT Program Plan.

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Sincerely,

, ' s'/

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$4 nan,, Director Projec Directorate #5 Division f PWR I.icensing-A

Enclosure:

Comments on ISAPs cc: See next page 1

o

Enclosure Comments on ISAP VII b.1 (Rev. 2)

Section 4.1.2.? essentially describes the plan's approach to resolution of the issue by a CPRT review of selected items that include at least two of three fab shop work activities (e.g. (1) cutting of material and traceability, (2) fitup and welding, (3) machining; threading, etc.1 performed in the course of fab shop work in producing the item. The CPRT will review the completed fabrication packages for the selected pieces for adequacy of material 4

identification, applicable drawings and procedures used and fabrication and inspection signoffs.

The plan will select three items per calendar quarter (12 per year) for the years January 1980 through December 1985 for a minimum total of 72 items.

COMMENTS Section 4.1.2.2 last paragraph states that the CPRT will review the completed fabrication packages.

It is not clear what a " completed fabrication package" is, or what it will consist of. One of the TRT's concerns was that there was no package per se (drawing, traveller, etc.) at the time the shop fabrication was performed, and the shop activity in many cases was accomplished in accordance with memos, telecons, sketches and material reouisitions that were prepared and issued in the fabrication shop. The plan should define: a " completed fabrication package" and/or identify the documentation to be used to identify the fabricated items selected for evaluation.

During the TRT's investigations, because of the lack of " fabrication packages" the TRT used the fabrication shop material requisition as the means for fabricated item identification that enabled a trail of evaluation of the work performed, drawing, procedure, inspection installation and acceptance as documented in the item / component QA record package.

The staff finds that the time span from January 1980 through December 1985 is of sufficient breadth to cover the issue, however, in view of the number of activities performed in the iron fabrication shop at the time of the TRT's investigations, July-September 1984, e.g.:

1.

Fabrication of ASME component supports 2.

Modification of vendor supplied items, sway struts, snubbers, spring hangers, supports, etc.

3.

Fabrication of miscellaneous steel 4.

Fabrication of non-ASME (safety related) component supports 5.

Fabrication of conduit supports 6.

Fabrication of cable tray hangers i

7.

Fabrication of other items / parts required for construction / installation, l

l

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. the staff finds that the plan may lack sufficient depth in addressing representative coverage for the issues or justification for the basps that a review of 72 selected items plus an undefined number of additional (selected) items will provide reasonable assurance that there are no undetected deficiencies.

Additionally, the CPRT should justify the change, in the plan's methodology, from sampling to an evaluation of selected items.

Sections 4.1.1.1 and 4.1.1.2 address concerns which may be evaluated by review of fabrication document packages or by review of procedures, surveillances, and audit records. However, the TRT findings were also concerned with ongoing activities within the fab shop which may not have resulted in documentation, e.g.,

1.

Shop foremen lacking knowledge of shop procedures.

2.

Craft being asked to perform work without knowledge of paperwork.

3.

Failure to comply with material traceability or identity requirements.

4.

Fabrication not in accordance with procedures.

This concern should also be addressed.

l

O 9

W. G. Counsil Comanche Peak Steam Electric Station Texas Utilities Generating Company Units 1 and 2 cc:

Nicholas S. Reynolds, Esq.

Resident Inspector /Com3nche Peak Bishop,l.iberman, Cook, Steam Electric Statibn Purcell & Reynolds c/o U.S. Nuclear Regulatory Commission 1200 Seventeenth Street, NW P. O. Box 38 Washington, D.C.

20036 Glen Rose, Texas 76043 Robert A. Wooldridge, Esq.

Regional Administrator, Region IV Worsham, Forsythe, Sampels &

U.S. Nuclear Regulatory Commission Wooldridge 611 Ryan Plaza Drive, Suite 1000 2001 Bryan Tower, Suite 2500 Arlington, Texas 76011 Dallas, Texas 75201 1.anny A. Sinkin Mr. Homer C. Schmidt Christic Institute Manager - Nuclear Services 1324 North Capitol Street Texas Utilities Generating Company Washington, D.C.

20002 Skyway Tower 400 North Olive Street, l..B.

81 Ms. Billie Pirner Garde Dallas, Texas 75201 Citizens Clinic Director Government Accountability Project Mr. Robert E. Ballard, Jr.

1555 Connecticut Avenue, N.W.

Director of Projects Suite 202 Gibbs and Hill, Inc.

Washington, D.C.

20009 11 Pen Plaza New York, New York 10001 David R. Pigott, Esq.

Orrick, Herrington & Sutcliffe 600 Montgomery Street Mr. R. S. Poward San Francisco, California 94111 Westinghouse Electric Corporation P. O. Box 355 Anthony 7. Roisman, Esq.

Pittsburgh, Pennsylvania 15230 Trial I.awyers for Public Justice 2000 P. Street, NW Renea Hicks, Esq.

Suite 611 Assistant Attorney General Washington, D.C.

20036 Environmental Protection Division P. O. Box 12548, Capitol Station Nancy E. Wiegers Austin, Texas 78711 Spiegel & McDiarmed 1350 New York Avenue, NW Mrs. Juanita Ellis, President Washington, D.C.

20005-4798 Citizens Association for Sound Energy 1426 South Polk Roy P. I.essy, Jr.

Dallas, Texas 75224 Morgan,i.ewis & Rockius 1800 M. Street, NW Ms. Nancy F. Williams Suite 700, North Tower CYGNA Washington, D.C.

20036 101 California Street San Francisco, California 94111

Texas Utilities Electric Company Comanche Peak Electric Station i.

Units 1 and ?

cc:

Resident Inspector - Comanche Peak c/o U.S. Nuclear Regulatory Commission P. O. Box 1029 Granbury, Texas 76048 Mr. John W. Beck Vice President Texas Utilities Generating Company Skyway Tower 400 N. Olive Street, LB#81 Dallas, Texas 75201 Mr. Jack Redding licensing Texas Utilities Generating Conpany 4901 Fairmont Avenue Bethesda, Maryland 20814 William A. Burchette, Esq.

Counsel for Tex-la Electric Cooperative of Texas Peron, Burchette, Ruckert & Rothwell Suite 700 1025 Thomas Jefferson Street, NW Washington, D.C.

20007 GDS Associstes, Inc.

2525 Cumoerland Parkway Suite 450 Atlanta, Georgia 30339 Administrative Judge Peter Bloch U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Elizabeth B. Johnson Administrative Judge Oak Ridge National I.aboratory P. O. Box X, Building 3500 Oak Ridge, Tennessee 37830 Dr. Kenneth A. McCollom 1107 West Knapp Stillwater, Oklahoma 74075 Dr. Walter H. Jordan 881 Outer Drive Oak Ridge, Tennessee 37830

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