ML20214Q815
| ML20214Q815 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/01/1986 |
| From: | Gad R ROPES & GRAY, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| References | |
| CON-#486-1740 OL, NUDOCS 8612050283 | |
| Download: ML20214Q815 (35) | |
Text
,
}/W4 Filed:.Daccmbar 1, 1986 k
00LKETED USHRC
~86 DEC -4 All :30 UNITED STATES OF AMERICA 6FFICE OF :E Js' 00 N g ggcg N M NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
)
)
Docket Nos. 50-445-OL TEXAS UTILITIES ELECTRIC
)
50-446-OL COMPANY et al.
)
)
(Application for an (Comanche Peak Steam Electric
)
Operating License) -
Station, Units 1 and 2)
)
)
APPLICANTS' THIRD 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 third " Progress Report."
i 1.
CPRT Milestones - Accomplished The Senior Review Team ("SRT") has approved and issued 21 Results Reports (representing 20 Action Plans), as set forth in Attachment 1.
The notice to CASE of the availability of the Working Files for all s
8612050283 861201 ADOCK05000g5 PDR G
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T 4-but one of these action plans has been issued (the notice for the remaining one will be issued as soon as the Working Files have been indexed and transmitted to Dallas), and the responses to.the Board's 14 Questions have been provided for all but 10 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.
As noted on the attachment, two Action Plans have been deleted.
Thus there are a total of 53 action plans (ISAPs and DSAPs), of which 22 have been deleted or completed.
In addition, as anticipated in the previous Progress Report, physical reinspections conducted under Action Plan VII.c were completed during this reporting period.
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:
Issuance of Results Reports for the Issue Specific Action Plans (I.a.1 though VII.b.5); '
)
r
q Issuance of the Collective Evaluation Report for the Testing Program; Completion of the Action Plan VII.c h'ardware re-Inspections; Issuance of the Results Report for Action Plan VII.c; Issuance of the Collective Evaluation Report for the QA/QC and Quality of Construction Program (CPRT Program Plan Appendix B);
Issuance of the Results Reports for the Discipline Specific Action Plans; Issuance of the Collective Evaluation Report for the_ Design Adequacy Program (CPRT Program-Plan Appendix A); and-Issuance of the overall-Collective Significance Report for the CPRT Program.
The CPRT does not work to a project schedule in the normal sense in which the term is used.
The CPRT Project Director collects and collates information from the CPRT Review Team Leaders ("RTLs") and Issue Coordinators ("ICs") with respect to progress, which information is used by the Project Director c.nd the SRT for planning purposes.
The following information may be helpful to the Board:
The milestones set forth above are expected to be accomplished essentially in the order listed. )
a There are 6 Action Plans that at the moment are viewed as likely to be completed in the period from the
'present through December 31, 1986.
These are:
AP No.
Name I.a.1 Heat Shrinkable Sleeves I.b.1 Flex / Flex Separation
.I.b.2 Flexible Conduit to Cable Separation I.b.4 Barrier Removal II.c Maintenance of Air Gap Between Concrete Structures V.d Plug Welds Total:
6 Action Plans These action plans are listed in numerical order, which does not represent an expectation that they will be completed in that order.
There are 13 additional Action Plans that at the moment are expected to be completed between' January 1, l
1987 and March 31, 1987.
These are:
l l
/ :
AP No.
Name I.a.2 Insp. Rprts. Butt Splices I.d.1
-QC Inspector Qualifications III.a.1 HFT Data Packages III.a.5 Preop Package Accept. Criteria
~III.b Conduct of the CILRT III.c Prerequisite Testing VII.a.1 Material Traceability VII.a.2 NCR and CA Systems VII.a.3 Document Control VII.b.1 Onsite Fabrication-VII.b.3 Pipe Support Inspections VII.b.4 Hilti Bolts / Inspection VII.c Construction Reinspection /
Documentation Review Plan Total:
13 Action Plans These action plans are listed in numerical order, which does not represent an expectation that they'will be completed in that order.
The remaining Action Plans.other than_the DSAPs are expected to be completed, and the Collective Evaluation Reports for the Quality of Construction, Construction QA/QC, and Testing Programs are expected to be issued, by approximately the end of the second quarter of 1987.
The Discipline Specific Action Plans and the Design Adequacy Program Collective _ Evaluation'(CPRT Program Plan Appendix A) are presently expected to be completed in mid-1987.
The final report of the SRT J
should follow four to six weeks thereafter.
This schedule does not take into account any possible implications of the matters discussed in " Corrective I
Action Schedule," infra.
In each case, " completed" with respect to an action plan refers to the. approval of a Results Report by the SRT.
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 i
some conscious decisions.
3.
Decisions Affecting Schedule In the first instance, the schedule for the completion of CPRT Action Plans is affected by what the RTL and IC for each Action Plan find.
The Action Plans are investigatory in nature and define conditions under which investigations may be expanded.
Such expansion cannot be foreseen or predicted, and the foregoing schedule includes no allowance for any expansion that may be required.
In addition, TUGC0 may decide for I
whatever reasons to undertake additional investigations or comprehensive corrective actions on its own (with overview by CPRT), of which examples are the piping and-pipe support program and the cable tray support program.
The SRT has been advised that TUGCO presently has under consideration a number of such programs, but the specifics of these programs are not available.
It 1
is likely that, as in the case of piping and pipe supports, these corrective action programs will result 4
in a modification of the DSAPs and, hence, the schedule for completion of the design adequacy program.
4.
Corrective Action Schedule As is set forth~in the Program Plan, corrective actions are the province of the CPSES project.
- Thus, completion of corrective actions is not, except to the 1
extent set forth in the CPRT Program Plan Appendix H, a
preprequisite for completion of'the CPRT program.
Similarly, until action plans are completed, no complete catalog of. the corrective actions that may be required can be formulated.
As the Board is aware, however, certain corrective actions are presently ongoing.
These include:
' u j
. s
s.
1.
Pipe Supports.
The status of this work is described in the TUCCO Letter #TXX-4844 (6/9/86), a copy of which was attached to the First Progress Report.
As the Board is aware, the-Stone & Webster
" Generic Technical Issues Report" has recently been made available, and the program is expected to be completed for large bore pipe and pipe supports,
~
including CPRT oversight, by March, 1987.
The Stone and Webster "CPSES-Unit I Large Bore Piping Final Report" was transmitted to the NRC on Novembe'r 14, 1986
(#TXX-6'085).
The completion of the small bore pipe and pipe support reinspection program is anticipated by September 1, 1987.
2.
Cable' Tray Hangers.
On September 17, 1986 (TXX-4987) copies of documents for " Evaluation and Resolution of Generic Technical Issues for Cable Tray Hangers" prepared by Ebasco Service Incorporated and Impell Corporation were transmitted to the NRC.
The
\\
program calls for a 1007,as-built re-inspection and re-analysis, including resolution of any External Source issues.
The work on this pro 9 ram, including CPRT oversight, is expected to be completed by April, 1987. s 9
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g
o 3.
Conduit Supports.
For Trains A and B conduit supports, the work on this program, including CPRT oversight, is expected to be completed by May, 1987.
A generic technical issues document similar to the piping and cable tray support documents was submitted to the NRC on November 4, 1986 (#TXX-6069).
No date is yet available for Train C completion.
4.
HVAC and Duct Supports.
The work on this program, including CPRT oversight, is expected to be completed by June, 1987.
4 As noted above, TUGCO is considering implementation of additional, similar programs.
The next Progress Report will be issued January 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 Robert A. Wooldridge WORSHAM, FORSYTHE, SAMPELS &
WOOLDRIDGE 2001 Bryan Tower, Suite 2500 Dallas, TX 75201 (214) 979-3000 S
I' 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-ROPES & GRAY 225 Franklin Street Boston, MA 02110 (617 0
By R. K. Gad 1
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ANNOTATED BIBLIOGRAPHIES Pursuant with the Board's Order of June 6, 1986, the Applicants submit herewith the attached annotated bibliographies for the time period of September 26, 1986 through flovember 25, 1986. The principals that were utilized, the documents that are annotated and the document sources are consistent with the guidelines and procedures that were used in previous annotated bibliographies.
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10 CFR 50.55(e)
November 25, 1986, TUGCo During the period of September 26 issued 76 letters to the NRC concerning 65 items which-had previously been identified as potentially reportable under 10 CFR 50.55(e). The letters are catagorized as follows:
A. 45 letters - Interim Report - Evaluation to determine reportability is continuing.
B. 23 letters - Interim Report - Item determined to be reportable, evaluation / corrective action continuing. (see listing below)
Date letter No.
S )AR #
Subject 9/26/86 TXX-5033 C)-85-35 Pipe supports Interim Report - The NRC was previously notified on June 9, 1986 of a reportable item involving the scope of plant modifications resulting from the project's pipe support reverification program.
This report notifies the NRC that engineering evaleation has not identified any additional instances which are con s i dtrred reportable pursuant to 10 CFR 50.55(e) and that evaluation is continuing.
Date__
Letter No.
SDAR #
_SubjeL t
9/26/86 TXX-5043 CP-85-54 Seismic ~ Qualification of HVAC Supports Interim Report - On December 20, 1985, the NRC was notified of a deficiency involving discrepancies in supplier provided HVAC support documents which could invalidate the seismic qualification of the supports. This report notifies the NRC that this deficiency is being resorted under provisions of 10 CFR 50.55(e) and that evaluation
.s continuing.
Date letter No.
SDAR #
Subject 9/26/86 TXX-5044 CP-86-10 Electrical Penetration Assemblies On April 24, 1986, the NRC was notified of a Interim Report reportable item involving the electrical penetration assemblies supplied by Bunker Ramo. This report notifies the NRC that EPA modules supplied by Bunker Ramo will be replaced by modules supplied by Conax. Rework in Unit I has been scheduled, however, rework in Unit 2 has not yet been. established.
Oate letter No.
SDAR #_
Subject _
9/26/86 TXX-5045 CP-86-19 Pressure Instrument Installations On March 21, 1986, the NRC was notified of a j
Interim Report reportable item involving the installation of steam service 2
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i pressure transmitters. Engineering has evaluated all Unit I and Unit 2
steam service installations to identify additional instruments which are mounted above their root valves without wet legs.
During the redesign process, an additional concern was encountered involving a potential change in the criteria for layout and/or support design due to post-accident elevated temperatures which may affect the tubing for these main steam instruments.
This letter notifies the NRC that an integrated design approach win i ch will address both concerns is being pursued.
ate Letter No.
Sl)AR #
S u b.ie c t
/86 TXX-5036 C'-86-11 Component Cooling Water Pump Impeller Linear Indications On June 23, 1986, the NRC. was notified of a Interim Report reportable item involving linear indications on impellers for the component cooling water pumps. This report notifies the NRC that the inspection of the Train A CCW pump impeller is scheduled for completion in October.1986. Train B impeller will be inspected following the av ail ab t.11 ty of Train A
Upon completion of each inspection, the extent of the rework will be determined and repair scheduled.
Letter No.
SDAR #
Subiect
/ /66 TXX-6007 C)-86-54 Original Design of Control Room Ceiling On August 6, 1986, the NRC was notified of a Interim Report potentially reportable item involving the design and installation of the control room ceiling. This report notifies the NRC that this issue is reportable pursuant to the provisions of 10 CFR 50.55(e) and detailed summary of the evaluation was attached.
Date Letter No.
SDAR t Su dact l
10/3/86 TXX-60ll CP-85-62 Polar
- rane Support Structure Interim Report - On September 4, 1986, the NRC was notified of a deficiency involving a misinterpretation of the polar crane load cases. This report notifies the NRC that this issue is being j
reported under the provisions of 10 CFR 50.55(e) and provides an evaluation of the issue and its safety implication. Design Change Authorizations have been prepared for Unit 1 with the schedule l
for implementation to be established no later than December 5, l
1986.
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L Letter No.
SDAR
- Sublect
,0/86 TXX-6017 CP-86-40 Applications of Non-Qualified Agastat Relays On May 28, 1986, the NRC was notified of a Interim Report deficiency involving the procurement and use of non-qualified Agastat relays in several Class 1E applications.
This report notifies the NRC that this issue is being reported under the provisions of 10 CFR 50.55(e) and provides the required information concerning a description and evaluation of safety implications for the issue.
Non cualified relays will be identified and scheduled for rep'acement.
Vendor designed equipment drawings showing the application of Agastat 7000 series-timing relays will be reviewed and revised as necessary to require the use of pre-qualified components for all future replacements. Procurement procedures will be revised to preclude the purchase of non qualified relays for CPSES applications.
Letter No.
S )AR #
Su b: ec <;
0/86 TXX-6015 C'-55-49 Conax Atap ;or Modules and Electrical Penetra-tions On July 11, 1986, the NRC was notified of a Interim Report deficiency involving the effects of polar-organic solvents on the sealants of Conax adaptor modules and electrical penetrations.
This report notifies the NRC that this issue is being reported under the provisions of 10 CFR 50.55(e) and provides the required information concerning a description and evaluation of safety implications for the issue.
Corrective action will include replacement of affected modules and modifications to applicable construction procedures and the. coating Engineering Verification Program so as to include provisions that assure solvents which affect end sealants do not come in contact with the sealants during the appiteations of coatings.
Letter No.
S1AR #
Subject
/86 TXX-6019 C3-55-50 Untstrut spring Nuts on Instrument Supports On July 16, 1986, the NRC was notified of a i
Interin Report deficiency involving nut alignment and torque requirements for Unistrut spring nuts on instrument mounts. This report notifies i
the NRC that this issue is being reported under the provisions of l
10 CFR 50.55(e) and provides the required information concerning a description and evaluation of safety implications for this issue.
Drawings and specifications for instrument racks and instrument and tubing support details have been revised to incorporate specific torque values. Inspection and construction procedures will be reviewed to determine the need for corresponding revisions. Additionally, efforts are underway to develop an integrated pl an-requiring 1005 rework of all installations possibly affected by this deficiency. _.
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o Letter No.
50AR #
S u )J ec t 3/86 TXX-6042 CP-85-72 Small lore Piping and Supports On June 6,
1986, the NRC was notified of a Interim Report reportable item involving the scope of plant modifications resulting from the project's pipe support reverification program.
This report. notifies the NRC that this issue is being divided into two parts to segregate small bore piping and supports from large bore piping and supports. This report provided a list of categories of piping or support modifications that will be tabulated in future interim reports.
Dat<L tetter No.
SDAR #
Sub: ect W,6/86 TXX.5027 CP-86-63 Pipe Support Installations Interim Report - On September 4, 1986, the NRC was notified of a deficiency involving a broken cotter pin on a snubber.
This report notifies the NRC that this issue is being reported under the provisions of 10 CFR 50.55(e) and provides the required information concerning a description and evaluation of s a.fe ty implications for this issue. A reinspection program, called the Hardware Validation Program, will be conducted to re-verify the adequacy of pipe support installations.
1 Mo Letter No.
5)AR #
Sub<act IU3/86 TXX-6044 C'-56-36 Large I; ore Piping and Supports On June 9,
1986, the NRC was notified of a Interim Report reportable item involving the scope of plant modifications from the project's pipe support reverification program.
This is a
follow-up interim report on a
reportable item under 10 CFR 4
50.55(e). This report notifies the NRC that the scope of this issue has been revised to delete small bore piping and supports that are not part.of the large bore stress problems.
An additional reportable item has been issued to encompass these 7
scope deletions. The continuing engineering evaluation for large l
bore piping and supports has identified additional instances which are considered reportable and this report provides a
description of those instances.
t Data Letter No.
50AR #
Subject 10/21/86 TXX-6046 C7-55-19 Conduit support Spans On May 15, 1986, the NRC was notified 'of a Interim Report regarding the use of.a nonrepresentative sample in deficiency determining generic values for typical conduit span calculations.
notifies the NRC that this issue is being reported This report under the provisions of 10 CFR 50.55(e) and provides the required-information regarding a description and evaluation of the safety implications of the issue. For Unit 1,
field verifications and engineering evaluations are continuing. For Unit 2, a complete !
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= ;, 3 5.., 3 design verification of the 52-2910 design package is being conducted, t
letter No.
SDAR #
Subject
/
/86 TXX 6047 CP-85-34 Conduit Support Design Interim Report - On September 6, 1986, the NRC was notified of a deficiency involving the adequacy of conduit supports to perform their intended design function. This report notifies the NRC that this issue is being reported under the provisions of 10 CFR 50.55(e) and provides the required information regarding a
description and evaluation of safety implications for this issue.
The identification and as-built configuration of conduit and conduit supports affected by. the revised design criteria is currently being established through field verification. Unistrut and transverse supports have been examined differently, namely, for Unistrut supports a Unistrut Test Program was implemented to determine the adequacy of Unistrut supports with regard to torsional loading and transverse supports will either be converted to multidirectional supports or will be demonstrated to be not needed.
Oata.
Letter No.
S)AR #
Subject 10/21/86 TXX-6048 C)-85-35 Cable Tray Hangar Design Interim Report - On September 6, 1986, the NRC was notified of a deficiency involving the design and construction activities of the cable tray hangar program. This report notifies the NRC that this issue is being reported under the provisions of 10 CFR 50.55(e) and provides the required description and evaluation of safety implications for this issue. EBASCO and Impell have been directed to perform a 100% verification of the cable tray system design. These design activities are being conducted in accordance with CPRT Program Plan Item DSAP VIII, which includes third-party overview to assure resolution of the issues and compliance to licensing commitments.
The verification program is being implemented for Units 1
and 2.
A testing program has been established to augment the cable tray support verification offort.
f Letter No.
SOAR #
Subject Qajj,g,1/86 10/z
'XX-6049 C'-85-42 Thermolag on Conduit Supports Interim Report - On September 20, 1986, the NRC was notified of a deficiency involving the possible adverse effect of the substitution of rectang'ular and oversized pre-formed sections of thermolag on conduit installations. This report notifies the NRC that this issue is being reported under the provisions of 10.CFR 50.55(e) and provides the required information regarding a
description and evaluation of the safety implications of the issue. Engineering analysis will continue for affected conduit s.
supports and associated appurtenances. The final evaluation and _ _
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Date letter No.
SOAR #
Subject
'IT/Tl/86 TXX-605Z CP-86-46 Gould Battery Racks Transverse Bracing f
On June 11, 1986, the N R f.
was notified of a Interim Report deficiency involving a design change to vendor supplied equipment being made without formal evaluation by the vendor. This report notifies the NRC that this issue is being reported under the provisions of 10 CFR 50.55(e) and provides the required information regarding a description and evaluation of safety implications for this issue. The design change in question has been voided and the original design requirements reestablished.
TUGCo Nuclear Engineering Procedure
" Engineering Review and Design Verification of Field Design Changes has been revised and now provides more detailed instructions and establishes a
verifiable approval record of all design changes including calculations. Rework associated with this issue is continuing.
Date letter No.
S)AR f Sublect 10/21/86 TXX-6054 C8-86-53 SeismLc Design of Conduit On July 25, 1986, the NRC was notified of a Interim Report deficiency involving the seismic design of conduit. This report notifies the NRC that this issue is being reported under the provisions of 10 CFR 50.55(e) and provides the required information regarding a description and evaluation of safety implications for this issue. A testing program has been scheduled to evaluate the ability of adhesives or clamps, applied to the conduit coupling af ter installation, to resist torsional moments.
Dato Letter No.
50AR #
!iubie :t Im/;,4/86 TXX-5091 C'-85-54 Orig'nal Oesign of Control Room Ceiling Interim Report - On October 3, 1986, the NRC was notified of a reportable item involving the design and installation of the control room ceiling. This report notifies the NRC that physical construction of the new ceiling is complete with the one remaining activity being quality control verification.
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SOAR #
. Subject Im/ L7/86 TXX-6090 CP-86-31 Diesel Generator Lube Oil Sump Tank Foot Valves Interim Report - On August 22, 1986, the NRC was notified of a reportable item involving the possible failure of the rubber facing on foot valves mounted in the diesel generator lube oil sump tank. This report notifies the NRC that new Viton liners have been purchased and received at the CpSES site. Unit I work orders have been issued. Unit 2 replacement liners are scheduled for installation after lule oil flush of the diesel generator system.
Date letter No.
5)AR #
Subject 11/17/86 TXX-6101 C)-86-49 Conax Adaptor Modules Interim Report - On October 10, 1986, the NRC was notified of a deficiency involving the effects of polar-organic solvents on the sealants of Conax adaptor modules and electrical penetrations.
This follow-up report notifies the NRC that applicable construction procedures and the coating engineering verificgtion program were modified to include provisions which ensure solvents, that affect end sealants, do not contact the sealants during the application of coatings. Evaluation is continuing.
Date Letter No.
SDAR #
Subject 11/20/86 TXX-6106 CP-85-54 Seismic Qualification of HVAC Supports Interim Report - On September 26, 1986, the NRC was notified of a deficiency involving discrepancies in supplier provided HVA' supports.
This letter notifies the NRC that the following
~
corrective action is being taken:
1)
Project organization and responsibilities for Unit 1
and common HVAC activities have been realigned.
- 2) The ~ field verification effort has been - expanded to encompass Unit 1 and Common Seismic Category 1 duct supports.
- 3) Engineering evaluation will be performed to ensure compliance with FSAR commitments.
- 4) Construction rework will.be performed, as deemed necessary by the engineering evaluation of field verified information, to ensure compliance with FSAR criteria for the affected supports.
S) Unit 2 HVAC supports are being field verified.
Activities and evaluations are continuing.
1
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7 letters.- Final Report - Deficiency not reportable (see listing below)
Date Letter No.
50AR #
Subject 9/26/86 TXX-5046 C ) 86-21 Qualification of Raychem Kit NPKS-02 01 On March 24,
- 1986, the NRC was notified of a Final Report deficiency involving possible discrepancies in vendor (Raychem) methodology for testing of environmental qualification which may render the Raychem Kit NPKS 01 unacceptable for specific published applications. This report transmits that documentation has been received from Raychem which provides technical justification and qualification of the CPSES installation configuration to the site-specific qualification report for the Raychem kit.
It has been concluded that this issue is not reportable pursuant to the provisions of 10 CFR 50.55(e).
Letter No.
SDAR #
Subject
/86 TXX-5047 CP-56-43 ITT sarton Model 580 Series Switches On June 4,
- 1986, the NRC was notified of a Final Report deficiency involving the environmentr.1 qualification of ITT Barton Model 580 series switches. This letter transmits that evaluation of the application of this issue has revealed the switch installations at CPSES are located outside containment and are not required to be qualified under LOCA conditions. Further evaluation has included a
verification of qualification documentation.
It has been concluded that this issue is not reportable under the provisions of 10 CFR 50.55(e).
Dato Letter No.
$1AR #
Subiect-10/L/86 TXX-6002 C!-86-15 Diese' Generator Control s On March 14,
- 1986, the NRC was notified of a Final Report deficiency involving the field flash and K1 relays which are required to operate during the starting process of the diesel generators.
This report transmits that the generator cor.trols i
were reviewed by Transamerica Delaval Inc. under the Owners Group i
Design Review and Quality Revalidation Program.
Clarification i
from the vendor rtveals that although the ficld flashing circuit current requirement is 90 Amp DC, the inductance of tht. generator field and the reverse potential developed across the battery terminals due to excitation will limit the battery contribution to a maximum of approximately 14 Amps DC. Based on this,- the voltage at the diesel generator control panel bus will be greater than 100 V DC. The deficiency will have no adverse affect on the safety of operation of the diesel generators and therefore it is concluded that this issue is not reportable pursuant to the provisions of 10 CFR 50.55(e). -
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- dE.:I Date Letter No.
SDAR #
Subject 10/15/86 TXX-6025 CP-86-57 Reinforcing Steel in i
Reactor Cavity Wall On August 29, 1986, the NRC was notified of a Final Report deficiency involving the reinforcing steel in the Unit I reactor cavity wall. Specifically, additional reinforcing steel for the wall was specified and deleted through subsequent drawing revisions without supporting design calculations.
This letter transmits that specific calculations justifying the adequacy of the wall, without the additional reinforcing steel shown in i
Revision 3 of Drawing 2323-$1 0572, were not generated because the design was restored to conditions specified per Revision 2 of the drawing.
Subsequently, additional calculations have been generated which demonstrate that the omission of the additional i
reinforcing steel does not impair the structural integrity of the reactor cavity wall and the as-built reinforcement configuration is adequate. It is concluded that this issue is not reportable under the provisions of 10 CFR 50.55(e).
Dato letter No.
Si)AR #
Subject 10/ 5/86 TXX 6029 C'-86-58 Orilling/ Cutting of-Peinforcing Steel in l
the Fuel Building On August 29, 1966, the NRC was notified of a Final Report deficiency involving the drilling / cutting of reinforcing steel in the fuel handling building.
Specifically, drilling / cutting activities were cited at elevation 810'-6" which possibly extend to the third layer of reinforcing steel although only cutting of the first layer was authorized.
This report transmits that structural evaluations have been performed which demonstrate that additional cutting ~ of the third layer of rebar steel is acceptable. The applicable design change change document has been revised to reflect acceptance of the condition. It is concluded that this issue is not reportable under provisions of 10 CFR 50.55(e).
Dato Letter No.
SDAR #
Subject IL/m4/86 TXX-6083 CP-85 24 Space & Motor Heaters On April 10, 1986, the NRC was notified of a Final Report deficiency involving the use of unqualified motor operator switch compartment space and motor heaters connected to IE circuits which ' could result in degraded class 1E circuitry. This letter transmits that the class 1E circuits that power the space heaters are protected by current interrupting.or limiting devices.
Therefore, reasonable assurance exists that the busses would not have been degraded if the heaters had remained connected and failure of the heaters would not have affected the safety of plant operations. The space heaters will be disconnected from their class IE circuitry to ensure proper isolation and ssparattn.
It is concluded that this issue is not reportable 10-1
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under the provisions of 10 CFR 50.55(e).
SDAR 8 -
Subiect Date letter No.-
CP-86-61 Polar Crane Restraints 11/17/86 TXX-6092 Final Report - On September 4, 1986, the NRC was notified of a deficiency involving the restraints for the polar crane rail.
Specifically, three. rail to rail ground wires have been found broken, two shims have partially dislodged from under the rail, and two cadwelds connecting the ground wire to the rail have been broken. This indicates that movement occurred in the Unit 1 polar crane rail assembly. This report notifies the NRC that the rail movement and associated loss of ground wires and dislodging of shims might have necessitated minor maintenance or
- repair, affect the aspects of polar. crane
- however, they do not ~ reliability that are required for its performance, safety, or intended safety function. It is concluded that this issue is not reportable under 10 CFR 50.55(e).
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I letters - Final Report - Deficiency is Reportable and Corrective Action Taken_(see listing below)
.Su_ ject b
Date letter No._
S] A R #_ _
10/17/86 TXX-6025 C ) 3 3 Stiffness values for Class 1 Stress Analysis On April 29, 1986, the NRC was notified of a Final Report deficiency involving the use of incorrect pipe su stiffness values in the Unit 1 Class 1 pipe stress analyses.pport This report transmits notification to the NRC that this issue is being reported under the provisions of 10 CFR 50.55(e) and provides the required information in regards to a description and evaluation of the safety implications of the issue. As identified during the CPSES pipe support requalification effort, incorrect stiffness values were used in the Unit 1 Class 1 pipe stress analyses.
Evaluation is continuing and support modifications will be issued as required to alleviate all unacceptable conditions. The status of support modifications is being reported via SDARs CP-86-36, CP-86-63 and CP-86-72.
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CPRT The following correspondence was issued by TUGCo to the NRC concerning CPRT during the period of September 26 - November 25, 1986:
Date Letter No.
Subject 9/Z5/86 TXX-5001 CPRT Results Report This letter transmitted Results Report I.d.2, Guidelines for Administration of QC Inspector Test, of the CPRT Program Plan to the Staff. Copies were also sent to,the ASL8.
Dato Letter No.
Subject 10/ 0/86 TXX-6020 CPRT checklists This letter transmitted revisions to be included in the manuals previously submitted which describe the use of CPRT Checklists.
Date letter No.
-Subject-10/17/86 TXX-6043 Revision of CPRT ISAF' This letter transmitted Revision 1 to CPRT Issue-Specific Action Pl an VII.a.9, Adequacy of Purchased Safety-Related Material and Equipment. Copies were also sent to the ASL8.
Dato Letter No.
Subject IL/m 4/86 TXX-5085 Stone & Webster Engineering Corporation Piping and Pipe Support Requalification This letter transmitted copies to the NRC of "CPSES-Unit 1 Large Bore Piping Final Report" prepared by SWEC for TUGCo. This report is part of the CPRT Piping and Pipe Support Requalification Program.
Date Letter No.
Subjoct 11/19/86 TXX-6113 CPRT Resu'ts Reports This letter transmitted the following Results Reports:
III.a.2 JTG Approval of Test Data - Rev.0 III.a.3 Technical Specification for Deferred Tests
- Rev.0 V.a Inspection for Certain Types of Skewed Welds in NF Supports - Rev.1 V.c Design Consideration for Piping Systems Between Seismic Category 1 Buildings-Rev.1 V.e Installation of Main Steam Pipes - Rev.1 i
VII.a.6 Exit Interviews - Rev.1 VII.a.8 Fuel Pool Liner Documentation - Rev.1 Copies were also sent to the ASLB. 1 3e
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- :. 3 g, a RESPONSES TO NRC INSPECTION REPORTS /
NOTICE OF VIOLATION / NOTICE OF DEVIATION _
The following correspondence was issued by TUGCo to the NRC Region IV concerning inspection reports during the period September 26 - November 25, 1986:
Date letter No.
Subject 10/9/86 TXX-5037 Response to NRC Notice of Violation, Inspection Rept.
Nos. 50-445/86-06 &
50-446/86 04 This Notice of Violation contained the following items:
Instructions and procedures do not address Item A-1 specification requirements with respect to workmanlike installation, training of cables without interlacing or installation of cables to a uniform depth.
Instances were observed of cables ' spilling o v e r._t h e Item A-2 siderails of cable trays and cables not laid in the tray at the vertical to horizontal transition between cable tray sections.
Item B_-
Instances were observed.where cable support grips were not installed as applicable to specifications.
This letter transmitted the following responses to these items:
Electrical Erection Specification, ES-100, will be reviewed and revised as necessary to clarify the general requirements of good workmanship, interlacing and uniform cable depth.
The specification will be reviewed and revised as necessary to adequately address installation sequences (e.g.
cable grips).
Applicable implementing procedures and instructions will be reviewed and revised to ensure compliance with the revised specification, i
Data Letter No.
Subie r j
10/13/86 TXX 5048 Response to N K Notice of Violation and Notice of Deviation-Inspection Report Nos. 50-445/86-01 50-446/86-01 The Notice of Violation contained the following items:
J Established procedures for handling of nonconforming Item A materials, parts, or components were not effectively implemented.
Six (6) observed conditions were cited. TUGCo disagreed with the alleged violation in two (2).of the observed conditions and cited supporting reasons in its response.
In response to the other conditions, the following corrective action was taken:
1)
A review of Deficiency Reports (ors) received was 14-l
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conducted and NCRs were issued for all ors not previously documented on NCRs.
2)
CP-QP-16.3 R2 now requires-that all out-of-scope observations be documented on NCRs regardless of the described condition.
All out-of-scope observations have been reviewed to determine - if NCRs were issued for them.
NCR0 have now been issued for all out-of-scope f
observations,
- 3) An NCR was generated to disposition all items listed on the 3-part menos.
- 4) Deficiency Notifications (DNs) may no longer be used to process DRs.
NCRs are used to document deficiencies regardless of the stage of component processing.
Specified field tests of cable reels were neither
_ Item 8 prescribed by implementing procedures nor performed.
TUGCo responded that it is of the opinion that the conditions described in this item are not a violation.
None of the manufacturers supplying cable reels to CPSEs have recommended field tests on cable reels. CPSES procurement documents invoke and reference all applicable specifications and/or testing whic.h is required of manufacturers.
The required certification / documentation-is transferred to CPSES with the shipment of cable and is reviewed for acceptability by receiving inspection and quality control.
Site 3rocedures invoke additional acceptance testing after l
installation which are more stringent than testing in the bulk real form. The requirements of the Gibbs & Hill specification in question (paragraph 6.15.1(t) of Spec.
2323-ES-100) is meaningless and redundant. In order to eliminate this redundancy, the paragraph was removed from the specification by design change DCA-24088 issued January 24, 1986.
l The Notice of Deviation contained the following items:
Itan A - Preoperational tests " Auxiliary Feedwater System" failed to lest the AFW pumps against a back pressure determined using main stream safety valve ' accumulation'
- pressure, but instead-incorrectly used the safety valve
' set' pressure.
CPSES Engineering is still evaluating this deviation and the tests 'and requirements for the Auxiliary Feedwater Pumps.
Item 8 - Four examples were cited where field reinspections were not performed in accordance with approved instructions.
This letter responds that a Deviation Report was prepared in three of l
the instances to document the deviation. NCRs were generated to disposition the condition.
In the fourth instance, an out-of-scope observation number was prepared and dispositioned.
Action was also taken to prevent recurrence.
In cases where inspector error was evident, the inspector and the lead inspector or population engineer discussed. specifics to determine why the
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error occurred. Action taken to address -the error and preclude recurrence typically included one or more of the following, as necessary: E
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. Documented retraining of the inspector (s) to the pertinent Qual.ity Instruction (s)
. Clarification or revision of the Quality Instruction (s)
An Overview Inspection program was imolemented to reinspect a sample of each inspector's work. Action is ongoing to analyze the results of this program which includes pertinent inspector error data from other sources (i.e. NRC inspections,etc.).
Item C "N/A" incorrectly indicated for attribute 1.e in the ERC inspection checklist resulting in f ailure to reinspect applicable attribute. This. letter responded that no corrective action has been planned for this deviation. The lack of reinspection ( one branch connection, in this instance) will not affect the final conclusions drawn concerning branch connection installation. A statistically sufficient quantity of branch connections have been inspected to permit the adequacy of branch connection installations to be determined. Additionally, ERC inspectors have been instructed to correct a checklist when an error is found or return the list to the QA/QC engineer for correction.
This instruction was confirmed by memorandum dated May 28, 1986.
Date letter No.
Subdect 10/31/86 TXX-6071 Supplemental Response to NRC Notice of Violation Inspection Report Nos.
50-445/86-06 & 50-446/86-04 In a previous response to a Notice of Violation (TXX-5037),
concerning Inspection Report Nos. 50-445/86-06 and 50-446/86-04, TUGCo stated that it would provide the date of full compliance to Item A by October 31, 1986. This letter transmits that the "date when full compliance will be achieved" is-June 1, 1987.
Date Letter No.
Subiec" 1;./4/86
'XX-6070 Supplemental Response lo NRC Notice of Violation & Notice of Deviation-Inspection Report Nos. 50-445/86-01 and 50-446/86-01
- os. 50-445/86-01 and 50-TUGCo responded to Inspection Report N
446/86-01 on October 13, 1986 (TXX-5048).
In the response to Notice of Deviation, Item A, it was stated that CPSES Engineering was still evaluating the NOV and the tests and requirements for the Auxiliary Feedwater Pumps. This letter transmits a response to this ites, namely, to ensure the adequacy of the Auxiliary Feedwater System, the test procedures and data are being reviewed
-and evaluated. Also, the design limits assumed-in each accident analysis will be reviewed against the FSAR Chapter 15 documentation and the FSAR corrected as required. Any resulting FSAR changes will be reviewed against the affected test procedures / test data packages-and corrective action documented as l
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discussed above for the Auxiliary Feedwater System.
Date _
Letter No.
Subject 11/12/86 TXX-6082 Response to. Concerns in Inspection Report Nos.
50-445/86-17 & 50-446/86-14 This letter transmitted responses to certain open items that were identified during an inspection that covered TERA's Quality Assurance Program for the Comanche Peak Design Adequacy Program for Comanche Peak Steam Electric Station Units 1 and 2.
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TUGC0 INTERNAL AUDIT Of ENGINEERING AND CONSTRUCTION ACTIVITIES Aeports Issued After September 25. 1986 Number:
TCP-88-29 Date:
08/04-08/86 Report Date:
10/28/86 Scope:
The audit wee performed to verify implementation of TNg Design Change Control quality related activities.
Number:
TCP-88-31 Date:
08/25-29/88 Report Date:
10/08/86 Scope:
The audit scope was to evaluate the adequacy and verify the implementation of the Construction And Quality Control progrene including A8ME for organisationel structure and the control and issuance of procedursa and instructicr.s.
Number:
TCP-88-32 Date:
09/08-12/85 Report Date:
09/26/86 i
Scope This audit wee performed to evaluate and verify the implomontation of Brown and Root's ASME N-5 Certification end Code Stamping program for Unit aumber 2.
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TCP-86-33 Date:
09/08-12/86 Report Deter 10/08/86 This audit was conducted ta verify the adequacy of Scope:
implementation of the prograne for installation and inspection of safety-related Conduit Maceway I
Supporte im Unit's 1 and 2 and the corresponding engineering As Built Programa for Conduits and Conduit Supporte.
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PAGE 2 Number:
TCP-86 -34 Date:
09/15-19/86 Report Date:
10/10/86 Scope:
This audit was performed to verify implementation of CPSBS training and certification program for ASME and Non-ASME inspectors, Brown und Root ASME euditors, and cenetruction personnel in accordance with applicable procedures and requiremente.
Number:
TCP-86-35 Date:
09/22-26/86 Report Date:
10/07/86 Scope:
The audit was performed to include verification of I&C activitime for atorage, installatten and inspection of instrumentation, tubing and supports in accordance with program requirementa and applicable procedure requiremente.
Number:
TCP-86-37 Date:
09/29-10/03/86 Report Date:
10/16/86 Scopa:
This audit was performed to evaluate and verify the implementation of TUCCO's A3ME Section XI repair / replacement program during the cometruction phase.
Number:
TCP-86-39 Date:
10/13-17/86 Report Date 10/24/86 Scope:
This audit wee performed to mesess the adequacy of the QA Surveillance Program and to verify compliance with QA requiremente.. _ - _ _ _.. - - _ _ _ _
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= c. 3 3, 2 3 MISCELLANEOUS--
The following additional correspondence was issued to the NRC during the period of September 26 - November 25, 1986:
1 Date letter No.
Subject 10/3/86 TXX-6014 FSAR Amendment This letter transmitted changes scheduled for a future FSAR amendment. Changes result from an analysis performed to justify cable splices in raceways.
Date Letter No.
Subject 10/7/86 TXX-5049 FSAR Amendment supplemental Information This letter transmitted additional information regarding changes related to the Stone & Webster Engineering Corporation piping and oipe support requalification effort. By letter TXX-5006 dated September 12, 1986, TUGCo transmitted to the NRC Staff an advince copy of a future CPSES FSAR amendment which incorporates these changes.
Date Letter No.
Subject 10/21/86 TXX-6057 Arbitrary Immediate Pipe Breaks This letter transmitted additional information, as requested on September 11,
- 1986, concerning elimination of arbitrary intermediate pipe breaks.
Date Letter No.
Subject 10/Z9/86 TXX-6177 Cygna and 5WEC Neeting This letter transmitted a notice of a forthcoming meeting between Cygna and Stone & Webster Engineering Corporation to discuss the piping system and pipe support corrective action program.
Date letter P o.
Subject 11/4/86 TXX-6065 Evaluation and Resolution of Generic Technical Issues This letter transmitted documents for -evaluation and resolution of generic technical issues for conduit and conduit supports as prepared by EBASCo.
Date Letter No.
Subject-11/4/86 TXX-6075 Evaluation / Resolution of Issues This letter transmitted documents for evaluation and resolution of Cygna Train A & B issues as applicable to Train C conduit supports.
Documents prepared by Impe11 Services Inc. - -
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_ Subject im/;,0/86 TXX-6086 Implementation of Revised GDC-4 This lett.or notifies the NRC that modifications have been made to the design basis for CPSES to take advantage of a final rule issued by the NRC on April 11, 1986, modifying GOC-4. This letter also transmitted an advance copy of FSAR revision which will document these changes in a future FSAR amendment.
Date _
Letter No.
Subject 11/12/86 TXX-6057 Potential Failure of Air-Operated Valve in Minimum Flow Recirculation Line This letter notifies the NRC that TUGCo has performed an evaluation of all the valves associated with IE Bulletin 86-03 and concludes that Comanche Peak does not have the single failure vulnerability problem described in the bulletin.
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=u3s.22 OTHER On behalf of Texas Utilities Generating
- Company, Robert A.
Wooldridge has submitted various documents to the Board for their information. These documents include the following:
September 26, 1986 Applicants' Answers to CASE's Interrogatories, Sets 1 and 2.
September 26, 1986 Copies of Appendices F,G & H to the CPRT Program Plan September 26, 1986 Approved Results Report, I.d.2 October 17, 1986 TXX-6043 and Revision 1 of CPRT ISAP VII.a.9 November 4, 1986 Documents for Evaluation / Resolution of Generic Issues. (Ebasco)
November 4, 1986 Documents for Evaluation /Resolud on of Cygna Train A
B Issues.
(Impell)
November 17, 1986 Copies of "CPSES-Unit 1-Large Bore Piping Final Report". (SWEC)
November 19, 1986 Approved Results Reports, III.a.2, III.a.3, V.a.
V.c, V.e, VII.a.6, and VII.a.8.
Internal Memo from J.F.
September 26, 1986 QQO-41 Streeter to J.W.
Beck transmitting the CPRT Overview Quality Team (0QT)
Progress and Status Report for September, 1986.
This resort includes a summary of the 0QT meeting held September 15-19,
.986 and a progress and status report of OQT's activities.
The following consultant reports have been received by engineering for the time period of September 26, 1986 to November 25, 1986:
Cross-Hole Geophysical Survey, Dames and Moore, July, 1986.
Geotechnical Laboratory Testing, Dames and Moore, October, 1986.
Probabilistic Seismic Hazard Assessment, October 23, 1986.
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Test Report for Tensile and Shear Strength Testing of Hilti Kwik Bolts for Train "C"
Conduit Supports, CCL Report No. A-736-36, Corporate Consulting and Development Company, Ltd., October 23.
1986.
Generic Pipe Support Stiffness Valves for piping
- Anaysis, September, 1986.
Engineering Evaluation and Hardware Modification Liability Assessment of Cinched U-bolt Supports, October 28, 1986.
Evaluation of Pipe Support Loads Developed by the Nomograph Method for Seismic Category II Piping, October 6, 1986.
Documentation of ASME-III, NA-1140 Review for Piping and Supports, October 28, 1986.
Piping and Pipe Support Requalification Program-Unit 1-Large Bore Piping Final Report, November 7, 1986.
An Evaluation of Capability Required to Support the Conversion of Selected Design Drawings to a Computer Aided Design (CAD) Sy s,t em at Comanche Peak Steam Electric Station, September 15, 1986.
Stir - CDRT-E-1, Butt Splice Report, October 29, 1986.
Low-level Radwaste Cost Study, November 7, 1986.
4 Audit of Liquid, Solid and Gaseous Radioactive Waste System.
November 7, 1986.
Records Management Program, Updated.
Monthly Status Reports from such organizations as Ebasco, SWEC and Impell.
f
a 00LKE!ED me CERTIFICATE OF SERVICE
'86 DEC -4 All :30 attorneys for the g h ants g,y I, Robert K. Gad III, one of the liRM1CH herein, hereby certify that on December 1, 1986, I made service of 1
the within " Applicants' Third Progress Report and Annotated Bibliographies", 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 Nancy Williams Administrative Judge Cygna Energy Services, Inc.
881 W. Outer Drive 101 California Street, Suite 1000 Oak Ridge, Tennessee 37830 San' Francisco, California 94111 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 Washington, D.C.
20555 n-~
6 e
1 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 Mr. Lanny A.
Sinkin Executive Director Christic Institute Trial Lawyers for Public Justice 1324 North Capitol Street 2000 P Street, N.W.,
Suite 611 Washington, D.C.
20002 Washington, D.C.
20036 Dr. Kenneth A. McCollom Mr. Robert D. Martin Administrative Judge Regional Administrator 1107 West Knapp Region IV Stillwater, Oklahoma 74075 U.S. Nuclear Regulatory Commission Suite 1000 611 Ryan Plaza Drive Arlington, Texas 76011 Elizabeth B.
Johnson Geary S. Mizuno, Esq.
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 Cid Georgetown Road Bethesda, Maryland 20814 Ms. Billie P. Garde Midwest Office 3424 N. Marcos Lane Appleton, Wisconsin 54911 j7 OI Robert K.
G d/ III
,