ML20236D796

Submits First Formal Request for NRC Action Re Unit 1 1982 RCS Primary Cold Hydrostatic Test,Per 880630 Joint Stipulation Among Case,Util & Nrc.Documented Request for Action Encl

ML20236D796
Person / Time
Site:	Comanche Peak
Issue date:	03/13/1989
From:	Ellis J Citizens Association for Sound Energy
To:	Murley T Office of Nuclear Reactor Regulation
Shared Package
ML20236D800	List: ML20236D796 ML20236D805
References
NUDOCS 8903230272
Download: ML20236D796 (4)

Text

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IO .A e C A S"E J CITIZENS ASSN.' FOR SOUND ENERGY)

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' March 13, 1989 ,

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,Mr. Thomas Murley,-Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission .

Washington,' D.C. '20555 I

Subject:

Documented Request for Action:

Unit I 1982 Reactor Coolant System l

Primary Cold Hydrostatic Test, j Comanche Peak Steam Electric Station, l Docket No. 50-445, TU Electric, L

l from Citizens Association for Sound Energy (CASE)

Dear Mr. Murley:

Pursuant to Section B.3. of the June 30, 1988, Joint Stipulation among Citizens Association for, Sound Energy (CASE), TU Electric (TU), and the Nuclear Regulatory Commission (NRC)' Staff, CASE hereby submits the first l formal request for NRC action in regard to the Comanche Peak nuclear power plant. The subject of the unresolved dispute between CASE and TU is the Reactor Coolant Systeu (RCS) Cold Hydrostatic Test as conducted and recorded in 1982.

In submitting this request CASE has fulfilled the conditions precedent as anticipated by the Joint Stipulation. Althcugh the process under the Joint Stipulation has not been entirely without problems, CASE, TU, and the NRC have all cooperated to make the process work more smoothly, and CASE believes that it has been confirmed that the Joint Stipulation can provide a workable alternative to litigation for resolving safety concerns and assuring that the public health and safety is protected.

CASE has evaluated the documentation that constitutes the official record of the subject test as presented to CASE by TU. As you know, CASE submitted a

) Draft CASE Inquiry Package (CI-88-0001) to TU on October 14, 1988, and Revision 0 dated October 31, 1988, of that package to TU on November 10, 1988, for the purpose of determining TU's response to a variety of CASE concerns. TU's primary response to CI-88-0001, Revision 0, was made on

January 12, 1989. On January 27, 1989, by my letter jointly to Mr. W. G.

l Counsil, Vice Chairman of TU Electric, and Mr. Christopher I. Grimes, Director, Comanche Peak Project Division, NRC Office of Special Projects, TU and the NRC were advised that the matter of the Cold Hydrostatic Test had reached the dispute stage; mutually agreed upon extensions have followed to allow CASE to receive, evaluate, and include further information.

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Additionally, it has been estimated'that.TU.has provided CASE access;to'over .i 136,000?pages of'necessary documentation as w' ell as provided' CASE's- j consultants-and; staff the' opportunity to discuss

certain' aspects of the test

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with cognizant site-personnel. Finally, pursuant'to Section.B.2. of the .

, Joint. Stipulation, TU and CASE.have participated in several' informal j meetings.in'an attempt to, resolve this matter, which' attempt was not.

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successful. j

> CASE also has had limited-discussions with the NRC Office of Special i Projects-(OSP) staff.as-well as with Mr. Steven M..Matthews, Program Manager l Land-Chief Inspector, Boiler Section,'of the Texas Department of Labor'and i f Standards (TDLS).

L CASE, through its quality assurance / quality control (0A/0C) staff 1 and f consultants, Scott Schum and Owen-Thero of the Quality Technology Company .j

(OTC), has-for the most part concluded.its overview and' evaluation, J sufficient to reach conclusions wh1ch dictate the submission of this formal

request for directed action. As summarized below,. CASE believes'NRC--

directed actionLis'necessary.to' satisfactorily resolveLthis matter.

Supporting. evidence, examples, and information are' included in the OTC q

- report, which ist part-of the basis for this documented. request foi action'. j

- (See 0TC Report, " Evaluation of the Texas Utilities Comanche Peak Steam

( Electric Station Reactor ' Coolant' System Primary . Cold Hydrostatic Test ,"

-which will be supplied under separate cover.)

(After considerable analysis of the official test records and-supporting information, CASE was unable to uncover sufficient evidence'to demonstrate that the~ subject test,'as performed and recorded, complied with the applicable requirements.. In fact, substantial evidence was uncovered to establish, in the view'of CASE's 0A/0C staff and consultants, that the 1982 Reactor. Coolant System Primary Cold Hydrostatic Test did not fully satisfy ASME Section III and other procedural and regulatory requirements.

! . Although the NRC/OSP and TDLS have publicly accepted the subject test, they have done so with a degree of reluctance and misgiving, and acknowledged in public~ meetings that certain requirements were not met in the 1982 performance of the test.

Nonetheless, to date the Office of Special Projects (OSP) at the Nuclear

-Regulatory Commission (NRC), and the State of Texa's have taken the position that the.1982 test is regulatorily acceptable.

L LIn spite of the NRC acceptance, CASE has informally ettempted to convince TU

' of the ne,::essity of redoing the RCS Cold Hydrostatic Test prior to doing the Hot Functional Test (HFT) in order to demonstrate to itself, and the public, that the Reactor Coolant System has been properly constructed and tested to

. ASME Section Ill requirements and will be able to withstand such pressures as postulated'to occur during normal operating conditions as well as under excessive. pressures in accident conditions.

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However, TU has taken the position that it is not necessary to repeat the RCS Cold Hydrostatic Test in order to demonstrate that the system will function as designed under normal and/or accident conditions. TU maintains that the original 1982 test did meet applicable industry codes and standards. Although TU admits to experiencing numerous quality assurance and design problems in the 1982 era, they maintain that the subject test in 1982 was not so negatively impacted that it is not a reliable measure of the system's safety under pressure.

TU has committed to perform an enhanced ASME Section XI (VT-2) test to provide confidence about the reliability of the system (January 11, 1989, letter from William J. Cahill, TU Executive Vice President, to NRC Document Control Desk). As discussed in more detail in the evaluation (which will be supplied under separate cover) by CASE consultant Jack Doyle, CASE agrees that this VT-2 test, if performed correctly under adequate procedures, will reduce or alleviate many of CASE's concerns. However, f rom a QA/0C aspect, CASE does not believe the proposed VT-2 test can or will provide the same degree of assurance to the public as if the original 1982 test had been properly done or if the test were repeated now. CASE recognizes the enhancement benefits of TU's proposed VT-2 Test; however, in CASE's view, it cannot satisfy the intended purpose of TU Electric's having originally completed a valid ASME Section III RCS Cold Hydrostatic Test, nor should it fully alleviate the misgivings and reluctance of the NRC and TDLS in accepting the 1982 original test.

As a result of the inability of CASE and TU to reach an agreement on the acceptability of the 1982 test or its repetition, CASE hereby formally raises this matter to the NRC pursuant to the Joint Stipulation and requests that the NRC staff require, as a condition of licensing, TU to perform an ASME Section III Cold Hydrostatic Test to the currently approved site code, standards, and legal requirements, prior to conducting the site Hot Functional Test.

Alternatively, should the NRC maintain its current position that repeating the RCS Cold Hydrostatic Test is not necessary because of the increased assurance which will be provided by the proposed Section XI VT-2 Test, CASE requests that the NRC Staff, either directly or by imposition of a licensing condition on TU, request a ruling by the ASME Code Committee or other proper ASME board providing a code case exception for TU in regard to their inability to establish that the 1982 test met applicable codes, standards, and legal requirements. It is imperative that all facts, including those provided by CASE and its consultants, be presented in any such request to ASME.

Attached to this letter is CASE's documented request for action.

This is not a formal request for action pursuant to 10 CFR 2.206.

CASE remains available to assist the NRC in their evaluation and determination of this request, and will provide the NRC with any information necessary to complete its determination. I 1

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I CASE anticipates that TU will be responding pursuant to Section B.4. of the Joint Stipulation, following which CASE looks forward to a prompt response from the NRC on this matter.

. Sincerely, CASE (Citizens Association for Sound )

Energy) I Mrs.) Juanita Ellis President cc: Mr. W. G. Counsil, Vice Chairman, TU Electric Mr. W. J. Cahill, Executive Vice President, TU Electric Mr. Steven M. Matthews, Program Manager and Chief Inspector, Boiler Section, Texas Department of Labor and Standards 1 Mr. Christopher I. Grimes, Director, Comancho Peak Project Division, NRC Office of Nuclear Reactor Regulation Mr. R. F. Warnick, Assistant Director for Inspection Program, Comanche Peak Project Division, NRC Office of Nuclear Reactor Regulation George L. Edgar, Esq., Newman & Holtzinger, P. C., Washington, D. C.

Ms. Susan S. Palmer, Stipulation Manager, TU Electric Billie P. Garde, Esq., Attorney for CASE Ms. Edna F. Ottney, CASE On-Site Monitoring Project Manager 4

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