TXX-6277, Forwards Responses to 870205 Request for Info Re Insp Repts 50-445/85-07,50-446/85-05,50-445/85-14,50-446/85-11, 50-445/85-16,50-446/85-13,50-445/86-06 & 50-446/86-04. Statistical Analysis of Concrete Tests Also Encl
| ML20211C814 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/13/1987 |
| From: | Counsil W, Woodlan D TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-6277, NUDOCS 8702200223 | |
| Download: ML20211C814 (21) | |
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P7 Log # TXX-6277 File # 10130
-- C IR 85-07/85-05 r C IR 85-14/85-11 7UELECTRIC IR 85-16/85-13 IR 86-06/86-04 2"lNNu. February 13, 1987 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 REQUEST FOR INFORMATION REGARDING INSPECTION REPORTS:
50-445/85-07. 50-446/85-05; 50-445/85-14, 50-446/85-11; 50-445/85-16, 50-446/85-13; 50-445/86-06, 50-446/86-04 REF: 1) NRC Letter from V. S. Noonan to W. G. Counsil dated February 5, 1987
We reviewed your letter (Reference 1) requesting additional information on the subject inspection reports, and responded to the five questions in our letter TXX-6272 (Reference 2). In our response to Question 1, we stated that based on discussions with the NRC staff on February 9, 1987, TU Electric will respond to this question by Thursday, February 12, 1987. We hereby respond to Question 1 in the attachment to this letter, based upon guidance received from the NRC staff on February 9, 1987.
In reference (2), we included (enclosure 1) an informal statistical analysis of a series of concrete tests. This analysis was submitted for information only at the request of the NRC staff. This document and others like it were not used for safety-related purposes and/or not considered to be quality documents. The data cannot necessarily be traced or verified. The documents were not used to determine the acceptability of any concrete placed at CPSES.
We are conducting a further review to determine whether any properly reviewed
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8702200223 870213 '
400 North Olhe Street I..It 81 Dallas lexas 75201
TXX-6277 February 13, 1987 Page 2 of 2 and approved concrete strength statistical distributions were generated for the period of 1977 to 1984. If valid information is identified, we will notify the NRC Staff of the information's availability.
Very truly yours, LN G W. G. Counsil j- By:
D. R. Woodlan Supervisor, Docket Licensing RSB @
Attachment c - Mr. E. H. Johnson, Region IV Mr. D. L. Kelley, RI - Region IV l Mr. H. S. Phillips, RI - Region IV l
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Attachment to TXX-6277 February 13, 1987 Page 1 of 19 SUPPLEMENTAL REQUEST FOR INFORMATION REGARDING INSPECTION REPORTS 50-445/85-07, 50-446/85-05; 50-445/85-14, 50-446/85-11; 50-445/85-16, 50-446/85-13; 50-445/86-06, 50-446/86-04
- 1. Provide TU Electric's evaluations and, as appropriate, proposed or corrective actions (including procedures generated) to unresolved items or open items addressed in inspection reports 50-445/85-07,50-446/85-05; 50-445/85-14, 50-446/85-11; 50-445/85-16, 50-446/85-13; 50-445/86-06, 50-446/86-04.
RESPONSE TO ITEM 1 446/8505-05 i
i The unresolved item was stated as follows: "Neither site prepared installation drawings nor specifications ... were available and the drawings examined did not show certain specific installation criterion such as centering tolerances, levelness tolerances and clearance between support brackets and support shoes.
The inspector considers this matter unresolved. (446/8505-05)"
RESPONSE
The item was closed in NRC Inspection Report 445/86-07,446/86-05 as follows:
"(Closed) Unresolved Item (446/8505-05): This item dealt with the unavailability of a site prepared installation drawing and specification with i respect to reactor pressure vessel (RPV) placement.
The NRC inspector performed a review of documentation associated with installation of the Unit 2 RPV. The governing procedure for installation was Brown & Root Procedure MCP-1, " Installation of Mechanical Equipment." Paragraph 4.1.1 in MCP-1 requires that equipment installation travelers be prepared in
- accordance with site Procedure CP-CPM-6.3, " Preparation, Approval, and Control of Operation Travelers." Operation Traveler ME79-248-5500, Revision 0, was issued to describe the field instructions for. installation of the Unit 2 RPV.
The operation traveler incorporated the requirements recommended by Westinghouse Nuclear Services Division (WNSD) procedures for this activity (i.e., " Procedure i for Setting of Major NSSS Components," Revision 2, dated February 13, 1979, and
" General Rector Vessel Setting Procedure," Revision 2, dated August 30,1974).
These WNSD procedures were not made a part of the traveler package, in that they are generic and have been used by WNSD at several sites. However, the specific guidelines were utilized during the traveler preparation. All of the necessary installation steps were reviewed and approved by site QA/QC personnel and by a site WNSD representative.
While there was no site specific installation procedure, an operation traveler was prepared, reviewed, approved, and issued; thus it became the controlling document."
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Attachment to TXX-6277 February 13, 1987 Page 2 of 19 SUPPLEMENTAL REQUEST FOR INFORMATION REGARDING INSPECTION REPORTS 50-445/85-07, 50-446/85-05; 50-445/85-14, 50-446/85-11; 50-445/85-16, 50-446/85-13; 50-445/86-06, 50-446/86 CONT'D 446/8505-06 The unresolved item was stated as follows: "The installation data reflected in attachment 3B of the traveler indicated an as-built clearance of 0.012 to 0.026 inch which exceeds both the original and revised tolerances. This condition was accepted on the traveler based on Westinghouse concurrence, and there was no documented engineering evaluation onsite justifying the final tolerances. This i
matter in considered unresolved pending documentation validating the final installation tolerances. (446/8505-06)"
RESPONSE
The item was closed in NRC Inspection Report 445/86-07; 446/86-05 as follows:
"(Closed) Unresolved Item (446/8505-06): This item dealt with no documented engineering evaluation onsite justifying the final tolerances of Unit 2 RPV clearances between support brackets and support shoes. This item was considered unresolved pending receipt of documentation validating the final installation tolerances.
The original tolerances specified on operation traveler ME79-2484500, Revision 0, were extracted from the WNSD generic procedures. The operation traveler's installation tolerances were subsequently revised to reflect site specific field conditions. Westinghouse concurrence with the revised tolerances was documented by signature on the operation traveler. In addition, Westinghouse Water Reactors Division provided the basis for the Unit 2 RPV shim installation I
tolerances in letter WPT-8148 dated January 10, 1986,.which was in response to l TU Electric's letter CPPA-48113. As a result of the receipt of documentation validating the final installation tolerances, this item is resolved."
446/8505-U-07 Does TU electric's audit plan require an audit be performed of surveillances of the Unit 2 reactor pressure vessel specifications, procedures, and installations?
l RESPONSE:
TU Electric's audit plan did not and does not require an audit or surveillance l of the Unit 2 reactor pressure vessel specifications, procedures, and installations. The objective of the TU Electric audit plan is to determine that a quality assurance program has been developed, documented and implemented in accordance with specified requirements. TU Electric accomplished that objective by performing audits on selected activities, not on all activities.
Attachment te TXX-6277 February 13, 1987 Page 3 of 19 SUPPLEMENTAL REQUEST FOR INFORMATION REGARDING INSPECTION REPORTS 50-445/85-07, 50-446/85-05; 50-445/85-14, 50-446/85-11; 50-445/85-16, 50-446/85-13; 50-445/86-06, 50-446/86 CONT'D 445/8514-U-04: 446/8511-U-04 TU Electric has not described the current QA record facilities and storage in the FSAR.
RESPONSE
The current revision of FSAR Chapter 17.1.17 adequately addresses the QA records system. TU Electric's position is that documents become records at the time they are final reviewed and accepted by TU Electric and forwarded to a records storage facility. Documents become subject to the record storage requirements of ANSI N45.2.9 at the time they become records. FSAR Chapter 17.1.17 addresses those records maintained in a record facility which must comply with ANSI N45.2.9 requirements. Incomplete or in-process documents are not required to meet the requirements of ANSI N45.2.9 and are therefore not addressed in the FSAR.
As a result of our review of this matter, TU Electric has determined that our procedures do not clearly describe the final TU Electric review and the
' conversion of documents to records. To enhance the overall records management program, including the clarification of the conversion of documents to records, NE0 procedures (2.13 and 2.23) are currently in the draft review cycle. These procedures will address document and record requirements consistent with the above stated position. Implementing procedures will be revised upon issuance of the NE0s.
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445/8514-U-05: 446/8511-U-05 ANSI N45.2.9 requirements are not adequately referenced in TU Electric and B&R Quality Assurance Program Manuals.
l l RESPONSE:
It is TU Electric's position that the QA Manuals and site procedures are adequate in meeting the requirements of ANSI N45.2.9. See our response to 445/8514-U-04, 446/8511-U-04 for further information regarding system changes.
Attachment to TXX-6277 February 13, 1987 Page 4 of 19 SUPPLEMENTAL REQUEST FOR INFORMATION REGARDING INSPECTION REPORTS 50-445/85-07, 50-446/85-05; 50-445/85-14, 50-446/85-11; 50-445/85-16, 50-446/85-13; 50-445/86-06, 50-446/86 CONT'D 445/8514-U-06: 446/8511-0-06 Provide documentation to demonstrate that the CB&I record controls were implemented for records shipped off site for copying.
RESPONSE
TU Electric QA provided the NRC inspector with copies of CB&I procedures which governed record control. These procedures were developed in accordance with the CB&I QA program requirements. Contractor documents are not considered TU Electric records until they are reviewed and accepted by TV Electric and forwarded to the records storage facility. The CB&I records are available on site for NRC review.
445/8514-U-07: 446/8511-0-07 The TU Electric Records Center has open-faced cabinets which can be deluged with water and deteriorate records. Also, manila folders may wash out and clog drains. ,
RESPONSE
Records storage on open-faced shelving is not in violation of ANSI N45.2.9-74 requirements. Regarding the potential for folders washing off shelves cloggino l drains, TV Electric has decided to install an alarm system (DM-85-106) in the l Records Center which will respond when the sprinkler system is activated to l alert personnel during off-shift hours to allow them to respond and prevent any i
possible flooding.
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Attachment to TXX-6277 February 13, 1987 Page 6 of 19 SUPPLEMENTAL REQUEST FOR INFORMATION REGARDING INSPECTION REPORTS 50-445/85-07, 50-446/85-05; 50-445/85-14, 50-446/85-11; 50-445/85-16, 50-446/85-13; 50-445/86-06, 50-446/86 CONT'D 445/8614-U-08: 446/8511-U-08 4
The failure to install fire suppression system, drains, and a sloped floor appears to deviate from ANSI N45.2.9 requirements. In addition NCR's and corrective action reports were stored in binders in bookcases.
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RESPONSE
Although not documented, those matters were considered.
TU Electric's position concerning a fire suppression system is that one is neither needed nor required and that ANSI N45.2.9 and FSAR Chapter 17.1 requirements have been satisfied.
A field survey of the vault floor was performed. The results indicated that the floor is sloped sufficiently to provide adequate drainage to prevent flooding; therefore, a drain is not necessary.
Although not in violation of ANSI N45.2.9 Draft 11 requirements, the NCR's and corrective action reports have been removed from binders arid stored in file cabinets.
i 445/8514-U-09: 446/8511-U-09 Records in the Paper Flow Group are not maintained in fire rated cabinets.
RESPONSE
Documents on the Paper Flow Group are considered in process documents. There is no requirement for in-process documents to be treated according to the record storage requirements of ANSI N45.2.9. Any controls placed upon documents are based on prudent management decisions. TU Electric has elected to store documents in the paper flow group in fire-rated cabinets for additional protection. Eighty additional fire-rated cabinets have been procured and are currently being utilized in the Paper Flow Group.
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-Attachment to TXX-6277 February 13, 1987 Page 6 of 19 SUPPLEMENTAL REQUEST FOR INFORMATION REGARDING INSPECTION REPORTS 50-445/85-07, 50-446/85-05; 50-445/85-14, 50-446/85-11; 50-445/85-16, 50-446/85-13; 50-445/86-06, 50-446/86 CONT'D' 445/8514-0-01: 446/8511-0-01 TU Electric indicated that the receipt of records from CB&I was handled in the same manner as the receipt of records from any vendor. Region IV will inspect the receipt of vendor records.
RESPONSE
TV Electric performed a sample review of CB&I documents to determine if the required documents were available and met the requirements of the specifications and contract documents. The results of that sample review indicated that the documentation required by the specifications and contract documents had been provided by CB&I and is available on site. Documentation of the sample review is available on site for flRC review.
445/8514-0-02: 446/8511-0-02 Water is leaking into the IRV through the ventilation system.
RESPONSE
The identified water leakage problem has been corrected. ,
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- Attachment to TXX-6277 February 13, 1987
- Page 7 of 19 SUPPLEMENTAL REQUEST FOR INFORMATION REGARDING INSPECTION REPORTS 50-445/85-07, 50-446/85-05; 50-445/85-14, 50-446/85-11; 50-445/85-16, 50-446/85-13; 50-445/86-06, 50-446/86 CONT'D
~445/8516-U-01: 446/8513-U-01 The unresolved item was stated as follows: "The NRC inspectors evaluated i
corrective action taken on reportable deficiencies by reviewing TUGC0 deficiency
, reports. .The inspector found no corrective action completion date for CP-84-29,
. 'HVAC Fire Scenario'. It was noted that corrective action for deficiency CP . 27, ' Ventilation Exhaust Dampers', was to be completed for Unit I by September 1985 and for Unit II before startup testing. However, as of November 30, 1985, Unit I deficiencies were not corrected and it was not clear how corrective action for Unit II will be tracked. Deficiencies CP-85-13 and CP-85-05, which are described in deficiency reports and the open items list, also give no corrective action dates.
Several final 10CFR50.55(e) reports contained corrective action completion dates; however, work was neither completed by the reported date nor was a supplemental report made to the NRC to report on significant corrective action date changes. Deficiency report 'for CP-84-31, ' Control Room Separation Wall',
stated that corrective action was scheduled for completion by December 15, 1984; however, it was not completed as of November 30, 1985. Similarly, deficiency reports for CP-85-11, ' Instrument Fitting Locations', and CP-85-12, ' Auxiliary Feedwater Pressure Control', stated that corrective action was scheduled to be i completed for Unit I by May 1985. The open items list indicated that they were not completed on November 30, 1985.
TUGC0 management has assembled a task force consisting of four to five engineers or specialists to evaluate and take action on the matters described above. This item is unresolved (445/8516-U-01; 446/8513-U-01)".
c RESPONSE:
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Presently, the verification and status of deviations and deficiencies reported pursuant to 10CFR50.55(e) are performed under the auspices of our corporate l
procedure NE0-CS-1, " Evaluation of and Reporting of Items / Events under 10CFR21 l and 10CFR50.55(e)". Originally issued in November 1985, the procedure includes specific provisions whereby the implementation of corrective actions are monitored and the NRC is provided notification. In addition, TU Electric has ,
established a licensing commitment resolution process to track the timely 4 completion of cor.nitments made to the NRC including corrective action for SDARs.
The " Task Force" noted in the unresolved item is currently a recognized unit within the CPE-Engineering Assurance, Regulatory Compliance Organization. This group is currently chartered to identify, validate, and assure positive closure through scheduling of all identified engineering and construction issues.
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Attachment to TXX-6277
, February 13, 1987 Page 8 of 19 SUPPLEMENTAL REQUEST FOR INFORMATION REGARDING INSPECTION REPORTS 50-445/85-07, 50-446/85-05; 50-445/85-14, 50-446/85-11; 50-445/85-16, 50-446/85-13; 50-445/86-06, 50-446/86 CONT'D 445/8516-U-02: 446/8513-U-02 The unresolved item was stated as follows: "In response to discussions regarding the _TU Electric program concerning IEBs, Circulars, and Information Notices, Region IV was informed that TU Electric will perform a review of related procedures and records to determine the adequacy of procedures and the completeness of associated records. The initiation of this effort will follow the task review of the 10CFR Part 50.55(e) program which is presently in progress.
[ This item is unresolved (445/8516-U-02, 446/8513-U-02)."
RESPONSE
i- The processing of IE Bulletins, Circulars, and Information Notices at CPSES is controlled by Operations and Engineering with procedures NOS-103 and ECE-AD-18, respectively. IE Bulletins requiring licensee responses are addressed by the
- Operation Support Section within Engineering per ECE-AD-18. All other referenced IE correspondence is routed to the Industrial Operating Experience Record Coordinator for evaluation per NOS-103. A complete record file of all such correspondence is maintained in the corporate office by TU Licensing.
l 445/8516-U-04: 446/8513-U-04 i
! The unresolved item was stated as follows: "IEB 79-28 identified deficiencies l with certain manufactured lots of NAMC0 EA 180 limit switches. The gasket material of the faulty lots, when exposed to temperatures above 195 F, vaporized and emitted a yellow-brown crystal like resin that can cause these switches to fail. The NRC inspector found the TV Electric documentation to be complete with respect to the specified corrective action of replacing these switches manufactured in acceptable lots.
Field verification of replacement of 14 switches identified, however, that the identity of 2 switches could not be traced to existing travelers. Specifically, the replacement NAMC0 limit switches on residual heat removal valves 1-HCV-606 and 1-FCV-618 were identified on travelers EE 82-1415-5801 and EE 83-0373-5801 as EA 180-32302 and EA 170-313-2, respectively. The switches actually installed in the field were identified as EA 180-31302 and EA 180-31302, respectively. TV Electric is evaluating this inconsistency to determine if there is other documentation to account for this.
This item is unresolved (445/8516-U-04, 446/8513-U-04)."
RESPONSE
! Our evaluation of this item has been submitted in TXX-6270, from W. G. Counsil, dated February 9, 1987, Attachment 3, " Response to Item 1."
Attachment to TXX-6277 February 13, 1987 Page 9 of 19 SUPPLEMENTAL REQUEST FOR INFORMATION REGARDING INSPECTION REPORTS 50-445/85-07, 50-446/85-05; 50-445/85-14, 50-446/85-11; 50-445/85-16, 50-446/85-13; 50-445/86-06, 50-446/86 CONT'D 445/8516-U-06: 446/8513-U-06 The unresolved item was stated as follows: "The following items are unresolved pending clarification or resolution:
- a. Reevaluation of available 1976 test documentation and recent test failures for 10 CFR Part 21 and 10 CFR Part 50.55(e) reportability (445/8516-U-06, 446/8513-U-06)."
RESPONSE
i i TU Electric has performed three reportability reviews pertaining to BISCO fire seals.
Our reviews concluded that one issue was not potentially reportable. Two issues were potentially reportable, but were withdrawn after further evaluation. The
, three issues are discussed below:
- 1. TDDR-85-063 - This deficiency report was written as a result of NRC concerns as identified in IE item 445/8516-U-07; 446/8513-U-07. The item was considered to be a deficiency related to supporting test documentation and l was not considered reportable or potentially reportable for the following reasons:
a) A BISCO representative came to the site prior to the August 20, 1985 ANI letter and assured TU Electric that the problem (ANI withdrawal of test acceptance) was purely an insurance matter, b) A letter from the same representative, dated September 16, 1985, reconfirmed the above position and offered an alternative seal design if the utility felt it was necessary.
c) The fire protection program is based on the concept of defense-in-depth, in that early detection, suppression, portable extinguishers, hose stations and the fire brigade in conjunction with fire barriers all contribute to the overall protection of equipment.
d) After a discussion with a site NRC representative a more in-depth review was conducted to see if there were any safety implications. The result of that review (TSG-19248) indicated that no problem existed which would jeopardize safety.
Attachment to TXX-6277 February 13, 1987 Page 10 of 19 SUPPLEMENTAL REQUEST FOR INFORMATION REGARDING INSPECTION REPORTS 50-445/85-07, 50-446/85-05; 50-445/85-14, 50-446/85-11; 50-445/85-16, 50-446/85-13; 50-445/86-06, 50-446/86 CONT'D RESPONSE TO 445/8516-U-06: 446/8513-U-06 CONT'D
- 2. SDAR CP-86 Refers to our response as stated in TXX-4986, dated August 19, 1986. The response indicated that the questionable seal was tested in accordance with ASTM-E119 criteria and found to be acceptable. The fire protection design matrix was upgraded by BISCO. A new fire test was added to further verify that the fire seal in question was acceptable. We concluded that the issue was not reportable under the provisions of 10CFR50.55(e).
" Response to Item 4," dated February 9, 1987.
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Attachment to TXX-6277 February 13, 1987 Page 11 of 19 SUPPLEMENTAL REQUEST FOR INFORMATION REGARDING INSPECTION REPORTS 50-445/85-07, 50-446/85-05; 50-445/85-14, 50-446/85-11; 50-445/85-16, 50-446/85-13; 50-445/86-06, 50-446/86 CONT'D 445/8516-U-07: 446/8513-U-07 The item is stated as follows:
"6. Electrical Penetrations In NRC Inspection Report 50-445/84-22 dated October 11, 1984, the certification of BISCO electrical penetration seals (fire barriers) was questioned with respect to the testing of the seals. During the follow-up of this item, which is discussed in paragraph 2.h above, the NRC inspector identified related but different findings.
The NRC inspector reviewed the records to determine if the documentation for eight BISCO seals support the certification statement. The eight penetrations inspected were: AB-790-174-1022A, EC-854-150A-1018A and -
10188, EC-854-151A-2003A and -2004A, EC-854-151B-2025A and -2026A, and TB-803-010A-1008A.
The following documents contained apparent conflicting information that the NRC inspector has identified for further follow-up:
BISCO letter to TUGC0 dated November 13, 1984, answered the NRC certification inquiry and stated that the subject fire barrier seal (Test No. PCA-76, ANI No. S-26, 24" X 42", floor / wall, material 6548, 9 inches depth, LAD or SLD tray, all cables, 40% loaded) met all test requirements of TUGC0 Contract No. CP-0707, Gibbs and Hill Specification 2323-MS-38F, ASTM E-119, and IEEE 634.
l American Nuclear Insurers (ANI) letter to BISCO dated August 20, 1985, withdrew its acceptance of BISCO SF-20 (1977) Silicone or Dow Corning 3-6548 RTV Silicone foam for 2- and 3-hour rating without a damming board left in place. The NRC inspectors ascertained that this withdrawal was based on BISCO not having complete documentation of the test results and the recent failure of a BISCO sample tested at an independent laboratory employed by the ANI.
i ANI letter dated August 20, 1985, to TUGC0 informed them of the rescinded acceptance and the test failure that occurred 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 35 minutes into the independent test performed in accordance with ASTM E-119. Further, it stated that this fire barrier may not be adequate where there is a strict requirement for a barrier with a 3-hour rating.
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Attachment to TXX-6277 February 13, 1987 Page 12 of 19 SUPPLEMENTAL REQUEST FOR INFORMATION REGARDING INSPECTION REPORTS 50-445/85-07, 50-446/85-05; 50-445/85-14, 50-446/85-11; 50-445/85-16, 50-446/85-13; 50-445/86-06, 50-446/86 CONT'D 445/8516-U-07: 446/8513-U-07 CONT'D Comanche Peak Final Safety Analysis Report (FSAR), page 9.5-223, requires that penetration seals be tested in accordance with ASTM E-119 and IEEE 634. FSAR Section 9.5, paragraph D.I.c requires: 1) each cable spreading room should be separated from other areas of the plant by barriers with a minimum fire resistance of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, and 2) cabling for redundant safety divisions should be separated by walls having a 3-hour rating as a fire barrier. Section 9.5, paragraph D.3.c requires a 3-hour rating for barriers for cable trays that contain cold shutdown cabling.
TUGC0 Design Deficiency Report (TDDR) No. FP-85-063 dated August 29, 1985, documented the deficiency. On the same report, the deficiency was marked not reportable in the 10CFR Part 21 and Part 50.55(e) reportable block. The corrective action was for BISCO to prove satisfactory testing of the failed seal and all other ANI accepted seals.
Note: The evaluation of reportability is being reevaluated by TUGCO.
BISCO letter dated September 16, 1985, stated that approval had been rescinded because the hose stream test data was destroyed or lost during either a 1965 fire or a subsequent move to another facility. It also stated that the ANI testing standards are much more stringent and stated that BISCO seals meet and surpass the test standards of ASTM E-119. The letter further stated that the ANI representative witnessed a test on 9-inch silicone foam using the same design configuration that failed in I
the ANI test. However, the letter also stated that the success of this BISCO test was based on applying a 3/8-inch proprietary coating on the face of the silicone foam. The letter stated that this retrofit corrective measure can be employed by those who wish to upgrade this l
particular seal design.
Note: It appears that the original seals that were tested had no coating.
TUGC0 interoffice memorandum (Creamer to Kennedy) dated October 16, 1985, discussed the rework of all seals affected by ANI disapproval of l S-26.
BISCO memorandum to TUGC0 (Trent to Anger) dated October 24, 1985, identified eight penetrations to be reworked.
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Attachment to TXX-6277 February 13, 1987 Page 13 of 19 SUPPLEMENTAL REQUEST FOR INFORMATION REGARDING INSPECTION REPORTS 50-445/85-07, 50-446/85-05; 50-445/85-14, 50-446/85-11; 50-445/85-16, 50-446/85-13; 50-445/86-06, 50-446/86 CONT'D 445/8516-U-07: 446/8513-U-07 COM'Q The letters discussed above appeared to contain conflicting statements. The BISCO letters dated November 13, 1984, and September 16, 1985, differed in that the first one certified to meeting ASTM E-119 and IEEE 634 test requirements, while the latter only mentioned ASTM E-119. The September 16, 1985, letter also stated that BISCO recently retested the original design configuration and it passed; however, in the same paragraph on page 2 they stated that they added a 3/8-inch proprietary coating, which according to TUGC0 is not on their barriers that are installed. In the same paragraph, BISCO discussed this coating as if it were a retrofit and/or a design change. Thus, BISCO's claim that their retest was successful appears to be based on testing an upgraded test sample. The ANI letter to TUGCO, dated August 20, 1985, stated that their test was in accordance with ASTM E-119; however, BISCO claimed that the ANI test exceeded ASTM E-119 requirements and thus is an inconsistency. It is also unclear as to how many test failures have occurred. Indications are that there were two recent failures, an ANI test and a BISCO test failure.
The following items are unresolved pending clarification or resolution:
- b. Inconsistent test methods and/or test results documented by BISCO and the ANI test laboratories for the specific design configuration PCA-76 (ANI No. S-26) for which the ANI rescinded acceptance and also the completion of TDDR No. FP-85-063 required corrective actions (445/8516-U-07,446/8513-U-07)."
REPORT CLARIFICATIONS:
TU Electric believes the following clarifications to parts of the above item are necessary. The report states:
"It is also unclear as to how many test failures have occurred. Indications are that there were two recent failures, an ANI test and BISCO test failure."
There was only one test failure, in that BISCO Test 748-183 dated August 6, 1985, and the referenced ANI independent test laboratory fire test are the same.
The joint ANI/ BISCO test was conducted at the Construction Technologies Laboratories in Skokie, Illinois.
Attachment to TXX-6277 February 13, 1987 Page 14 of' 19 SUPPLEMENTAL REQUEST FOR INFORMATION REGARDING INSPECTION REPORTS 50-445/85-07, 50-446/85-05; 50-445/85-14, 50-446/85-11; 50-445/85-16, 50-446/85-13; 50-445/86-06, 50-446/86 CONT'D 445/8516-U-07: 446/8513-U-07 CONT'D REPORT CLARIFICATIONS CONT'D:
"The September 16, 1985, letter also stated that BISCO recently retested the original design configuration and it passed; however, in the same paragraph on page 2 they stated that they added a 3/8-inch proprietary coating, which according to TUGC0 is not on their barriers that are installed. In the same paragraph, BISCO discussed this coating as if it were a retrofit and/or a design change. Thus, BISCO's claim that their retest was successful appears to be based on testing an upgraded test sample."
The successful test that BISCO refers to is in fact Test No. 748-134 (foam without ceramic board backing dam using 2-15" X 30" versus 1-30" X 30" seal) dated May 14, 1984, which did not have the 3/8-inch coating applied to it.
The next sentence in the report states:
"The ANI letter to TUGCO, dated August 20, 1985, stated that their test was in accordance with ASTM E-119; however, BISCO claimed that the ANI test exceeded ASTM E-119 requirements and thus is an inconsistency."
A letter from BISCO dated August 20, 1985 states:
"In conclusion, those plants in which BISCO has installed the seals in question do not have a problem with American Nuclear Insurers since they will continue to accept these seals 'for insurance purposes only' and testing documentation verifies these same seals are acceptable to the NRC based on conformance with ASTM E-119 test standards."
BISCO's was referring to the original PCA-0CT-76 test, not to the failed ANI test specimen. BISCO based this assumption (NRC acceptability) on thermocouple readings at the unexposed surface of the seal at the end of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> being 110 degrees F. TV Electric elected not to use PCA-0CT-76 and ANI S-26 (ANI test acceptance document) by substituting completely acceptable testing instead.
^
Attachment to TXX-6277 February 13, 1987 Page 15 of 19
' SUPPLEMENTAL REQUEST FOR INFORMATION REGARDING INSPECTION REPORTS 50-445/85-07, 50-446/85-05; 50-445/85-14, 50-446/85-11; l
50-445/85-16, 50-446/85-13; 50-445/86-06, 50-446/86 CONT'D l
, 445/8516-U-07: 446/8513-U-07 CONT'D
- RESPONSE: I As stated in the inspection report, the PCA-0CT-7 test was rescinded due to insufficient documentation and the failure of a similar test conducted jointly ,
j by ANI and BISCO.
- Because the ANI rescinded acceptance of testing, which appeared to be necessary to qualify certain seal designs installed by BISCO at this site, a TDDR was j initiated to identify a lack of documentation for seal qualification. A review of the PCA-0CT-76 test and other 9" silicone foam tests gave TU Electric confidence that a 9" seal would be acceptable. The TDDR was marked "Not i Reportable" and corrective action was initiated to update the BISCO Design Matrix.
i As a result of discussions with site NRC representatives, TU Electric was asked j to reevaluate the reportability of TDDR-FP-85-063. TU Electric considered two
- elements in the reevaluation:
- 1. An analysis between the recent test failure and the acceptable 9-inch designs being used, to identify differences and similarities, and
- 2. Evaluation to identify all installed seals which exceeded 15" x 30" and for those seals that exceeded this size to assess safety impact.
l After reviewing Item 1, which encompassed configuration, sealant material, thermocouple readings, cable fill, cable types, and hose stream, it was i determined that the subdivision of the 30" x 30" blockout into two 15" x 30"
' specimens appeared to be the significant difference. The penetration seal schedule was then checked for electrical blockouts which exceeded the 15" x 30" i size. Of the blockouts reviewed only five appeared to be sealed to the 9' inch
! depth and exceeded the 15" x 30" dimension. Of the five noted, two penetrations ;
were in the Unit 2 Turbine area in areas not adjacent to safety related ,
structures, two were floor blockouts which always utilize permanent one (1) inch ceramic board backdam material (as mentioned in ANI's alternatives in their August 20, 1985 letter), and one penetration in the Auxiliary Building exterior wall adjacent to the Unit 2 Safeguards.
b The Auxiliary Building penetration #7010179000 (TR.1022) was also noted by l BISCO in their letter dated October 24, 1985.
As a part of the TV Electric review of the larger blockouts, a field inspection of the penetrations was made. During that inspection it was noted that one of the floor blockouts did not appear to have the ceramic divider material in place. BISCO was notified and their QC initiated an NCR to document that '
deficiency (BISCO NCR No. 25). TV Eiectric analysis of the NCR prompted issuance of SDAR CP-86-47, based on a possible programmatic problem with BISCO procedures.
Attachment to TXX-6277 February 13, 1987 Page 16 of 19 SUPPLEMENTAL REQUEST FOR INFORMATION REGARDING INSPECTION REPORTS 50-445/85-07, 50-446/85-05; 50-445/85-14, 50-446/85-11; 50-445/85-16, 50-446/85-13; 50-445/86-06, 50-446/86 CONT'D 445/8516-U-07: 446/8513-U-07 RESPONSE CONT'D:
After the above events TV Electric performed non-rated barrier analysis TSG-19248) which concluded that the Auxiliary Building seal 7010179000 (TR. 1022),
and the floor blockout (NCR No. 25) 6006883100 (TR. 5022), did not have any safety implications.
Although the detailed non-rated barrier analysis was not formally documented at the time of TDDR disposition, the end result substantiated TU Electric's initial position in this matter.
Attachment to TXX-6277 February 13, 1987 Page 17 of 19 SUPPLEMENTAL REQUEST FOR INFORMATION REGARDING
, INSPECTION REPORTS 50-445/85-0/, 50-446/85-05; 50-445/85-14, 50-446/85-11; 50-445/85-16, 50-446/85-13; 50-445/86-06, 50-446/86 CONT'D 445/8516-0-03: 446/8513-0-03 The unresolved item was stated as follows: "The TV Electric actions on two IEBs (i.e., Nos. 79-14 and 79-28) were selected to review hardware evaluations or repair / replacements. TU Electric 10ER Log Sheet, page 10, dated April 9,1984, was reviewed to determine the status of the IEBs.
! 1) IEB 79-14 was evaluate'd by TU Electric and was statused in 1983 as closed.
The NRC inspector indicated that the closure of IEB 79-14 was premature since Stone & Webster is currently analyzing Unit I seismic analysis versus as-built drawings, which directly relates to this IEB. Unit 2 as-built work has also not been completed. TU Electric stated that the IEB 79-14 file will be reopened and a supplemental report will be submitted upon completion of the ongoing project engineering work.
The above item (IEB No. 79-14) status is considered an open item (445/8516-0-03,446/8513-0-03)."
4 i- RESPONSE:
l Our response to this item, submitted as TXX-4729 dated April 3, 1986, is as follows:
" Texas Utilities' Letter TXX-3597 dated December 3, 1982 described the CPSES As- ~
, built Verification Program initiated in response to IE Bulletin 79-14.
! Specifically, items 2 and 3 of the bulletin required inspections of safety
. related piping systems to verify that drawings relied on for seismic analyses accurately reflected the as-built condition. Construction permit holders were required to report the results of these inspections within 120 days. This -
- reporting requirement appeared to be directed toward plants where piping systems were substantially complete. Since the CPSES piping systems of concern were
, still under construction at the time the bulletin was issued, the reporting requirement was deemed to be inappropriate. Rather, the inspection and verification requirements of the bulletin were incorporated into the appropriate CPSES design and construction procedures. Based on these procedures the reference letter closed our response to the bulletin. !
I Implementation of these procedures has been ongoing throughout construction of Units 1 and 2. The Unit 1 program is now complete; the Unit 2 program is continuing. As a result of design verification requirements arising from the CPSES licensing proceedings, TU Electric commissioned Stone and Webster Engineering Corporation (SWEC) to perform stress requalifications of code piping and pipe supports. To establish sufficient confidence in the adequacy of dimensions and functions shown on drawings used in their analyses, SWEC sampled Unit I as-built documentation to verify the following attributes:
i
- - - + . yv,..v., -. -mw ..m. --_._,__-m______-----m--,.__.-.,_,___..-_..-.,,_m.- ._.-,,,,.-,-,-~_-,,-_.__-..,_...,_-._,.,-_,,y_ _ - . - - - - _ _ _ . . _ - - _ - -
Attachment to TXX-6277 February 13, 1987 Page 18 of 19 SUPPLEMENTAL REQUEST FOR INFORMATION REGARDING INSPECTION REPORTS 50-445/85-07, 50-446/85-05; 50-445/85-14, 50-446/85-11; 50-445/85-16, 50-446/85-13; 50-445/86-06, 50-446/86 CONT'D RESPONSE TO 445/8516-0-03: 446/8513-0-03 CONT'D Valve location Pipe support location Pipe support function Valve and support orientation With the exception of discrepancies in the tolerance of some valve and support orientations, the review determined that the remaining attributes were adequate.
TU Electric initiated an inspection of all valve and support orientations, issuing nonconformances where conditions were found to be outside tolerance limits. Any modifications resulting from the nonconformances or from the SWEC requalification effort will be performed in accordance with the CPSES as-built program, which requires that any modifications to piping systems or supports be reconciled with seismic analyses."
445/8516-0-05: 446/8513-0-05 The open item was stated as follows: "The NRC inspectors found that construction deficiency and IEB files were not stored in the QA records vaults.
Because such records have not been deposited in a central location, difficulties have been encountered in retrieval. TV Electric is assessing this record file issue.
This item is open pending the completion of their review (445/8516-0-05; 446/8513-0-05)."
RESPONSE
l TV Electric does not believe that any regulatory basis exists which requires ANSI N45.2.9 storage of files pertaining to construction deficiency reports (which are in this case construed to be issues reported pursuant to 10CFR l
50.55[e]) or IE Bulletins. As a convenience, TU Electric has compiled a copy of responses to IEB and 10CFR50.55(e) reports. In addition we have, and are continuing, to compile copies or references of records or other documentation which support statements made in our responses. These files are maintained on site. Formal responses and copies of these issues are maintained in our Dallas office. Based on the above, TV Electric does not consider the item to be safety significant.
Attachment to TXX-6277 February 13, 1987 Page 19 of 19 SUPPLEMENTAL REQUEST FOR INFORMATION REGARDING INSPECTION REPORTS 50-445/85-07, 50-446/85-05; 50-445/85-14, 50-446/85-11; 50-445/85-16, 50-446/85-13; 50-445/86-06, 50-446/86 CONT'D 445/8606-U-01: 446/8604-U-01 This item is unresolved pending the receipt and review of all 1980-1986 Brown &
Root audit files.
RESPONSE
Brown & Root Audits CP-17 dated April 4, 1980 through CP-31 dated April 16, 1986 were provided to the inspector for his review.
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