TXX-6928, Interim Deficiency Rept CP-85-36 Re Installation of non- Safety Related Conduit on non-safety Related Dead Weight Supports.Initially Reported on 850906.Scheduled Completion for Unit 1 by 871231.Next Rept Will Be Submitted by 880301
| ML20236L494 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/05/1987 |
| From: | Counsil W, Wooslan D TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| CP-85-36, TXX-6928, NUDOCS 8711100372 | |
| Download: ML20236L494 (3) | |
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Log # TXX-6928 L
File # 10110
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903.9 1UELECTRIC " # IU "
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wmtam c. counsu November 5, 1987 Executive & President V. S. Nuclear Regulatory Commission ATTN: -Document Control Desk Washington, D.C.
20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES) 00CKET NOS. 50-445 AND 50-446 j
TRAIN "C" CONDUIT SUPPORTS SDAR: CP-85-36 (INTERIM REPORT) 1 1
1 Gentlemen:
1 On September 6,1985, we verbally notified your Mr, C. Gould of a deficiency involving the installation of non-safety related conduit (two-inch diameter and smaller) on non-safety related dead weight supports.in Category I areas.
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Our last interim report, logged TXX-6556, was submitted on July 7, 1987.
After further evaluation we have determined that this item is reportable under the provisions of 10CFR50.55(e) and the required information follows.
Description of Deficiency During the construction review conducted by the NRC Technical Review Team (TRT), the TRT examined the installation of non-safety related conduit I
supports in selected Category I areas of the plant.
The support installation for non-safety related conduits less than or equal to 2 inches was inconsistent with seismic requirements.
Further, no evidence was observed which substantiated the adequacy of the installation for non-safety related conduit of any size.
According to Regulatory Guide 1.29 and the CPSES FSAR Section 3.78.2.8, the Seismic Category Il and non-seismic items should be designed in such a way that their failure would not adversely affect the l
function of safety-related components or cause injury to plant personnel.
TV Electric was directed to propose a program that would assure the adequacy of the seismic support system installation for non-safety related conduit in all seismic Category I areas of the plant.
The following was recommended:
Provide the results of seismic analysis which demonstrates that all non-safety related conduits and their support systems, satisfy the provisions of Regulatory Guide 1.29 and FSAR Section 3.78.2.8.
Verify that non-safety related conduit less than or equal to 2 inches in diameter, not installed in accordance with the requirements of Regulatory Guide 1.29, satisfy applicable design requirements.
8711100372 G71105 PDR ADOCK 05000445 S
PDR s
400 North Olive Street LB 81 Dallas, Texas 75201 I f
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TXX-6928 November 5, 1987 Page 2 of 3
'l Safety Implications j
A Train C Corrective Action Program (CAP) was initiated for the Unit 1 and Common Areas in order to comply (73% of total) conduit supports have been with the NRC direction.
Under this program, q
to date, approximately 77,000 j
evaluated and approximately 600 modifications have been made to comply with FSAR and Regulatory Guide 1.29 requirements.
Since our evaluation has determined that hardware modifications.were necessary, this item was determined to be reportable under the provisions of 10CFR50.55(e).
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Corrective Action Currently, we are implementing the Train C Corrective Action Program (CAP) for the Unit 1 and Common Areas. The design validation process has been completed with the following results:
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1.
All Validation Procedures are in place for the resolution of all related CPRT issues (Issue Specific Action Plan I.c).
These procedures have been reviewed and concurred with by the Third Party and are final (except for I
minor editorial and efficiency enhancement revisions which are ongoing as the program continues).
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All DIR's (51) which resulted from the Third Party's review of Impell's Train C Validation Procedures have been resolved.
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All complex (unique) supports have been evaluated and modifications identified and validated.
4.
To date, approximately 77,000 conduit supports have been evaluated in the Unit 1 and Common Area.
This represents about 73% of all supports in the Unit 1 and Common Area. This effort has resulted in approximately 600 modifications.
The Post Construction Hardware Validation Program (PCilVP) for these conduits and supports was implemented concurrently with the design validation process.
5.
The remaining 28,000 supports are single (generic) supports for which the design has been validated.
These supports are currently being physically i
validated under the PCHVP Program.
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A long term maintenance program has been established to provide for a review of all new construction activies which would affect previously l
validated areas.
The review will be performed in accordance with the criteria established in the Train C Corrective Action Program.
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O-TXX-6928' November 5, 1987 Page 3 of 3-The-scheduled completion date for the remaining PCHVP activities and' associated. design modifications of:the Unit 1 and Common Area is-December 31,..
1987., -Our.next report for the Unit 2 activities'will be submitted no-later than March _1 1988.
Very truly yours, 1
W. G. Counsil-
. By : -
D. R. Woodlan Supervisor, Docket Licensing DAR/grr c - R.'D.' Martin, Region IV ResidentInspectors,CPSES-(3) l lf I
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