ML20204F644

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Forwards Annotated Bibliographies of Ltrs to NRC Re Insp Repts,Including Responses to Notices of Violations & Deviations & Ltrs to NRC Re Comanche Peak Review Team. Certificate of Svc Encl.Related Correspondence
ML20204F644
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 07/30/1986
From: Gad R
ROPES & GRAY, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
References
CON-#386-160 OL, NUDOCS 8608040262
Download: ML20204F644 (17)


Text

b Filed: July 30, 19800 SELATED COM!*tbyONue.M u O AIE ~j A10:{3 ffV.. Rl. er :- .

UNITED STATES OF AMERICA 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 ) Oper,ating License)

Station, Units 1 and 2) )

)

ANNOTATED BIBLIOGRAPHIES In accordance with the Board's Order of June 6, 1986, the Applicants submit herewith the attached Annotated Bibliographies.

The following types of documents are annotated:

Letters to NRC regarding NRC Inspection Reports, including responses to Notices of Violations and Deviations.

Consultant Reports.

TUGCO Internal Audit Reports.

Letters to NRC concerning CPRT.

8608040262 860730 PDR ADOCK 05000445 ,3

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Letters to NRC concerning various subjects such as FSAR amendments, response., to I&E Bulletins.

Documents submitted to the Boa.d (exclusive of filed pleadings).

The following principals were utilize d to prepare this bibliography:

Filed or transmitted documents relating to CPRT

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activities are included.

Filed or transmitted documents relating to Contention 5 are included (i.e. Only Construction and Design QA, not Operations or Startup). '

Since all parties are submitting Abstracts, the Applicants have not annotated documentation received from CASE or NRC Staff.

TUGCO Site audits only, not vendor.

Part 21's are documented via the 50.55(e)/SDAR program.

Abstracts will begin with documents issued since June 6, 1986 and continue on a bimonthly basis with documents issued prior to the 25th of the month. This initial abstract covers June 6 -

July 25, 1986. The next abstract will be due September 30, 1986 and cover July 26 - September 25, 1986.

The documents were determined from the following sources:

1. Review of outgoing NRC correspondence log (TXX)
2. Review of internal audit report files / logs
3. Discussions with Project personnel

-The Applicants have attempted to apply the Board's request as we belive the. Board intended. We are receptive to suggestions of additional documents that should be screened for future abstracts (or documents that the Board feels can be deleted from the existing list of screened documents).

Respectfully submitted, '

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 3200 Dallas, TX 75201 (214) 979-3000 Roy P. Lessy, Jr.

WRIGHT & TALISMAN, P.C.

1050 Seventeenth Street, N.W.

t , C -5566 (202) 31 9 1 *

('homas . Di a, r.  %

R. K. Gad II  ;

ROPES & GR Y 225 Frankl'n Street Boston, MA 02110

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(617) 423-6100 1

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50.55(e)

During the period of June 6 through July 25, 1986. TUGC0 issued forty-eight letters to the NRC concerning forty-one items which had previously been identified as potentially reportable under 100FR50.55(e). The letters are broken down as follows:

42 letters: Interim Report - Evaluation to detemine Reportability is continuing 4 letters: Interim Reoort - Item determined to be Reportable, evaluation / corrective actions continuing Date Letter No. SDAR# Subject

-0670F86 ixx-es44 LT55-36 P1pe Supports Interim Report - During the Pipe Supwrt reverification program being performed by SWEC, the engineering evaluation las identified one instance which is reportable. In the seismic evaluation of stress problem 1-045T, for the chemical volume and control system, an over stress condition has been identified. The cause was the use of inappropriate response spectra in the previous G&H piping analysis.

Date Letter No. SDARf Subject 067FJ786 Ixx-se/1 CP BE-11 Component Cooling Water Pump Impeller Linear Indications Interim Report - This report notifies the NRC that the deficiency has been determined to be reportable. Corrective action comunitments are provided and are being implemented. Evaluation of the issue is continuing.

Date Letter No. SDAR Subject 067IU86 TXX-4453 -

-10 Electrical Penetration Assemblies Interim Report - The NRC has previously been notified that the deficiency is reportable. This report states that the assemblies supplied by Bunker Ramo will be replaced with units supplied by Conax. The investigation into the circumstances resulting in the deficiencies is still ongoing.

Date Letter No. SDARf Sobject 07/Fl[86 TAA-49Z9 CP BI-10 E'ectrical Penetration Assemblies Followup - Interim Report - The investigation into the circumstances resulting in the deficiencies is scheduled to be completed in August 1986. A specific construction schedule will be provided upon receipt of the hardware.

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2 letters: Final Report - Deficiency Not Reportable Da Letter No. SDAR# Subject 0 6 Txx-eatu CP;55-20 WFI Products Final Report - The deficiency concerned a breakdown in the QA program of a supplier (WFI Products) of fittings and flanges. The deficiency was determined l to be an administsstive deficiency which did not affect the integrity of items  ;

supplied to WFI's customers. The issue was determined to be not reportable.

Date i.etter No. SDAti Subject 077IT/86 -

1xx-4918 E K-44 Qualification of 480V Switchgear Final Report - Issue detensined to be not reportable. The cooling system for the 480V switchgear transformers is not required to maintain the qualified status of the equipment.

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- CPRT The following correspondence was issued by TUGC0 to the NRC concerning CPRT during the period of June 6 - July 25,1986:

Date Letter No. Subject 06755786 TAK-4545 GPRT Results Reports and Appendix E. Rev. 2 This letter transmitted Results Reports I.a.3 and VII.c. 4 and Appendix E. Rev. 2 of the CPRT Program Plan to the staff. Copies were also sent to the ASLB.

Date L_etter No. Subject 077597'86 Txx-+ssa saw Report - Generic Technical issues This letter transmitted the " Report on Stone & Webster Engineering Corporations

- Evaluation and Resolution of Generic Technical Issues" to the NRC Staff. Copies were also sent to the ASLB.

Date letter No. Sub; ect 077TU7'86 Txx-4905 GPRT Ghecklists This letter transmitted copies of CPRT checklists and procedures which contain checklists to the Staff as agreed to in TXX-4846 dated 6/9/86.

Date Letter No. Subject 077T5786 Txx-eszl status of ISAP I.a.4 Results Report This letter transmitted a response to Staff questions regarding (1) additional sampling done after issuance of an approved results report; and (2) incorporation of "out-of-scope" observations into the results reports of another action plan.

Da e Letter Noi Subject 7/ IAA-95ZZ Rev. 2 of Appendix E of CPRT Program Plan This letter was transmitted in response to Staff questions regarding the issuance of Rev. 2 of Appendix E to the CPRT Program Plan. An additional copy of Rev. 2 of Appendix E, containing revision bars was attached. Copies were also sent to the ASLB.

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Date Letter No. Subject-07/74786 Txx-4931 crni overview Quality Team (0QT)

This letter was transmitted in response to Staff questions regarding the activities of the 0QT. Attached was a copy of the 0QT audit schedule for July -

September 1986 and the 0QT Program for CPRT activities.

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Date Letter No. Subject 077 5 /86 Txx-es33 Implementing procedures for SWEC Resolution of Generic Technical Issues This letter transmitted copies of updated Stone & Webster procedures pertinent to the resolution of external source issues related to pipe & pipe support

, design.

Date Letter No. Subject -

077FT/86 N Response to NRC July 15, 1986 Request for Information ISAP VII.b.2 Results Report This letter was transmitted in response to staff questions regarding missing documentation associated with ASME valves identified in ISAP VII.b.2

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Responses to NRC Inspection Reports /

Notice of Violation / Notice of Deviation The following correspondence was issued by TUGC0 to the NRC Region IV concerning f inspection reports, during the period of June 6 - July 25,1986:

Date Letter No. Sub.iect 67I5786 N Response to NRC Notice of Violation and Notice of Deviation for Inspection Reports 50-445/85-16 and

, 50-446/35-13 The Notice of Violation contained four items (A-D):

. Item A concerned Unit 1 field substitution of a grouted Richmond insert for a Super-Hilti bolt that was authorized by DCA without being subject to design control measures commensurate to those applied to the original design. Actions taken included performance of review and calculations which found the substitution acceptable. This was determined to be an -

isolated instance.

Item B concerned a hilti spacing violation which had teen inspected and accepted without evidence of any design change documents approving the condition. The condition was properly documented per procedure, however the support number was incorrectly recorded which resulted in the documentation being improperly filed. The fem was revised and a review perfonned to detect any other similar deficiencies. No further problems were identified.

Item C identified a pipe support with undersize welds which had been previously inspected and accepted by QC. An NCR was generated to resolve the condition. The support addressed had been inspected in July, 83, prior to revision of the inspection procedure to provide for better control and documentation of weld size inspection.

Item D identified an improper field modification and inadequate QC inspection of an HVAC duct joint. A deficiency report was issued and dispositioned use-as-is. Craft and QC were provided with additional training and instruction.

The Notice of Deviation included three items (A-C):

Item A identified eight subitems where CPRT field reinspections of hardware itecs were not perfomed in accordance with approved instructions.

Actions were taken as appropriate.

Item B concerned the proper method to measure contour for the cylindrical and dome liners. The Quality Instruction did not provide comprehensive instructions for reinspection of the containment liner. The response noted that the inspections were perfonned correctly, however the QI was revised to clarify. Other QI's related to ISAP's VII.b.3 and VII.c were also reviewed, no change required.

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Item C concerned a CPRT reinsnection checklist attribute which was left blank. The checklist had been approved and signed. The attribute was reinspected and the package revised accordingly. Based on this example and others identified by an ERC QA surveillance, meetings were held with inspection personnel to reemphasize importance. Also,an Overview Inspection Program has been implemented to reinspect a sample of each; inspectors work on a continuing basis.

Date Letter No. Subject 677T/B6 N Response to NRC Inspection Report 50-445/85-18 and 50-446/85-15, Notice of Violation and Notice of Deviation.

The Notice of Violation included four items (A-D):

~ Item A concerned inspector certification activities. The response provided corrective actions to one item and disagreed that the second item concerning waiver of on-the-job training was a violation. A procedure was revised, however to eliminate the need for on-the-job training -

waivers.

Item B concerned installed conduct lengths in excess of procedural requirements. The response provided corrective and preventive actions to resolve the condition.

Item C concerned design change control procedures which did not provide for necessary review by and coordination among design interfaces with respect to performance of actions required by the change. Corrective actions were taken which included revision of the specific DCA, performance of an Engineering walkdown to identify nonconformances with the revised DCA, and formulation of a detailed design basis document and significant improvement to the interdiscipline review process.

Item D concerned lack of color coding on certain thermolagged cable tray and conduits. Corrective action included issuance of NCRs. retraining of personnel, and identification and color coding of thermolag prior to fuel load.

The Notice of Deviation included three items (A-C).

Item A concerned CPRT failure to document, disposition and track discrepancies found during CPR7 Task Force Review (Ref ISAP III.d).

No corrective action was provided. The objective of the action plan was met and there was no adverse affect on the Startup testing program.

Item B identified five examples where CPRT field reinspections were not performed in accordance with approved instructions. Actions were documented and taken as appropriate.

Item C identified an example where a CPRT checklist had been incorrectly marked N/A. Corrective and preventive actions were taken.

. l TXX-4gl7 Additional Response to NRC Concerns regarding Response te 7/16/86 Inspection Report 50-445/84-08 A response was provided to the NRC concerning some additional concerns identified with TUGC0 response to Notice of Violation for 50-445/84-08.

One item concerned a further question regarding actionsih taken to ensu inspectors they are assigned.

are certified for the full scope of inspection ac July 1985 CPRT Action Plans I.d.1. I.d.2A and reviewVII.c will address gene of recent Present certification system is adequate.

concerns.

inspection documents was perforwed with no deficiencies identified.

The second itse concerned the reason for TUGCO's incomplete inspect crossover Violation.

leg restraints and initially incorrect The initially incorrect respons

- any generic failure to conduct required inspections.

response was attributed to confusing the probism w .

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TUGC0 Internal Audits of Engineering and Construction Activities Reports Issued After June 6, 1986 l

Number: TCP-86-20 Date: 5/27 - 6/10/86 Rpt. Date: 7/2/86.

Scope: This audit was conducted to verify implementation of TNE's design control program in civil, Mechanical and pipe support engineering (PSE). As discussed in the summary, however, PSE was deleted from  ;

the scope, based on current activity levels. l

. Number: TCP-86-17 l

Date: 5/6 - 14/86

. Rpt. Date: 6/9/86 Scope: The audit team was to determine the effectiveness of the established .

program associated with fabrication, installation and quality control acceptance of cable tray and conduit racewey systems in Unit II.

Number: TCP-86-22 Date: 5/19 - 22/86 Rpt. Date: 6/9/86 I

Scope: The purpose of this audit was to assess the effectiveness of TUGCO's "as-built" inspection / verification program for Unit I Class IE Cable Tray Hangers. The audit scope encompassed QC's inspection activities of Unit I cable tray hangers for compliance with -

procedure requirements.

Number: TCP-86-23 Date: 6/2 - 6/86 Rpt. Date: 6/13/86 Scope: The audit scope was to evaluate the adequacy and verify the implementation of the Unit II Paper Flow Group and Interim Records Vault programs.

Number: TCP-86-24 Date: 6/16 - 20/86 Rpt. Date: 7/2/86 Scope: The purpose of this audit was to verify the effectiveness and implementation of the construction and QC program for the installation and inspection of Unit II class IE electri al equipment.

D Number: TIN-86-01 Date: 5/19 - 29/86 Rpt. Date: 6/23/86 Scope:

The audit was a limited scope audit conducted to evaluate TUGC0's g nce with certain regulatory posting requirements, inclu

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Number: TIN-86 02 Date: 6/23 27/86 Rpt. Date: 7/23/86 In Scope: To verify implementation of NEO policies and Procedure manual.

addition the program for reporting of significant items / events as required by 10CFR50.55(e) was evaluated to determine program adequacy and compliance to requirements and effectiveness of implementation.

- Miscellaneous Correspondence.

The following additional correspondence was issued to the NRC during June 6 -

July 25, 1986:

Date Letter No. Sub; ect 67I7/86 N rsAI! Amendment No. 59 Description The letter provides a section by section statement of the changes in Amendment No. 59. There were numerous changes affecting multiple subjects, including changes to reflect recent TUGC0 organizational changes.

Date Letter No. Subject 67I7/86 Txx-gaso Transnittal of FSAR Amendment 59 This letter transmitted Amendment No. 59 to NRR. ,

l Date Letter No. Sub.iect ,

7725786 T!!" PET'- Rev. z to Diesel senerator DR/QR Report This letter transmitted Rev. 2 of the Final Design Review / Quality Revalidation (DR/QR) Report for the CPSES Diesel Generators to NRR. The purpose of the revision is to provide TDI owners a set of maintenance and surveillance i recommendations for diesel generator components, which have been developed by TDI and/or the Owner's group.  ;

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Date Letter No. Subject 67IV86 IAA-gags RURts-0737, Item II.D.1, Performance Testing of Relief and Safety Valves This letter provided a response to NRC questions concerning perforinance testing of relief and safety valves NUREG-0737 Item II.D.I.

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OTHER July 2, 1986 Assessment of TUGC0 As-Built Documentation for Piping and Pipe Supports.

This report provides an overall assessment of activities associated with Safety-related piping systems to address concerns of the NRC Staff related to IE Bulletin 79-14 program and the use of the results of that effort by SWEC in the Stress Requalification Program. Conclusions were that necessary procedures and programs are in place; however, some improvements should be implemented.

June 19, 1986 CP0-1588 Letter from SWEC to TUGC0 transmitting Piping and '

Sup> ort Requalification Program - CPPP-5 5 mall Bore Walcdown Report ,

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This report describes the results of the walkdown of small bore piping conducted by SWEC in accordance with Project Procedures CPPP-5. -

June 2, 1986 QQD-25 Internal memo from J.F. Streeter to J.W. Beck transmitting the CPRT Overview Quality Team (0QT)

Progress and Status Report for June 1986 This report includes a summary of the OQT meeting held June 2 - 6 and 23 - 27, 1986 and a progress and status report of 0QT's activities.

Monthly Status Reports from organizations such as Ebasco, SWEC and Impe11.

'I On behalf of the Texas Utilities Generating Co., Robert A. Wooldridge has submitted various documents to the Board for their information. These include the following:

June 9, 1986 Approved Results Reports June 9, 1986 May 29,1986 TUEC Form 8K July 7, 1986 SWEC Generic Technical Issues Report July 8, 1986 June 18, 1986 TUEC Form 8K July 14, 1986 July 11, 1986 TUEC Form 8K

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a 00txttro USNHC N NE ~1 AIO:13 CERTIFICATE OF SERVICE x T NG ifi((y-BRANCtf I, Robert K. Gad III, one of the attorneys for the Applicants herein, hereby certify that on July 30, 1986, I made service of the within " 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 Mr. William L. Clements Administrative Judge Docketing & Services Branch 881 W. Outer Drive U.S. Nuclear Regulatory Commission Oak Ridge, Tennessee 37830 Washington, D.C. 20555 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 l

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t 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 Ms. Billie Pirner Garde Geary S. Mizuno, Esq.

Citizens Clinic Director Office of the Executive Government Accountability Project Legal Director '

1901 Que Street, N.W. U.S. Nuclear Regulatory Commission Washington, D.C. 20009 Maryland National Bank Bldg.

Room 10105 7735 Old Georgetown Road Bethesda, Maryland 20814 Elizabeth B. Johnson Administrative Judge Oak Ridge National Laboratory P.O. Box X, Building 3500 Oak Ridge, Tennessee 37830 Nancy Williams Cygna Energy Services, Inc.

101 California Street Suite 1000 San Francisco, California 94

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Robert K. ad III

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