ML19351A067

Application to Amend CPPR-126 & CPPR-127 to Reflect 810801 & 830801 as Latest Dates for Completion of Units 1 & 2, Respectively

ML19351A067
Person / Time
Site:	Comanche Peak
Issue date:	06/19/1981
From:	TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML19351A066	List: ML19351A065 ML19351A067 ML19351A068
References
NUDOCS 8106250192
Download: ML19351A067 (6)

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O UNITED STATES OF AMERICA  ;

NUCLEAR REGULATORY COMMISSION In the Matter of )

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TEXAS UTILITIES GENERATING .) Docket-Nos. 50-445

. COMPANY, et al. ) 50-446

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- (Comanche Peak Steam Electric )

Station, Units 1 and 2) )

APPLICATION FOR AMENDMENT OF CONSTRUCTION PERMITS TO REFLECT NEW LATEST COMPLETION CATES Texas Utilities Generating Company ("TUGC0") is presently the holder of NRC Construction Permits Nos. CPPR-126 and -127 for the Comanche Peak Steam Electric Station, Units 1 and 2 (cPSES). The construction permits presently reflect the " latest date for completion" of August 1; 1981 for Unit 1 and Augurt 1,1983 for Unit 2. For the reasons listed herein, TUGC0 requests that the subject construction pennits be amended to reflect the " latest date of completion" of August 1,1985 for Unit 1 and August 1, 1987 for Unit 2. While we anticipate the units to be

. completed well in advance of these " latest dates of completion", we have, nevertheless, included considerable margin for unforeseen contingencies.

1. Additional Time Requested' An additional time of 48, months is requested to complete CPSES Unit 1 and Unit 2. As stated above this additional time includes considerable margin for unforeseer. contingencies.

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2. Factors Contributing to Delay A. Construction delays due to extended delivery of materials and components The summary sample below comparing scheduled vs. actual receipt dates from major-equipment indicates delays impacting the construction sequence. All referenced contracts were issued between Jan.1,1975 and June 1,1976.

Description Delivery Scheduled Actual Generator Step-Up Transformers Oct. 77 Oct. 78 345KV Start-Up Transformers Oct. 77 June 78 138KV Start-Up transformers Oct. 77 Jan. 78 138KV Unit Auxiliary Transformers Oct. 77 June 78 Turbine Gcnerators June 77 Incomplete Diesel Generators Sept. 76 Nov. 80 Centrifugal Water Chillers Nov. 76 Oct. 79 Service Water Pumps Feb. 77 Oct. 78 Nuclear Ptsnps Nov. 76 April 79

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• Delays range 3 to 50 months beyond original scheduled delivery dates.

B. Design modifications resulting from revised or additional regulatory requirements Several significant design modifications include:

New requirements concerning the incorporation of an alternative shutdown system capable of maintaing hot shutdown or standby in the event of a major control room or cable spreading room incident. Mandatory objectives were issued

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t Feb. 1980. Final design issued March 1981.

TMI related issues such as the Post Accident Sampling System imposed extensive modifications to major (installad) equipment in conjunction with additional systems. Functional Criteria for Emergency Response Facilities required design of a complete data acquisition and display system including revised facility requirements and the upgrade / replacement of instrumentation.

C. Construction delays due to difficulities encountered in the install. , ion of various components, primarily pipe hangers and restraints Difficulties have been encountered in going from analysis to installation of various components because of compliance with equipment environmental qualification and pipe support criteria.

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Imposition of new requirements based on IEE!-323-1974 and associated standards has resulted in the late submittal of acceptable plans, reporo., and certification packages as evidenced by the following sampling:

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Description Submittal Sch. Anticipated

. Switchgear May 80 Oct. 81 1E Lighting & Misc. Transformers March 80 Oct. 81 Miniature Recorders March 80 Oct. 81 Main Control Bd. & Hot Shutdown Panel March 80 Oct. 81 Mainsteam Isolation Valves March 80 Oct. 81 2 Section X-Core Neutron Detectors March 80 May 82 Source Range Pre-Amplifier March 80 May 82

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Due to the impact of coda certification of the component.

support system and the multiplicity of criteria imposed on associated support systems, including seismic and non-seismic categories, project and vendor organizations have expended massive engineering efforts in the definition and implementation of design, installation and analysis activities including as-built verification. This has also impacted the procurement of code fabricated pp ..hich was originally scheduled for complete delivery in Dec.1979 but deliveries were not completed until April 1981.

3. Contribution of Each Factor Contributing to Delay

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Factor A - 24 months - based on extended procurement requirements to support factor B.

Factor B - 18 months - based on design, rework and construction of facilities.

Factor C - 30 months - based on current schedules and subsequent certification activities.

4. Critical Path or Pacing Factor The pacing factor is the design, analysis and installation of

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pipe supports as discussed in C above. The critical path will bp tracked by the implementation of a system turnover schedule.

This schedule will establish priorities based on systems but will address an " area concept" where feasible.

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5. Environmental Impact Appraisti, l A proposed Environmental Impact Appraisal prepared by TUGC0 is attached. T'u result of this appraisal is a " Finding of No Significant Impact" to address the negative environmental impact  :

of this construction pennit extension' request.

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6. Request to Dispense With Advance Notice i

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Since the requested amendments cf the construction pennits

. involve no significant hazards considerations, it is requested that the NRC dispense with advance notice and publication l requirements as pemitted under Section 189(a) of the Atomic l Energy Act of 19r4, 42 U.S.C. 2239(a).  !

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7. Communications l

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All NRC communications pertaining to this request should to be sent to:

R. J. Gary Executive Vice President and General Manager Texas Utilities Generating Company 2001 Bryan Tower Dallas, Ter.as 75201 In addition, it is requested that copies of each such communication be sent to:

H. C. Schmidt Manager, Nuclear Services Texas Utilities Generating Canpany 2001 Bryan Tower Dallas, Texas 75201

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and to Texas Utilities. Generating Company Counsel:

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Spencer C. Relyea, Esquire Worsham, Forsythe.& Sampels 2001 Bryan Tower, Suite 2500 Dallas, Texas 75201 t

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Nicholas S. Reynolds, Esquire

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Debevoise & Libeman 1200 Seventeenth Street, N.W.

Washington, D.C. 20036

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