ML20154C642

Requests That Licensee Review Encl Allegations & Conduct Insps or Investigations Necessary to Reasonably Prove or Disprove Allegations.Licensee Also Requested to Inform NRC of Resolution of Matter & Make Records of Completed Action

ML20154C642
Person / Time
Site:	Comanche Peak
Issue date:	05/06/1988
From:	Mckee P NRC OFFICE OF SPECIAL PROJECTS
To:	Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
NUDOCS 8805180253
Download: ML20154C642 (6)

Text

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4 # 'o UNITED STATES

!" NUCLEAR REGULATORY COMMISSION s-q {' g WASHINGTON, D. C. 20555 g, j v ,o 8

• • • • • May 6, 1988 Docket Nos. 50-445 and 50-446 TV Electric ATTN: Mr. William G. Counsil '

Executive Vice President 400 North Olive Street, Lock Box 81 Dallas, TX 75201 Gentlemen:

SUBJECT:

Allep tion No. OSP-87-0021 We hereby request that you review the attached allegations received by NRC that relate to your operations. As part of your review, we furthermore request that you conduct whatever inspections or investigations necessary to reasonably prove or disprove the allegations. Finally, we request that you inform NRC of the resolution of this matter and make records of your completed action available for NRC inspection. Of course, a substantiated allegation may warrant corrective action or may be the subject of a completed or ongoing corrective action. Where a substantiated allegation is encompassed by ongoing or completed corrective action programs, your response should clearly reference these programs and describe how they address the issue. Where a substantiated allegation is not addressed by an ongoing program, please provide to us your plans and schedule for addressing the issue.

Should your review of the allegation bring into question a safety issue (such as the adequacy of a safety component, system, or analysis), we expect that that issue will be promptly brought to our attention.

Should you have any questions concerning our requests or our role in this matter, please contact me or our Allegations Coordinator, George Gower.

Sincerely.

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Phillip . McKee, Deputy Director Conanche Peak Project Director Office of Special Projects

Enclosure:

As stated cc: See next page 8805100253 880506 PDR ADOCK 05000445 A PDR

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4 Comanche Peak Steam Electric Station W. G. Counsil Units 1 and 2 Texas Utilities Electric Company cc: Asst. Director for Inspec. Programs Jack R. Newman, Esq.

Newman & Holtzinger, P.C. Comanche Peak Project Division U.S.. Nuclear Regulatory Commission Suite 1000 1615 L Street, N.W. P. O. Box 1029 Washington, D.C. 20036 Granbury, Texas 76048 Robert A. Wooldridge, Esq. Regional Administrator, Region IV Worsham, Forsythe, Sampels & U.S. Nuclear Regulatory Commission Wooldridge 611 Ryan Plaza Drive, Suite 1000 2001 Bryan Tower, Suite 2500 Arlington, Texas 76011 Dallas, Texas 75201 Lanny A. Sinkin Mr. Homer C. Schmidt Christic Institute 1324 North Capitol Street Director of Nuclear Services Washington, D.C. 20002 Texas Utilities Electric Company Skyway Tover Ms. Billie Pirner Garde, Esq.

400 North Olive Street, L.B. 81 Government Accountability Project Dallas, Texas 75201 Midwest Office Mr. Robert E. Ballard, Jr. 104 East Wisconsin Avenue Director of Projects Appleton, Wisconsin 54911 Gibbs and Hill, Inc.

11 Penn Plaza David R. Pigott, Esq.

New York, New York 10001 Orrick, Herrington & Sutcliffe 600 Montgomery Street San Francisco, California 94111 Mr. J. L. Vota Westinghouse Electric Corporation Anthony Z. Roisman, Esq.

P. O. Box 355 Pittsburgh, Pennsylvania 15230 Suite 600 1401 New York Avenue, NW Washington, D.C. 20005 Susan M. Theisen Assistant Attorney General Environmental Protection Division Robert Jablon P. O. Box 12543, Capitol Station Bonnie S. Blair Austin, Texas 78711-1548 Spiegel & McDiarmid 1350 New York Avenue, NW Mrs. Juanita Ellis, President Washington, D.C. 20005-4798 Citizens Association for Sound Energy George A. Parker, Chairman 1426 South Polk Public Utility Connittee Dallas, Texas 75224 Senior Citizens Alliance Of Ms. Nancy H. Williams Tarrant County, Inc.

CYGNA Energy Services 6048 Wonder Drive 2121 H. California Blvd., Suite 590 Fort Worth, Texas 76133 Walnut Creek, CA 94596 l

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4 W. G. Counsil Comanche Peak Electric Station Texas Utilities Electric Company Units 1 and 2 CC*

Joseph F. Fulbright Fulbright & Jaworski 1301 McKinney Street Houston, Texas 77010 Roger D. Walker Manager, Nuclear Licensing Texas Utilities Electric Company Skyway Tower 400 North Olive Street, L.B. 81 Dallas, Texas 75201 Mr. Jack Redding c/o Bethesda Licensing Texas Utilities Electric Company 3 Metro Center, Suite 610 Bethesda, Maryland 20814 William A. Burchette, Esq.

Counsel for Tex-La Electric Cooperative of Texas Heron, Burchette, Ruckert & Rothwell Suite 700 1025 Thomas Jefferson Street, NW Washington, D.C. 20007 GOS ASSOCIATES, INC.

Suite 720 1850 Parkway Place Marietta, Georgia 30067-8237 Administrative Judge Peter Bloch U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Elizabeth B. Johnson Administrative Judge Oak Ridge National Laboratory P. O. Box X, Building 3500 Oak Ridge, Tennessee 37830 Dr. Kenneth A. McCollom 1107 West Knapp Stillwater, Oklahoma 74075 Dr. Walter H. Jordan 881 West Guter Drive Oak Ridae, TN 37830 t

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Enclosure Allegations:

1. Numerous problems were alleged concerning the documentation maintained in the Document Control Center. These problems which were alleged to be present in 1986 included:

a. Timeliness for updating drawings. The alleger stated that at times as many as 600 or more Design Chance Authori?.etions (DCAs) and Component Modification Cards (CMCs) were outstanding without the affected drawing being updated. This was alleged to create serious problems for someone trying to use the drawing to determine the currently applicable design. As an erample, the alleger stated that several hundred DCAs were associated with the drawings for the place-ment of the hydrogen supply line from bulk storage to the plant.

Because of the number of DCAs, the required placenent of the hydrogen supply line could not be determined, and sketches were required.

b. Inadequate Cross-Roferencing For DCAs. As an example, the alleger stated that there were significant problems in determining which DCAs were applicable to a specific system component such as a valve.

It was stated that one DCA might be written on the valve operator, one on the valve body and another on the control devices to the valve operator. When such a situation occurred, the alleger stated that the combined effect of the DCAs on the operation of the valve or the effect of one DCA on another was often not considered.

c. Sone DCAs and CMCs, which were rejected by design reviewers, were alleged to have disappeared from the DCC.

2. It was alleged that (circa 1985,1986) often the design basis for certain features was not available. As an example, the alleger stated that the design criteria for accounting for the effects of the length of instru-mentation tubing on temperature instruments was not available in DCC (e.g., drawings and specifications). In such cases, it was alleged that criteria not specifically applicable to the Comanche peak configuration were used. The pressure and temperature instrumentation tubing associated with the main steam system was cited as a specific example.

3. The alleger stated that documentation for the sizing of an orifice plate used for pressure control / reduction in the nitrogen system could not be found. The problem with the lost documentation appeared to coincide with reclassification of the system from nuclear safety related to non-nuclear safety related. The orifice plate in question was the one from the nitrogen supply line supplying blanketing nitrogen to the NaOH tank in the Containment Spray Syster

4. It was allegeo that several preoperational test procedures were poorly prepared and that the tests did not adequately include anticipated operational conditions. As an example, preoperational tests for the service water pumps were alleged to not adequately reflect conditions

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when water hamer (water column separation and cavity collapse) neight occur following pump trips. Also, it was alleged that the test data packages for the service water pumps were poorly documented.

5. The alleger stated that during a hot functional testing (circa mid-1984) inspection of the gaps between the pipe wall and the pipe whip restraints found various cases where the gap exceeded a specified tolerance (1/8-1/4 inch) so that reanalysis of the pipe. restraint interaction was required. With one telephone call made between the Gibbs & Hill onsite and New York offices, a new tolerance ot' 1/2 inch was shortly obtained (one or two. days). Such new tolerance served to eliminate many of the tolerance deviations which may have required reanalysis and eventual re-evaluation of the restraint design (load carrying capability). Given the quickness of the turnaround on the tolerance re-evaluation by G&H's New York office, the alleger questioned the adequacy of the analysis supporting the allowance of larger tolerances.

.TV Electric May 6, 1988 Mr. William G. Counsil . Allegation No. OSP-87=0021 .

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