ML20205R520

Permittees Further Responses to M Gregory Interrogatories & Request for Production of Documents (Set 5).* Certificate of Svc Encl.Related Correspondence

ML20205R520
Person / Time
Site:	Comanche Peak
Issue date:	03/27/1987
From:	Eggeling W ROPES & GRAY, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	GREGORY, M.
Shared Package
ML20205R503	List: ML20205R499 ML20205R520
References
CPA, NUDOCS 8704060371
Download: ML20205R520 (12)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

_before the ATOMIC SAFETY AND LICENSING BOARD

!- )

In the Matter of )

)

TEXAS UTILITIES GENERATING ) Docket No. 50-445-CPA

COMPANY et al. )

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4 (Comanche Peak Steam Electric )

j Station, Units 1 and 2) )

i' )

)

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PERMITTEES' FURTHER1 RESPONSES.

'i TO "MEDDIE GREGORY'S INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS (SET 5)"

Pursuant to 10 CFR $$ 2.740, 2.740b and 2.741, the Permittees respond herein to "Meddie Gregory's j Interrogatories and Request for Production of Documents I

]

(Set 5)." ]

The Permittees have ignored the definitions and guidelines in the paragraphs labelled "a" through "e,"

inclusive, as contained in the document entitled "Meddie Gregory's Interrogatories and Request for l 1

i By agreement of the parties, the Permittees are continuing to respond to these Interrogatories as their

investigation with regard to each issue is completed.

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i B704060371 B70327 PDR ADOCK 05000445 9 PDR

Production of Documents (Set 5)," insofar as the same are contrary to the Rules of Practice.

Interrogatory 1:

When did Applicants first receive notice of the issues identified by the NRC's TRT Reports and SSERs, and in what form did that notice come (i.e., NCR, IR, audit report, memorandum, consultant's report, etc.)?

Interrogatory 2:

, For each item identified in Interrogatory 1, identify

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what response was taken to the problem and by whom.

Interrogatory 3:

If the answer to Interrogatory 2 is that no action was taken, explain the reason that no action was taken. If that reason is because Applicants relied on a "second opinion," identify the individuals or organizations who provided that opinion.

l l Interrogatory 4:

Identify how each " finding" identified in Interrogatory 1 was integrated into consideration of the subsequent findings by others. (For example, how were the findings by the NRC in 1978 and 1979 integrated into Applicants' response to the findings by the Management Analysis Corporation (MAC)?) i PERMITTEES' RESPONSES l l

(ISSUE: SEISMIC DESIGN CONSIDERATIONS FOR PIPE SYSTEMS GOING FROM SAFETY-RELATED BUILDINGS TO  !

NONSAFETY-RELATED BUILDINGS):

At Page N-238 of SSER 10 dated April 1985, the TRT l

] states l

The TRT agreed with the SRT that. piping lines going from a seismic Category I building to a nonseismic Category I building could cause damage to supports and the piping system on the siesmic Category I side. The TRT determined that these effects must be considered unless an isolation anchor was provided between the two buildings.

Piping systems at CPSES, such as those for the main 4

steam auxiliary steam and feedwater systems, are routed between the electrical control building, which is seismic Category I, and the turbine building, which is nonseismic Category I, without any isolation. To be acceptable, each nonseismic Category I piping system should be isolated from any seismic Category I piping system by separation, barrier or constraint. If isolation is not feasible, then the effect on the seismic Category I pipinq of the failure in the nonseismic Category I piping must be considered (CPSES ESAR 3.7B.3-13.1). j In the case of CPSES, the FSAR, Section 3.7B.2.8, l establishes that the Turbine Buildinq is a nonseismic Category I structure and failure is postulated during the seismic (SSE) event. The effect of turbine building failure on any '

non-isolated piping routed between the turbine ,

building and any seismic Category I building must i be considered. In addition, for nonscismic Category I piping connected to seismic Category I piping, the dynamic effects of the nonseismic Category I piping must be considered in the seismic design of the seismic Category I piping and supports, unless TUEC can show that the dynamic effects of the nonseismic Category I piping are isolated by anchors or restraints. The anchors or restraints used for isolation purposes must be ,

designed to withstand the combined loading imposed '

by both the seismic Category I and nonseismic Category I piping. l The general concern expressed by the TRT in these and related explanatory paragraphs of the SSER is that piping classified as seismic Category I in accordance with Regulatory Guide 1.29 must be adequately isolated from connected nonseismic piping both at interfaces

within seismic Category I Buildings and where the piping may have an interaction with a nonseismic building. In both cases, the TRT emphasized that the stress analysis for the seismic Category I piping must conservatively address dynanic inputs from the nonseismic piping.

In April, 1984, the.NRC's Comanche Peak Special Review Team performed a limited review of Comanche Peak Steam Electric Station. One particular concern raised by the Special Review Team was that criteria used for the auxilliary steam line piping analysis may not have been adequate to prevent a failure in the Turbine Building from causing damage to the pipe in the  !

Electrical and Control Building.

< Permittees believe a July 13, 1984 NRC letter to the Permittees outlining the NRC's Comanche Peak Special Review Team's report was their first notice that the Project's resolution of the concerns underlying the TRT issues regarding the auxilliary main steam line might be claimed to be inadequate. Earlier, in August, 1982, the TUGCO Damage Study Group had evaluated the restraint located between the two buildings and determined that the restraint was adequate in isolating the Turbine Building from the Electrical and Control Building. (Damage Study Problem Book, AB-1-135A). The Permittees believed this

evaluation adequately established CPSES conformance with the FSAR in this regard.

The TRT letter of November 29, 1984, however, reaffirmed the NRC's Comanche Peak Special Review Team's concern and expanded the issue to include the group of lines which pass from a nonseismic building to a seismic Category I building and connect to a seismic Category I line. Subsequently, the CPRT issued ISAP V.c (Design Consideration for Piping Systems Between Seismic Category I and Non-seismic Category I Buildings) to address the TRT findings.

(TRT ISSUE: TRACEABILITY OF TEST EQUIPMENT)

At pages J-72 and J-73 of SSER 7 dated January 1985, the TRT found:

. . .[A]lthough temperatures were taken and logged during the test [1CP-PT-55-11, " Thermal Expansion"), the specific [ temperature] measuring device used at each monitoring location was not logged. As a result the calibration of the

! measuring device could not be traced to the monitored location with the information contained in the test data packages. The TRT found that the completed test data packages did contain the calibration data for the measuring devices used, but as alleged, the devices could not be traced directly to specific monitoring locations. While pursuing this matter, the TRT interviewed TUEC personnel who participated in the testing and found that a test coordinator maintained a log which tied the devices to the specific monitoring locations; however, the log was not made a part of the test data package. The TRT pointed out to TUEC that while the direct connection was not required by the

tesc procedure as written, the data must be j included as part of the test data package.

Permittees believe that the TRT letter of September 18, 1984 was their first notice of this supposed issue.

According to CPSES procedures, compliance with equipment traceability requirements may be achieved by establishing traceability either to a specific test procedure or to a specific location. Providing traceability for measuring and testing equipment to-each monitoring location can prove to be useful when performing the required evaluation after identifying a nonconformance. However, this degree of traceability (as requested by the TRT for ICP-PT-5511) is not a requirement; it is a matter of convenience and economics in order to minimize the amount of retesting which may be required (if equipment is subsequently found to be out of calibration). The appropriate information required by Startup Administrative Procedures for recording calibration data was included in the test package for 1CP-PT-55-11.

l Following notification by TRT of this issue on i 4 i September 18, 1984, TUEC formed the CPRT and issued ISAP III.a.4 (Traceability of Test Equipment) to address the TRT finding as stated in SSER 7.

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(TRT ISSUE: CONCRETE COMPRESSION STRENGTH)

At page K-64 of SSER 8 dated February, 1985, the

- TRT found: l The allegation (AQC-7) that compressive strength test results were. falsified cannot be closed at this time. The TRT agrees with the Region IV staff i that the uniformity ofLthe fresh concrete placed  ;

during this period suggests that there was no serious problem with the hardened. concrete and, therefore, .no serious safety problem. However, this conclusion is based on air content, slump, and strength tests, all of which have been alleged to be falsified. The issues regarding air content and slump, as well as other allegations discussed above,-were resolved on the basis of the concrete strength test results. Due to the importance of concrete strength test results, the TRT concludes that additional action by TUEC is necessary to provide confirmatory evidence that the reported concrete strength test results are indeed representative of the strength of the concrete placed in the Category I structures.

1 Permittees believe that their first notice of possible falsification of concrete compressive strength tests was Brown & Root QA, Deficiency and Disposition Report (DDR) C-448, which was received by the TUGCO/Gibbs & Hill Site Supervisor on February 24, 1977. This report identified potential falsification of concrete records. The falsification incident had been reported to Brown & Root by the R.W.-Hunt Company-on February 14, 1977 via DDR No. 0217 (Revised).

1 The NRC Region IV staff was informed of the report on 2/25/77 by the TUGCO QA Manager. At the request of i

the TUGCO QA Manager (2/26/77), a joint investigation 1

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l into the reported R.W. Hunt record falsification incident was performed. .The investigation involved personnel from Brown & Root QA, Gibbs & Hill QA,.and R.W. Hunt Company. A " Summary of Investigation" from this effort was attached to TUGCO NCR, CP-77-1, dated March 2, 1977.

Concurrently, during the period of March 1-4, 1977, i

the NRC conducted a site investigation and issued IE Investigation Report Nos. 50-445/77-02 & 50-446/77-02.

These reports identified the scope of the NRC investigation as being "to review the circumstances surrounding the reported falsification of records, interview involved personnel, [and] assess the intent, safety and generic implication." The NRC's conclusions were that any falsification "was an isolated occurrence" and "had little effect, if any, on the structural soundness, or quality of the concrete placed."

During April 5-7, 1979, NRC Region IV inspectors conducted an on-site investigation of new allegations made by former R.W. Hunt Company employees regarding

} #w concrete inspection and testing improprieties. NRC IE Report Nos. 50-445/79-09 & 50-446/79-09 were received by TUGCO on June 6, 1979. NRC Region IV determined that the specific allegation it had identified l regarding concrete strength tests being falsified could l

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r not be substantiated and no.TUGCO action was required.

At this time, TUGCO believed any problems relating to possible falsification of concrete compressive strength tests to be resolved.

The NRC letter of 9/18/84, informed TUGCO that the TRT had reviewed the Region IV Reports (50-445/79-09 &

50-446/79-09) concerning falsified concrete strength, however, and had concluded that specific additional actions should be taken with regard thereto.

Subsequently, the CPRT was formed and ISAP II.b (Concrete Compression Strength) was issued to address the TRT concern regarding the adequacy of concrete strength. l (TRT ISSUE: TECHNICAL SPECIFICATIONS FOR DEFERRED TESTS) i At page J-118 of SSER No. 7 dated, January 1985, the TRT states as follows:

1 The TRT pointed out that in order to conduct preoperational tests at the necessary temperatures and pressures after fuel load, certain limiting conditions of the proposed technical specifications.

[at CPSES] cannot be met.

Permittees believe that the TRT letter of September 18, 1984 was their first notice of this supposed issue.

Procedures STA-805, " Deferred Testing" and STA-707,

" Safety Evaluations" were in effect and functioning

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i prior to the TRT identification of this issue. STA-805 .

requires that any proposed deferred testing must be supported by a safety evaluation according to STA-707.

STA-707 establishes procedures to determine if the proposed deferred test would create an unreviewed safety question or require a change to the Technical Specifications. Thus, CPSES procedures provide for evaluation of deferred preoperational testing and include consideration of the requirements of the Technical Specifications.

Following notification by TRT of this issue, TUEC formed the CPRT and issued ISAP III.a.3 (Technical Specifications for Deferred Tests) to address the TRT finding as stated originally in the September 18, 1984 TRT letter. SSER No. 7 was issued four months after the TRT letter and stated that the action originally required of TUEC by the TRT to resolve this issue is no longer applicable since the TRT has been informed by TUEC that these tests will be conducted prior to fuel load.

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00LKETED USNRC CERTIFICATE OF SERVICE 1R NH -2 P1 'A9 I, William S. Eggeling, hereby certify that on March 27, 1987, OFFICE 0F Het !ARY I made service of the within document by mailiAQCHsfggidfGeof, 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 Ms. Billie Pirner Garde Administrative Judge Midwest Office 881 W. Outer Drive 3424 N. Marcos Lane Oak Ridge, Tennessee 37830 Appleton, WI 54911 4

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 Lawrence J. Chandler, 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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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 Elizabeth B. Johnson Geary S. Mizuno, Esq.

Administrative Judge Office of the Executive Oak Ridge National Laboratory Legal Director P.O. Box X, Building 3500 U.S. Nuclear Regulatory Commission Oak Ridge, Tennessee 37830 Washington, D.C. 20555 Nancy Williams Cygna Energy Services, Inc.

101 California Street Suite 1000 San Francisco, California 94111 William S.'E lin i

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