ML20236X216

Permittees Supplemental Response to Meddie Gregory Interrogatories & Request for Documents (Set 5).* Response to 870409 Interrogatories Re Seismic Design of Control Room Ceiling.Certificate of Svc Encl.Related Correspondence

ML20236X216
Person / Time
Site:	Comanche Peak
Issue date:	12/04/1987
From:	May J ROPES & GRAY, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	GREGORY, M.
References
CON-#487-4989 CPA, NUDOCS 8712090053
Download: ML20236X216 (8)

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pg/dE.D M M M DOCKETED USflRC i Filed: December 4, 1987

'87 DEC -8 A9 @8 Office OF SEEETAFY UNITED STATES OF AMERICA $[fflCi NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of )

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TEXAS UTILITIES ELECTRIC )

COMPANY, et al. )

) Docket No. 50-445-CPA (Comanche Peak Steam Electric )

Station, Unit 1) )

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PERMITTEES' SUPPLEMENTAL RESPONSE TO MEDDIE GREGORY'S INTERROGATORIES AND REQUEST FOR DOCUMENTS (Set 5) ,

Pursuant to 10 C.F.R. 2.740 (e) (2) (ii), "Permittees' Further Response to Meddie Gregory's Interrogatories and Request for Production of Documents (Set 5)" served and filed on April 9, 1987, is hereby supplemented. Additional information relative to the TRT issue in question has come to the attention of Permittees and is herein incorporated in our prior answer.

8712090053 971204 gDR ADOCK 05000445~

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4 (TRT ISSUE: SEISMIC DESIGN OF CONTROL ROOM CEILING ELEMENTS)

At pages K-84 and K-85 of SSER 8 dated February 1985, the TRT found:

not all' items in the Control Room ceiling fall under the seismic category I or II designation.

Specifically, these items are the suspended drywall, acoustical, and louvered ceilings. These components, designated as nonseismic, do not satisfy the provisions of Regulatory Guide 1.29, since they were not designed to accommodate seismic effects.

At pages K-160 and K-161 SSER 8 further elaboration was presented:

The TRT investigated the seismic design of the ceiling elements installed in the control room. The following matrix designates those ceiling elements present in the control room and their seismic category designation:

1. Heating, Ventilation and Air Conditioning Seismic Category I

2. Safety-Related Conduits Seismic Category I

3. Nonsafety-Related Cc duits Seismic Category II

4. Lignting Fixtures Seismic Category II

5. Sloping Suspended Drywall Ceiling Non-Seismic

6. Acoustical Suspended Ceiling Non-Seismic

7. Lowered Suspended Ceiling Non-Seismic According to Regulatory Guide 1.29 and FSAR Section 3.7B.2.8, the seismic Category II and nonseismic items should be designed in such way that their failure would not adversely affect the functions of safety-related components or cause injury to operators. For nonseismic items (other than the sloping suspanded drywall ceiling), and for nonsafety-related conduits whose diameter is 2 inches or less, the TRT could find no evidence that the possible effects of a failure of these .

items had been considered. In addition, the TRT 1 determined that calculations for seismic Category II components (e.g., lighting fixtures) and the calculations for the sloping suspended drywall ceiling did not adequately reflect the rotational interaction 4 l

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with the nonseismic items, nor were the fundamental frequencies of the supported masses determined to assess the influence of the seismic response spectrum at the control room ceiling elevation would have on the seismic response of the ceiling elements.

The history of the control room and wall design in question dates back to the original engineering design of the CPSES control room which was being done in late 1976 and early 1977. This design called for a nonseismic ceiling.

Gibbs & Hill letter GTN-16489, dated March 9, 1977, to TUGCO transmitted information (three publications) pertinent to the design and requested further direction from TU Electric.

On April 5, 1977, TUSI via TGH-4483, transmitted to Gibbs &

Hill the results of its evaluation of the information and conveyed its decision to proceed with the design basis per original concept (i.e., a nonseismic design).

On January 9, 1979, Gibbs & Hill issued letter GTN-33023 to TUGCO. An attachment to this letter was a Design / Engineering Change Request (N-338) which revised the lower ceiling in the control room (above the control board) to include acoustical tile above the louvered ceiling in lieu of plaster and also provided for gypsum board in lieu of plaster for the sloping fascia wall connecting the lower and upper ceilings. On June 14, 1979, Gibbs & Hill reissued the architectural drawings for the construction of the control room ceiling.

Permittees first had notice of concerns related to the TRT control room ceiling issue, i.e., inability to

i adequately demonstrate compliance with the provisions of Regulatory Guide 1.29, on September 3, 1980, when the TUGCO i

Project Civil Engineer telephoned Gibbs & Hill inquiring ]

l about ceiling compliance with Regulatory Guide 1.29 (per Project Civil Engineer's log). The following month, on October 7, 1980, TWX-12537 was generated from TUGCO to Gibbs 1

& Hill requesting an engineering justification for the nonseismic classification of the suspended ceiling and gypsum walls in the control room. The transmittal and receipt of this document precipitated several telephone conversations between TUGCO and Gibbs & Hill in regard to the ceiling design compliance with Regulatory Guide 1.29.

On February 12, 1981, Memo CPP-4512 from TUGCO Project Civil Engineer to TUGCO Engineering Manager was generated which proposed to strengthen and supply back-up support to the existing gypsum sloping wall. This proposal

("CPSES-Seismic Qualification of Control Room Ceiling and Gypsum Wall") was transmitted to Gibbs & Hill via TUGCO Memo CPPA-11410 on July 22, 1981. TUGCO's memo requested the comments and concurrence of Gibbs & Hill with the described proposal in which: (1) the suspended acoustical and louvered ceilings in the Control Room are considered acceptable in their as-built conditions; and (2) the gypsum wall is to be additionally supported in two identified areas. In response to the request, Gibbs & Hill issued a letter (GTT-7964) on August 7, 1981, to TUGCO which stated concurrence with the 4

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L l aforementioned proposal, but acknowledged a lack of current substantiating documentation.

By letter dated March 11, 1983, CASE notified the NRC that CASE had just recuived (on March 7, 1983) information about non-seismic items associated with the control room.

As a result of this letter, allegations relative to improperly supported items in the control room were investigated by the NRC Senior Resident Inspector as part of inspections conducted from March 1983 through July 1983.

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i The results of this inspection were reported in Inspection Report 50-445/83-24, 50-445/83-15 received by TUGCO in August 1983. The Senior Resident Inspector concluded that the items inspected (field run conduit above the control room, drywall (suspended ceiling and sloping wall) (and lights) . . . appear to fully satisfy the intent of the licensee's commitment to comply with Regulatory Guide 1.29."

No violations or deviations associated with the control room were identified during the special inspection effort to respond to CASE's allegations. ,

l Following a meeting between CPSES staff and TRT staff on j July 31, 1984 in which the question of seismic design adequacy in regard to Regulatory Guide 1.29 was raised, TUGCO initiated a written response to File (CPPA-40224, 1

dated August 3, 1984) which addressed the requests of the l

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TRT staff and justified the architectural wall and ceiling l

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i systems in the Control Room as being in compliance with the I

intent of Regulatory Guide 1.29. j

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Subsequently, the NRC letter of September 18, 1984, j l

formally reiterated to TUGCO the TRT concerns regarding the j 1

control room ceiling. Following receipt of the letter, the CPRT was formed and ISAP II.d (Seismic Design of Control Room Ceiling Elements) was issued to address the TRT concerns regarding control room ceiling seismic design adequacy.

TEXAS UTILITIES ELECTRIC COMPANY For the Owners of CPSES g.

Willliam S. Eg ling Jef/reyH.

j Ma David A. Mart and Ropes & Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100 Attorneys for Texas Utilities ,

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b GMMDE?uy.sgops UdNRC CERTIFICATE OF SERVICE 17 DEC -8 A9'48 1987, I, Jeffrey H. May, hereby certify that on December 4, OFFICE Of 9 GrUAnY I made service of "Permittees' Supplemental Re00gemeGBRANCH T6EMeddie (Set 5)" by Gregory's Interrogatories And Request For Documents mailing copies thereof, postage prepaid, to:

Peter B. Bloch, Esquire Asst. Director for Inspection Programs Chairman Comanche Peak Project Division Administrative Judge Atomic Safety and Licensing U.S. Nuclear Regulatory l

Board Commission 5 U.S. Nuclear Regulatory P. O. Box 1029 Granbury, Texas 76048 Commission Washington, D.C. 20555 Dr. Walter H. Jordan Ms. Billie Pirner Garde Administrative Judge GAP-Midwest Office 881 W. Outer Drive 104 E. Wisconsin Ave. -B 37830 Appleton, WI 54911-4897 Oak Ridge, Tennessee Chairman chairman Atomic Safety and Licensing Atom!.c 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 Janice E. Moore Mrs. Juanita Ellis President, CASE office of the General Counsel 1426 S. Polk Street U.S. Nuclear Regulatory Dallas, Texas 75224 Commission Washington, D.C. 20555 Renea Hicks, Esquire Ellen Ginsburg, Esquire Assistant Attorney General Atomic Safety and Licensing Environmental Protection Division Board Panel U.S. Nuclear Regulatory P. O. Box 12548 Commission Capitol Station Washington, D.C. 20555 Austin, Texas 78711 I

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Anthony Roisman,. Esquire Mr.-Lanny A. Sinkin Christic Institute Suite 600 1324 North Capitol Street 1401'New York Avenue,-N.W. 20002 Washington, D.C. 20005 Washington, D.C.

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, Esquire Administrative Judge Office of-the Executive.

Oak Ridge National Laboratory Legal Director U.S. Nuclear Regulatory P. O. BoxLX, Building 3500 Oak Ridge, Tennessee 37830 Commission Washington, D.C. 205E3 Jack R. Newman, Esquire Nancy H. Williams Newman & Holtzinger, P.C. 2121 N. California Blvd.

Suite 1000 Suite 1390 1615 L. St., N.W. Walnut Creek, CA 94596 Washington, D.C. 20036 i

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.M,.  % V Jeffrey H. May /

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