ML20147D614

Forwards Licensee Final Submittal of Confirmed Issues Chronologies Per ASLB 860808 Request.W/Certificate of Svc

ML20147D614
Person / Time
Site:	Comanche Peak
Issue date:	02/29/1988
From:	Edgar G NEWMAN & HOLTZINGER, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Bloch P, Jordan W, Mccollum K Atomic Safety and Licensing Board Panel
References
CON-#188-5729 OL, NUDOCS 8803040064
Download: ML20147D614 (43)

Text

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Peter B. Bloch, Esquire Dr. Kenneth A. McCollom Chairman Administrative Judge Atomic Safety and Licensing 1107 West Knapp Board Stillwater, Oklahoma 74075 U.S. Nuclear Regulatory Commission Elizabeth B. Johnson Washington, D.C. 20555 Oak Ridge National Laboratory P.O. Box X, Building 3500 Dr. Walter H. Jordan Oak Ridge, Tennessee 37830 881 West Outer Drive Oak Ridge, Tennessee 37830 Re: Texas Utilities Generating Company, et al.

Docket Nos. 50-445-OL and 50-446-OL

Dear Administrative Judges:

Applicants herewith make their final submittal of chronolo-gies of confirmed issues in response to the Board's request of August 8, 1986.

Sincerely, George L. Edgar Enclosures cc: Service List G

K [

])S D

Improper Shortening of Anchor Bolts in l

, Steam Generator Upper Lateral Supports )

l ISAP V.b i Historv  !

l In SSER-10, page N-328, the TRT made the following assessment of technical issues and allegations concerning improper shortening of anchor bolts in steam generator upper lateral restraints:

"The TRT was informed that some anchor bolts in the steam generator upper support beams were shortened during installation to less than the length shown on l the design drawing without proper authorization. The .

TRT was told that the bolt cutting incident occurred either because the hole of the anchor device was filled with debris, or the threaded. portion of the bolt had concrete mix stuck to it. There are 18 bolts at each end of four beams, totalling 144 bolts. There is one beam for each steam generator. The bolt threads into an anchor device embedded in the concrete wall. The acceptable bolt length or the length of bolt available for threading into the anchor device is vital to ensure structural capability of the support beams."

l "The TRT attempted to review TUEC records for Ultrasonic (UT) measurement results and general installation practices. The TRT was told that Ultrasonic testing of these types of bolts was not a procedural requirement; however, TUEC was unable to provide any other installation racerds for TRT review.

The TRT concludes that such untuthorized bolt cutting l and lack of installation inspection records is a violation of QA procedures and Criterion XVII in Appendix B of 10CFR50. Since the support beams are t essential to provide lateral restraint for the steam generator during a LOCA or seismic event, adequate anc'horing capability of the bolts has safety i

significance and, as a result, appropriate measures are l needed to ensure conformance with General Design

Criterion 1 of 10CTR50."

Prior to March 20, 1984, the NRC's Region IV received an allegation that some anchor bolts holding the upper steam generator lateral supports in place were cut off and were 1

incapable of securing the lateral supports in accordance with design requirements. The NRC conducted an on-site investigation of CPSES between March 20, 1984, and May 18, 1984, and it was during this investigation that Applicants first became aware of the allegation and existence of any potential issue related to shortening of anchor bolts.

As a result of NRC investigation inquiries, the CPSES QA Manager requested the Assistant Project Manager to provide a response to the allegations concerning shortening of anchor bolts holding the upper steam generator lateral supports in place (TUQ-2037, 4/19/84),

On July 23, 1984, the results of the NRC inspection conducted from March 20 to May 9, 1984, were sent to TUEC. NRC Inspection Report 50-445/84-12 stated that there was no technical merit or safety concern related to cutting the anchor bolts and further that no violations or deviations were identified. .

Accordingly, TUEC believed any potential concern regarding shortening of anchor bolts to be resolved.

During its on-site review, however, the TRT reinvestigated the allegation of unauthorized anchor bolt shortening for the ,

1 steam generator upper lateral support becms. As part of that  ;

investigation TUGCO was requested to provide the inatallation and ,

Inspection Records for the subject beams. The records, however, could not be located in the permanent plant records vault. Non-conformance Report, NCR-M-84-100384 was issued by TUGCO Quality i

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Control to document the lack of Inspection Records. (NCR-M '

• 100384, 9/6/8 4.) .

In a TUGCO raemo dated September 6, 1984, L. A. Kattness, Quality Engineer, offered a possible explanation for the lack of installation inspection records based on a lack of clarity in the division of responsibility between ASME and Non-ASME mechanical inspections. At the time the anchor bolt installation was performed, it was not clear as to which category this particular work belonged. A similar memo dated 9/19/84 sought to provide additional clarification.

On October 4, 1984, Gibbs & Hill was asked by TUGCO to determine the minimum thread engagement required (TWX-14, 964, 10/4/84) and an interim response was provided on October 17, 1984.

On November 29, 1984, the NRC letter to TUGCO formally confirmed the TRT concerns regarding improper shortening of anchor bolts. Following formation of the CPRT, ISAP V.b (Improper Shortening of Anchor Bolts in Steam Generator Upper Lateral Supports) was issued to address the TRT findings. On I

December 7, 1987 the Results Report for ISAP V.b was published.

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Train C Conduit and Supports e

ISAP I.c History As a result of TRT findings contained in the letter of September 18, 1984, the following concerns regarding Train C conduit and supports were identified by the NRC:

"The Nuclear Regulatory Commission (NRC) Technical Review Team (TRT) examined the non-safety-related conduit support installation in selected seismic Category I areas of the plant. The support installation for non-safety-related conduit that is less than or equal to 2 inches in diameter was inconsistent with seismic requirements, and no evidence cculd be found that substantiated the adequacy of the installation for non-safety-related conduit of any size. According to Regulatory Guide 1.29 (Reference 9.2) and FSAR Section 3.7B.2.8 (Reference 9.3), the seismic Category II and non-seismic items should be designed in such a way that their failure would not adversely affect the function of safety-related components or cause injury to occupants of the

, Control room."

Applicants believe that the chronological history of issue related to Train C conduit and supports commences with the TRT letter of 09/18/84. Prior to this date, Applicants had taken action in regard to seismic supports at CPSES. Specifically, on April 30, 1979, TUSI Systems Engineering Memo (CPP01176) was issued to the TUSI Engineering and Construction Manager, recommending the seismic declassification of Class 5 piping and Train C conduits in the Auxiliary, Fuel and Electrical & Control (E&C) Buildings.

The subsequent issuance of DCA 4693 on July 20, 1979, allowed for Train C conduits (all sizes) to be non-seismically supported in seismic Category 1 buildings. The DCA also stated 1

that protective measures would be taken to protect safety-related equipment where engineering analysis determines that failure of the conduit or supports could degrade that equipment or its operability. Shortly thereafter, memo CPPA-2142, from the TUSI Engineering and Construction Manager to the Brown & Root Project Manager, identified where Train C conduits larger than 2 inches will require seismic support and stated that elsewhere, support will be nonseismic. Train C conduits, 2 inches and smaller, were to remain nonseismically supported in all areas. A reiteration of this policy regarding nonseismic support of conduits 2 inches and under in the Containment and Safeguards Building was made on July 10, 1979 via memo CPPA-2269 from the TUSI Engineering and Construction Manager to Brown & Root Company.

The generic issue of nonseismic support of Train C hardware ha; been addressed during the construction of CPSES through the CPSES Damage Study Program. In the summer of 1979, the Damage Study began to examine the effects of failure of nonseismic conduit supports on nearby equipment. This systematic study was performed for the interaction of all nonseismic piping and conduits greater than two inches in diameter, with equipment and structures with safety-related components in Category 1 buildings for Unit 1 and common areas. The support of conduits less than or equal to 2 inches in diameter was assumed to be adequate to assure that the conduit would not result in an adverse interaction during a seismic event. Accordingly, this interaction was not considered by the Damage Study.

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During the time period of December, 1979 through September,

, 1984, various revisions were issued to the aforementioned DCA 4693. However, conduits two inches and smaller remained nonseismically supported in all areas except as identified on a case-by-case basis to be required.

During the same time span, namely, on March 10, 1980, a memo from Gibbs & Hill Manager of Projects (GTN-44706) to the TUGCO Engineering and Construction Manager elaborated on TUSI's nonseismic support criteria. This memo transmitted meeting minutes from a February 6 and 7, 1980 meeting between Gibbs & Hill and TUSI in which TUSI provided an explanation as to why the two inches and smaller conduit supports were specified as nonseismic. TUSI stated that the decision to allow nonseismic support of conduits two inches or smaller was based on NRC criteria for the damage potential for two inch diameter standard wall thickness pipe. The NRC study for pipes was extrapolated by TUSI to include two inch diameter rigid steel conduits.

On 09/18/84, however, the NRC letter to TUGCO notified TUGCO of the TRT concern with electrical conduit supports.

Subsequently, the CPRT was formed and ISAP I.c (Electrical Conduit Support) was issued to address the TRT finding with regard to the adequacy of the seismic support system installation for non-safety related conduits. The Results Report for ISAP I.c was published on November 9, 1987.

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Polar Crane Shimming

. ISAP VI.b History At pages K-181 and K-183 of SSER-8, the TRT expressed the following concerns with regard to the Unit 1 polar crane rail support system:

"The TRT investigated the installation of the polar crane rail support system by visual inspection, review of associated documentation, and discussions with TUEC representatives and their contractors. Region IV Inspection Report 50-445/84-08; 50-446/84-04, and Notice of Violation, dated July 26, 1984, documented that gaps on the Unit 1 polar crane bracket seismic connections exceeded design requirements. In Texas Utilities Generating Company responses of August 23, 1984, and September 7, 1984, the gaps were attributed to crane and bolting self-adjustment resulting from crane operation. A site design change (DCA-9872, Revision 4, dated August 14, 1984) was issued to document the acceptability of gaps in excess of 1/16 inch which were identified in the above NRC

] inspection report.

During further investigation of the allegation that shims for the rail support system had been altered during installation, the TRT observed gaps which may

{ have been excessive between the crane girder and the i girder support bracket. Detailed specifications addressing the gap tolerances in the girder seat connection did not exist; however, Gibbs and Hill letter GHF.2207, date.d November 28, 1977 had stated that the "seated connections will not require shimming since the area in bearing is at least the width of the bottom flange of the crane girder." contrary to this Gibbs and Hill assumption, the TRT observed nine girders with gaps which extended under the bottom flange that reduced the bearing surface to less than the 20 inch flange width stated in the letter. The TRT also observed conditions which indicate that the crane rail may still be moving in a c'ircumferential direction,that three rail-to-rail ground wires were broken, that two shims had partially worked out from under the rail, and that two cadwalds were broken."

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Applicants believe that the Region IV Inspection Report 50-445/84-08, 50-446/84-04 and Notice of Violation, dated July 26, 1984, documenting gaps on the Unit 1 polar crane bracket and seismic connections as exceeding design requirements was the historical origin of any concern regarding possible inadequacies in polar crane shimming. It can conceivably be urged, however, that the first indication of the potential for a problem with polar crane shimming was recognized in July, 1982, when the NRC issued Notice of Violation 50-445/82-11 citing that no inspections of the fabrication nnd installation of certain shim's, as specified in Design Change Authorization DEC-9872 R/O and sketch SK-82032 were performed. In response to the Notice of Violation, NCR M82-894 was generated by TUGCO on July 7, 1982.

This 1982 NOV related to deficiencies in implementing inspection procedures and not the precise problems identified in the TRT findings.

Interoffice Memo "of July 27, 1982, from Brown & Root to TUGCO Site QA Manager provided a corrective and preventive action response to NCR M82-894 and a date for compliance. On August 2, 1982, TUGCO submitted a written response to the NRC's Notice of Violation citing the Brown & Root corrective action memo (TXX-3554, 8/2/82). Shortly thereafter on Aunust 9, 1982, Design Change Authorization revisions, DCA-9872, R/1 and DCA-9872, R/2, were issued to clarify shimming and bolting requirements on the polar crane. These revisions recognized as acceptable occasional shim gaps of less than 1/16 inch.

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During October, 1982, Operational Traveler CE-82-370-3104 was issued implementing QC requirements that "all gaps greater than 1/16" wide shall be shimmed."

The NRC conducted an on-site inspection of CPSES during the period 11/14/83 to 3/31/84 and expressed concerns regarding the as built shim gsps in the upper brackets of the polar crane.

During the inspection, the Comanche Peak Plant Engineer requested a Gibss & Hill analysis of the shim's "as built" on January 31, 1984. The Gibbs & Hill response contained in a February 16, 1984, letter, (CPPA-36900) provided that as long as there is a positive contact at the girder top flange, the seismic loads will be transmitted directly into the containment wall through the horizontal stiffeners of the attachment and therefore the gaps at tha periphery of the shims will be of no concern (GTN-68522 1/15/84).

Site Quality Control originated NCR H 84-918, R/1 on 3/27/84 for loose bolts found on the polar crane support brackets, on April 2, 1984, NCR 84-918, R/1 was closed following efforts to tighten all bolts.

On 6/4/84 and 6/3/84 Gibbs & Hill provided evaluation of as-built gaps in upper bracket supports of the polar crane and in each instance the analysis concluded, with small exception, that the as-built condition was considered acceptable. (GTT-10372; GTT-10457)

It was at this point, as noted previously, that NRC Region IV Inspection Reports 50-445/84-08, 50-445/84-04 and Notice of 3

Violation dated July 26, 1984, were issued. In TUGCO's responses of August 23, 1984, and September 7, 1984 the gaps were attributed to crane and bolting self-adjustment resulting from crane operation. A site Design Change Authorization, DCA-9872 R/4, dated August 24, 1984, was issued to document the acceptability of the gaps in excess of 1/16 inch which were identified in the NRC Inspection Report.

The NRC letter of November 29, 1984, informed TUGCO of the TRT's continuing concerns regarding polar crane shimming.

Subsequently, the CPRT was formed and ISAP VI,b (Polar Crane Shimming) was issued to address the TRT concerns. On October 5, 1987, the Results Report for ISAP VI.b was published.

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Inspection Reports on Butt Splices ISAP I.a.2 l History At page J-29 of Supplemental Safety Evaluation Report No. 7 (SSER-7), the TRT identified the following concerns relating to  !

inspection reports on butt-splicas:

" ...the TRT reviewed the QC Inspection Reports for 12 butt-splices and found the following:

Nine of these splices were documented on the inspection form designated in paragraph 3.3 of the procedure for post-installation inspections instead of on the correct form designated for witnessing-type inspections.

It should be noted that all splices were required to be witnessed by QC personnel per paragraph 3.1.d of the procedure (QI-QP-11.3-28, Revision 21, "Class 1E Cable Terminations").

Six of the nine incorrect forms contained handwritten notes by the inspector indicating that he had witnessed the splice; however, no reference was added to indicate that the installation of the heat-shrinkable sleeves was required to be witnessed.

The remaining three of the nine incorrect forms did not indicate that the splices had been witnessed.

For three splices which were documented on the correct forms, the forms all contained an "N/A" (not applicable) handwritten by the inspector on the line indicating that the installation of the heat-shrinkable sleeve was witnessed."

These TRT concerns were initially expressed in a September 18, 1984 letter and, subsequent to implementation of CPRT, incorporated as ISAP I.a.2, Inspections Reports on Butt-Splices.

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From late 1982 through mid-1983, while incorporating certain "human factors" modifications and while completing various other rework on control panels, some conductors were found to be too short to be properly terminated at designated termination points.

In lieu of repulling cables or redesigning cabinet internals, either of which would have involved significant disassembly and rework, the CPSES Projact elected to add extensions to the subject conductors by using butt splices. The type of butt-splice used by the CPSES Project for splicing in panels was the AMP Pre-Insulated Environmentally Sealed (PIES) splice. IEEE l

383-1974, "IEEE Standard for Type Test of Class lE Electric l Cables, Field Splices, and Connections for Nuclear Power

Generating Stations," recognizes that qualified field splicing is acceptable and provides criteria for the qualification of such splices.

Originally, Section 8.1.5.2.4 of the FSAR committed CPSES to the provisions sa Dratt Sta?.dard IEEE 42C '073, "IEEE Trial-Use Guide' for Class 1E Control Switchboards fo Nuclear Power Generating Stations." This Standard st%es that splices are not allowed within control switchboards (including panels).

Regulatory Guide 1.75, Rev. 1, "Physical Independence of Electric Systems," states that splices in raceways should be prohibited.

In July, 1983, TUGCO contacted the NRC staff (TCO #549 and TCO

1. 550) to discuss the potential need to revise the FSAR to cover AMP PIES splices. Accordingly, FSAR Amendment 44 was issued in October, 1983, to encompass the use of these splices in control 2

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panels. The TRT investigation occurred in July, 1984, which was

- subsequent to the submittal of FSAR Amendment 44, but prior to the NRC's approval which was received by TUGCO on September 14, 1984.

Prior to TRT investigation, the craft Construction Procedures EEI-8, "Class 1E and Non-Class 1E Terminations," did not contain specific instructions regarding the selection, installation or inspection of AMP PIES splices. This procedure did indicate that manufactures' instructions were to be used for installation of connectors, but no specific instructions with respect to selection of splice type or size, the correct tool to use, or accept / reject criteria for installation were included.

Likewise, the QC Inspection Procedure QI-QP-11.3-28, "Class 1E Terminations." did not contain specific instructions regarding the selection, installation or inspection of AMP PIES splices.

This procedures did contain some general statements about using manufacturers' instructions, but no specific instructions in the area of splicing.

Notwithstanding the lack of specific instructions regarding the installation or inspection of AMP PIES splices, existing procedures were adhered to by Applicants and should be roted in context of the TRT findings. Four inspection reports that were reviewed by TRT (IR ET-1-0005393, ET-1-0005394, and ET-1-0005395, and ET-1-0005396) documented the splicing of cables on the

inspection report normally used for post installation (verification) inspections. The inspector added a handwritten 3

witness attribute to these inspections reports, "Verify splicing (refer to QI-QP-11.3-28.13)." By adding this attribute, these inspections reports were converted to a form capable of documenting the- required witness criteria of the splice installation. Authority for adding attributes to inspection reports is found in CP-QP-18.0 Rev. 13, paragraph 3.1, "the attributes listed on the Inspection Report shall be predetermined although additional conditions may be noted."

Also, concerning the installation of heat-shrink sleeves, no reference was added regarding a heat-shrink attribute since heat-shrink sleeves were not required for this splice installation as per Design Change Authorization (DCA) 7463 Rev. 1 dated 05/29/80.

(Th3s DCA was later consolidated into DCA 9985 Rev. 4 dated 08/17/82.)

Finally, in respect to an inspection report reviewed by the NRC (IR ET-1-0014790) which did not indicate that the splice had been witnessed, research has revealed that this inspection was performed for the purpose of documenting the retermination of a cable after the installation of a cable grip. The witnessing of the splice had previously been documented on IR ET-1-0006776.

On July 13, 1984, the NRC issued a Special Review Team Report (Letter Docket Nos. 50-445 & 50-446) to TUGCO that resulted from a special review conducted at CPSES during the period of April 3-13, 1984. At page 27 of this report, reference is made that "(d)uring the inspection for electrical separation in the above panels, it was noted that some cables in the panels 4

were being splir:ed. This was determined to be satisfactory and

. meets FSAR commitments ...

Nevertheless, upon inspection of documentation associated ,

I with twelve of the c3ntrol room splices, the NRC-TRT noted the concerns as listed in Sdca 7. These concerns were transmitted to !

l TUGCO by the 09/18/84 TRT letter. Subsequently, the Comanche l Peak Response Team (CPRT) was formed and Issue-Specific Action Plan (ISAP) I.a.2 (Inspection Reports on Butt-Splices) was issued to address the TRT findings regarding proper witnessing and documentation of inspections on butt-splices. The Results Report for ISAP I.a.2 was published on April 27, 1987.

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Seismic Design of Control Room Ceiling Elements ISAP II.d History Technical issues and allegations concerning conduit, lighting fixtures and suspended ceilings installed in the control room at CPSES were identified by the NRC in SSER-8 as follows:

"Technical issues and certain allegations with potential safety implications were identified and communicated by the NRC to TU Electric. It was alleged that the field run conduit, the drywall, and the lighting installed in the area above the ceiling panel in the control room were classified as non-seismic and supported only by wires and might fall as a result of a seismic event. The following excerpts from the assessment of the allegation were taken from pages K-83, -84, and -85 of SSER 8 (Reference 9.1):

"General Design Criteria No. 19 requires that

, safe occupancy of the control room during abnormal conditions be provided for in its design. The Comanche Peak Steam Electric Station (CPSES) control room is in a seismic Category I structure, with certain seismic Category II and non-seismic components located in the ceiling. Seismic Category I refers to those systems or components which

must remain functional in the event of an l 1

earthquake. Seismic Category II refers to

[

those systems or components whose continued i

functioning is not required, but whose j failure could reduce the functioning of any seismic Category I system or component (as defined in Regulatory Guide 1.29) to an unacceptable level or could result in an incapacitating injury to occupants of the I control roora. Seismic Category II systems or

! components are, therefore, designed and constructed so that a Safe Shutdown Earthquake (SSE) will not cause such failure or injury.

"In assessing this allegation, the TRT reviewed the CPSES nonsafety-related conduit, lighting fixtures, and the suspended ceilings installed in the control room. Three types of suspended ceiling exist in the control room: drywall, louvered, and acoustical.

• he following list designates those ceiling elements present in the control room and their seismic category designation

1. Heating, Ventilating and Seismic Category I Air Conditioning

2. Safety-related Conduits Seismic Category I

3. NonSafety-related Conduits Seismic Category II

4. Lighting Fixtures Seismic Category II

5. Sloping Suspended Drywall Ceiling Non-seismic

6. Acoustical Suspended Ceiling Non-seismic

7. Louvered Suspended ceiling "The TRT determined that none of the suspended ceiling elements were considered tc be either seismic Category I or II; however, TUEC had modified the sloping suspended drywall to add more support. G&H could not provide backup calculations to support this modification, nor could TUEC provide justification for their position that the remaining suspended ceiling elements (i.e.,

and louvered and acoustic elements) would not fall and cause an incapacitating injury to operating personnel. This would indicate failure of the quality ssurance program to ensure that applicable provisions of Regulatory Guide 1.29 were fully met."

"The TRT four.d that nonsafety-related conduits that were less than or equal to 2 inches in diameter were not supported by redundant seismic Category II cable restraints. The TRT also verified the adequacy of calculaticas for the nonsafety-i related conduits larger than 2 inches in diameter."

"The TRT found that 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 non-seismic, do not satisfy the provisions of Regulatory Guide 1.29, since they were not designed to accommodate seismic

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effects. Non-safety-related conduits.that are 2 inches in diameter and less also were not designed to accommodate seismic effects."

"The TRT concludes that calculations sup rting the seismic Category II lighting fix.ures do not adequately reflect the rotational interaction with the non-seismic items. In addition, the fundamental frequencies of the supported masses were not calculated to determine the influence of the seismic response spectrum at the control room ceiling elevation."

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 non-seismic 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. (11gt, a non-seismic design).

On Jtnuary 9, 1979, Gibbs & Hill issued letter GTN-33023 to TUGCO. An attachment to this letter was a j Design / Engineering Change Request (N-338) which revised the lower 1

ceiling in the control room (above the control board) to include acoustical tile above the louvered ceiling in lieu of plaster and j also provided for gypsum board in lieu of plaster for the sloping 1

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4 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.

Applicants first had notice of concerns related to the TRT control room ceiling issue, 12gt, inability to adequately demonstrate compliance with the provisions of Regulatory Guide 1.29, on September 3, 1980, when the TUGCO Project Civil Engineer telephoned Gibbs & Hill inquiring 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 & Hill requesting an engineering justification for i

the non-seismic 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-ll410 on July 22, 1981. TUGCO's memo requested the comments Lnd 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 aforementioned proposal, but acknowledged a lack of current substantiating documentation.

By letter dated March 11, 1983, CASE notified the NRC that CASE had just received (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. 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.

Following a meeting between CPSES staff and TRT staff on 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, dated August 3, 1984)

which addressed the requests of the TRT staff and justified the architectural wall and ceiling systems in the Control Room as being in compliance with the intent of Regulatory Guide 1.29.

Subsequently, the NRC letter of September 18, 1984, formally reiterated to TUGCO the TRT concerns regarding the 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. On November 8, 1987, the Results Report for ISAP II.d was published.

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QC Inspector Qualifications ISAP I.d.1 History Concerns regarding QC inspector qualifications were identified by the TRT in SSER-7, page J-110 as follows:

"The TRT examined electrical QC inspector training and certification fjles, and requirements for personnel testing, on-the-job training, and recertification. The TRT also interviewed selected electrical QA/QC personnel.

The TRT found a lack of supportive documentation regarding personnel qualifications in the training and certification files, as required by procedures and regulatory requirements. Also, the TRT found a lack of docilmentation for assuring that the requirements for electrical QC inspection racertification were being met. Specific examples are:

o one case of no documentation of a high school diploma or General Equivalency Diploma o one case of no documentation to waive the remaining 2 months of the required 1 year experience.

o one case where a QC technician had not passed the required color vision examination administered by a professional eye specialist. A makeup test using colored pencils was administered by a QC supervisor, was passed, and then a waiver was given, o Two cases where the experience requirements to become a Level I technician were only marginally met.

l o one case of no documen ation in the training and certification files substantiating that the person met the experience requirement."

The TRT letter of September 18, 1984 is believed to be the first event in the history of concerns regarding QC inspector 1

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qualification. The TRT letter identified qualification issues for six electrical QC inspector files examined by the TRT.

Electrical QC inspectors are classified as non-ASME.

Brown & Root was responsible for non-ASME site inspection activities prior to L978. In 1978, TUGCO assumed responsibility for the non-ASME QA program and established a QC inspector certification program. The education and experience requirements and the records maintenance requirements for the various levels l of inspectors (I, II and III) are detailed in Regulatory Guide )

1.58, Revision 1, "Qualification of Nuclear Power Plant Inspection, Examination, and Test Personnel for the Construction Phase of Nuclear Power Plants." The TRT examined the qualifications of the six QC inspectors to determine compliance with the requirements of Reg. Guide 1.58 and ANSI Standard N45.2.6-1978. TUGCO was not committed to Reg. Guide 1.58 and ANSI Standard N45.2.6-1878 until January 30, 1981 when amendment 14 to the FSAR was issued. TUGCO Procedure CP-OP-2.1, "Training of Inspection Personal," Revision 8 (July 1981) met the requirements of Reg. Guide 1.58 and ANSI Standard N4 5. 2. 6-1978.

Prior to receipt of the September 18, 1984 TRT letter, but after commitment to Reg. Guide 1.58 and ANSI Standard N4 5. 2. 6-1878 on January 30, 1981, there were issues raised regarding the adequacy of QC inspector qualifications involving the overall functioning of the QC inspection qualification program and not merely the qualifications of QC inspectors. While such programmatic issues go beyond the scope of the above TRT finding, 2

an adequate understanding of TU's actions with regard to inspector qualifications is not complete without touching upon these tangential issues.

The Lobbin Report of February 4, 1982, stated that interviews with various individuals at CPSES revealed a concern with regard to the level of experience of inspection personnel.

On February 23, 1982, the TUGCO QA Manager notified the TUGCO, Vice President Operations of QA's responses to the Lobbin Report findings by memo QBC-18. The specific response regarding the inspection program findings stated that inspection personnel were qualified as appropriate to industry standards. The response also stated that personnel qualifications were routinely examined incidental to audits of safety related activities, but that an audit of inspection personnel training and certification had been scheduled for March, 1982.

TUGCO QA Audit Report TCP-36, which reported the results of the audit of Site QA/QC Personnel Training performed on March 8-12, 1982, was transmitted to the TUGCO Site QA Supervisor by memo QTQ-120 from the TUGCO QA manager. The scheduling of this audit was referenced in the February 23, 1982, TUGCO QA response to the Lobbin Report findings. The Audit Report presented only one concern that was directly related to the TUGCO non-ASME QC inspector certification program procedures. .However, this was a programmatic concern rather than a specific inspector qualifications concern as identified by the TRT finding to which this answer is responsive. The report cited two deficiencies 3

that were directly rela 1.ad to non-ASME inspection personnel qualifications. Deficiency No. 1 stated that formal training records within some non-ASME personnel certification training files did not contain complete instruction information.

Deficiency No. 2 stated that inspector certification records did not reflect a certification in each given inspection function as required.

On December 21, 1982, the TUGCO Site C.A Supervisor provided responses to the Audit Report TCP-56 deficiencies by memo TUQ-1497 to the TUGCO QA manager. The memo stated that corrective actions for Deficiency Nos. 1 and 2 would consist of revisions to applicable procedures. On January 25, 1983, the TUGCO QA Manager provided an evaluation of the December 21, 1982, responses to Audit Report TCP-56 deficiencies in memo QTN-623 to the TUGCO Site QA Supervisor. The response evaluation closed Deficiency No. 1 but requested specification of an implementation date for the Deficiency No. *2 corrective action. The requested information was provided on March 14, 1983, by memo TUQ-1583 from the TUGCO Site QA Supervisor to the TUGCO QA Manager.

On April 11, 1983, the NRC transmitted to TUGCO the NRC Construction Appraisal Team (CAT) Inspection Report. The inspection was conducted between January 24 and March 3, 1983, at CPSES and at TUGCO's Dallas Corporate office and consisted in part of a review of the QA Program and examination of procedures and records. Interviews with quality control inspectors and

, certification reviews revealed that some inspectors had been 4

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certified without the required combination of education and

• experience as specified by ANSI Standard N45.1.6-1978.

Additionally, interviews and document reviews revealed that individuals not certified as Level II were evaluating the validity and acceptability of final inspections contrary to the requirements of ANSI Standard N45.2.6-1978 as committed to in the FSAR. On April 14, 1983, after evaluating the CAT Report findings, the TUGCO Site QA Supervisor stated by memo to the TI-086 file, that the NRC CAT inspector's interpretation of the "inspector of record" concept was a matter of opinion and that this interpretation had not been imposed on the industry by NRC.

He also stated that a review of ANSI Standard N45.2.6-1978 and Reg. Guide 1.58 supported the CPSES program and that no changes would be planned.

On May 4, 1983, the TUGCO Mechanical / Civil QA/QC Supervisor notified the TUGCO Site QA Supervisor by memo TUQ-1647 of his further evaluation of the CAT findings. He stated that the plant was in compliance with the intent of both Reg. Guide 1.58 and ANSI Standard N45.2.6.-1978. On June 15, 1983, testimony was provided before the ASLB by various intervanor and TUGCO witnesses regarding CAT Report proposed enforcements. One of the specific subjects covered included qualifications of inspectors.

On August 25, 1983, the TUGCO QA Manager transmitted TUGCO QA Audit report TCP-78 by memo QTQ-430 to the TUGCO Site QA Supervisor. The report provided the results of the audit of cable tray and conduit supports installation and inspection 5

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I activities performed on July 11-15, 1983. The audit included a

. review of qualification and training of QC inspectors.

Deficiency No. 2 stated that OJT Training Record Sheets from selected personnel files were reviewed and found to be inconsistent in documenting required information. Deficiency No. 3 stated that a review of selected qualification files indicated no documented evidence that three individuals were qualified / certified to perform as instructors in the identified procedure / activity.

On September 22, 1983, the TUGCO Site QA Supervisor provided responses to the Audit Report TCP-1978 deficiencies by memo TUQ-1807 to the TUGCO QA Manager. The response to Deficiency No. 2 stated that the qualification files in question had been corrected so that the required information was documented. The response to Deficiency No. 3 provided the qualification information for the three individuals in question. On December 8, 1983, the TUGCO QA manager notified the TUGCO Site QA Supervisor, by memo QTQ-520, that the responses to Deficiency Nos. 2 and 3 for Audit Report TCP-78 were considered unacceptable because they were directed toward the symptom of the problem and not the problem itself. On January 11, 1984, by memo TUQ-1903, the TUGCO Site QA Supervisor provided the TUGCO QA manager with the information believed to be adequate to close out Deficiency Nos. 2 and 3.

On October 3, 1983, the NRC Region IV Reactor Project Branch Chief transmitted to TUGCO the NRC Investigation Report Nc%. 50-6

445/83-28, 50-446/83-14 for investigations conducted at CPSES on June 27 to September 16, 1983. This inspection was a follow up to the earlier CAT inspection and consisted of a more in-depth review and evaluation of the CAT Report findings. The Inspection Report results stated that the certifications of the inspectors examined were generally consistent with the requirements of ANSI Standard N45.2.6-1978 and Reg. Guide 1.58. The Region IV inspectors also reviewed the CAT finding regarding the "inspector of record" issue for Level I and Level II inspectors. They agreed with the TUGC0 Site QA Supervisor's interpretation and concluded that the "inspector of record" and the level of review at CPSES was appropriate for the type of inspections in question.

Following notification by TRT of the QC inspector 4

qualifications issue on September 18, 1984, TUEC formed the CPRT and issued ISAP I.d.1 (QC Inspector Qualifications) to address the TRT finding as stated in SSER No. 7. The Results Report for ISAP I.d.1 was published on January 18, 1988.

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Reinforcing Steel in the Reactor Cavity

. ISAP II.a History Allegations and concerns regarding reinforcing steel in the reactor cavity at CPSES were identified in an enclosure to the NRC's TRT letter of September 18, 1984. On page 7 of the enclosure at Reference 9.1 the TRT noted as follows:

"The TRT investigated a documented occurrence in which reinforcing steel was omitted from a Unit i reactor cavity concrete placement between the 812-foot and 819-foot 1/2-inch elevations. This reinforcement was installed and inspected according to drawing 2323-S1-0572, Revision 2. However, after the concrete was placed, Revision 3 to the drawing was issued showing a substantial increase in reinforcing steel over that which was installed. Gibbs & Hill Engineering was informed of the omission by Brown & Root Nonconformance Report C-669. Gibbs & Hill Engineering replied that the omission in no way impaired the structural integrity of the structure. Nevertheless, the additional reinforcing steel was added as a premution against cracking which might occur in the vicinaty of the neutron detector slots should a loss of coolant accident (LOCA) occur. A portion of the omitted reinforcing steel was also placed in the next concrete lift above the 819-foot 1/2 inch level. This was done to partially compensate for the reinforcing steel omitted in the previous concrete lif t and to minimize the overall area potentially subject to cracking.

The TRT requested documentation indicating that an analysis was performed supporting the Gibbs & Hill conclusion. The TRT was subsequently informed that an analysis had not been performed. Therefore, the TRT cannot determine the safety significance of this issue until an analysis is performed verifying the adequacy of the reinforcing steel as installed."

Applicant believes that issues related to reinforcing steel in the reactor cavity had their origin in the June 22, 1977 Brown & Root Nonconformance Report, C-669. In accordance with Gibbs & Hill drawing No. 2323-S1-0572, Rev. 2, concrete was 1

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placed in the Unit i reactor cavity between 812-foot and 819-

. foot, 1/2-inch elevations. This pour was made on May 25, 1977, eight days after Rev. 3 of G&H drawing No. 2323-S1-0572 was transmitted to CPSES site, but 22 days prior to the drawing being issued for construction. The new drawing, Rev. 3, showed additional rebar within the pour area which was not installed.

Accordingly, Brown & Root issued NCR-669 on June 22, 1977, which dEAcribed the omission of additional robar to the reactor cavity wall. On June 23, 1977, a corresponding NCR (CP-77-6) was issued by TUGCO describing the omission of additional rebar to the reactor cavity wall.

Telex No. TWX-762 (06/23/77) from Gibbs & Hill Engineering (site) to Gibbs & Hill (New York) confirmed a telephone conversation concerning the omitted rebars. Gibbs & Hill Telex No. GTT-1259 (06/27/77) responded to the site Telex No. TWX-762 and requested that the contractor be asked not to take any action that would preclude adding reinforcing steel in the concrete placement above the one where the rebar was omitted.

Gibbs & Hill (New York) followed-up on the subject on July 6, 1977, via letter GTN-19823 to TUGCO which stated that their analysis indicates the omitted rebars do not jeopardize the I structural integrity of the reactor primary shield structure j under any postulated loading condition. The letter also referenced the previously mentioned G&H Telev No. GTT-1259 and 4

reaffirmed the suggestion that stress distributing rebar be included in the next lift above 819-foot, 1/2-inch elevation.

2

The letter noted that this action would serve two purposes, neither of which is related to public safety. First, it would provide partial compensation for the rebar which was omitted below and, second, it would minimize the overall area subject to possible cracking. The letter stated that drilling into the existing concrete would not be required. Upon receipt of this information from Gibbs & Hill, Applicants believed any potential problems relating to the omission of reinforced steel in the reactor cavity had been adequately resolved.

On 09/18/84, the NRC letter to TUGCO confirmed the TRT's finding in regard to rebar in the reactor cavity. Subsequently, the CPRT was formed and ISAP II.a (Reinforcing Steel in the Reactor Cavity) was issued to address the TRT concern regarding an analysis to support the Gibbs & Hill conclusion verifying the adequacy of the reinforcing steel as installed. The Results Report for ISAP II.a was published on November 9, 1987.

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Rebar in the Fuel Handling Building 1

. ISAP II.e History 1 Concerns regarding unauthorized cutting of rebar in the Fuel Handling Building were identified by the NRC in SSER-8, page K-89 as follows:

"Allegation AC-15 identifies a specific instance of the possible unauthorized cutting of rebar. In this case, a former Brown & Root employee stated he possibly drilled holes through rebar in a concrete floor without a component modification card (CMC) or a design change authorization (DCA). He explained that in January 1983 he drilled approximately 10 holes about 9 inches deep while installing 22 metal plates with a core drill. He said the metal plates were used to secure the trolley process aisle rails located on the 810-foot, 6-inch floor level in Room 252 of the Fuel Handling Building.

The TRT inspected the trolley process aisle rails and its anchoring system and observed no violations of projects drawings or specifications. The TRT reviewed the reinforcement drawings (2323-S-0800 and 2323-S-0820) for the Fuel Handling Building to determine the location of rebar. The drawing showed three layers of reinforcement in the upper part of the mat, which consisted of a No. 18 bar running in the east-west direction, in the first and third layers, and a No. 11 bar running in the north-south direction, in the second layer (See Figure 1).

The review of the reinforcement drawings (2323-s-0800 and 2323-S-0820) revealed that the layout of the east-west reinforcement and the trolley process aisle rails was such that only one bar of the east-west reinforcement could be cut by drilling holes for rail anchors. However, if 9-inch holes were drilled, both layers of the No. 18 reinforcing bar would be cut.

Design Change Authorization (DCA) No. 7401 was written for authorization to cut the uppermost No. 18 bar at only one rail, but it did not reference the authorization to cut the lowermost No. 18 bar. The DCA (No. 7041) also stated that the expansion bolts and baseplates could be moved in the east-west direction to avoid interference with the No. 11 reinforcement running in the north-south direction. The information described in DCA No. 7041 was substantiated by Gibbs i

1 I

and Hill calculations. The DCA approval was based on

. the understanding that only the uppermost No. 18 reinforcement would be cut. If the 10 holes were actually drilled 9 inches deep, then the allegation that reinforcement was cut without proper authorization may be valid."

Applicants believe that the history of this issue can be traced to NRC letter 50-445/83-27 to TUGCO (September 29, 1983).

In this letter, the NRC reported to TUGCO the results of their interview on September 1, 1983, with a Brown & Root millwright who alleged that he had cut rebar, without authorization, while installing trolley rails in the Fuel Handling Building. The NRC letter identified this issue as being an unsubstantiated allegation, therefore, no action was taken by TUGCO.

Nevertheless, the TRT letter of 09/18/84 to TUGCO identified a concern regarding cutting of the rebar and required that action be taken to ensure that if unauthorized cutting did take place, it would have no effect on the structural integrity of the Fuel Handling Building. Subsequently, the CPRT was formed and ISAP II.e (Rebar in the Fuel Handling Building) was issued to address the TRT concern regarding the cutting of rebar in the fuel handling building. On September 29, 1987, the Results Report for ISAP II.e was published.

s 2

i o Pipe Supports Inspections  ;

ISAP VII.b.3 History Issues regarding inspection of as-built safety-related pipe support installations were identified by the TRT in SSER-11, page 0-282 as follows:

"The TRT conducted a series of inspections encompassing as-built safety-related pipe support... installations.

These inspections were of completed systems or components that had been previously inspected and accepted by TUEC as meeting the respective construction and installation requirements.

o Pice Suecort Inscactions The TRT inspected 42 pipe supports in Unit 1, 37 of which were randomly selected while five originated from an alleger's list. Forty-six deviations were identified in the supports '

inspected. Tables 1 and 2 summarize the results of this TRT inspection effort.

The TRT also inspected 92 pipe supports in i

Room 77N of the Safeguards Building, Unit 1.

Table 3 sumniarizes the results of this TRT inspection effort, o Deficiencies With Hiah Rate of Occurrence The TRT identified six specific deviation types which need further evaluation to assess their generic implications. The six deviation types are listed in Table 3. The TRT concern is that these deviation types may

] have a high rate of occurrence throughout '

1 plant safety-related systems."

j The sequence of historical events regarding pipe support inspection issues related to as-built configurations started with the development of the applicable inspection programs. Procedure QI-AQP-11.1-28 Rev. O was issued on 09/08/80 to support the  !

1 I

beginning phases of ASME Class 1, 2 and 3 component support

, fabrication, installation and inspection. This procedure contained the basic criteria for inspection of all attributes regarding ASME component support installation and acceptance.

Included was a configuration check, material verification, weld acceptance and nondestructive examination, as applicable.

Based on requirements set forth in NRC 1E Bulletin No. 79-14, Rev. 1 to procedure CP-EI-4.5-1 (General Program for As-Built Verification) was issued on 04/27/81. This procedure was to establish methods for performance of As-Built Verification of all safety related piping 2-1/2 inches in diameter and greater, and to Seismic category 1 piping, regardless of size which was dynamically analyzed by computer. Included in this verification was support location and type. The intent of this procedure was to provide a vehicle for verification of stress analysis based on the As-Built configuration. It was not intended to be a reverification of previous inspections performed during construction and final acceptance of the included pipe supports.

Following the NRC Region IV Inspection 81-13, procedure QI-Qp-11.13-1 Rev. 1 (As-Built Piping Verification Instructions) was issued on 09/17/81. This procedura provided instructions to the Quality Assurance As-Built Coordinator for verification of stress problem packages per procedure CP-EI-4.5-1. The instructions also provided details on sway strut inspection.

On 10/22/81, procedure QI-QP-11.13-2 Rev. 0 (Installation Reinspection of Pipe Supports) was issued which committed CPSES 2

to a reinspection program for all class 1, 2, 3, and 5 pipe supports. Based on the issuance of this procedure, the NRC Region IV closed Inspection Report 81-13 while performing a routine inspection under Inspection Report IR-81-18. (01/25/82)

During the course of ASME pipe support fabrication and installation, the Authorized Nuclear Inspector (ANI) performed numerous audits on the CPSES ASME program to ensure compliance with all ASME requirements. On 10/14/82, SIS Report no. 314 was generated based on the ANI review of field assembly work which had been performed. Per this inspection, the ANI determined that the final review hanger packages being presented for his review and acceptance were deficient. They did not comply with NA-4540 of the ASME Code, the ANI stated, in that: "the status of material verification and visual examination of welds is indeterminate. The actual scope of rework performed is not defined or described by drawings, CMC, IRN or any other document within the package. Since all QC inspections are final there is not objective evidence available that the QC inspector was aware of the extent of examination and verification to be performed."

Brown & Root Interoffice Memo No. 35-1195, dated 11/20/82, was issued by the Procurement / Surveillance Supervisor to the Lead Authorized Inspector providing Brown & Root's response to SIS Report No. 314. This memo proposed that: (1) the construction operation required and the work scope will be listed on the Weld Data Card so that the ANI will have an understanding of the extent of work involved; (2) effective 12/1/83, the QC inspector 3

shall indicate the revision number of the drawing used for a hanger inspection; and (3) the Document Review Group (DRG) will assist the ANI in ascertaining the applicable revisions of the drawings used for past inspection. Subsequently, based on further review, SIS Report No. 314 was closed out by the ANI in SIS Report No. 314, Attachment 10 (acceptance dated 11/29/82).

Due largely to the multiple design reviews conducted on pipe supports, Engineering and QA determined that the most logical time for QA to evaluate the final acceptability of a pipe support, without a large probability of subsequent design change, was following the iterative design review process. As a result of a meeting held in January, 1983, Engineering and Quality Assurance implemented a Vender Certified / Design Reviewed Drawing (VCD/DRD) program through the issuance of Revision 4 to procedure CP-QAP-12.1 (Inspection Criteria and Documentation Requirements Prior to System N-5 Certification). The VCD/DRD program resulted in a support drawing into which all design changes had been incorporated. Additionally, Engineering would annotate the drawing to show changes which had been made to the design which they wanted reverified by QA.

Within a few weeks of implementing the QA VCD/DRD inspection however, it was identified that Engineering was increasing the size requirements of many welds as a result of final field analysis and that some existing welds had been ground by the paint department to obtain a satisfactory coating profile, which reduced the weld below the acceptable level. Due to the 4

determination that work being reviewed under the VCD/DRD program was still "in-process," previously accepted items were .. st considered finally accepted, hence this was not considered a reportable condition under 10 CFR 50.55(e).

As a result, the QA checklist contained in Revision 5 of CP-QAP-12.1 was revised in March, 1943, to reinspect all accessible welds, including those on supports previously accepted under the VCD/DRD program. Additionally, the VCD/DRD flow was revised to require construction to verify support acceptability prior to submitting the support to QA for final acceptance.

A construction appraisal inspection was performed by the NRC Region IV during the period of January 24 through Febr4ary 4, and February 14 through March 3, 1983, for the purpose of evaluating management control of construction activities and the quality at CPSES. On 04/11/83, based on NRC Region IV Construction Appraisal Team Inspection 50/445/83-18 and 50/446/83-12, potential Notice of Violations were issued to TUGCO inclusive of issues regarding pipe supports and their inspection.

In response to the construction Appraisal Team inspection, ,

i Section III.B.2, Interoffice Memos from the Brown & Root Site QA Manager to the TUGCO Site QA Manager were generated (05/02/83).

These memos related the Brown & Root Site QA Manager's position relative to the items of deficieng alleged to have been found by ,

the NRC. A follow-up inspectior. vas performed by the NRC Region

IV during the period of June, 27 through September 16, 1983, for i l the purpose of assess 3.g the "Potential Enforcement Findings" 5

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noted during ao Construction Appraisal Team's inspection as

. documented in NRC Inspectiori Report 83-18 and 83-12. In the area of pipe supports and their inspections, the B&R and TUGCO review l of the previously identified Construction Appraisal Team findings l included oiamssions with the ANI. The fact that none of the supports had been finally inspected per CP-QAP-12.1 indicated to B&R and TUGCO that the program was functioning as intended. This l

item was subsequently considered to be closed per NRC Region IV Inspection Report 83-28/83-14 dated October 3, 1983.

During the months of May and June, 1983, a special NRC inspection was conducted of the Fuel Building. During the course of this inspection several areas of concern were identified related to the inspection of pipe supports. The results of Region IV's inspection was documented on Inspection Report 83-23 dated 07/27/83. Notice of Violations were cited ln the area of  !

both large and small bore ASME supports. Deviations from the VCD were noted on the large bore supports. Further deviation from the final design documents for small bore supports was also 1

noted. An open item was also noted regarding completed Class 5 support traveler packages which did not contain the current drawings, inspection reports and CMC's. An interoffice memo from the Brown & Root Site QA Manager to the TUGCO Site QA Manager (08/23/83) was generated regarding corrective actions taken for ASME components cited in NRC Inspection Report 83-23. Also, TUGCO letter TXX-4031 was issued ;F. 08/24/83 to the NRC Region IV 6

O detailing actions taken on ASME large bore supports found to be in noncompliance during the NRC inspection documented per IR 83-23.

On 08/31/83, TMCO letter TXX-4037 was issued to NRC Region IV regarding the remainder of the items cited in the Notice of Violation associated with IR 83-23. In this response, TUGCO stated their conclusion that, per their estimate, there would have been no safety significance had these items gone undetected.

It was further stated that no improvements appeared necessary in the QA/QC program although minor changes to inspection procedures and checklists had been made based on the concerns noted in NRC IR 83-23. (Subsequently, based on inspections performed by NRC Region IV during the period of August - October 1984, NRC Inspection Report 84-34/84-13 (dated 12/31/84) reviewed and documented the closure of those violations regarding pipe supports as listed in IR 83-23.)

Trior to the closure of these issues, however, during the month of April, 1984, the NRC fielded a Special Review Team for the purpose of: evaluating current implementation of TUGCO's l

l management control of construction, inspection and test programs; l

gaining an indepth understanding and obtaining background information regarding CPSES; and further obtaining information necessary to establish a management plan for resolution of all outstanding regulatory actions. During the course of this review, issues concerning discrepancies found on completed vendor certified pipe supports were again identified. On 7

07/13/84, NRC Region IV issued these review findings to TUGCO and stated that the tanulta 44.5 identified a number of actions which were to be followed-up by the Technical Review Team which had been established pursuant to the management plan.

Additional NRC inspections were performed during the period of May - July 1984 which identified probisme in the pipa support area regarding as-built dimensions being out of tolerance. These findings were contained in NRC Region IV Inspection Report 84-22/84-07 dated 10/11/84. Also included was a Notico of Violation regarding several subjects inclusive of pipe support as-built configuration problems. In response to IR 34-22/84-07, l Interoffice Memo No. 27986 (11/07/84) was generated by the Brown & Root Site QA Manager to TUGCO QA relating their response to the finding of discrepant as-built dimensions (i.e, per support SI-1-071-002-532X) . The response conta!ned a history of drawing and procedural changes which had occurred relative to this particular support.

TUGCO letter TXX-4354 (11/09/84) was issued to ths NRC Region IV providing responses to the Notice of Violation issued with NAC IR 84-22/84-07. The response regarding the as-built dimension problems outlined the fact that one item (center line location of the I-beam) was causing the other aspects of the j basip) ate to be incorrectly identified as out of tolerance.

TU',,o further identified issuance of NCR-M-14557N which had been ri iewed by Engineering and accepted as is.

8

On 01/08/85, the NRC letter to TUGCO provided written notification of the concerns of the TRT regarding inspections performed on pipe supports. Following the formation of the CPRT, Issue Specific Action Plan (ISAP) VII.b.3 (Pipe Support Inspections) was issued to address the specified findings of the TRT in regard to inspections of pipe supports. The Results Report for ISAP VII.b.3 was published on January 18, 1988.

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UNITED STATFS OF AMERICA D0}gKE[C gi EO

NUCLEAR REGULATORY COMMISSION

'88 FEB 29 P3 :44 before t.ne ATOMIC SAFETY AND LICENSING BOARD OfflCE 0f HCETAA1 00CKEllHG A idiiV!Cf.

BRANCH

)

In the Matter of ) Docket Nos. 50-445-OL

) 50-446-OL TEXAS UTILITIES GENERATING )

COMPANY et al. )

) (Application for an (Comanche Peak Steam Electric ) Operating License)

Station, Units 1 and 2) )

)

CERTIFICATE OF SERVICE I, Thomas A. Schmutz, hereby certify that the foregoing Final Submittal of Chronologies was served this 29th day of February 1988, by mailing copies thereof (unless otherwise indicated),

first class mail, postage prepaid to:

L

• Peter B. Bloch, Esquire *B. Paul Cotter, Jr., ELg.

Chairman Chairman -

Atomic Safety and Licensing Atomic Safety and Licensing Board Board Panel -

U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555

• Alan S. Rosenthal, Esq. Assistant Director for l Chairman Inspection Programs l Atomic Safety and Licensing Comanche Peak Project Division i Appeal Panel U.S. Nuclear Regulatory

U.S. Nuclear Regulatory Commission Commission P.O. Box 1029 Washington, D.C. 20555 Granbury, TX 76048 l

• / Asterisk indicates service by har.d or overnight courier.

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• Juanita Ellis Robert D. Martin President ~, Case Regional Administrator, 1426 South Polk Street Region IV Dallas, TX 75224 U.S. Nuclear Regulatory '

Commission William R. Burchette, Esquire 611 Ryan Plaza Drive Heron, Burchette, Ruckert, Suite 1000

& Rothwell Arlington, Texas 76011 Suite 700~

1025 Thomas Jefferson St., N.W. *Dr. Kenneth A. McCollom Washington, D.C. 20007 Administrative Judge 1107 West Knapp

• William L. Clements Stillwater, Oklahoma 74075 Docketing & Service Branch U.S. Nuclear Regulatory Joseph Gallo, Esquire Commission Hopkins & Sutter Washington, D.C. 20555 Suite 1250 1050 Connecticut Avenue, N.W.

• Billie-Pirner Garde Washington, D.C. 20036 Governt.it Accountability Projec. *Janice E. Moore, Esquire Midwest CEfice Office of the General Counsel 104 E. Wisconsin Avenue - B U.S. Nuclear Regulatory Appleton, WI 54911-4897 Commission Washington, D.C. 20555 Renea Hicks, Esquire Assistant Attorney General

• Anthony Roisman, Esquire Environmental Protection 1401 New York Avanue, N.W.

Division Suite 600 Capitol Station Washington, D.C. 20005 P.O. Box 12548 Austin, Texas 78701 Lanny A. Sinkin Christic Institute Robert A. Jablon, Esquire 1324 North Capitol Street Spiegel & McDiarmid Washington, D.C. 20002 1350 New York Avenue, N.W.

Washington, D.C. 20005-4798 Nancy Williams CYGNA Energy Services, Inc.

• Elizabeth B. Johnson 2121 N. California Blvd.

Oak Ridge National Laboratory Suite 390 P.O. Box X Building 3500 Walnut Creek, CA 94596 Oak Ridge, Tennessee 37330 David R. Pigott

• Dr. Walter H. Jordan Orrick, Herrington & Sutcliffe 881 Nest Outer Drive 600 Montgomery Street Oak Rioge, Tennessee 37830 San Francisco, CA 94111 i

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• Fobert~A. Mooldridge, Esquire Worsham, Forsythe, Sampels

& Wooldridge

'2001 Bryan Tower, Suite 3200 Dallas, Texas 75201

• W. G. Counsil Executive Vice President Texas Utilities Electric -

General Division 400 N. Olive, L.B. 81 Dallas, Texas 75201 ,

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YAI Thomas A. Schmutz pr Dated: February 29, 1988

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