ML20006A410

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Forwards Case 900117 Response to Util Analysis of Scaling Calculations.Intervenor Concerned Re Generic Implications of QA Programmatic Breakdown in Util Scaling Calculation Process for Station Svc Water & Auxiliary Feedwater Sys
ML20006A410
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 01/19/1990
From: Ellis J
Citizens Association for Sound Energy
To: Charemagne Grimes
Office of Nuclear Reactor Regulation
References
NUDOCS 9001260231
Download: ML20006A410 (42)
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i (CITIZENS ASSN. FOR SOUND ENERGY) .

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January 19, 1990 i

Mr . Christ opher 1. Grimes Director  !

! Comanche Peak Proj ect Da va sion .

Office of Nuclear Reector Regulation

U. S. Nuclear Regulat ory Commis sion b Washington, D. C. 20$$$

i Dear Mr. Grimesi Subj ont : Texas Utilities Electrae Conopony, et al., I (Comanche Peak St earn Electric St ation, '

Unit s 1 and 2). Docket Nos. 50-445/50-446 Peoponse to TU Electric Letter to NRC's Christopher I. Grimes. Regarding the CASE [

Documented Reques t f or Action --  ;

Scalsno Calculationd ,

We are enclosing the CASE Monitors' January 17 1990. Response to TU Electric Letter to NRC's Christcpher I Grimes, for your consideration  ;

regard 2ng the CASE Documented Request f or Action -- Scaling Calculations .

Copies _also are being sent today to TU Electric. {

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-If you need any additional inf ormation, please let us know. j Si nc e r el y ,

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CASE (Citizens Association for Sound Energy) '

022 2 - lAr i s.)'JuanitaEklis Pr e s ident ect Mr. Dennis Crutc hfield , As sistant Director of Special Projects. NRC Mr . R . G. War nic k , As si s t ant Dir ector f or Inspection Program. Comanc he i Peak Project DAYasion, NRC .

Mr . William Counsil . Vice Chairman, TU Electric Mr. W. J . Cahill , Jr . , Executive Vice President , TU Electric Dr . Aus af liusain, Chairrnan, Operations Review Committee (ORC). TU l: Electric .

l Mr. George L. Edgar Esq . Newman & Holtzinger, P. C.

Ms. Sus an Paltner . Stipulation Manager, TU Electric V

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t January 19, 1990 Mr. William Counial i Vice Chairman l TU Electric 2001 Bryan Tower, Suit e 1900 Dallas, Texas 15201 {

Dear Mr . Couns11:

l Subj ect : Texas Utalities Electric Company, et al.,

(Comanche Peak Steam Electric Station.

Unit s 1 and 2), Docket Nos, 50-445/50-446 Response to TU Electric Letter to NRC's Christopher I . Grimes , Regarding the CASE .

Documented Request f or Action --

Scaline Calculations.

As we discussed this morning at the CASE /TU management meeting, we are ,

enclosing the CASE Monitors January 17, 1990 Response to TU Electric (

Letter to NRC's Christopher I,, Grimes , Regarding the CASE Documented Request *

. f or Action -- Scaling Calculat1ons ,  :

,1 If you have any questions or need additional inf ormation, please let us know. .

Si nc e r ely , i CASE (Citizens Association f or Sound Energy) u2 _ ka A1.

k s .) Juanita Ellis i President .

cc Mr . Dennas Crutchfield Assa stant Director of Special Proj ects , NRC

-Mr . Christopher I . Grames , Direct or Comanche Peak Pr oj ect Di vi s i on.

Office of Nuclear Reactor Regulation, NRC Mr . R. G . War nic k, As sis t ant Director for Inspect 1on Program, Comanche i.

J Peak Pr oj ect Division, NRC l

Dr. Ausaf Husain, Chairman, Operations Review Committee (ORC), TU ,

Electric Mr. W. J . Cahill, Jr . , Executive Vice Pr esident , TU Electric Mr. George L. Edgar, Esq. , Newman & Holtzinger . P. C.

Ms. Susan Palmer , Stipulation Manager , TU Elect rac 1

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TROM: Owen L. Thero, CASE Consultant (

70: Mr s . Juanit a Ellis , CASE Pr esident DATE: January 17 1990

SUBJECT:

Response to TU Electric Lett er to NRC, Mr . Christopher I Grimes ,

I' Regarding the CASE Documented Request f or Action - Scaling Calculations i r

f REi TU Electric Log #TXX-89850, dated December 21, 1989 {

This memorandum on behalf of the three CASE Monitors as in response to .

the s ubj ec t TU Electric analysis of the CASE Monitors Draft Report i submittal to TU Electric of December 6,1989 regarding the scaling calculation and documentation review concerns originally adsntified to CPSES ,

by Mr . Gary Bodif ord in 1986-1987. Also included are those concerns identified during the monit oring involve ment of TU Electric activities since May 1989 (by CASE and Mr. Bodaf ord), which was an ef f ort designed to resolve hi s c onc er ns . As a point of reference, at should be noted that Mr.

Bodif ord's original aggregat e c onc er ns wer e subs tant a st ed as' cur r ent' existing problems , as evidenced in the results of the TAP audit . ATP 146S, and the results of the CECO /TU Electric technical interf ace meetings (see TU Electric " Action Plan *).

At - t his point in time , at is the position of the CASE Monitors that to respond to each item addressed by TU Electric in Attachment 1 of TXX-89850 would serve no beneficial purpose, since the assues are now before the Nuclear Regulatory Conma s sion (NRC) f or res olution. However , s ome c omment s -

and observations are appropriate and necessary f or clarification.

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In summary, the responses provided under the 'TU Electric Additional I ' Comment s

  • c olumn d o not address the f acts. In all cases , an a straightf orward manner , confuse the assues by speaking an generelttaes rather than to the specific concern, and these solutions to *1solated i f

problems" are too narrowly f ocused f or CPSES to properly address the pr ogr ammatic is s ues .

In response to a epecific revision of the initial TU Electric response TXX-89850 to the CASE Draf t Report (contained in TU Electric Letter , Log 87XX-90009, dated Januar y 5,1990, CASE It em 1.10), CASE recognizes s ome ponitive statements (although not without qualifiers) utilized by TU Electric in resolving Mr. Bodif ord's concerns as sociat ed with the NCB1/NCB11 and NCH circuit cards. Had TU Electrac's initial responses to all of Mr .

Bodif ord's concerns utilized a samtlarly positive approach, it would not i

have been necessary to raise these matters to the level of a dispute. The TU Electric revised response stated, in part (pages 5 and 6 of 11):

'TU ELECTRIC WISHES TO EMPHASIZE THAT IT DOES NOT CONTEND THAT ITS ACTIONS ADDRESSING SCALING CALCULATIONS WERE, IN ALL CASES. EFFECTIVE. ENCLOSURE 2. PAGES 3, 4, & 5, INDICATES THAT THERE WERE ACTIONS THAT WERE NOT PROPERLY TRACKED TO I CLOSURE BY SWEC IN RESPONSE TO TU ELECTRIC *S MAY 10, 1988 '

MEMORANDUM DIRECTING ACTIONS ON SCALING CALCULATIONS, fURTHER, HAD MR. BODIFORD NOT RAISED HIS CONCERNS AND TU ELECTRIC INITI ATED THE TAP AUDIT, THE INTERCHANGES OF NCB1 '

AND NCB11 PRINTED CIRCUIT CARDS AND THE USE OF NCH CIRCUIT CARDS MIGHT NOT HAVE BEEN IDENTIFIED FOR CORRECTION. A CAR WAS INITI ATED TOR bOTH INSTANCES. THE CAR INVESTIGATION '

RESULTS ARE NOW AVAILABLE FOR BOTH SUBJECTS, AND IN NEITHER 0F THESE CASES DID THE IDENTIFIED CONDITIONS RFSULT IN A ',

l TAILURE TO PERFORM AN INTENDED SATETY FUNCTION, TAP WILL CONFIRM THAT THE RESPONSE TO THE CAR SATISFACTORILY ADDRESSED BOTH THE SPECIFIC AND PROGRAMMATIC ISSUES IDENTIFIED IN THE CAR.

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  • WITH RESPECT TO NCH CARDS. CECO ENGINEERING REQUESTED ADDITIONAL SEISMIC ERROR DATA FROM WESTINGHOUSF,. UPON RECEIPT OF THIS DATA. CECO ENGINEERING EVALUATED ITS IMPACT ON THE SETPOINT AND LOOP ACCURACY CALCULATIONS. THIS DATA L WAS INCORPORATED INTO THE CALCULATIONS AND FOUND TO BE WITHIN THE ACCEPTABLE MARGIN ALLOWABLE IN THE CALCULATIONS. FOR MOST CASES. THE RESULTS OF FOUR CALCULATIONS WERE FOUND TO BE OUTSIDE THE ALLOWABLE MARGIN ASSOCIATED WITH THE ORIGINAL CALCULATIONS. THESE CALCULATIONS WERE REVISED TO BE CONSISTENT WITH THE NEW SEISMIC ERROR DATA. AND NEW SETPOINTS WERE ISSUED. EVALUATION OF THESE MINOR ADJUSTMENTS IN SETPOINTS IDENTIFIED NO SAFETY CONCERNS. THE ENVIRONMENTAL QUALIFICATION GROUP WAS PROVIDED THE NEW SEISMIC ERROR DATA FOR INCORPORATION INTO THE APPLICABLE QUALIFICATION REPORTS.

THERE ARE NO REMAINING CPEN ITEMS ASSOCI ATED WITH THIS ISSUE.

WITH RECARD TO THE NCB1/NCB11 CARDS. CECO ENGINEERING REQUESTED OPERATIONS TO IDf;,NTIFY THE CURRENT AS-BUILT LOCATION OF NCB1/NCB11 CARDS. AFTER REVIEWING THIS DATA.

CECO ENGINEERING ISSUED A DCA TO REVISE APPLICABLE DRAWINGS 70 REFLECT THE AS-BUILT CONFIGURATION. TO ADDRESS THE ISSUE OF FUTURE DOCUMENTATION CONTROL FOR THESE CARDS. IT WAS DETERMINED THAT APPLICABLE DESIGN DOCUMENTS AND DRAWIN_GS SHOULD BE REVISED TO ALLON UTILIZATION OF EITHER CARD AND TO IDENTIFY ANY LIMITATION / RESTRICTIONS ON THE USE OF THESE CARDS. . .

(Emphases added.)

While the CASE Monitors agree with the actions taken by 70 Electric to resolve the technical issues associated with the circuit cards and the supporting engineering definition documentation. at as not clear to the CASE Monsters that the QA programmatic breakdown, which allowed those technical concerns to exist since Mr , Bodif ord first identified them in 1986, will receive the same level of eff ort to prevent recur r ence of _ its generic implic ati ons .

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The position of the CASE Monitors an the Draf t Report cubnd t t ed December 6,1989 f urther emphasized in the Final Report (1/ (yet to be r eleased) and this memorandum, as that TU Electric was f or a number of years in noncompliance with the requiremente mandated by 10 CTR Part 50 Appendix B, which r esult ed in a deficient , unauditable scaling calculation and documentation review program at CPSES.

TU Electric and its supplier , Stone & Webster Engineering Corporation (SWEC), did not properly and thoroughly investigate and subsequently resolve 1

the concerns adentified by Mr. Bodif ord, who first came to them as a concer ned employee. This inaction allowed those concerns to remain, in excess of two (2) years , even though TU Electric directed SWEC to implement corrective action over a year and a half ago (NE-19097).

With f ew exceptione , the CASE Monit ors

  • Draft submittal appears to have been unpersuasive to TU Electric . This becomes visable on page 1 of the ref erenced TU Electric letter which states , in part: I

. . . [T]hus. TU Electrac's ref erences to the overall portions of its previous documents supporting each such paragraph were considered suflacient to document TU Electric's position, which was not chanced by any of CASE's aroument s ." (Emphasis added.)

' This response addresses each of the f ollowing sections presented by TU Electric, where appropriate. The respons e clarifies t he CASE Monitor s '

position on atoms that are incorrectly presented by TU Electric.

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(1/ Inf ormation provided in the Final Report is essentially the same as document ed in the Draf t . Additional insight and clarification has been  !

i provided, as well as correlation to the issues documented in the Atomic  !

Saf ety and Licensing Board's Memoranda and Orders of December 28, 1983, i and February 8, 1984.  ;

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1. TU Electric's Report Heading:
  • TU Electric's Action Plan Relatino t o Seals no Calculations is Adecuato.*

CASE Nonit or s ' R e s pons e :

Our evaluation of the *TU Electric Action Plan

  • only dealt with .

the specific items included an the TU Electric submittal. The

" dispute" as specifically documented an detail on the 203 pages preceding Att achment 2 of the draf t submittal. The TU Electric' Action Plan is a very f ocused document , dealing only wa th the mechanics of r.

developing scaling calculattons stemming f rom a controlled scaling calculation and documentation review program, and does not deal with 1-the CPSES QA programmatic breakdowns profiled by the CASE Nonators or the deficiencies / observations recorded by the TU Electric TAP auditors in ATP-89-146S.

The 'TU Electric Action Plan

  • was initially developed in response I

to a meeting between the CASE Nonitors and TU Electrie/ CECO personnel approximat ely one-third into the conduc t of TAP Audit ATP-89-1463.

Tha s

  • Action Plan
  • was a ndependent- of t he TAP Audit end did not reflect any preliminary findings. of the TAP Auditors at that point an the ,

4 perf ormance of the TAP audst. As stated above, the TU Electric I

  • Action Plan
  • resulted f rom technical discussions between TU

. Electric / CECO / CASE personnel dealing with the maj or scaling calculation controlling documents and Westinghouse documentation used as the design i-

.e basis. The TU Electric

  • Action Plan
  • has developed into a total
  • action plan
  • encompassing the TAP ATP-89-146S audit results, and a 5

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plan that CASE has on . numerous occasions recommended and requested that TU Electric control by a f ormal Corrective Action Request (CAR).

Following is f urther explanation of the genesis of the '" Action

' Plan" and the events immediately f ollowing receipt of the plan by CASE. i f=

-1) The original " Action Plan" received by CASE was not dated or +

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signed. It was the understanding r,f the CASE Monitors that this plan was a response to the technical meetings held with

.TU Electric management and CECO technical staff personnel, i

This " Action Plan" was not understood by the CASE Monitors to ~ ,

present the TU Electric approach in resolving Mr-. Bodiford*s

< gate concerns, but rather that it was , in f act , follow-

= ution to .the May 10, 1988, memorandum NE-19097 direction s

  • .esolve certain of Mr . Bodif ord's concerns , coupled with

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-ne results of the technical meetings .

2) Af ter the CASE Monitors acknowledged general concurrence with

-i the TU Electric basic '" Action Plan " the CASE Monitors concluded their assessment of the overall lack of the CPSES Proj ect's QA compliance with 10 CTR Part 50. Appendix B, and requested that the TU Electric Director of -Quality

" - Assurance issue a Stop Work Order (SWO) that would require

"- the issuance of a f ormal Corrective Action Request (CAR) to verifiably track the resolution of the issues to a lasting i'

corrective action.

3) The TU Electric Director of Quality Assurance declined to issue a Stop Work Order based on his evaluation of the 6

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conditions and r equirements , and t o dat e , t o the bes t knowledge of the CASE Monitors , has not issued a CAR 4ealing

- with the overall . specific and programmatic issues requiring  !

correction. The CASE Nonitors have repeatedly stated their i view-that TU Electric, by its lack of action in not issuing _;

a SWO and subsequent CAR, is in noncompliance with essential elements'of its own Quality Assurance program and is consequently in noncompliance with critical f acets of 10 CFR- q Part 50, Appendix B (e.g., Crateria II, XVI), and 10 CFR 50.55(o).

Therefore, it remains the CASE Monitors' position that a Stop Work Order (SWO) and a Corrective Action Request (CAR) were required under the 1

pr ovisions of NEO Procedure 3.25, and are necessary in order to verifiably. [

track and correct the CPSES QA programmatic breakdowns encountered with the scaling calculations and documentation review ef f ort c onc er ns identified by L s

Mr . Bodif ord and CASE, and that potential adverse generic implications, also-identified by the CASE Nonitors in the " Documented Request for Action -

Scaling Calculations ." mus t be evaluated and resolved in a verifiable manner .

2. TU' Electric's Report Meadina:

"TU Electric's Safety-Related Calculations are Technically Adequate "

i TU Electric's Statement (in part ):

a) " CASE attempts to avoid this f act by arguing that the real 'end product' is the safety-related calculations, and not the field conditions (see e.g., CASE Report, Page 3 Paragraph 2 page 174).

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from this CASE evidently inf ers that the existance of deficiencies an' the documentation underivina the calculations necessarily means that the end product (the calculation) is deficient." (Emphasis

  • added.)

CASE Monit ors' Res pons e s a), ' Per the CASE Monitors' compilation of the statistics . TAP Audit ATP-89-146S'alone (not including the technical meeting results) recorded sixty-six (66) deficient ins t anc e s r esulting f rom twenty-one (21) questions investigated pertaining only t o the five -

. (5) safety-related calculations audited, not the underlying documentation /2/.

The CASE Monitors did not need to *inf er ,* as TU Electric has stated, that the calculations were " deficient

  • TU Electric itself document ed t hi s f ac t . The CASE Monitors did not take issue with 3 actual " field conditions," either bef ore or subsequent to the TAP audit ATP-89-146S. It is the CASE Monitors' understanding that the combined purpose of the t echnical int erchange meetings and TAP -

L audit reviews was to investigate Mr. Bod 1f ord's and. CASE's safety-related and Balance of Plant (BOP) non-saf ety-r elat ed concerns dealing strictly with the technical concerns and the lack of programmatic controls involving the scaling calculation and documentation r eview ef f ort being conducted by SWEC at the CPSES facility. The TAP audit questions listed below were to assure L2/ See listing which f ollows of the specific TAP audit ATP-89-146S questions asked and subs equent audit deficiencies recorded. It should be noted that if one (1) question reported five (5) examples of ,

deficient conditions, the CASE Monitors counted that as five (5) deficiencies, not one (1) deficiency.

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" technical" adequacy of the calculations : therefore, the deficiencies recorded in the -TAP audit also af f ected the technical

,g compliance aspects of each scaling calculation. Additionally, the ,

technical questions asked by the TAP auditors . with the resultant  ;

' deficiencies identified refutes the TU Electric position that the e

scaling calculations are " technically. adequate.'

1) Scalina Calculation 1-SC-34-19 TAP Audit ATP-89-146S Ouestioni

'4a) Verif y accuracy of data transf er from specification sheets ,

drawings, scaling appendices, setpoint calculations, and the Standard Ref erence Documents in Section 2.0 of the Scaling.

' Calculation Manual to the scaling calculations .'

TAP Audit Deficiency No.89-146S-02

" Contrary to the above, design activities are not prescribed in-eufficient . written detail to define. the relationship of the -;

LE .various source or ref erence' documents utilized in the production of scaling calculations. Specifically, there is no single l document which provides an overall " road map' for the preparation of scaling calculations 'which addresses input data sources, equipment. ref erence manuals and calculation content 'and methodology. .Neither DBD-EE-032, ~ Scaling Calculation Manual (SC-

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-8800) .nor any of several other ref erences provide the required overall' procedural definition or guidelines f or this activity."

TAP Audit ATP-89-146S Question:

"de) Verify that all premisos utilized in the scaling calculations are supported by appropriate reference documentation."

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_1) Scalino celculation 1-SC-34-19 (continued) l

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' TAP A'udit Defielency No.89-146S-01: 4 4

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" Contrary to the above, most of the scaling calculations reviewed exhibited one or more of the f ollowing deficient conditions (In many cases recourse to the preparer was required to understand the  !

calculations):

  • 1. Section 3 of the calculations contains ref er enc e t o ' Standard '

Reference Documents' in Section 2.0 of the Scaling Calculation -

Manual (1-SC-8800): however , Section 2.0 -contains 29 documents,

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not all of which are applicable to any one calculation.

Additionally, these references do not contain revision levels or dates, yet specific inf ormation contained-in these documents (e.g., gain, bias values, etc.) was used in the calculations.

"2. The body of the calculations does not contain specific input f reference sources (e.g., document number, revision number, )

. titles, issue date, section, page, etc.) f or : module gain, bias, and input voltage s j umpers required or removed: or resistors required.

' "3, Input reference sources are not stated for module equations or transf er f unctions utilized.

, "4. Explanatory notes are not provided f or mathematical -

manipulations perf ormed. nor are -the manipulations shown.

"S. Sect 1on 6 of the calculations contains the statement 'For Loop Accuracies, see Scaling Calculation Manual. Appendix H (1-SC-8800-H, Rev. 1)* i however , Appendix H only provides guidelines for determination of loop accuracy values rather than providing actual loop accuracy values themselves. (A similar statement is made in Proj ect Procedur e PP-009, At t ac hment B, page 7, Paragraph E.)

"6. Figure 1 of the calculations does not contain a ref er ence f or.

the source (e.g.. Westinghouse Process Control Block Diagram, etc.) of the loop c onfiguration. "

k TAP Audit ATP-89-146S Question:

"5b) For cards in the i ns t rument loop. verif y type. group number, tag number. inputs, outputs, bench calibration accuracy.

Jumpers required, resistors, etc."

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1)' Scalina Calculation 1-SC-34-19 (continued)

TAP Audit Deficione y No.89-146S-03 t

i "19. Calculations 1-SC-37-18 and 1-SC-34-19 did not identify the jumper patterns required to implement the binary timer range i code. Als o~, the charact er s 1000 and 0000 were not identified- ,

as binary codes ."

TAP Audit Defici ency No .89-146S-04 i

" Contrary to the above, Scaling Calculations 1-SC-37-18 and 1-SC  ;

19 did not specif y the type of timer module required (Westinghouse produces f our timer modules , none of which are directly

-i nt e r c hang e able . )"

TAP Audit Def i c i enc y No.89-146S-09 "1. Contrary to the above requirement, PROMS are not ' consistently identified within the design document set. For example:

"- Scaling Calculation 1-SC-38-18. Rev. 4, page 9 adentifies t the instrument tag number and the respective NPL card locations but does not reference the PROM Library nor identif y which PROM is to be used in which PROM location.

The PROM Library drawing 8358A95 ref erences the instrument tag number for only 4 of the 10 PROMS in this set of i drawings.

"- IWD 8815D31, Sheet 41 Rev. 7 provides the instrument tag number but'does not include the PROM Library drawing 1 number. Other_IWDs appropriately list both the tag number and library drawing number for other PROM-related NPL cards.

"2. Contrary to the above, t her e is no PROM-specific procedure t- which describes the controls to be used f or programming PROMS ,  ;

for verification of PROM programs, and f or physical 1 identification of programmed PROMS. The procedure should address the application of all types of Westinghouse 7300 series PROMS at CPSES."

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2) Scalino Calculation 1-SC-37-18 TAP Audit ATP-89-146S Ouestion
  • 4a) Verif y accuracy of data transf er f rom specification sheets .

. drawings, scaling appendices , setpoint calculations, and the Standard Ref erence Document s in Section 2,0 of the Sc aling

-Calculations Manual to the scaling calculation "

TAP Audit Deficiency No.89-146S-02

' Contrary to the above, design activities are not prescribed in

. suf ficient written detail to define the relationship of the various source or ref erence documents utilized in the production of scaling calculations. Specifically, there is no single document which provides an overall ' road map' for the preparation-of scaling calculations which addresses input data sources, equipment reference manuals and calculation content and methodology. Neither DBD-EE-032, Scaling Calculation Manual (SC-8800) nor any of several other r ef er enc es provide the required overall procedural definition or guidelines . f or t his activity. '

TAP Audit Deficiency No.89-146S-06

" Contrary t o the above , Westinghouse Interconnection Wiring Diagram 8815D36. Sheets 2 and 3 were not _ updated to incorporate the

' Approved-Except-as-Noted' (AEN) annotations as required by Deficiency Report C-87-05180."

TAP Audit ATP-89-146S Ouestion "4b) Verif y that the latest inf ormation (as of the calculation sign off date), including Design Change Authorizations (DCAs) was utilized in the preparation of the scaling calculations ."

TAP Audit Def i c i e nc y No.89-146S-05

  • 1. DCA-88869 Rev. 1 failed on pages 10, 11, and 16 to properly reflect the required timer circuit. The DCA calls f or a Time-Delay-Drop-Out logic, . Additional logic elements required to implement the f unction described in the DCA were not included in the Circuit development.

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2)' Scal'ina Calculation 1-SC-37-18 (continued _1 "2. DCA-88869. Rev. 1 f ailed to identif y Drawing 835BA95. Sheets 11-and 12 as the PROM program on the Interconnection Wiring

  • Di agr ams . "

NOTE: The CASE Monitors reviewed Revision 0 of DCA 88869 (not  !

Rev. 1) and brought the deficient condition to the "

attention of CECO personnel in one of the technical interchange meetings expressly called to discuss the DCA and its fix.

TAP-Audit ATP-89-146S Question "4c) Verify.that all prendees utilized in the scaling calculations are supported by appropriate reference documentation.'

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? TAP Audit De f ic i e nc y No.89-146S-01

" Contrary to the above, most of the scaling calculations reviewed ,

axhibited one : or more of the f ollowing deficient conditions (In many

. cases recourse to the preparer was required to understand the calculations):

"1. Sect.t cin 3 of the calculations c ontains ref er ence to ' Standard Ref er enc e Document s ' in Section 2.0 of the Scaling Calculation Manual (1-SC-8800): however, Section 2.0 contains 29 documents ,

not all of which are applicable to any one calculation.

Additionally, these ref erences do not contain revision levels or dates, yet specific inf ormation contained in these documents (e.g., gain, bias. Values, etc.) was used in the calculations .  ;

  • 2. The body of the calculations does not contain specific input reference sources (e.g., document number, revision number,

,' titles. issue date, section. page, etc .) f or : module gain, bias, and input voltage jumpers required or removed; or resistors required.

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  • 3. I nput reference sources are not stated f or module equations or transfer functions utilized.

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2) Scalina Calculation 1-SC-37-18 (continued)

"4. Explanatory notes are not provided f or mathematical 4

' manipulations perf ormed nor are the manipulations shown.  !

~ "5. Section 6 of the calculations contains the statement "For ,

Loop Accuracies, see Scaling Calculation Manual Appendix H (1-  ;

SC-8800-H, Rev. 1)* i however Appendix H only provides .

guidelines f or determination af loop accuracy values rather' ,

than providing actual loop accuracy values themselves. (A similar statement is made in Proj ect Procedure PP-009, At t ac hment B, page 7. Paragraph E.) 't "6. Figure 1 of the calculations does not contain a ref erence f or the source (e.g., Westinghouse Process Control Block Diagram,.

etc . ) of the loop configur ation. " -i

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. TAP Audit ATP-89-146S Ouestion i

'5b) For cards in the instrument loop, verif y type. group number, .

tag number, inputs, outputs , bench calibration accuracy,'

jumpers required resistors required, etc."

TAP Audit De f i c i e nc y No.89-146S-03 -

"19) Calculations 1-SC-37-18 and 1-SC-34-19 did not identif y the jumper patterns required to implement the binary timer range code. Also, the characters .1000 and 000 were not identified as binar y c odes . "

TAP Audit ATP-89-146S Ouestion "5d) For signal comparators verif y type, tag number, inputs, setpoint value and reference source, s et point voltage, reset voltage, resistors r equir ed , j umper s , etc."

TAP Audit Def i c i enc y No.89-146S-04

" Contrary to the above. Scaling Calculations 1-SC-37-18 and 1-SC 19 did not specif y the type of timer module r equired (Wes tinghouse L produces f our timer modules, none of which are directly interchangeable)."

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2) . Scalina Calculation 1-SC-37-18 (continued)

' TAP Audit Deficiency No .89-146S-09

" l '. Contrary to the above requirement, PROMS are not consistently sc identified within the design document set. For examples

"- Scaling Calculation 1-SC-38-18 Rey, 4 .page 9 adentifies the tag number and the respective NPL card locations but

( does not ref erence the PROM Library nor adentif y which PROM is ' to be used in which PROM location.

"- The- PROM Library drawing 8358A95 ref erences the instrument tag number f or only 4 of the 10 PROMS in this set of drawings,

" - IWD 8815D31, Sheet.41 Rev. 7 provides the instrument tag number but does not include the PROM Library drawing .

number. .0ther IWDs appropriately list both the tag number and library drawing number f or other PROM-related NPL cards, >

s "2. Contrary to the above, there as no PROM-specific procedure which describes the controls t o ' be us ed f or programming th0Ms.

for verification ef PROM programs, and f or physical.

identification of. programmed PROMS. The procedure should address the application of all types of Westinghouse 7300

> > series PROMS at CPSES."

3. Scalino Calculation 1-SC-55-04 i

l' TAP Audit ATP-89-146S Question:

l' "4a) Verif y accuracy of data transf er f rom specification sheets ,

drawings, scaling appendices, s e t poi nt c alc ule t i ons , and the ,

Standard Ref erence Documents in Section 2.0 of the Scaling

.. Calculation' Manual to the scaling calculations ."

4

' TAP Audit Def i c i e nc y No.89-146S-02

, " Contrary to the abovw, design activities are not prescribed in suf ficient w.itten detail to define the relationship of the various source or ref erence documents utilized in the productions of scaling calculat i ons . Specifically, there is no single document whic h provides an overall ' road map' f or the preparation of scaling ,

calculations which addresses input data sources, equipment reference 15

=). . .- - . _ _ . - _ _ _ . _ _

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3 '. Scalina Calculation 1-SC-55-04 (continued)

TAP Audit De f i c i e nc y No. 89-1463-02 (continued)

. manuals and calculation content and methodology. Neither DBD-EE-032, Scaling Calculation Manual (SC-8800) nor any of several ot her ref erences ' provide the required overall procedural definition or guidelines f or this ac tivit y. "

TAP Audit ATP-89-146S Ouestion- 1 "4c) Verif y that 'all premises utilized in the scaling calculations are supported by appropriate reference documentation."

' TAP Audit De f i c i e nc y No.89-146S-01 ,

" Contrary to the above, most of the scaling calculations reviewed exhibited one or more of: the f ollowing deficient conditions (In many ,

cases ' recourse to the preparer was required to understand the ,'

calculations):

l-b "1. Section 3 .of the calculations . contains ref er ence to ' Standard Ref er enc e Documents' in Section 2.0 of the Scaling Calculation -

Manual (1-SC-8000); however, Section 2.0 contains 29 documents, not all of which are applicable to any one calculation.

Additionally, these ref erences do not contain revision levels i or dates, yet specific inf ormation contained in' these~ documents (

(e.g., gain, bias values, etc . ) ' was used in the calculations . ,

"2. The body of the calculations.does not contain specific input reference sources (e.g., document number, r evision number ,

titles, 1ssue date, section, page, etc) f or: . module gain, bias, and input voltages jumpers required or removedi or resistors required.

"3. Input r ef e r enc e sources are-not stated f or module equations or

' transf er f unctions utilized.  !

"4. Explanatory notes are not provided f or mathematical manipulations perf ormed nor are the manipulations shown.

"5. Section 6 of the calculations contains the statement "For Loop Accuracies, see Scaling Calculation Manual Appendix H (1- ,

SC-8800-H, Rev.1)' s however , Appendix H only provides guidelines f or determination of loop accuracy values rather 16 i

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than providing actual loop accuracy values themselves . (A =!

similar st at ement is made in Proj ect Procedure PP-009 At t ac hment B, page 7 Paragraph E.) i "6. Figure 1 of the calculations does not contain a ref erence f or

-source ( e .. g . , Wes tinghous e . ?r cc es s Control Bloc k Diagr am, etc.)

of ?he loop configuration. '

up 4. Scalina Calculation 1-SC-55-52 TAP Audit ATP-89-146S Ouestion "Ic ) 'If ' ' Confirmation Requir ed

  • has Lbeen removed in this revision, O obtain previous rovision and review technical j ustification f or c onfirmation r equir ed it ems . "  !

TAP: Audit Deficiency No.89-146S-03

[ ..

" Contrary to the above, the calculation preparation and review pr oces s, f ailed t o identif y .the f ollowing errors , omissions , and ,

inconsistencies which were identified during the audit 1 of scaling j- -calculations:

"2)- Calculation 1-SC-55-52 confirmation item 2. states IWestinghouse Instrumentation Sheets f or Shop Order 320. 325,,

and 395. Revise to show current status.' ~

This note apparently ,

applies to confirmation item 6 which relates to the revision of l

-Section 2 of the Scaling Calculation Manual."

e TAP Audit ATP-89-146S Ouestion "3a) All' devices, cards, power supplies, indicator numbers, etc..

agree with Specification Sheets. Int erconnection Wiring Diagrams (IWDs), and the Instrumentation and Control Diagrams (CDs)." i TAP Audit Def i c i e nc y No.89-146S-03 "1) Calculation 1-SC-55-52. Rev. 4 shows relay card NRC8 as 1-TS/411F, whereas the r ef er enc ed Wes tinghous e IWD 8810D31, i Sheet 6 shows t his devic e as TS/411E."

17

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4. - Sc aling Calculation 1-SC-55-52 (continued) 7 TAP Audit ATP-89-146S Question

'4a) Verify accuracy of data transf er f rom specification sheets ,

drawings, scaling appendices, s etpoint calculations ,- and the Standard Reference Documents in Section 2.0 of the Scaling' ,

Calculation Manual to the scaling calculations ,"

t I

TAP Audit Def ic i e nc y No.89-146S-02

  • Contrary to the above, design activities are not prescribed in ,

s uf fici ent written detail to define the relationship of the- various source or ' r ef erenc e document s utilized in the pr oduc tion .of scaling calculations. Specifically, t her e is no single document whic h provides an overall "rced map for the pr eparation of. scaling -

calculations which addresses input data sources, equipment r ef er enc e manuals and calculation content and methodology, Neither DBD-EE-032, Scaling Calculation Manual (SC-8800) nor any of several other ref er ences - provide the required overall procedural definition or guidelines f or this activity."

J' TAP Audit ATP-89-146S Question "4c) Verify'that all premises utilized in the scaling calculations are supported by appropriate ref erence documentation." .c l

i TAP Audit De f ic i e nc y No.89-146S-01

" Contrary to the above, most of the ' scaling calculations reviewed exhibited one or more of the following deficient conditions (In many cases recourse _to the preparer was required to understand the calculations):

  • l. Section 3 of the calculations c ont ai ns r ef er ence to ' Standard Reference Documents' in Section 2.0 of the Scaling Calculation Manual (1-SC-8800): however, Section 2.0 contains 29 documents, not all of which are applicable to any one calculation. ,

Additionally, thes e r ef er enc es do not contain revision levels or dates, yet specific inf ormation contained in these documents (e.g., gain, bias values, etc . ) was used in the calculations .

"2. The body of the calculations does not contain specific input reference sources (e.g., document number, r evision number ,

18 1

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4. - Scalino Calculation 1-SC-55-52 (continued)

TAP Audit Def i c i e nc y No.89-146S-01 (continued) titles, issue date, section,'page, etc.) f or : module gain,

'l bias, and input voltage s j umper s r equired or removed s or resistors _ required.

[ f "3. Input ref erence sources are not stat ed f or module equations or .

't ransf er f unctions utilized. '

"4. Explanatory notes are not provided f or mathematical manipulations perf ormed, not are the manipulations shown.

"S. Section. 6 of the calculations contains the statement *For Loop Accuracies, see Scaling Calculation Manual Appendix'H (1-SC-8800-H, Rev. 1)' s however , Appendix H only provides guidelines f or ' determination of loop accuracy values rather-than providing actual loop accuracy values themselves. (A-similar statement is made in Proj ect Procedure PP-009 At t ac hment - B , page 7, Paragraph E.)

"6. Figure 1 of the calculations does not contain a reference for the source (e.g., Westinghouse Process Control Block Diagram,-

etc . ) of the loop configuration."

TAP Audit De f ic i e nc y No. 89-146-03 "3. Calculation 1-SC-55-52, Rev. 4, page 20, Sections D-1 and D-2 reference Westinghouse Precautions, Limit a t s ons and Setpoints (PL&S), Rev. 2 as the source or the Lo and Lo-Lo TAvg.

interlock setpoints . Rev. 3 of the PL&S was issued in January 1985. The calculation (issued 3/2/88) did not reference the latest revision of the PL&S.

t >

"S. Calculation 1-SC-55-52 Rev. 4, pages 21 and 22 reference  !

Westinghouse Scaling Manual Supplement, Rev. 2 as a source of setpoint values. Thi s reference is not appr opriate sinc e it is '!

based on Rev. 2 of the PL&S. Rev. 3 of the PL&S has been 1 issued since Rev. 2 of the Scaling Manual (Cet ober 1983)."

l j TAP Audit ATP-89-146S Ouestion l

l "5d) For signal comparators verify type, tag number, inputs, setpoint value and ref erence source, s e t poi nt voltage, reset  !

voltage, res.stors r equir ed , j umper s , etc."

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4 4 ', Scalino Calculation 1-SC-55-52 (continued)

-1 6

TAP Audit Deficiency No.89-146S-01

  • Contrary to the above, most of the scaling calculations r eviewed. ,

exhibited one or' more of the f ollowing deficient conditions (In many i

-cases recourse to the preparer was required to understand the calculations)t

  • 1. Section 3 of the calculations contains ref erence to ' Standard . '

Ref er enc e Document s ' in Section 2.0 of the Scaling Calculation Manual (1-SC-8800): however, Section 2.0 contains 29 documents, not all of which are applicable to any one calculation.

Additionally, these ref erences do not. contain revision levels or dates, yet specific inf ormation contained in these documents (e.g., gain, bias values, etc . ) was us ed in the calculations .

O- "2. The body. of the calculations does'not contain specific input reference.aources (e.g., document number, revision number,

. titles,. issue date, section, page, etc . ) f or t module gain, bias, and-input voltagei jumpers required or removeda.or resistors required.

  • 3. Input reference sources are not stated f or module equations or-transf er functions utilized,
  • 4, Explanatory notes are not provided f or mathematical mani pulati ons perf ormed, nor are the manipulations shown.

4 "S. Section 6 of the calculations contains the statement 'For ,

Loop Accuracies, see Scaling Calculation Manual Appendix H (1-SC-8800-H. Rev. 1)' i however, Appendix H only provides

[ guidelines - f or determination of loop accuracy values - rather l than providing actual loop accuracy values themselves. (A similar statement is made in Proj ect Prscedure PP-009, At t ac hment B, page 7., Paragraph E.) j "6. Figure l' of the calculations does not contain a reference for the source (e.g., Westinghouse Process Control Block Diagram, etc . ) of the loop c onfiguration. "

TAP Audit Deficiency No.89-146S-03 "3. Calculation 1-SC-55-52, Rev. 4, page 20. Sections D-1 and D-2  ;'

r ef erence Wes tinghous e Procautions, Limitations ' and Setpoint s (PLES), Rev. 2 as the source of the Lo and Lo-Lo TAvg.

interlock setpoints. Rev. 3 of the PL&S was is sued in Januar y 20

par-" ,

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e 1-lE r,

? 4. ' Scalino- Calculation 1-SC-55-52 (continued)

L TAP Audit Def i ci enc y No.89-146S-03 (cont inued) l 1985. The calculations (issued 3/2/88) did 'not ref erence the latest revision'of the PLES.

  • 5. Calculation 1-SC-55-52 Rev. 4, pages 21 and 22 reference Westinghouse Scaling Manual Supplement , Rev. 2 as a source of setpoint values. Thi s r ef er enc e is not appropriate since it is based on Rev. 2 of the PL&S. Rev. 3 of the PL&S has been issued since Rev. 2 of the Scaling Manual (October 1983)."

t

5) Scaling Calculation 1-SC-55-28 ,

TAP Audit ATP-89-146S Ouestion .[

" 3b) Model number s and card gr oup numbers agr ee with. th's instrumentation- specifications and the Equipment Ref erence Manuals, r e s pec ti vely . "

TAP Audit Defic i e nc y No.89-146S-03 "6. Calculation 1-SC-55-28 Rev. 5, Figure i shows device JY-410K as an.NCH1 card, whereas DCA 88520 indicates that this device is.an.NCH4 card." ,

I TAP Audit ATP-89-146S Question "4a) Verif y accuracy of data transf er from specification sheets , .

drawings.-scaling appendices, setpoint calculations, and the l Standard Reference Documents in Section 2.0 of the Sc aling Calculation Manual to the scaling calculations ."

TAP Audit Def i c i e nc y No.89-146S-02 L " Contrary to the above, design activities are not prescribed in sufficient written detail to define the relationship of the various g source or ref erence documents ' utilized in the production of scaling l

c alc ulat i o ns . Specifically, there is no single doeurent whic h provides an overall ' road map' f or the preparation of scaling l-.

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5) Scalino Calculatton 1-SC-55-28 (continued) '

TAP Audit - Deficiency No.89-146S-02 (continued) calculations which addr es ses input data sources, equi pment reference manuals and calculation cont ent and methodology. Neither DBD-EE-032, Scaling Calculation Manual (SC-8800) nor any of several other ref erences . provide the r equir ed overall procedural definition' or guidelines f or this activity."

, TAP Audit ATP-89-146S Ouestion >

"4b) Verif y that the latest inf ormation (as - of the calculation sign off date). including Design Change Authorizations (DCAs) was utilized in the. preparation of the scaling calculations ."

TAP Audit - Deficioney No. 89-146-03 "6. Calculati on ' l-SC-55-28, Rey , 5 Figure 1 shows device JY-410K as an NCH1 card, whereas DCA 88528 andicates that this device is.an NCH4 card."

... .I TAP Audit ATP189-146S Ouestion "4c) Verify.that all premises utilized in the scaling calculations-are supported by appropriate ref erence documentation."

TAP Audit Def i c i e nc y No.89-146S-01 ~

t

" Contrary to the above, most of the scaling calculations reviewed  ;

exhibited one or more of the f ollowing deficient conditions (In many cases r ecour s e . to the pr eparer was required t o under s tand tne >

calculations):

  • 1. Section 3 of' the calculations contains reference to ' Standard Reference Documents
  • in Section 2.0 of the Scaling Calculation Manual (1-SC-8800): however, Section 2.0 contains 29 documents, not all of which are applicable to any one calculation.

Additionally, these references do not contain r evision levels or dates, yet specific inf ormation contained in these documents (e.g., gain, bias values, etc.) was used in the calculations .

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5) Scaling ' Calculation 1-SC-55-28 (continued)

TAP Audit Deficionev- No. *9-1463-01 (continued)

"2. The body of the calculations does not contaan specific input l ref er ence sources (a.c., document number . - r evi sion number ,

titles. assue date. section, page, etc.)-fori module gain, .j'

  1. - bias and input voJ tsge s j umper s required or r emoved: - or resistors _ required.

"3. Input r ef er enc e sources are not stated for module equations or C' transf er - f unctions utilized.

"4. Explanatory notes are not provided f or mathematical mani pulati ons performed, ror are the manipulations s hown.

"S. Section 6 of the calculations contains the s t a t'ement *For Loop Accurecies, see Scaling Calculation Manual Appendix H (1-SC-8800-H. Rev. 1)*;.however, Appendix H only provides -

guideltr2es_for determination of loop cc9uracy values rather than.pr oviding actual loop accuracy values themselves . (A s a ma).ar s tat ement is made in Proj ect Procedure PP-009, At tachment B , page 7, Paragraph E. )

"6, ' Figure 1 of the calculations does not contain a ref erence f or the-source (e.g., Westinghouse Process Control Block Diagram..

etc .) of the loop configuration."  ;

TAP Audit-ATP-89-146S Question L

"Sc) For indicators, verify type, tag number, location, input ,

output, scale, scale factor, etc."

.Th.P Audit De f i c i e nc y No.89-146S-03 "7, Calculation 1-SC-55-28. Rer. 5, page 8 states that B enc h -

Calibration Accuracy f or Summining Amplifier 1-JY-410A is +

0.10% of span or 1 0.10 VDC. The span is 0 - 10 VDC, thus the correci value.should be 1 0.01 VDC." .

e44 23 1

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5) - Scalino Calculation 1-SC-55-28 (continued)

-c . .

TAP Audit ATP-89-146S Question

  • Sd) For signal'comparators verify type, tag number, inputs, s et point value and r ef erence source, s et poi nt voltage, reset voltage, resistors r equir ed , ' j umper s , et c . "

TAP Audit Def i ci enc y No.89-146S-03 "9. Calculation 1-SC-55-28. Rev. 5, page 8 calculates f or NSA 1 card 1-JY-410A~as ' RI - 50K - ohms /0.1 -500 K ohms , use 499 K ohms. No explanatory note was indicated f or using a 499 K ohm resistor in place of the calculated value of 500 K ohms ."

.It'ehould be noted that the only audit deficiency issued that did-not pertain to a specific saf ety-related scaling calculation was explained as such on page 27 of 71 of the TAP audit ATP-89-146S,.

Checklist Matrix Notes, item S2 which states : " Westinghouse documents obtainedLfrom DCC however, PIP Master Index had not been updated (see Deficiency No.89-146S-08) by Adminis trative Servic es . .The deficiency is not against the scaling calculations." (Emphasis added.)

] 1 The TU Electric statement that.the " Safety-Related Calculations l

ar e ? Technic ally Adequat e" is Anaccurate, as verified by the TAP audit ATP-89-146S ques tions and deficiencies lis t ed above . .{

i The CASE Monitors have not waivered f rom their position that the l scaling calculations, not the field conditions , are the end product of  ;

the scaling calculation and documentation review ef f ort . This does not 'l i

in any way minimize t he impor t a nc e t ha t the ultimate field condition be f correct. But the process by which the field condition is arrived at is also important in and of it s elf .

i 24 i

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l The CASE Monit or s neit her at t empt ed t o "denigrat e* nor mi s r epr es ent the f acts obtained f rom their reviews of t he "TU Electrac*a g scaling calculation ef f orts ," as TU Electric has indicated. We merely compiled the data. - in the context of each TU Electric /SWEC/ CECO /SAFETEAM effort (surveillanc es . audits , investigations) and pr esent ed the profile that the results of those activities f ell f ar short of resolving the concerns identified by Mz , Bodiford. Since those concerne surfaced over 2-1/2 years ago. it could only be concluded by the- CASE Monitors that with those concerne still unresolved and the deficient conditions c ontinui ng t o exi s t an the CPSES scaling calculation and documentation r evi ew . effort, corrective action was neither ' timely" nor effective.

The CASE Monitors do not disagree with the TU Electric statement that t he Int r oduction. t o 10 CFR - Part 50, Append 1r B , discus s es the f act that ". ,

, quality assurance comprises all those planned and systematic actions neces sar y. to pr ovide adequate c onfidence that a structure, system or component vill perf orm satisf act orily in s ervice. " That statement merely indicates to the CASE Monitors the importance- placed on carrying out each criterion of Appendix B f rom the dec1gn phase to the daily operation of the plant . The statement was an " Introduction" and did not place mor e impor tanc e on any one criterion or facet of the 4 program than on the others. All are expected to be in compliance.

The f ollowing (although we are not certain whether or not it is specifically required for CPSES) at a minimum indicates the impor t a nc e attached to such complianc e by the NRC 10 CFR 50. 34(f). Additional TMI-related requirements, states, in part l

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  • (3) To satisf y the f ollowing r equirement s , the application l s hall' pr ovide . suf fici ent inf ormation to demonstrate that the requirement has been met. This inf ormat ion a s of the type customarily required to satisf y paragraph (a)(1) of this

!U section or'to address t he applic ant 's - t ec hnical <

quallfacations and management structure and competence . . .

"4

  • (1) Provide ' administrative procedures f or evaluating operating, design and construction experience and f or ensuring that applicable important industry experiences will f

U  :

'be provided in a timely manner to those designing and cons tructing the plant . (I.C,5) . . .  ;

"(111) Establish a- quality assurance (QA) program based on '

consideration oft ( A)' Ensuring independence of the organization perf orming checking' functions from the i"

organization responsible f or- perf orming the f unctions i (B) >

perf orming quality assurance / quality control functioning at construction sites to the nacimum feasible extent s (C) i

' including ' QA personnel an the documented review of and I concurrence an quality related procedures associated with  ;

design, construction and installation: (D) establishing-  :

criteria f or determining QA programmatic requiremente s (E) establishing qualification requirements f or QA and QC ,

personneli (F) sizing the QA staf f. commensurate with its ~

(

duties;and' responsibilities: (G) establishing procedures f or ~

maint enanc e -of ' as'-built

  • documentations and (H) providing a QA role in design and analysis ac ti vi ti e s . " ,

, - - 10 CFR' 50. 34(f)(3)(1) anf (iii) t It appears to the c CASE Monitor s that TU Electric is confusing one requirement (10 CFR' Part. 50, Appendix B) with the conditions ' of another separate, but related, requirement (10 CFR 50.55(e)) 1.e.. TU Electric closely tracks the language of , and substitutes the intent of,10 CFR 50.55(e) f or the design, cons truction, inspec tion, testing, and operation requirements mandated by 10 CFR Part 50, Appendix B. 10 CFR i 50.55(e) does not contend that af the requirements contained therein I J were not met, no violation of any, or all, criteria of Appendix B were n.

violated. -In its response. TU Electric states. in part:

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h, *[E)xpressed in other words, none of the deficiencies was saf ety significant within the meaning of 10.CFR Part 50, i Appendix B. That is, the documentation deficiencies were such that' even if lef t uncorrected, none would have adverselv i p' impacted the capability of -the saf ety-related systems and components to' perf orm their intended saf ety functions , .

4 -(Emphasis added. ) i O

Even if TU Electric's premise were correct (a premise with which we disagree), the quoted TU Electric statement is also incorrect, e.g. -

n

1) DCA 88869 was incorrectly designed, and if lef t unc orr ec t ed i

y-and incorporated would not have f unctioned: therefore, its saf ety-related f unction would not have been served.

1

2) The NCH cards could f ail to perf orm their saf ety-relat'ed function during a seismically induced event / problem, f TU Electric =1mplies.that the end result is the hardware and that l

the field condition is acceptable s however , even if accurate, such f act l does-not, and cannot, j ustif y any nonccmpliances with 10 CFR Part 50, 3

Appendix B , design, construction, inspec tion,! t es ting , and. operation requirements, 1

The CASE Monitors have stated that at least thirt een (13) criteria l 4

of 10 CFR Part 50. Appendix B , were in noncompliance in carrying out -

the sceling calculation and documentation review ef f ort , resulting in a

' defici ent scaling calculations being issued and f orwarded to IGC f or j implementation. The important fact requiring in-depth consideration is  !

4 t hat' a deficient scaling calculation and documentation review program i

has existed at CPSES for over 2-1/2 years, in spite of those l 27

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' deficiencies being known by the CPSES Proj ect'. This f act alone can only allow the CASE Monitors to conclude that the QA programs at CPSES

~were not eff ective in assuring adequate compliance with 10 CFR Part 50,

. Appendix B, except per haps in _ a couple of isolated' instances (Criteria i III and V), and even those were stated by TO Electric not to be actual vi olati ons because they were not " safety significant."

This CPSES Proj ect QA philosophy is, in the assessment of the CASE Moni t or e , a significant indication that TU Electric needs to revisit and re-evaluate the requirements mandated by 10 CFR Part 50. Appendix B ,cl0 CFR 50.55(e), the CPSES FSAR, the- QA Manual. and TU Electric's own commitment to quality.

3. TU Electric s Report Headinci m-l "TU Electric *s Actions-Addressing Scalina Calculations are Tinely." j i

CASE Monit ors' Response I

The CASE Monitors' position remains that the CPSES proj ect was i L. neither responsive nor timely in implementing lasting. corrective action in. r es olving ' the s caling . calculation and documentation review concerns identified by Mr. Bodiford and as verified by the CPSES Proj ect and the .l CASE Monitor s .  !

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4. TU Electric's-Report' Heading:

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  • TU Electric Properly As sessed the Programmatic I mpli c_a t i ons of its Scalino Calculations Findinos." 4 i

CASE Monitors' Re s pons e i The CASE Monitors' position remains unchanged that widespread ,

O CPSES Proj ect QA programmatic breakdowns existed an the CPSES scaling calculation and documentation review ef f ort since at least 1987, and remained unchecked until Mr . Bodif ord and CASE interceded in mid-1989.

The CASE Monitors conclude that a very disturbing fact continues to be unresolved, as evidenced by TU Electric's inability to recognize I

its inadequat e pr ogrammatic controle , thereby causing TU Electric to be lacking in an eff ective, t otal appr oac h t o Quality ( Appendix B) .1.e . ,

.TU Electric's statement ". . , [T]1r st ,. although ' improvement s were needed in the specific ref erencina of calculation inputs .and cuidelines for calculation preparation . . ." (Emphasis added.) The f act remains i . -

that the CPSES Proj ect (1) was significantly deficient in maintaining i an adequate and verifiable scaling calculation and documention procram at CPSES, (2) required more than *1mprovements" in developing.

c ont r olli ng , and ref erencing design basis documents supporting a i procram, and (3) required more than a " guideline" -(or . " r oad map" ) f or p

t the preparation and control of scaling calculations , in order to comply

with 10 CFR Part 50, Appendix B.

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5. TU Electric's Report Headina:

"TU Electric Properly Declined CASE's Requests f or a Stop Work Order."

CASE Monitors' R e s pons e :

The conditions (" circumstances") upon which CASE based its .

j. recommendation and request that the CPSES Proj ect issue issue a Stop U Work Order (SWO) on scaling calculations were clear and remain valid, e.g.:

a) An auditable program did not exist at CPSES supporting the development . . maint enanc e , and control of scaling calculations :

b) Specific technical and programmatic concerns (deficiencies) identified by Mr . Bodif ord over 2-1/2 years ago continued to exist ,

J uncorrected' or unresolved, in the scaling calculation and documentation review ef f ort ,

c ). A deficient Design Basis Doc ument (DBD-EE-032) (now deleted),

existed which was a fundamental engineering deflodtion controlling document for NSSS and' BOP scaling calculations :

d) Westinghouse and CPSES scaling calculation design input ~ and i controlling document s . wor e obs olete ,- uncontrolled, and deficient (e.g., Westinghouse WCAP 9696, 1-SC-8800): and, s

e) Widespread CPSES Proj ect' QA programmatic breakdowns existed in j regards to the scaling calculation and documentation efforts these breakdowns moot one or more of the criteria of Stop Work Order Procedure 3.25.

Although TU Electric declined to issue a Stop Work Order. CPSES in

. fact did stop work on the scaling calculations . An " Action Plan" was 30

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I issued which acknowledged some of the problems identified by Mr . j Bodifordi however, it appears to t he CASE Monit or s that , in s electing the " Action Plan" to control the effort necessary to resolve the deficient issues, the 10 CFR 50,55(e) reportability review process has f been compr omis ed. It appears to the CASE Monit or s that TU Electric e

circumvented their own QA program f or reasons that are not based on adherence to r egulat ory 'and indus t r y standards . CASE considers this to be a " political," Drather than a saf ety-based motivation [3/. It also.as  ;

not clear to the CASE Monitors whether or not the TU Electric Quality Assurance organization intends to verif y 1mplementation of the actions committed to in the- TU Electric " Action Plan," ,

i It is clear to the' CASE Monitors that, with f ew exceptions and f or

  • the most part, TU Electric has gone to greet lengths not' to openly admit -I t

that' Mr . Bodif ord had legitimate conc erns . They have attempted to provide rationale and justification f or each CASE Monitor concern, without documenting that the specific and aggregate concerns were' based ,

on f actual existing program def ects and resulted in substantial problems , requiring extensive resources to respond to the concerns. 1 Instead TU Electric stated that resolution of the scaling calculation and documentation review concerns "were timely." However , t his is not supported by the f act that it has taken TU Electric over 2-1/2 years to 23/ " Political," as used in this report, does not refer to partisan politics, but rather to an assessment based on some combination of cost, schedule, regulatory c oncerns , rate issues, public image and appearance, as opposed to strict adherence to t echnical, programmatic, and design criteria required to meet 10 CFR Part 50, Appendix B .

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p t take the actions necessary to resolve Mr . Bodif ord's issues. TU ,

Electric _ does_ not pr ovide its evaluation and analysis of 10 CFR Part 50, Appendix B, Criterion XVI, that justifies the fact t hat TU Electric had  ;

not corrected the deficiencies identified by Mr . Bodif ord, and how the correction of these deficiencies in late 1989 complies with the

1 I

r equir ement' t o promptly identif y and c orr ect . The approach to minimize

  • Mr. Bodif ord's concerne is unwarranted, and again appears to the CASE Monitors to be " politically" motivated.

Additionally, at no time, either verbally or in the documentation i

generated by CASE ~to this point, has any representative of CASE claimed that "TU Electric's real motive was to circumvent" the 10 CFR 50,55(e):

evaluation process, as stated by TU Electric. It does remain a .f act ,

howeverc.that by the CPSES Proj ect's f ailing to issue appropriate ,

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deficiency documentation and declining to issue a SWO/ CAR on the deficiencies in the scal $ ng calculation and documentation review effort

--one acknowledged by_theLTAP Audit ATP-89-146S and technical meetings ,

a (when those deficiencies were identified by the CASE Monators) -- the f ormal 10 CFR 50.55(e) reportability review process was averted.

6.

- TU Electric's Report Headinai-

"TU Electric's - Good Faith Ef f ort s to Investicate Poss2ble Manacement and Intimidation Allecations Have Been Impaired by Mr . Bodiford's Inactions."

CASE Monitors' Response:

The TU Electric management "inves tipation" c onduc t ed by Mr .

Streeter does not appear to the CASE Monitors to be a " good f aith 32 s

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effort

  • by TU Electric to.either probe or resolve matters of
intimidation and harassment at CPSES, based upon the apparent "limi t ed" investigation as described in TU Electric's response. Neither has Mr. I Bodiford impaired TU Electric's investigation nor f ailed to cooperate g
-

, with any of TU Electric's efforts to conduct personal interviews or its  !

investigatation of the issues reported by Mr. Bodif ord or the CASE

. Monitors. TU Electric management responded, in writing on 10/12/89. to Mr. Bodif ord's- Intimidation and Harassment issues, without speaking to

. Mr. Bodif ord in order to obtain specific details and impressions , even- ;g ,

I though he was available to TU Electric. i The TU, Electric

  • Corporate Security" int erview conduct ed with Mr .

Bodiford'on June 17, 1989, was aus ef f ort f or the purpose of gatharing f acts with which- to launch an -investigation. This " good f aith* ef f ort p .was adminis ter ed by TU Electric ninetsen months af ter Mr .- Bodif ord reported his technical, programmatic ; and intimidation and harassment concerns to SAFETEAM, and- af ter TU Electric had put investigative t activities on adndnistrative hold dealing with the issues identified by Mr . Bodiford.

7. TU Electric's Report Headino:

-t "NRC Should Deny the Request for Action." ,

i ,

CASE Monitors' R e s po ns e -

t With regard to TU Electric's comments about root cause, the draft report submitted by CASE stands on its own in pointing out s hor tc omings 33 i

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by TU Electric in dealing with the identification and resolution of the scaling calculation and document ation revs ew deficier.cies . Although the l'

December 6.1989, report submitted by the CASE Nonitors was an Draf t b f orm. At was dotatled with sufficient f acts to clearly conclude that TU Electric has yet to perf orm an in-depth probable r oot caus e analysis of

. the scaling calculation and documentatson review ef f ort , In the view of the CASE Nonitors, there is a need f or TU Electric to develop an approach which considers their plant as a whole, rat her than tr eating i as sues as isolat ed events .

The CASE Nonators were and are extremely concerned about the generic amp 11 cations of a QA programmatic breakdown an the scaling calculation process by TU Electrac's allowsng fundamental QA program violations to exist , especially af ter the history behind the CPSES pr oj ec t , In the view of the CASE Nonitors , the possibility exists that problems an the St ation Service Water System (SSWS) and Auxiliary feedwater System (ATW) could perhaps have been minimized or even avoided altogether had TU Electric responded promptly and ef f ectively when Wr ,

o Budiford first brought the problems with the scalang calculations to TU's attention.

The possibility should now be considered that , had TU Electric put into place an effective root cause analysis pr ogram at _t hat time, and i

had such a program already been in effect and fully cperational at the  ;

i time of the SSWS and AFW a ncident s , thos e ancidents night have been averted. The CASE Monitors believe that such a possability should ba included in any f uture in-depth root cause analysis which is perf ormed.

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, In conclusion TU Electric's approach to address and resolve the technical and programmatie def acs oncies identaised an the scaling I

calculation and documentation review ef f ort was , in t he assessment of the CASE Monitors , lacking an comprehensive analysis regarding the p potential f or adver s e generic progr ammatic impact , and lacking an i i

U recognition of 10 CTR Part 50 Appendix L, noncompliances . Ther ef or e, t

the CASE Monitors remain concerned about whether ef f ective and adequate total corrective action on these assues can be obtained.

Although the CASE Monitors working on the scalang calculation offert were not involved in t he operating license proceedings . it is  !

interesting to note that s ever al points discus s ed an the CASE Monit ors' Draft Report a nd in t hi s response are similar to those discussed in the Atomic Saf ety and Licensing Board's December 28, 1983. Memor andum and i

Order (Quality Assurance f or Design), and February 8.1984, Memorandum and Order (Reconsiderattort Concerning Quality Assurance f or Design).

Although these samalarities might conceivably be viewed as simply a >

dif f er ence of opinion, a nt erpretation, or preference, these samslarities were andependently concluded by individuals not c og na zant of what i

transpired in 1983-1984. Those Licensing Board Orders stated, in part From the Atonde Saf ety and Licensing Board's December 28, 1983, Memorandum and Order (Quality Assurance for Design):

  • It se applicant's (TU Electrac's) position that ' Appendix B does not addr ess inadequat e designs but rather addresses the conf ormance of installed hardware and t he ins pection thereof to the design.' {F oot not e omi t t ed . ) We conclude that t hi s position as unacceptable. The applicant and (RRC) s t af f ,

which agr ees with it , have adopted a fallacious interpr et ation of (10 CTR, Part 50) Appendix B .

-- 12/28/83 Board Order at 2 35 an - --

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From the Atonde Saf ety and Licensing Board's December 28 1983. Memorandum and Order (Quality Assurance f or Design)

(c ontinued):

  • 0ur tour through Appendix B begins with the Introduction, which pr ovides that an applicant must have a quality assurance plan f or deston and construction of sta nuclear pl a nt . We do not consador at f ortuitous that design as listed first. Quality assurance f or design log;cally precedes quality assurance f or construction, w}1ch conf orms construction to design. We f ind t hat this theme recurs throughout Appendix B.

" Paragraph I of Appendix B specifies the estabisshment of

' t he qualit y as sur anc e pr ogr am,' which shall escure that activaties af f ecting the saf ety-related f unctions have been correctly performed.' Nothing an this section is limited to construction activities . It encompasses all activities af f ecting saf ety, including design activities .

  • Paragraph II requires that the quality assurance program be established 'at the earliest practicable time' and that. 'The applicant shall recularly review the status and adequacy of the quality assurance program.' (footnote omitted.) Thi s concern about the timeliness of quality assurance is echoed an Paragraph XVI, which requires that " conditions adver se t o quality (bel . . promptly identified and corr ec t ed.
  • Paragraph XVI also contemplates the identification and correction of the causes of significant deviations from quality: it r equires the reas onably prompt identification, documentation and correction of deficiencies. {F oot not e omitted.)

"The need f or prompt identification of deficiencies as consistent with 10 CFR 50.55(e)(1), which requires that the holder of a construction permit 'shall notif y the commis sion of each [significant] deficiency f ound in desson and construction, which, were at to have remained uncorrected, could have adversely af f ected the saf ety of operations of the nuclear power plant . . . .' { Foot not e omit t ed . ) It is apparent that f ulfillment of the obligation to report design deficiencies to the Comadssion requires that an applicant have an ongoing quality assurance program f or design and that its program must have the capacity t o spot , track and resolve s ignific ant design deficiencies on an ongoing basis. [6/

  • (1/ Arguably, (paragraph) 50.55(e)(1)(11) as restrictive because at only requires a report of 'a significant deficiency in final desion as approved 36

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From the Atomic Saf ety and Laconsang Board's December 28,

1983, Memorandum and Order (Quality Assurance f or Design) l (c onti nued)

I and released f or construction . . . . * (Emphasas i

by the Licensing Board in its Order .) However.

  • final design' s hould be int er pr et ed t o be consistent uith industry useage, reflected in the j f ollowing definition of ' final design' in ANSI

[E N4$.2.11-1974, (paragraph) 1.4 ' Appr oved design '

output document s er ' approved changes ther et o. '

Consequently, documvat s used t o cons t r uct t he ,

plant are final design documents and deficiencies ,

6 in those documents , as approved and released f or '

construction, are covered by (paragraph) 50.55 ,

r epor ting r equir ement s .

  • The importance of design control also as recognized in l' Appendix B paragraph III. The first sub-paragraph of t hat paragraph recognizes that design documents have a commanding place in the qualit y contr ol s yst em because t hose documents

' include provisions to assure that appropriate quality standards are specified. . . The first s ent enc e of t he  ;

I. third subparagraph states that design control measures 'shall provide f or verif ying or checking the adequacy of design.'

"The f ourth subparagraph of paragraph III recognizes the  ;

  • 1terative process' f or the design of plants . It provides a method of making field changes an design. It states l

"' Design changes , including field changes , shall b6 s ubj ec t to decagn control measures commensurate with those applied to the original design and be approved by

  • the organization that perf ormed the original design unless the applicant designates another responsible or g a ni za t i on. '  ;

"We interpret this provision as intending to assure that whatever design changes are made be of high quality. F ur t he r mor e , that .

qualit y, which af f ect s the enta re process of cons t ruction, was intended to be subject to all the requirements f or an ongoing l quality assurance program.

l "We reject the view, pr opounded by t he s t af f , that - 'the l: segulations don' t have a time sequence built into them as to when  !

(footnote omitted.) A ppli c ant (TU you have to run an analysis.

Electrac) as incorrect in believing that it is permit t ed an i ndefini t e period of time to catch errors committed early in the design process because. " in the later stages of design reytow' it

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From the Atomic Saf ety and Laconsang Board's December 28, )

i 1983, Memorandum and Order (Quality Assurance f or Design) i L

(c ontinued):

b will have highly experienced and capable engineers check the -

sys t em once again. 48/

  • L8/ Applicant's Findings at 25. Compare to ANSI l N45.2.11-1974, (paragr aph) 11.5, requiring that

' Audits should be conducted on a routano. basis to -

establish the adequacy of and conf ormance to the design qualit y as sur anc e r equir ement s . '

'It as our view that the regulations require tinaly identification '

L and correction of errors. We rej ect the view that the promptness <

requirements of the regulations applies to construction deficiencies and not to design deficiencies . Such a view necessarily rests on an allogical interpretation of the regulations it would require us'to believe that the Commission sought prompt correction of construction deficiencies, defined as a f ailure to comply with design documents that are themselves '

exempt f rom the need f or prompt correction of deficiencies . In that view, quality assurance as a scholastic pursuit not related '

to the actual quality of the plant. A pref erable view as that .

both construction and design deficiencies must be identified, &

reduced to writing, and corr ect ed with r eas onable promptness ,

  • 12/28/83 Board Order at 3 t hr oug h 7 (All emphases in the Board Order.)

p From the Atomic Saf ety and Licensing Board's February 8, 1984, Memorandum and Order (Reconsideration Concerning Quality Assurance for Design): '

'Our conclusion that Applicant has not anterpreted Appendix B, Criterion XVI, correctly in this proceeding also is related to t he general conduct of the case. CASE has attempted to show deficiencies in particular design documents. Instead of '

demonstrating the existence of a system to identif y and correct 5 deficiencies Applicant chose to show that :

"' the designs raised by [ CASE's) . . witnesses were taken f rom the initial stages of a carefully designed and comprehensive storative design process and thus do l not (nor were they intended to) reflect the quality of j the final pipe support designs at Comanche Peak.

(f oot not e ond t t ed . )"

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i' From the Atende Saf ety and Licensing Board's February 8.1984 Memorandun and Order (Reconsideration Concerning Quality Assurance f or Design) (continued):

  • We do not consider this to be isolat ed language. It represents Applicant *s litigation approach. in which the [NRC) Staff concurred. There has been no recognition that errors an dest on documents ar e an independent c onc e r n . reoardless of whet her t hey j may be correct ed bef ore the plant as completed. E.sch deston d oc ume nt must be a cuality document. Although er ror s may be made.

sagpificant errors --particularly errors of which Applicant has been made aware throuch employee concerns and 11tication-- should be promptly identified, ' document ed' , and c orrect ed wit h reasonable speed.* (Emphases added.)

, . . the adequacy of { Applicant's) . . . system . . . has not yet been demonstrated 4B/ . . .

"LB/ Cratorion XVI (of 10 CTR, Part 50. Appendix B) requires that conditions adverse to quality be promptly identified and corrected. Compare A ppli c a nt s ' Reconsideration at 19,

" Although Cratorien XVI restricts the r equirements to identif y the caus e of a condition and to document that condition to significant deficiencies, the requirement to identif y conditions as not restricted by use of the adj ec tive , ' s a gnif i c ant . ' . . .

(Emphases added by Licensing Board in its Order.)

2/8/84 Board Order at 5 and 6

  • We f ound that the
  • need f or prompt identification of deficiencies {

[ pursuant to Appendix B, Criterson XVI) is consistent with 10 CFR l 50.55(e)(1)* and that f ulf 111 ment of the 50.55(e)(1) requirement  !

to report s i gnif i c ant deficiencies requires that the ' ongoing quality assurance program f or design . . have the capacity to track and resolve significant deficiencies on an ongoing basis '

(Foot not e omit t ed . ) Applicant asks us to reconsider this position and to state that 50.55(e) 'does not impose ,any requirement s concerning the timing of activities under Appendix B.' (Footnote l- omi t t ed . ) This we r ef us e t o do. We have merely interpreted two I sections of the regulations to be consonant with one another , a  !

l standard method of regulatory intepretation. The requirement for L t he " pr ompt ' detection of defielencies in Appendix B assures that l

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b I f rom the Atomic Saf ety and Licensing Board's February 8.--1984', .

i-l . Memorandum and Order (Reconsadoration Concerning Quality Assurance f or Design)-(continued):-

significant deficiencies should be protoptly detected'and reported;

. pursuant to $0,5$(e). We f ail to understand what other' position s

, (, . Applicant . would have us adopt .*

[h; a t - 2/8/84 Board Order at 8 and 9-  ;

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