ML20041E071
| ML20041E071 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 03/04/1982 |
| From: | Doherty J DOHERTY, J.F. |
| To: | HOUSTON LIGHTING & POWER CO. |
| References | |
| ISSUANCES-CP, NUDOCS 8203100097 | |
| Download: ML20041E071 (12) | |
Text
._
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.. O UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION March'.4, 1982
_P2 FORE THE ATOMIC SAFETY & LICENSING BOARD -
m In the Matter of:
.c2 PM "a
$p"Iq HOUSTON LIGHTING & POWER CO.
Docket No. 5,0-%6 CP GMc0 (Allens Creek Nuclear Generating
{
Station, Unit 1
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INTERVENOR DOHERTY'S SECOND SET OF INTERROGATORIESxTO APPLI
,?/
CANT WITH REGARD TO TEXPIRG CONTENTION 31 AND QUADREX/MATTERSi./
~QW John F. Doherty, Intervanor in the above construction license proceeding, and acting under the Board Order of Jan-uary 28, 1982, now files the below Interrogatories pursuant to 10 CFR 2 740(b) and 10 CFR 2.741.
Please answer each question fully.
Please identify all documents and studies relied' upon by Applicant which support the anwer and make available such documents to this Intervenor.
Identify ex-pert witnesses who answer thtquesticns and give their exact relationship to Applicant. Identify any expert witness who Applicant intends to have testify on the subject matter questoned, and state the Expert's qualifications.
Thank you.
THE INTERROGATORIES
- 1. Has Applicant discussed the results of the Quadrex Report with the Quadrex company at any' time after the report was presented in final form?
If so, give the dates, dura-tions, and who among Applicant participated'in the meeting for:
- a. Civil /3tructural; b. Computer codes;
- c. Electrical /I&C;
- d. HVAC; e. Mechanical,
- f. Nuclear; 5. Piping and Support;
- h. radiological; i. In-service inspection.
1>5DI
- 2. With regard to finding (a) under Sec. 3.1 "Most Serious o@@
Generic Findings" of the Quadrex Reoort (hereafter: Recort),
/
no R8 did Quadrex mean that there had never been an " effective
/
systems integration and overview function" through Brown &
o Root's (BLR) entirety of association with the STNP until oO oc the report?
8x
- 3. What action (if any) did HL&P take with regard to lac:of cio mac effective systems integration and overview function at the
-2's J
3 6TNP site on the part of B&R prior to the hiring of Quadrex?
Make available any documents or correspondance between HL&P and B&R with regard to this if there were actions on th,e part of HL&P on these deficienei,es by indicating same in your answer to this interrogatory.
(a) What division within HL&P's' organization was res-ponsible for systems integration and overview by B&R at STNP?
(b) Having seen the criticism by Quadrex on systemshi-tegration and overview by B&R, what steps will'HL&P take to prevent the reoccurence of this at ACNGS?
4.
Referring to Interrogatory #2, (Suora.) if the answer is "no'", for what duration does Quadrex believe the deficiency had be,en current at the STNP site?
5 Has Quadrex su'pplied any explaina. tion for this general deficiency to RL&P management, and a recomendation as to how to prevent it in the future?
5 What is Applicant's current belief as toe tbLmeaning of the sentence: "The technical disciplines are organized very tightly.", on p. 3-2 of the Reoort?
(a) What significance is this to the problem of a working interface relationship among the discipl'nes?
(b)
Referring to Report, p. 3-2, when was an assigned responsibility for systems engineering developed at STNP?
(c)
Is a systems engineering function planned for Applicant in its work'ofiinterfacing with Ebasco at ACNGS?
(Recort,
- p. 3-2)?
If so, what is the title of that department, 1
or sub-area?
6.
Assuming personnel turnover does not decrease in frequency at ACNGS from what it was at STNP, what steps will HL&P take to assure internal consistency'among various design documents and the maintainance of that consistency? (Recort, p. 3-2) l
(,s -
- 7. Has EL&P had experience with high personel turnover problems at other construction projects?
(a) Has HL&P drawn on the experience of,any other utilities with this problem?
(b) If the answer to 7(a) ir les", which utilities, and at which nuclear constru.cion projects?
(c) Will dealing with this problem be a responsibility of Mr. Goldberg?
8.
Was Brown & Root terminated on September 24, 1981?
(a) Referring to Exhibit "A" attached, what is.the basis for the " confidence" mentioned on the 3rd page of Exhibit "A"?
9.
What provisions will be made to confirm that all disciplines at the ACNGS sites will use the same interpretation of various criteria, such as " single failure criteria", that were not provisions at the STNP site?
(a) What provisions were there at the STNP site?
10.
(See Reoort, p. 3-3,); in what form will input data'to technical groups be given at ACNGS?
(a) Is this the same form as at STNP?
(b) Does HL&P agree with Quadrer that such input data was not " consistently reviewed" for reasonableness prior to use at STNP?
(c) Were the technical groups required to indiccte to the' source of such data that it had completed a re-view of it prior to use?
(d) In the Reoort, p. 3-3, Sec. 3.1(b)(1) does the tech-nical group refer only to B&R7 (e) If the answer to (d) above is "yes", was EL&P a recipient of output data?
'(f) To how many different contractors (or groups of other status) did this output data go to?
(g) In Sec. 3.1(b)(1), item M-28 of the report is referred to as showing an instance where figures should have been checked for reasonableness but were not.
Does EL&P agree with Quadrex that Question M-28 shows this omission?
~
e
- /
-4 (h) If (g) is "yes", was the uso of g plant design events what concerned Quadrex?
If so, was B&R using data for a W plant that differed from STNP7 (i) Who or what group at HL&P provided oversight.over
~
- the Mechanical group at B&R7 (j) Had HL&P noticed this prior to Quadrex?
If so, when did they notice, and what steps did they take, if any?
11 (Referring to Question H-3 of the Reoort); does EL&P believe the Quadrex assessment that heat load calcula-tions were not. reviewed for'bff-normal conditions by the HVAC department of Brown & Root?
How will HL&P management be certain heat load calculations for off-normal conditions will be reviewed by Ebasco at STNP?
- 12. On November 18, 1981, did Mr. Goldberg travel to. San' Antonio, Texas, at HL&P expense to attend a meeting where he tal:ced about the STNP7 13.
Referring to item 3.1(b)(1) of the Reoort,what data was not checked for reasonableness prior to use in relation to question H-27 on air supply rate for the battery reom ventilation system?
14 Referring to item 3.1(b)(1) of the Recort, what items did Quadrex site to EL&P as showing that technical groups do not consistently check to see that their l
output data is used correctly?.
15 How does HL&P plan to reduce the number of calculations
[
containing errors being reviewed and found correct by Ebasco when they begin work at the ACNGS site, in civil / structural work? (See Reoort, Sec. 3 1(b)(2)).
16.
Referring to question N-1, how did the "...large tem-perature error in the main steam line break analysis" j
get accepted into the PSAR without notice?
Has Appli-cant determined whose responsibility that was?
(a) What division of HL&P monitored the work of the l
nuclear analysis branch of B&R?
(b) What are the technical qualifications of the leader of that division of HL&P?
g.
. ~
- 18. What are the persona 1 qualifications of R. Uffer of Quadrex Corp?
- 19. Does HL&P agree that as calculated by B&R, and as stated by Quadrex on page N-17, simultaneous orderly shutdown of both STNP plants would have violated Technical Specifications of Essential Cooling Pond temperatures?
(a) Does EL&P agree that re-examination of these calculations at this time is "not timely'?
(b) What partrof HL&P was delegated to examine B&R's effort on this calculation, if any?
(c) Had HL&P noted this problem previously and taken steps to change it?
- 20. Was B&R originally retained by Applicant for what is typically called (loosely) a " cost-plus contract"?
(a) Was the particular contract one that called for costs plus $12 million dollars.for STNP7 (b) Was the decision to make that offer based on advise from HL&P engineering people in any way?
- 21. Is there documented criteria goveraing the evaluation process for vendor reports for the ACNGS?
- 22. Does Applicant agree with Quadrex that there was no documented criteria existing governing the evaluation process for vendor reports at STNP?
(a) Was it the resconsibility of HL&P QA/QC to be certain such criteria were used at STNP?
(b) If this was a QA/QC function, how does EL&P QA/QC differ for ACNGS, than it did for STNP at the time of Quadrox?
(c) Had any division or group at EL&P noticed the item numbered 3.1(b)(3), on p. 3-3 of the Recort, and if so was anything tried to alleviate lack of cri-teria?
23 With regard to the Recort,
- p. M-41:
(a) Is the Refueling Water Storage Tank (RWST) the sole source of ECCS water during an accident?
(b) Was it the Applicant's responsibility to make sure B&R had verified the design of the tank?
(c) By March 27, 1981, had the tank been purchased?
I.
(d) In Question M-41, the Recort states, "Page 14 - The cal -
culation of hydrodynamic mass appears incorrect".
Have you or Bechtel determined that this calculation is def-in6tely correct or incorrect, and if so, which?
(e) Are the component cooling water heat exchangers (.CCWHE) of any safety system?
(f) Are these analogous to BWR residual heat removal system heat exchangers?
(g) Had any HL&P personnel noticed prior to the Quadrex Heport that: (1-) weight calculations for the CCWHE ignored the fluid weight in the tubes?; (2)hydrodyng'mic mass effects in the calculation of the tube sheet natural frequsney had been ignored?
(h) What are the personal qualifications of D. Munson, of Quadrex, Inc?
(i) What organizational changes have been made by Applicant in response to lack of documented criteria documenting the evaluation process for vendor reports used by the mechanical engineering branch of the STNP architect-engineer?
Will these or any other be carried over to the architect-engineer at ACNGS?
- 24. Referring to Question M-52, did Quadrex state what it j
was they had in mind when they stated, "The licensing acceptability of analysis done to demonstrate pump oper-ability under normal and accident service conditions is question'able?"
(a) Was the " accident" the Designed based LOCA?
(b) How will the licensing acceptability of pumps j
I be determined for ACNGS?
(c) What role will Applicant play?
(d) Will Apolicant review all pumps, or audit?
- 25. In question N-1, NUS (a corporation) is mentioned in l
l the Quadrex assessment portion.
Is NUS a completely separate company from B&R?
(a) How did they become chosen to work on the GTNP?
l
~
r
.,7-26". On the third page of Question N -1, it states:
There are many values of maximum containment temperature being utilized. (See Figure N-1)
- B&R is using saturation temperatures (T )
A rather than actual vacor temperatures for defining equiptment environments (e. g.
compliance to IEEE 323-1974) without per-forming analyses to determine.if equipt-ment can respond to superheat....
(a) Is figure N-1 actually figure N-1-E, " Main Steam Line' Break", the first figure after the text of N-1?
(b) Was the value for maximum containment temp-erature using a saturation temperature TA used in:
(1) Determining the containment _ stress?
(2) Suitable containment materials?
7 (3) Containment welding procedures?
(4) Was the containment shell completed before the Quadrex report for STNP-I as far as
. welding the plates, but excluding penetrations or doorways?
(c)
Did HL&P ever notice the error Quadrex mentions on the third page of N-1, and if so, what was done about it?
(d)
Were any EL&P personnel aware that, "The use of saturation rather than actual vacor temperature is not necessarily conservative for equiptment and has not been justified by analysis.",with regard to design basis event containment temperature?
(1) If so, what will be done on the ACNGS site to prevent the misuse of saturation temper-ature from continuing until equiptment is actually purchased?'(See last text page of-N-1, Recort)
- 27. What has Applicant done in the case of STNP, and in the case of ACNGS to verify that a controlled plan to develope environmental conditions for coponent qualification will be done? (Sec N-1, 4th page Text, Reoort)
28.
Is EL&P aware of any plans used for STNP borrowed or otherwise taken from the Commanche Peak Station?
- 29. Prio,r to the Quadrex report, was Applicant aware that BaR had & continuing policy of assuming work. performed by suppliers such as EDS Nuclear and Westinghouse could be assumed correct?
(See: Report p. 3-3)
(a)
Did Applicant agree with this policy if they knew about it?
(b)
Is it set forth in any documents that HL&P is opposed to this policy prior to the Quadrex report?
(c)
Iffhere are documents as requested in (b) above, please list them and make them available to this Intervenor.
s
- 30. Referring to Sec. 4 3 2.1 of the Report, does Applicant agree with the statement in sub-part 4.3.2.1 (a), that the common instrument air line, as depicted in FSAR drawing 9.4.2-2 attached to R-6, does not meet the single failure criterion required by IEEE 279-1971 and 10 CFR 50?
If not, why not?
(a) If Applicant regards this as a deficiency, has it determined what it should have done to detect the defect prior to Quadrex's investigation?
(b) In what way has Applicant a superior organization l
for the ACNGS site, so that this type of problen will be caught?
r l
(c) Has Applicant considered the significance of this concern raised by Quadrer as part of R-67 l
(d) If Applicant filed a report on this under 10 CFR 1
50.55(e), on what date did it do so?
(e) If Applicant has not, is this because Applicant does not believe it is reportable?
f (f) Who within EL&P decides if a problem, etc. is re-l portable under 10 CFR 50.55(e) at STNP?
(g) Will that be the same person as the one who will make 10 CFR 50.55(e) reports for ACNGS?
l l
31 With regard to the statement on p. 3-11 of the Report:
The absence of specific reliability require-ments in both mechanical and electrical equipt-ment specifications, and the inability to produce
.a standard checklist of postulated failures to be considered casts doubt on the rigor of the safety-related evaluation process.
(a) Has Applicant discussed this finding with Quadrex?
(b) Has Applicant agreement with Quadrez that the finding is accurate?
(c) If the answer to (b) supra. is negative, what does Applicant believe correct?
(d) Has Applicant's technical personnel reviewed the finding and reported this under 10 CPR 50.55(e),
as notfincompliance with 10 CFR 50, App. B, Criterion II?
32.
With re5ard to the statement on p. 3-2 of the Retort:
A work'ing interface relationship among the disciplines is not routine particularly re-garding follow-through at the discipline input-output interface..
(a) Has Applicant disctssed this finding with Quadrex?
(b) If so, with whom at Quadrex did Applicant discuss it?
(c) Does Applicant agree with Quadrez on this?
(d) If the answer to (c) supra. is negative, what does Applicant believe?
(e) Has Applicant's personnel reviewed the finding and reported this under 10 CFR 50 55(e), as a deficiency uhder 10 CFR 50, App. B, Criterion III?
(f) If not, what is the technical basis for believing it is not reportable?
33 Referring to Interro6atory 31 above, if Applicant did not report the Quadrex finding on soecification and check-list absence, what was or is the technical basis for believing it is not reportable under 10 CFR 50 55(e)?
34.
With regard to the statement on p. 3-8 of the Report:
"In a number of areas the PSAR is out of date."
and the statement on p. 3-8 of the Report:
"There is little evidence of a well-thought-out and consistent basis for design" and the statement in Sec. 3.1(c), p. 3-4 of the Reoort:
f Design criteria provided in issued System Design Descriptions (SDDs) and Technical Reference Documents (TRDs) appear to ade-quately reflect industry issues for the 1973-1975 time fra=e; however, they do not adequately address more recent developments (without consideration of TMI-2 considerations) such as loss of offsite power, environmental conditions in specific plant area, postulated failure modes, and anticipated operating con-ditions degraded from a norms 1, full-power, all equiptment o~perable initial assumption.
(a) Has Applicant discussed all of these findings with Quadrex Corp.?
~
(b) Does Applicant agree with Quadrex on each of these findings?
(c) If there are any findings above that Applicant does not believe correct, please st~ ate Applicant!s reasons.
(d) Does Applicant believe Quadrez Corp. is qualified fully to make such conclusions with regard to B&R at STNP?
(e) Did Applicant report any of these findings to the NRC under 10 CFR 50.55(e) prior to December 1981?
/
(f) Has Applicant reported any of these findings to'the NRC under 10 CFR 50 55(e)(1)(ii)?
(g) If none of the above Quadrex findings were reported-under 10 CFR 50 55(e)(1)(ii) prior to December,1981, what was the technical basis for believing them un-reportable?
(h) If none of the above Quadrex findings has been re-ported under 10 CFR 50 55(e)(1)(ii) what is the technical basis for believing them unreportable?
35 With regard to the statement on p. 3-8, Sec.3.1(f) of the Report:
A. consistent and documented B&R position.regarding~
Code and Standards interpreations was not evident.
These interpretations are left to individuals or to vendor suppliers.
The ASME Code interpretstion area appears to be particularly weak (see Question M-30).
and a Quadrex Assessment on Question M-30 which states:
Five specifications were examined, and all had deficiencies.
Some of the deficiencies are poten-
tially serious, and, M-30 continued:
That a systematic review (should) be provided for all NRC and industry revised requirements to determine their impact on procured equiptment.
(a) Eas Applicant discussed the findin's with Quadrex?
(b) Does Applicant accept the Quadrex finding?
(c) Has Applicant filed a report with the NRC under 10 CPR 50 55(e)(iii) on this finding with re-gard to its architect-engineer, BLR?
(d) What is the technic'al basis for believing a filing under 10 CFR 50 55(e)(iii) is not needed?
36.
Referring to Sec. 4.9.1 of the Reoort, is it true.
the "In Service Inspection" TRD was in draft form and there was no other document Brown & Root was using for design for ISI later.than 1973 in creation?
(a) Was Applicant aware of the lack of ISI documents during this eight year period?
(b) What did Applicant attempt to do prior to 1979 with regard to ISI at STNP, if it knew BLR was using a 1973 document?
(c) Did Applicant believe that the use by B&R of a 1973 guidance document was satisfactory?
(d) When did Applicant first document access design problems at STNP?
(e) Did HL&P QA ever attempt a stop work order due to access engineering failures?
(f) If so, was the QA group successful immediately in getting the order issued?
(g) When was it issued?
(h) If the answer to (f) is "no",
what does Applicant believe was the reason?
(i) What part of the Applicant's organization monitored access engineering or ISI at STNP?
(j) In what ways will that part of Applicant's organiza-tion be different at ACNGS?
(k) Has Applicant been satisfied with ISI Acess Engineering at the ACNGS?
(1) If not, has Applicant attempted to bring this to the attention of Ebasco Services?
- 37. Has Applicant required Ebasco Services to improve on its ISI engineering management'at ACNGS?
Why did they have to?
- 38. What part of Applicant's QA/QC was responsible for monitoring Computer Pro 6 ram Verification of B&R in-house comptter programs havin6 heavy usa 6e? (See Report, 4-14)
(a) Had Applicant assessed computer codes used on STNP prior to the assessment mentioned in Mr. Oprea's June 5, 1981 letter (ST-HL-AE678; SFN: V-0530) to Mr. Seyfrit, NRC, Region IV?
(b) How long had the assessment been going on prior to that letter?
39 In Sec. 4.2.2.1(b) of the Report, it states, "The basis used by B&R for determination of safety-related is not sufficient."
(a) Did Applicant provide this " basis"?
(b) Did Applicant ever expressly approve "the_ basis used by B&R" With awareness it would be used to determine which computer codes would be '.' safety-related veri-fied" or not?
CERTIFICATE OF SERVICE I certify that copies of: INTERVENOR DORERTY'S SECOND SET OF INTERROGATORIES TO APPLICANT WITH REGARD TO TEXPIRG CONTEN-belowviaFirstClassU.S.PostalService,thisspies TION 31, AND QUADREX MATTERS were served on the pa of March, 1981, from Houston, Texas.
Sheldon Wo.lfe, Esq. Administrative Judge Dr. E. Leonard Cheatum Administrative Judge Gustave A. Linenberger, Jr. Administrative Judge J. Gregory Copeland Esq. Apolicant Jack R. Newman, Esq. Applicant Richard A. Black, Esq. Staff Atomic Safety Licensing & Appeal Board Docketing & Service Branch, USNRC The Several Intervening Parties Respectfully, John F. Doherty, Intervenor uro se
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x October 16, 19 P.1 ST-HL-AE-741 Mr. Karl Seyfrit Director, Region IV Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76012
Dear Mr. Seyfrit:
South Texas Project Units 1 f, 2 Docket Nos. STN 50-498, STN 50-499 This letter supersedes our letter of 9/18/81 requesting concurrence to proceed on certain safety related construction activities.
As we discussed with you on.10/15/81, we have previously announced intention to change the engineering and construction management responsibilities for STP and are in the process of developing a transition plan for accomplishing same.
Meanwhile, we have developed a list of safety related work that we plan to continue (Attachment A).
As we discussed with you and your staff, our objectiva for continuing this work is to:
(1) maintain critical crafts.
(2) perform useful work and (3) attain a logical construction stopping point.
We have looked at this work against a risk criteria and have determined with Bechtel Power Corporation that it is reasonable to continue this work.
The risk criteria is as follows:
the work (1) will be allowed to continue if we have no conscious knowledge of a problem, and (2) is not considered irreversible.
There an e a few exceptions to this criteria as indicated on the Attachment A and the corresponding note.
We estimate that this work will take place over approximately the next four months.
During this period, Bechtel's QA staff will augment our staff in performing quality surveillance over this work.
1 As a matter of information, Attachment B is included and describes
'the work that we are continuing in non-safety related areas.
Accordingly, we respectfully request your concurrence with this plan for the safety related ' work.
Yours v,ery truin
.y pe%F C
.%.dve Vice President Execu CWO /s ra
October 16, 1981.'.
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ATTACHMENT A 8 2.,
l SOUTH TEXAS PROJECT
.I SAFETY RELATED OR PARTI ALLY SAFETY RELATED t
JOBSITE ACTIVITIES TO CONTINUE I
DURING TRANSITION PHASE (about 4 mos.)
l l
CENERAL i
Jobsite Maintenar$ce (including) l 1.
A.
Maintenance of dewatering system B.
Maintenance of installed equipment 2.
Material Handling A.
Receiving / Warehousing l
B.
Preventive maintenance of stored equipment 3.
Concrete Production A.
Concrete batching for approved structures 4.
Fabrication Shop A.
Rework of Q class items B.
Fabrication of conduit and cable tray supports.
5.
Applying of coatings in all areas 6.
Maintain Records Vault and continue document contro!
7.
Maintain fire protection system l
REACTOR COOLANT BUILDING UNIT 1 I
1.*
Continue containment dome concrete to completion (1) 2.
Continue reactor coolant loop welding (1) 3.
Rework and repair ASME and AWS welds REACTOR COOLANT BUILDING UNIT 2 l
l 1.
Continue containment shell concrete placements (1) i I
F.H.B. UNIT 1 i
l 1.
Continue rework and repair of ASME/AWS welding 2.
Continue operations for roof concrete placements ( 1 )'
l D.G. B. I l
1.
Continue concrete placements (1)
1 s.
( :'
R3 D
D.C.B.1 (continued) 2.
Install Diesel Generator sole plates D.G. B. 11 1.
Start installation of basemat foundation (1) t B.O.P.
4 1.
Continue repair and installation of E.C.W. aluminum bronze piping including Area D plus hydro
.1 l
M.E. A.B. UNIT 1 I
1.
Rework and repair of ASME/AWS welding j
2.
Continue installation of cable tray supports 3.
Continue installation of conduit and supports 4.
Continue installation of structural steel
,3 j
5.
Continue installation of permanent lighting J
NOTE 1 l
4 These activities are not reversible but owing to high technical confidence, we consider that this work should continue, i
i
.I
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f s
A r
1 i
1
)
1 I
i 4