ML20042B238
| ML20042B238 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 03/15/1982 |
| From: | Doherty J DOHERTY, J.F. |
| To: | HOUSTON LIGHTING & POWER CO. |
| References | |
| NUDOCS 8203250128 | |
| Download: ML20042B238 (12) | |
Text
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- a..; u :mwver.m UNITED STATES CF AMERICA March 15.,1982 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY & LICENSING BOARD In the Matter of:
2 li"' 19 P0:55 HOUSTON' LIGHTING AND POWER CO.
(Allens Creek Nuclear Generating Docket No. 50-466 Station, Unit 1)
INTERVENOR DOHERTY' SIXTH SET OF INTERROGATORIES TO APPLICANT WITH REGARD TO TEXPIRG ADDITIONAL CONTENTION 31 AND QUADREX REPORT MATTERS.
Qt 14%
John F. Doherty, Intervenor in the above constructi g
license proceeding, and acting under the Board Crder o
- ggg, January ?8, 1982, nowfiles the below Interrogatories p 4
841982 6 3 suant to 10 CFR 2 740(b) and 10 CFR 2.741.
Please answer, each question fully.
Please identify all documents, m a nasD I orands, reports, studies, or other similar papers relied (,
/f upon by Apolicant which support the answer, and make avail " l $
able such documents to this Int'ervenor.
Identify expert witnesses who answer the questions and give their. relation-shios to Applicant.
Identify any expert witnesses who Applicant intends to have testify on the subject matter questioned, and state the expert's qualifications.
Thank you.
THE INTERROGATORIES
- 1. Is the Attachment A to this set of Interrogatories th e first HIAP3ecognigtion that B&R's ISI (in-service inspec-tion) manual contained the entire Winter of 1975 Addenda to ASME Section II, in error?
(a) If not, idicate an earlier discovery and give the iden-tity of the aemo, etc. and make it available.
(b) For how long had this " error been going on?
(c) How will HI&P strengthen its organization at ACNGS to prevent recurrence of a similar event?
'2.
(With regard to Applicant's reply to this Intervenor's Interrogatory #22, in his Set #1 of February 17, 1982,)
How does Applicant believe the fact that Quadrex had, O!$0$j 6 PDR hI
._.( Interrogatory 2, Continued)
... [$ot observed other evidenco rufficient to concludo that an effective systems integration function existed in the B&R design process,"1/ could be, a "Most Serious Finding"? ( A Most Serious Finding is one "...that pose (s) a serious threat to plant licensability because either (a) the findin6 would prevent the obtaining of a license, or (b) the finding could produce a significant delay in getting license, or (c) the finding addresses a matter of serious concern to the NPC at this time)2!
- 3. Did Applicant hold any post-Quadrex Report conferences with Quadrex Corp. in which this item was., clarified?
What result?
- 4. Did Quadrex maintain it should have been able to observe such evidence?
5.
What prompted the creation.of the "B&R System Design Assurance group... created in February, 1980"E/7 If Applicant prompted the formation of this group, when did Applicant first request or demand it?
- 6. Wasn't the Attachment 1 to"Apolicant's Answers to Doherty'.s First Set of Interrogatories Re Quadrer", questioning of Mr. Goldberg by Mr. Reis of the NRC Staff?
- 7. Won't the two lines mentioned In Interrogatory #7, of this Intervenor's Set #5, require Augmented Inservice Inspection?
What is " augmented in-service inspection?
- 8. When did HL&P first begin its recruitment of the position or need eventually filled by Mr. J. H. Goldberg?
- 9. (Referring to Attachment B, an:' HL&P office memorandum, what is meant by the statement:
The problems we have, and are experiencing today are due to the identical problems Ebasco had with access engineering on the Allens Creek Project. (?)
- 10. Who lacked program management?
3! Applicant's Answers, p. 11 O! Reoort, p.3-1, Sec. 3.0(1)
)! Aeolicant's Answers, p. 11.
s.
- 11. Who lacked program plan and scheduling?
- 12. Who lacked staffing?
- 13. Who was unclear and inconsistenkin interpretation of the scope of access design review?
- 14. What problems did Ebasco have with access engineering on Allens Creek Project?
(a)When did Applicant first become aware of these problems?
(b)What steps,if any,has Applicant taken to mitigate these
" problems"?
(c) Please list any documents, reports, or memos which show HL&P was taking steps to alleviate this problems at ACNGS, indicate if this covers the entire period until 3
3 i
close-out of the problem, and make these available to 3
this Intervenor.
15.
Referring to Question E-8 of the Report, what did Quadrex
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mean by a " logic 6hoice"?
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(a) Did they indicate it'is industry practice, or good
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practice to have documentation or analysis of logic choices?
,c.
16.
Referring to Question E-16 of the Reoort, what is the process radiation monitoring system in a PWR7 (a) Was it the job of B&R nuclear analysis to determine fij the amount of radiation to be metered at various L
points in this system?
(b) Was it the job of B&R I&C to provide instruments (N
that met those ranges of radiation?
4 (c) If the anwer to (a) and (b) above is "Yes" and "Yes",
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wouldn't Applicant say their communication would be essential?
(d) What organizational steps will applicant take to
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be certain analagous groups at ACNGS have adequate communications?
ll 17.
B&R replied to Question E-1, in part, "For the independence
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criteria especially, STP is implementing a multi-discipline review group to address the hazard protection criteria of 8%
3E570EQ0006 and assure compliance."
"5 (a) Is the independence criteria different from separation
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=a criteria?
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(b) Did Applicant request "STP" to implement the review group?
(c) If so, when did Applican, do this?
(d) Did Quadrex indicate t< HI&P they thought lack
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of this group had caus3d inadequate electrical work in the STNP which would have to be redone?
18.
Referring to Question E-15 of the Reo'o'rt, what are the hazards to plant safety if there is inadequate separation of electrical system design or instruments and controls design for " turbine trip causing reactor trip"?
(a) Had HI&P Q/A ever audited,MR's work in this area?
~
(b)WastheQuadrexReportthefirsttipeHI&Phadheard there was a deficiency of MR/NI regard to describing how separation was to be achieved?
(c) What organizational differences between that of STNP prior to Quadrex and ACNGS is Applicant expecting to prevent recurrence of the problem?
19.
Referring to Question E-15 of the Report, what are the hazards to plant safety if there is' inadequate separation of electrical system design or instruments and controls design separation for main feedwater pump trip causing auxilliary feedwater pump ialtiation?
(a) Had HI&P Q/A ever audited MR's work in this area?
(b) Was the Quadrex Report the first time HI&P had heard there was a deficiency of MR with regard to Describing hcw neparation was to be achieved?
20.
Referring.to Question E-15 of the report, in the "Quadrex Assessment, on its line 10, "others"is. mentioned?
Would this specifically not include HI&P?
21.
Referring to Question E-1 of the Reoort, did Applicant ever suggest to MR that it identify all Technical Referen-ceiDocuments (TRDs) as suggested there by Quadrex?
(a) If so, give the date, and indicate if appropriate what was impeding progress toward achieving that gatherin67
_5-22.
Referring to Question E-2, was Applicant awaro B&R was using Flamemastic material and that it was not acceptable for use as a fire barrier?
(a) Has any such material actually been installed in STNP?
(b) What will Applicant do in organizing its monitoring staff at ACNGS, that it did not do at STNP to avert the use of unacceptable flame-retardant materials?
23.
Referring to Question E-2, did Applicant give permission for the use of PVC by STNP at STNP?
24.
Prior to Quadrex, did Applicant notice that Specification ZQ-003, and its Appendix A allow the use of FVC?
25 Was STNP the first nuclear plant B&R eter designed?
26.
Prior to Quadrex, did Applicant notice that B&R had no documentation for-defining separation barrier require-ments? (See: Sec.4.3.2.1(e))
(a) If sc, what steps did Applicant take if any?
(b) Give the date of any memo where Applicant noticed this, identify it, and make it available please.
27 Referring to Question E-6, did Applicant give permission to B&R for the use of Glastic in electrical or control systems?
(a) For what purpose was Glastic used, or planned to be used at STNP?
(b) Has any Glastic actually been used in the contru.ction of STNP thusfar?
(c) If Applicant ever disapproved of the use of Glastic in the STNP, please provide a memo or similar item showing this, and mention any other steps taken by Applicant to prevent or eliminate the use of this material', please.
28.
Was Applicant aware the specifications used for physical separation for each redundant ESF logic contained no such specifications for separation' barriers,'and no' definitions for hazards and materials?
6-(Interrogatory 28, Continued)
(a) If so, when did Applicant become awa7e, and when J
did it take any steps to alter the B&R use af this specification?
(b) 29 Question E-3 states:
B&R presents an understanding of the difference in the qualification requirments for equipment operability versus structural integrity, but provided no basis for the classification of egip-ment into these catagories.
If B&R had no basis for determining what operation class equipment fell in nor a basis for determining what structural integrity-class to put items in, was Applicant aware of this prior to Quadrex?
(a) If Apolicant was, what steps did it take to alter the situation?
(b) Please give the date and identity, and make available any cemo, report, etc., that shows an effort to change this lack of basis in B&R's work in this aspect.
(c) What in Apolicant's organizational plans at ACNGS will prevent recurrence of this?
30.
Did Applicant know prior to Qu:tdrex that B&R was using a part of the FSAR as a design input document? (See:
Sec. E-3, "Quadrez Assessment, paragraph 1) 31.
Had Apolicant be advised by B&R or noticed on its own prior to the Quadrer Corp's work,that B&R had no doc-umentation for isolation devises to be used and the appropriate circuit applications?
(Refer to Question E-14)
(a) Did B&R have a procedure for documenting what iso-lation devises were oventually used in construction?
(b) Are there currently installed isolation devises in the STNP today, with no documentation of their selec-tion as to acceptability?
(c) LIf Applicant was aware of this prior to the Quadrex report, please give the date and identity of any memo, report, etc. that shows this and provide it to this Intervenor.
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- 32. On page 1-1 of the Quadrex Report on EBASCO, is the date of May, 1981, the date Quadrex was " asked to assist EL&P in its review of EBASCO?*
(a) Did Mr. Goldberg suggest this study by Ebasco?
(b) Did either Mr. Goldberg or Mr. Oprea mention the Quadrex report on Ebasco in their testimony on Allens Creek?
(c) Did each of these witnesses know that Quadrex.had been retained by HL&P to review the Ebasco design work for ACNGS at the time they testified in the ACNGS proceeding?
(d) What was the cost of this report?
33 What is the effect on plant safety if there is boron precipitation in the ECCS loops as mentioned in the "Quadrex Assessment"of Question E-22 of the Report (Vol II)?
What does " heat tracing do to alleviate this problem, or assist in improving plant safety in this instance?
34 Refering to Question E-3 of the Report, Vol. II, what is a "supoort" system as mentioned in the last sentence of the "Quadre,. Assessment"?
What is the concern if no basis or procedures existed for these systems?
35 Was Applicant aware B&R did not consider Plant Oper-ating Procedures within the scope of its design work prior to the Quadrex Report?
(Recort, E-21)
(a) If so, please indicate the date and identity of any paper, memo, etc., which shows this.
(b) If not, how will the ACNGS procedures and organiza-tion be different such that this won't recurr at that cite?
36.
Was Apolicant aware that a lar6e break in the Emergency Cooling Water (ECW) system might not be promptly detec-ted and isolated becauce sump pumps are non-safety re-lated (and hence might fail)?
(a) Where is the electrical system for detecting a large ECS break located?
(b) Are the' sump pumps at STNP classified as non-safety related?
(Intorrogstory #36, Continued)
(c) Prior to the Quadrex report, was Applicant aware of the lack of certainty of, mitigation of an ECW 1arge break because of lack of detection and isolation due to sump pump failure?
(d) If "yes" give the date of any correspondance, report, et6. between Applicant and B&R which shows this, please.
Also identify the report, etc., and make it available.
37 At tho time it was performing work.at the STNP, was the NUS Corporation owned by Brown & Root?
(a) If not who owned this company?
Respectfully 1
ohn F. Doherty 1
i:
OERTIFICATE OF SERVICE I certify that Copies of the above: INTERVENOR DOHERTY'S SIXTH SET OF INTERROGATORIES TO APPLICANT WITH REGARD TO TEXPIRG ADDITONAL CONTENTION 31 AND QUADREX RELATED MATTERS, and its attachments, together with, INTERVENOR DOHERTY'S L
MOTION TO SUBPOENA QUADREX CORPORATION EMPLOYEE WITNESSES FOR THE APRIL 1982 HEARINGS were served on the parties below via First Class U. S. Postal Service,. this I!P% of i4 arch, 1982, from Houston, Texas.
j John F. Doherty' Sheldon J. Wolfe, Esq.
Administrative Jud 8 h
6 Gustave A. Linenberger Administrative Judge
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Dr.. E. Leonard Cheatum Administrevive Judge Richard A. Black, Esq.
Staff Jack R. Newman, Esq.
Applicant J. Gregory Copeland, Edq. Applicant
-g The Several Intervening Parties t-Atomic Safety & Licensing Appeal Board Docketing & Service Branch, USNRC O
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Houston Lighting & Power Company _ _.fY1TACHIAENt R
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February 22, 1980 OFFICE MEMOR ANDUM ST-HL-15152 To Mr. A. J. Granger JfS SFN: Q 7000 Mr. T. D. Stanley g,,,,n B6R ISI >%NUAL UO10 W001C Sub/ect The STP FSAR ASME Section XI commitment is the 1974 Edition through the Summer of 1975 Addenda plus Appendix III of the Winter of 1975 Addenda.
(FSAR 5.2.4.3 Page 5.2-22) Appendix III and only Appendix III of the Winter of 1975 (Appendix III defines the NDE The NRC techniques for piping) is applicable to the STP project.
has specifically withheld its approval of all Section XI Addenda fror the Winter of 1975 through and including the Winter of 1976.
(See Federal Register Vol. 44 No. 196, October 9, 1979)
A review of these facts with regard to the B5R ISI anual indicates that BGR has incorporated the entire Winter of.475 Addenda into their manual. This error is illustrated in several areas as listed below:
Pages 39, 50 - Item Numbers 1.2 and 1.3 are not listed in the manual.
Pages 45, 51 - I*.em Number 3.11 is listed by the manual but is an erroneous requirement because this re-quirement for STP is defined in the Technical Specification of the FSAR not by Section XI.
Pages 46, 52 - Item B4.7 not liste d by the manual.
Pages 45, 52 - ltem B5.1 not listed by the r.anual.
Pages 49, 52 - Item B6.1 not listed by the manual.
Page 53
- ISI Hanual - Class 1 Exemption Criteria.
This wording is a quote of the Ninter of 1975 and differs from the Su=mer of 1975 Addenda.
Pages 56, 57 - ISI Programs A and B cs described by the manual are taken from the Winter of 1975 Addenda.
Page 57
- The Steam Generator ISI Program at STP is go-(
verned by Reg. Guide 1.83 and the Technical Specification of the FSAR not ASMF Section XI as listed in the ISI Manual.
The above omissions are in total agreement with the Winter of 1975 Addenda of ASMF.Section XI but'are not applicable to the f_, South Texas Project, hence, the ISI manual as it is now wr is not appropriate to this project.
j Considering the problems that have been identified here and
- r g,, 'N elsewhere, such as, missing augmented ISI requirements, outdated
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PSID drawings, and etc. it is my opinion that the present ual should he voided and rewritten. The final document should then be instituted as a TRD with appropriate document control.
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3 Houston. Lighting & l'ower Company
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OFFICE MEMORANDUM To Page 2 g
From Subject This subject has been discussed informally with D. Martinez.
Your response is requested by the week of March 25th.
If you have any questions, please call Mr. H. R. Hesidence or me at any time.
TDS/lhh cc: Messrs. R. C. Henson M. F. Herring II. R. Hesidence
- 4. A rtinez Outgoing File RMS 78047.2 I
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HoustF Lighting & Power Com;.ly W-OFFICE ME RANDUM January 15, 1981 a
To Mr. A. J. Granger ST-HL-17906 M
j, from Mr. S. A. Viac1'ovsky
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SFN: Q-7000
/".t,R.)5 Subicer Brown 6 Root Access Review ISI Implementing Procedures Re: ST-HL-17843 (Attachment 1)
AC-HL-ES-2928 (Attachment 3)
Brown 6 Root (B6R) has responded to NCR number ST-5 stating that they have implementing procedures for performing access design review and verifi-cation for inservice inspection consideration. They state that their imple-menting procedure is STP-DC-015. Our office memorandum, ST-HL-17843,, clearly states that Procedure STP-DC-015 is not an implementing g
procedure for assuring access and performing design review for accessibility for inservice inspection. Attachment _2.provides examples of what implement-ing procedures should consist of.
kThe lems we have, and are experiencing today, are due to the identical problems Ebasco had wi.th access engineering on the Allens Creek et.
Tho r problems are as follow =*
- 1) A lack of program management
- 2) A lack of program plan and scheduling 3)
Inadequate staffing
- 4) An unclear and inconsistent interpretation of the scope of access design review due to the absence of a program plan.
The BULarcejss design _engineermMr.,._J_._ B,lakley.,_is _ doing__ an excellertt j ob _ cons id ering the..l ack.c f_ management..s.upport.
Specific details of the above four items are defined in Attachment 3, AC-HL-ES-2928. This attachment is l
applicable to the B5R access program proiilems.
It is my recommendation that HLSP STP Engineering and QA Audit 6 Technical Services personnel evaluate BER's present access review program.
In addition, personnel from Allens Creek Engineering should particip, ate in this review. This effort should be coordinated through Mr. H. R. He'sidence with the objective of identifying whether BSR meets Items I, II, III, and IV discussed in the attachment.
I have formally sent Mr. Blakley a copy of Attachment 2 after he informed us of his plans to develop some implementing procedures and incorporate them into the new Technical Reference Document (TRD) which he is presently developing.
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Houston Lighting & Power Commny s-OFFICE MEMORANDUM January 15, 1981 D
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afb To ST-HL-17906 IghD @
i from SFN: Q-7000 T
Sub/ect Brown 6 Root Access Review Page ho
-i ISI Implementing Procedures 1
b The response to ST-5 is being formally coordinated through our Audits 6 Technical Services group in accordance with Procedure QAP-12.
Please contact me if I can be of assistance.
l FH:rka Attachments e
cc: Messrs. R. L. Ulrey
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