ML20054D557
| ML20054D557 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/20/1982 |
| From: | Harin W, Horin W, Reynolds N DEBEVOISE & LIBERMAN, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Citizens Association for Sound Energy |
| References | |
| NUDOCS 8204230130 | |
| Download: ML20054D557 (31) | |
Text
{{#Wiki_filter:Sof' o April:2d, 1982 UNITED STATES OF AMERICA ,O7 g y ,f\9'.'8 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD-L. In the Matter of )
)
TEXAS UTILITIES GENERATING ) Docket Nos. 50-445 and COMPANY,et- al. ) 50-446
) c)
(Comanche Peak Steam Electric ) (Application for ,p s \ Station, Units 1 and 2) ) Operating Licens $;)" g sN l lb 97
~1 c.- -{$4 42-
-l APPLICANTS' ANSWERS TO CASE'S @%o % :p $
i' ' NINTH SET OF INTERROGATORIES _ j, f 9/ d)
/' /
~. j g\
Pursuant to 10 C.F.R. 2.740b(b), Texas Utilities Generating Co., et al. (" Applicants") hereby submit their answers to " CASE's Ninth Set of Interrogatories to Applicants," served April 5, 1982. Applicants are in the process of identifying and gathering documents requested in this Ninth Set. Pursuant to our ongoing discussions with CASE, Applicants will make these documents available for inspection and copying either at the Comanche Peak site or in Applicants' corporate offices in Dallas, as appropriate, in the near future. ANSWERS TO CASE'S NINTH SET OF INTERROGATORIES
- 1. Yes.
- 2. Not applicable.
wo3 V g
- 3. Not applicable. .
Yes. ll 4. 8204230130 820420 PDR ADOCK 05000445 G PDR
V o s
- 5. Not applicable.
- 6. Not applicable.
- 7. The Component Modification Card (CMC) and Design Change Authorization (DCA) are the documents by which approved engineering changes are implemented. The CMC and DCA Logs have been made available to CASE previously for inspection and copying.
- 8. The following documents typically pertain to a given concrete placement:
A. Concrete Pour Card with pre-established pour number B. Concrete / Mortar Batch Tickets C. Laboratory Test Records D. QC Inspection Reports / Checklists As Applicants have previously stated, there is not a '
-document entitled " concrete pour log." The Concrete Pour Card is the controlling document for the concrete pour. Batch tickets are prepared for all. grout and concrete used in the pour.- OC Inspections are documented on inspection reports or checklists. Laboratory tests are recorded on laboratory test records. These documents .i are submitted to the Permanent Plant Records Vault where they are accumulated as a " package." With respect to inclusion of relevant information in the computer, information from the concrete pour card is first trans-ferred onto.a data sheet. The data sheet is then used to input information into the computer. These drta
, sheets are not retained. The computer printout furnished I to CASE is an index of the~ pre-established concrete pour
- card numbers that have been captured in the record system.
- 9. " 9 . -Four (4).
"10." Four (4).
"11." Regarding Question "9."
- a. The Hartford Steam Boiler Inspection and Insurance Company audits were performed pursuant to ANSI l N626.0.
- b. The conclusions are as documented in the audit reports, which have been made available to CASE for inspection and copying.
1 I
, ---- . - - . . . - , --w-e- ,- -
l
- c. The Hartford Steam Boiler Inspection and Insurance Company.
- d. Copies are available in the Dallas office of Texas Utilities for inspection and copying by CASE.
Regarding Question "10 . Report No. 1
- a. The " Final Concrete Evaluation of Refueling Pool Structure at Comanche Peak, Unit No. 2, Glen Rose, Texas" was prepared by Richard A. Muenow, P.E.
It was performed for the purpose of detecting, locating, and delineating internal discontinuities in the concrete of the titled structure.
- b. The conclusions are as documented in the report, which has been made available to CASE for inspection and copying.
- c. The tests were authorized by Robert B. Williams, Tf s t .
- d. A copy is available in the Dallas office of Texas Utilities for inspection and copying by CASE.
Report No. 2
- a. The " Final Report on the Concrete Evaluation in Dome Roof Section of Comanche Peak, Unit No. 1, Glen Rose, Texas" was prepared by Muenow and Associates.
It was conducted to provide information relative to the concrete quality, in addition to detecting and defining internal discontinuities.
- b. The conclusions are as documented in the final report, which has been made available to CASE for inspection and copying.
- c. The evaluation was authorized by Robert B. Williams, )
TUSI.
- d. A copy is available in the Dallas office of Texas Utilities for inspection and copying by CASE.
O lo-1 I-Report No. 3
- a. The Final Report for the " Review of the Quality Assurance Program for the Design and Construction of the Comanche Peak Steam Electric Station" was prepared by Fred Lobbin to provide an independent assessment of the QA program and, in particular, to identify areas Which could be improved and Which should receive management attention.
- b. The conclusions are as documented in the final report, which has been made available to CASE for inspection and copying.
- c. This reveiw was instituted by Billy R. Clements.
- d. A copy is in the Dallas office of Texas Utilities for inspection and copying by CASE.
Report No. 4
- a. The " Report of Independent Review and Analysis of QA Records Management Systems for Texas Utilities Services Incorporated," by Ebasco Services Inc.,
was performed to review, evaluate, and report on the effectiveness of the TUGCO OA records manage-s ment system.
- b. The conclusions are as documented in the report, which has been made available to CASE for inspection and copying.
- c. John T. Merritt instituted the review.
- d. A copy is available in the Dallas office of Texas Utilities for inspection and copying by CASE.
- 10. No.
- 11. Not applicable.
- 12. Not applicable.
- 13. No.
- 14. Not applicable.
- 15. Applicants will supply these documents for inspection and copying. Arrangements will be made for CASE to examine and request copies of these documents in the near future.
Applicants note that handwritten version' of DDR logs were an interim step before the fin. DD; logs were typed. Applicants generally did not .etain the handwristen versions once they were typed, and therefore they are no longer available. CASE should recognize that logs are not " records" and are therefore not retained as such. Logs are used primarily for tracking purposes. 16-18. Applicants will supply these documents for inspection and copying. Arrangements will be made for CASE to examine and request copies of these documents in the near future.
- 19. As stated in our response to Interrogatory 8, data sheets are the interim document from which information is indexed onto the computer. These documents are not considered " records" and are, therefore, not retained.
- 20. Mr. Lobbin's evaluation was primarily a review of the audit and vendor compliance function within the TUGCO QA organization. To a much lesser extent, Mr. Lobbin reviewed the Surveillance and Inspection Programs of TUGCO.
- 21. See Attachment 1.
- 22. Another utility recommended Mr. Lobbin to Applicants.
See response to Interrogatory 23.
- 23. Applicants decided last year to obtain an independent assessment of the TUGCO/TUSI QA program. In consulting with other utilities regarding possible approaches to this idea, one of the utilities recommended Mr. Lobbin, should it be decided to retain a consultant for this evaluation. Applicants deteamined that employing a consultant would be an effective means to accomplish the evaluation and selected Mr. Lobbin on the basis of the above-mentioned recommendation.
- 24. See response to Interrogatory 20.
- 25. Billy R. Clements, TUGCO Vice President, Nuclear.
- 26. While there is no requirement that such an audit be performed, Mr. Clements commissioned the review in order to obtain an independent assessment of the TUGCO/TUSI QA program.
- 27. No.
- 28. No.
f
- 29. TUGCO Executive Vice President and General Manager -
Robert J. Gary. TUGCO Vice President, Nuclear - Billy R. Clements TUGCO Manager, Quality Assurance - Envid N. Chapman TUGCO Supervisor, Quality Assurance Services - Antonio Vega
- 30. A program established to monitor, review, or observe selected activities. In this instance, the activities monitored, reviewed and observed were various construc- ,
tion and QA/QC activities at the Comanche Peak site.
- 31. December 14 - 18, 1981, and January 4 - 8, 1982. No holidays are included in these time frames.
- 32. No. However, the CPSES Quality Assurance Plan was available for his review.
~
- 33. The prime contractors for Comanche Feak are Westinghouse Electric Corporation, Gibbs & Hill, Inc. and Brown &
Root, Inc. Mr. Lobbin did not reveal the identity of the prime contractor to which he referred, presumably because it was not within the scope of the report. As stated in the Lobbin Report, at p. 4, Mr. Lobbin made "no effort ... to evaluate directly the effectiveness and implementation of the Comanche Peak QA programs of TUGCO's prime contractors."
- 34. No. However, Chapter 17.1 of the Final Safety Analysis Report ("FSAR") defines TUGCO's responsibilities for audits and surveillances of the Quality Assurance program. These responsibilities include audits and surveillances of Brown & Root's ASME program. Also included in Chapter 17.1 of the FSAR are the applicable organizational interfaces.
- 35. Not applicable.
- 36. Not applicable.
- 37. Not applicable.
- 38. Corporate Quality Procedure COP-CS-4, Revision 2, of the Corporate Quality Procedures / Instructions Manual establishes the procedures for this activity in effect at the time of Mr. Lobbin's evaluation. This procedure previously was made available to CASE for inspection and copying.
- 39. Corporate Quality Instruction COI-CS-4.5, Revision 1 of the Corporate Quality Procedures / Instructions Manual establishes the procedures for this activity in effect at the time of Mr. Lobbin's evaluation.
This procedure previously was made available to CASE for inspection and copying.
- 40. Yes.
- 41. Both of the procedures identified in the responses to Interrogatories 38 and 39 have been revised.
42.-43. Applicants will supply these documents for inspection and copying. Arrangements will be made for CASE to examine and request copies of these documents in the near future.
- 44. The TUGCO persons qualified to participate as auditors in the vendor QA audit program are:
Debra L. Anderson Cecil Manning Bailey F. Cambell Rick Hoelscher Roland F. Cote' Antonio Vega Steve Davis Tony Valdez Al'An Kesler ~ Debara Paris Larry Rillera Albert Boren Robert H. Shoemake Wayne Parry Susan L. Spencer David Deviney
-j Lisa M. Bielfeldt Richard Curtis John Maxwell Charles Killough Jim Smith John Echterhoff Leonard A. L'amb Alan Lancaster
- 45. Mr. Lobbin has informed Applicants that the Comanche Peak vendor audit activity was compared to only one other nuclear project, Arizona Public Service's Palo Verde Plant.
- 46. See response to Interrogatory 45.
- 47. No. At the time this report was written the figures were correct. However, as our response briefly pointed out, any meaningful comparison of the number of activities performed is impossible without, at the same time, considering the breadth and depth of each of those activities.
- 48. Not applicable.
- 49. Mr. Lobbin has informed Applicants that the Comanche Peak design and construction audit activity was compared only to one other nuclear project, Arizona Public Service's Palo Verde Plant.
- 50. 1975 - 11 1976 -- 24 1977 - 31 1978 - 32 1979 - 40 1980 - 46 1981 - 24 1982 (to date) - 8 (+ 1 in progress)
, 51. 1975 - 0 1976 - 0 1977 - 0 1978 - 54 1979 - 80 1980 - 16 1981 - 18 1982 (to date) - 4
- 52. Brown & Root, Hartford Steam Boiler Inspection and Insurance Company, and The National Board of Boiler and Pressure Vessel Inspectors.
- 53. Brown & Root Hartford National Board 1975 - 3 1979 - 2 1979 - 2 1976 - 4 1980 - 1 1977 - 3 1981 - 1 1978 - 3 1979 - 2 1980 - 1 1981 - 1 1982 (to date) - 2
- 54. For all activities which require audits, such audits are scheduled and performed without consideration of resources. See Procedure COP-CS-4 of the Corporate Quality Procedures / Instructions Manual.
- 55. None. Manpower is allocated to specific audits as required and in no way is considered to be a potentially limiting factor.
- 56. The Applicants have not yet completed this evaluation and, therefore, have no results.
- 57. See response to Interrogatory 56.
- 58. All nine audits included work done under the Brown &
Root ASME Certificates of Authorization. Any audit of Brown & Root would have been performed against their ASME OA Program, not specific ASME-related functions.
- 59. None.
15 0 . At one time or another, all areas of the ASME program were reviewed.
- 61. Yes. These reports have already been made available to CASE for inspection and copying in response to CASE's Sixth Set of Interrogatories.
- 62. Not applicable.
- 63. As of January, 1982, the authorized TUGCO OA audit staff level was 13 persons.
- 64. As of January, 1982, the TUGCO OA audit staff consisted of 6 auditors, supplemented, on an as-needed basis, by OA engineers and technicians, all of whom are qualified auditors.
- 65. The TUGCO OA audit staff was formed in 1979. Prior to -
that time, there were no TUGCO employees dedicated solely to audits. The TUGCO audits were performed primarily by engineers in the OA department who were
! qualified as auditors. The TUGCO OA audit staff continues to rely on persons such as these to support the audit effort. The authorized TUGCO OA staff levels for 1979 and subsequent years are, as follows:
1981 - 9 1980 - 2 1979 - 2
- 66. 1981 - 6 1980 - 2 1979 - 2 Prior to 1979 - O. See response to Interrogatory 65.
- 67. Applicants will supply this document for inspection and copying. Arrangements will be made for CASE to obtain a copy of this document in the near future.
l , 68 ? Yes. l
~
l
- 69. All audits include technical review of procedures by audit team members to assure, from a programmatic basis, that procedures establish adequate and effective controls on safety-related activities. In addition, Engineers at the site review procedures to assure they are concise and accurately reflect appropriate design parameters in their acceptance criteria.
- 70. As stated in the response to Interrogatory 69, evalua-tion of procedures for adequacy and effectiveness of controls is an integral part of every audit. There is no requirement to, and the Applicants do not record whether a technical review is initiated in the presence or absence of a particular problem.
- 71. Yes.
. 72. TCP-28 was the only audit performed specifically on Nonconformance Report administration. However, other audits may include a review of nonconformance records as they may apply to the activity being audited.
- 73. Yes.
- 74. The folJowing audits included a review of prime contrac-tors' audit functions performed pursuant to 10 C.F.R.
Part 50, Appendix B, Criterion XVIII: TBR-1, 2, 5 through 8 TGH-1, 3, 7, 10, 11 and 17 TWH-1 through 14, 18, 20 and 21
- 75. As stated in the Lobbin Report (p. 15), determination of generic effect is made on every audit as a result of audit findings. Specifically, an auditor, upon finding a deficiency, must determine, by further review and investigation, whether the deficiency is an isolated incident or whether there are additional instances of the same type of problem. In addition, the auditor determines whether the problem is the result of a program or procedure deficiency, inadequate training, or attitude. Although there is no requirement to, and the applicant does not record this logic sequence, this evaluation is in fact performed on every audit performed by the Applicant.
4
- 76. Yes.
- 77. Together with the audit reports, all corrective and preventive action responses, if required, have been made available to CASE for inspection and copying with each audit report produced.
- 78. Applicants will supply these documents for inspection and copying. Arrangements will made for CASE to examine and request copies of these documents in the near future.
- 79. Older audit reports do not contain such a description; however, the scope of the audit was contained in the audit notification letter. More recent audit reports contain a description of both the scope and impact of the audit.
- 80. Yes. Applicants perform these reviews during the
- course of audits which include review of activities conducted pursuant to 10 C.F.R. Part 50, Appendix B, Criterion XVIII.
- 81. This information may be obtained by reviewing the audits being provided in response to Interrogatories 113 and 114.
- 82. Applicants note that there is no regulatory requirement for " surveillance." Nevertheless, Applicants provide the following information:
Surveillance may be used as a management tool to identify areas that might need additional attention and/or to participate in problem resolution. Applicants believe Surveillance organization and visibility should be in the form and to the degree management deems appro-priate given the specific role played by surveillance on a specific project, as determined on a case-by-case basis. Accordingly, the importance of the various concepts listed in parts (a) through (d) will vary for each surveillance.
- 83. Not applicable.
- 84. Not applicable.
- 85. No. Prior to this reorganization, two surveillance l groups reported to the Supervisor, Quality Assurance Services. With this reorganization, responsibility for construction surveillance groups was assigned to the Site OA Supervisor.
- 86. Applicants believe they have employed and utilized personnel with the experience necessary to perform the surveillance activities. Any difficulties which are encountered in hiring such personnel arise because personnel with extensive design and construction experience are in great demand.
- 87. TUGCO has contacted personnel agencies specializing in technical personnel, and in particular, nuclear experience. In addition, recruiting ads have been placed in industry magazines and newspapers.
- 88. Yes.
- 89. Not applicable.
90.-91. Mr Lobbin did not identify the particular " project organization" to which he referred or those who consider
~
the surveillance group "of little benefit." CASE should recognize that the surveillance program is an independent, voluntary activity that is conducted in addition to the TUCGO QA program mandated by and performed pursuant to 10 C.F.R. Part 50, Appendix B. Nonetheless, as indicated in Applicants' response to the Lobbin Report findings, see TUGCO QA Response 4 at p. 27, Applicants are desirous of an effective / surveillance program, and believe the program has functioned well and has performed a useful service for the Comanche Peak project.
- 92. The results 'of this audit are documented in our audit report TCP-36. Two deficiencies, one concern, and two comments were identified.
- 93. Applicants will supply this document for inspection and copying. Arrangements will be made for CASE to examine and request a copy of this document in the near future.
- 94. a. There were no previous audits of a similar nature performed by TUGCO.
- b. No. However, TCP-36 was an audit of Brown & Root and TUGCO inspection personnel.
- c. See responses to Interrogatories 94.a. and b.
i
_ - ~ . _ _ _ __ . . I l 1
- 95. The-requirement for this training is contained in, and Applicants have previously provided, the following Procedures and Instructions:
- Brown & Root CP-QAP-2.1, " Personnel Training and Certification, " Brown & Root QI-QAP-2.1-1, "NDE Personnel Certification," and Brown & Root QI-QAP-2.1-5, "T"sining and Certification of Inspection Personssel"; contained in the Brown &
Root "ASME Quality Assurance Procedures Manual." In addition, the "OA/QC Non-ASME Personnel Training Manual" contains additional procedures and instructions. t
- 96. Applicants will supply the "OA/QC Non-ASME Personnel Training Manual" for inspection and copying. Arrange-ments will be made for CASE to examine and request a copy of this document in the near future.
l 97. There are approximately 250 QA and .OC inspectors currently located at the Comanche Peak site. In that production of the requested information for each of those persons, and for all past employees, would be burdensome.on both Applicants and CASE, Applicants , will await further specification by CASE before responding, as agreed in Applicants conversation with CASE on April 12, 1982. I
- 98. See Attachment 2.
- 99. There are programs in place at Comanche Peak which require that non-conformances be reviewed in an effort l to preclude repetition of conditions adverso to quality.
100. Both Brown & Root and TUGCO quality assurance organiza-tions implement a program as described in the response to Interrogatory 99. 101. Applicants will supply this document for inspection and copying. Arrangements will be made for CASE to examine and request a copy of this document in the near future. t 3 P _ . _ - ,. - - - , . . ~ . - -, - . . , , , _ . , _ - - . - -- - , , , . . , - , -, -
~
102. Applicants ha're no present plans to call Mr. Lobbin to testify. 103. Billy R. Clements, TUGCO Vice President, Nuclear. 104. The TUGCO/TUSI OA Program. 105. It was Mr. Lobbin's opinion that the effectiveness of the evaluation would be enhanced by limiting the scope to the activities described in the response to Interro-gatory 20. Th'e duration, however, was expanded to two weeks rather than the originally scheduled one-week period. 106. As stated earlier, Mr. Lobbin was retained to evaluate the TUGCO/TUSI OA Program. In that TUGCO evaluates the Brown & Root program, Mr. Lobbin's efforts in this
. area would be redundant.
107. During his evaluation, Mr. Lobbin had unlimited access to all files maintained by TUGCO OA. Mr. Lobbin himself selected these documents. 108. See response to Interrogatory 107. 109. Mr. Lobbin has informed Applicants that he did not note which specific audits he reviewed. 110. See response to Interrogatory 109. 111. Mr. Lobbin has informed Applicants that he did not note which specific Westinghouse audits he reviewed. 112. See response to Interrogatory 111. 113. Applicants will supply these documents for inspection and copying. Arrangements will be made for CASE to examine and request copies of these documents in the near future. 114. Applicants will supply these documents for inspection and copying. Arrangements will be made for CASE to examine and request copies of these documents in the near future. I i
115. CASE has not previously requested these particular audits. Only in CASE's Seventh Set of Interrogatories, Question 8, did CASE pose an interrogatory which encom-passed such vendor audits (aud3ts by TUGCO of vendors at the vendors' facilities). However, CASE indicated in its February 19, 1982 conversation with Applicants that Applicants did not need to supply those audits at that time and that CASE would pursue this question at a later date. 116. Mr. Lobbin has informed Applicants that these documents were selected by him at random. 117. Mr. Lobbin has informed Applicants that he did not note which records were reviewed. 118. See response to Interrogatory 117. 119. Applicants will supply these documents for inspection and copying. Arrangements will be made for CASE to examine and request copies of these documents in the near future. 120. Listed below are the names and titles of all individuals identified as being interviewed by Mr. Lobbin. All individuals are employed by Texas Utilities Generating Company unless otherwise noted. David N. Chapman - Manager, Quality Assurance Antonio Vega - Supervisor, Quality Assurance Services Albert H. Boren - Supervisor, Vendor Compliance Ronald G. Tolson - Site Quality Assurance Supervisor Debra L. Anderson - Quality Assurance Auditor Susan L. Spencer - Quality Assurance Auditor Bob C. Scott - Ebasco-OA/OC Supervisor - General Gerald W. Parry - Sr. Quality Assurance Technician Cecil Manning - Sr. Quality Assurance Technician Dennis Schmidt - Sr. Quality Assurance Technician Michael Bever - Sr. Quality Assurance Technician Robert G. Taylor - Nuclear Regulatory Commission - Senior Resident Reactor Inspector 121. No. As stated in the response to Interrogatory 107, Mr. Lobbin had unlimited access to all files maintained by TUGCO OA. 122. See response to Interrogatory 121 above. l
123. See response to Interrogatory 121 above. 124. No. Mr. Lobbin was aware of, and had access to, yet chose not to review Inspection and Enforcement Reports. 125. Not applicable. 126. Site Surveillance Reports ("SSR") 126 through 166. 127. SSR-1 through 36 (1979) SSR-37 through 125 (1980) SSR-001 through 010 (1982) In addition, site surveillance reports were issued in prior years pursuant to surveillance activities per-formed by Brown & Root. Mr. Lobbin did not review those reports. 128. Applicants will supply these documents for inspection and copying. Arrangements will be made for CASE to examine and request copies of these documents in the near future. 129. Mr. Lobbin's review of the Quality Assurance program included past and present activities with increased emphasis on the more recent activities. Reviews of past activities included documents such as audit reports, surveillance reports, and vendor compliance records. 130. No. . 131. Not applicable. 132. Not applicable. 133. No. 134. Not applicable. 135. Not applicable. 136. The vendor audit program has been in effect since September, 1973. The compliance program has been in effect since August, 1978. 137. No. All nonconformance reports ar_e reviewed by Quality Assurance personnel at CPSES to determine whether or not the nonconformance is reportable under the requirements of 10 C.F.R. 9 50.55(e).
138. Not applicable. 139. Not applicable. 140. See Attachment 3. 141. " Action Addressee" (TUGCO Log) and " Disposition Assignment" (Brown & Root Log) are virtually synonymous. The applicable Engineering or Construction management personnel identified as Action Addressee / Disposition Assignment are responsible for evaluating and disposi-tioning NCR's assigned to them. 142. Both terms have the same meaning. Each NCR is given a trend category number in crder to associate it with the proper trend category. The categories are used as an objective method of ascertaining the need for corrective action. 143. See Attachment 4. 144. If a Corrective Action Request (CAR) is issued, a "Yes" is entered into this column. If a CAR is not issued, a "No" is entered into this column. 145. A CAR is issued when a problem becomes repetitive or - it is significant enough to warrant escalated corrective action. 146. No. Quality Assurance management makes that determination. 147. The r. umber that appears in the " CAR Rqd Yes/No" column is the number of the associated Corrective Action Request (CAR). 148. " Reportable Yes/No" refers to whether or not the noncon-formance may be reportable under the requirements of 10 C.F.R. s 50.55(e). "TWR", Temporary Waiver Request, was a document by which Construction / Engineering requested authorization to continue the subject activity on a
" risk removal" basis. There is no relation between the two terms.
The Reportable Yes/No column was deleted from the Brown & Root NCR Log because Brown & Root does not have responsibility for formally reporting conditions to the NRC that may be reportable under 10 C.F.R. 9 50.55(e). Subsequently, the "TWR" heading was placed in the column from which " Reportable Yes/No" had been deleted.
149. In both cases, the number shown is the number of a Temporary Waiver Request, which was used as a tracking or status indicator. 150. If a "yes" appears in the " reportable yes/no" column, Brown & Root OA believed that the matter may fall under the criteria of 10 C.F.R. $ 50.55(e), and has brought the matter to the Applicants' attention. If a "no" appears, Brown & Root OA did not believe that the matter met the reportability criteria of 10 C.F.R.
$ 50.55(e). Refer to the response to Interrogatory 149 for the explanation of the numbers which appear in those columns.
If a "no" or "- " appears in the "TWR" column, a Temporary Waiver was not requested. Refer to the response to Interrogatory 149 for the explanation of the numbers which appear in those columns. Also, see response to Interrogatory 155. 151. No. Quality Assurance management makes that determination. 152. "Psbl" is an abbreviation for the word Possible. As stated in response to Interrogatory 150, Brown & Root OA brought this matter to the Applicants' attention. If the matter met the criteria of 10 C.F.R. $ 50.55(e), it was reported. The following list indicates whether the NCR's identified.as "Psbl" were reported: NCR 617 - Reported NCR 669 - Not reported NCR 694 - Reported NCR 704 - Not reported NCR 722 - Not reported NCR 806 - Not reported NCR 809 - Not reported NCR 810 - Not reported NCR 811 - Not reported NCR 815 - Not reported NCR 831 - Not reported NCR 833 - Not reported NCR 894 - Not reported NCR 899 - Not reported l NCR 906 - Not reported NCR 907 - Not reported l
153. The criteria used in determining whether or not each item is actually reported are contained in 10 C.F.R.
$ 50.55(e).
154. This responsibility is defined in site quality proce-dure CP-QP-16.1 (TUGCO " Quality Procedures Manual") and procedure COP-CS-6 (Corporate Quality Procedures / Instructions Manual), which have been made available to CASE for inspection and copying. 155. Prior to October, 1981, a dash in this column means a Temporary Waiver was not requested, i.e., a "No". If a Temporary Waiver was requested by Construction / Engineer-ing, and Quality Assurance management concurred with the request, the Waiver was issued. If issued, a TWR number was recorded. There is no connection between TWR's and Whether or not the item is reported under 10 C.F.R.
$50.55(e). After October, 1981, TWR's were no longer used and the dash indicates that fact.
156. Procedure CP-OP-16.0, Paragraph 3.1.5.1 (TUGCO " Quality Procedures Manual") and procedure CP-QAP-16.1, Paragraph 3.2.1.3 (Corporate Quality Procedures / Instructions Manual) define the processes of voiding NCR's. These procedures have been made available to CASE for inspection and copying. 157. See response to Interrogatory 156. 158. As clarified in Applicants' telephone conversation with CASE on April 19, 1982, Applicants respond as follows: The only documents from TUGCO and Brown & Root that are of a sir.tilar nature to non-conformance report logs, and which Appli-cants have not previously provided to CASE, are Field Deficiency Report logs. 159. Applicants will supply these documents for inspection and copying. Arrangements will be made for CASE to examine and request copies of these documents in the near future. l
160. July 10, 1980. I 161. The NCR Log was initiated to track NCR's associated with the non-ASME OA program. 162. TUGCO NCR's are applicable to non-ASME activities, I while Brown & Root NCR's are applicable to ASME activities. Items generally are not duplicated because of the different activities covered. l 163. The letter designation preceding each NCR number identifies the discipline (i.e., C = Civil, M= ; Mechanical, E = Electrical, I = Instrumentation). 164. Applicants will supply these documents for inspection , and copying. Arrangements will be made for CASE to i examine and request copies of these documents in the i near future. i Respectful submitted,
/
r* Nicholai S.' Reynolds f J William A. Horin [ DEBEVOISE & LIBERMAN i 1200 17th Street, N.W. l Washington, D.C. 20036 [ (202) 857-9817 Counsel for Applicants April 20, 1982 I
. l ATTACHMENT 1 Page 1 of 2 FREDERICK P. LOBBIN, P.E. Consulting Engineer Education 1964 - New Yo'rk State Maritime College - Bachelor of Science, Nuclear Science 1967 - The Catholic University of America - Master of Science, Nuclear Engineering Professional Experience 1981-Date - Private engineering and management consultant to electric utility industry. Involved primarily in areas related to the design and evaluation of management systems for power plant engineering, construction, testing and operations. 1977-1981 - Associate - Gasser Associates, Inc. Provided technical consulting services to the firm's nuclear utility clients and was responsible for new business development and strategic planning. The firm's clients were primarily utilities with - nuclear plants nearing or in commercial operation. 1972-1977 - Director of Engineering - General Physics Corporation. Responsible for a significant por-tion of the firm's early growth in nuclear power cons 61 ting, in particular, in areas related to nuclear plant operations quality assurance and management systems design, engineering support for plant design modifications, and inservice inspection. 1971-1972 - Staff Engineer - Southern Nuclear Engineering, Inc. Assignments included preparation and review of licensing documents for the firm's nuclear utility clients, including preliminary and final safety analyses and environmental reports, and preparation of both preoperational and startup test procedures for a large PWR nuclear plant. 1967-1971 - Senior Engineer - Hittman Nuclear & Development Corporation. Project engineer for a number of engineering projects related to power systems design and safety analysis. Technical expertise was in steady state and transient thermal-hydraulic analysis of power plant systems.
Attachment 1 Page 2 of 2 1964-1967 - Graduate Assistant - The Catholic University of America. Assisted with Nuclear Engineering Department lab projects involving use of the AGN-2Ol research reactor and other lab equipment, including a small analog reactor i simulator, a heat transfer loop, and various
- radiation measurement equipment. Obtained l
an AEC Reactor Operator License for the AGN-201. Professional Affiliations American Society of Mechanical Engineers American Society for Quality Control American Nuclear Society 4 4 e
't
l ATTACHMENT 2 CPSES OA/OC Organization Management Brown & Root Title Start End P.L. Bussolini B&R Project OA 12/02/74 1/21/78 Manager J.P. Clark Project QA Manager 9/11/77 To present J.V. Hawkins Project GA Manager 8/24/79 10/30/81 Rose Klimist Project OA Manager 1/13/80 8/02/80 Gordon Purdy Project GA Manager 10/30/81 To present Bob Scott Project GA Manager 4/05/76 6/08/79 TUGCO Prentice M. Milam Site OA Supervisor 6/75 2/77 Ronald G. Tolson Site OA Supervisor 2/77 To present Although the following are not "OA/OC organizations at CPSES," they do perform OA functions within their own activities. CBI */ Mike Jeffers OA Supervisor 7/75 7/79 Dennis Williams OA Supervisor 2/79 To present Bahnson **/ Tilman O. Bryan Site OA Manager 9/77 9/78 David Mcdonald Site OA Manager 5/78 6/79 Richard Owens Site OA Manager 2/79 To present Grinnell ***/ Steve Danks OA Manager 8/81 To present Joseph T. Merreck OA Manager 8/80 8/81 Leon Reese OA Manager 7/79 8/80
*/ Chicago Bridge & Iron-
*T/ Bahnson Service Company
***/ Grinnell Fire Protection Systems Co., Inc.
l
ATTACHMENT 3 Page 1 of 2 TUGCO NCR LOG
" Action Addressee" Name Position Doug Frankum B&R Project Manager Larry Popplewell Project Electrical Engineer John T. Merritt Engineering & Construction Manager Jerry Allen Project Civil / Structural Engineer Dick Kissinger Project Civil Engineer John Finneran Project Pipe Support Engineer Ronald G. Tolson Site QA Supervisor Claude Moehlman Field Mechanical Engineering Supervisor Jim Keller Field Mechanical Engineering Supervisor Gayle Creamer Project I & C Engineer Bill Baker Project Welding Engineer Jay Ryan Project Pipe Support Engineer (Lg. Bore)
Charlie Britt Construction General Electrical Superintendant Project Mechanical Design Ned Baker Engineer James V. Hawkins B&R Project QA Manager Mark Smith Field Mechanical Systems Engineer Ron Estes Technical Support Lead Engineer BROWN & ROOT NCR LOG
" Action Addressee" Name Position Doug Frankum B&R Project Manager H.C. Dodd B&R Project Manager Charles Gatchell Project Engineer TUSI-P.L. Bussolini B&R Project QA Manager U.D. Douglas B&R Project Manager J.P. Clark III B&R QA. Manager John T. Merritt Engineering and Construction Manager Ronald V. Fleck QA Engineer
l l t O l Attachment 3 cont. : Page 2 of 2 Brown & Root NCR LOG
" Action Addressee" Name Position Ronald G. Tolson Site QA Supervisor James V. Hawkins B&R Project QA Manager i
Tom Schreeder QC Supervisor Walt Lisiewski Project Electrical Engineer Rose Klimist B&R Project QA Manager Bill Baker Project Welding Engineer Gordon Purdy B&R Project QA Manager John Finneran Project Pipe Support Engineer Claude Moehlman Field Mechanical Engineering Supervisor ' Mark Smith Field Mechanical Systems Engineer Jim Keller Field Mechanical Engineerin'g Supervisor c
l e ATTACHMENT 4 Page 1 of 3 TUGCO NCR TREND CATEGORIES
- 1) Item / Material Identification 0 Improper Identification 0 Traceability Lost 0 Tags Missing i
- 2) Storage -
0 Material Stored in Wrong Place O Material Stored with Wrong Environment 0 Maintenance During Storage Incorrect
- 3) Calibration -
0 Tools out-of-Calibration or Not in Program O Calibration Stickers Missing 0 Tools not Calibrated on Schedule
- 4) Hold Points -
A Violation of OC Holdpoints B Unauthorized Use of Equipment in Hold C Violation of Procedure
- 5) Material A Improper Assembly, Installation, Etc.
B Damage C Missing or Defective Equipment
- 6) Documentation 0 Documents Missing, Incomplete, Incorrect or l Inconsistent
- 7) Welding O Any Non-ASME Welding-related Nonconformance.
i 1 1
i Attachment 4 Page 2 of 3 l
- 8) Cleanliness O Housekeeping or Nonconformances that are a Direct Result of Poor Cleanliness
- 9) Testing O Failures on Testing Done after Installation O Incorrect Testing Procedures Used; E.g., Concrete which fails 28-day Strength Test; Hydro Test Failures
. 10) Separation O Violation of Separation Criteria
- 11) Drawings / Specifications O Design Documents Incorrect, Incomplete, Inconsistent, Missing, etc.
BROWN & ROOT NCR TREND CATEGORIES I. General Shipping Damage G1 Incomplete Documentation G2 Noncompliance with Specifications (including configuration during receiving / procedures) G3 Handling / Storage G4 Cleanliness G5 Calibration G6 Coatings / Painting G7 Installation Construction Damage G8 Improper Material G9 Storage Maintenance GlO Installed Maintenance Gll Dwg/ CMC Incorrect G12
o 9 Attachment 4 Page 3 of 3 II. Mechanical (Piping and Equipment) Equipment Installation M1 Equipment Alignment M2 Piping Fabrication M3 Piping Installation M4 Welding M5 Nondestructive Examination Results M6 Heat Treatment M7 Hydrostatic Testing M8 Equipment Malfunction M9 Inspection / Surveillance M10 Minimum Wall Mll Violation of Holdpoints M12 Material M13 III. Mechanical (Component Supports) Support Fabrication M14 Support Installation M15 WPS Violation M16A Unqual. Welder M16B RDE . M17 Heat Treatment M18 Material M19 Holdpoint Violation M20 Dwg/ CMC Incorrect M21 Documentation Incomplete / Incorrect M22 Specification Violation M23
O
.= .
9 . STATE OF TEXAS ) . . P COUNTY OF DALLAS) i Homer C. Schmidt, being duly sworn, deposes and says: That he is Manager. Nuclear Services. Texas Utilities services Inc., and knows the contents of the foregofng App 1fcant's' Answerto
' CASE's Ninth Set of interrogatories; that the same is true of his own' .
inowledge except as to matters therein stated on infomation and .. !' belief,' and as to that, he believes them to be true. ,
; ? ,
. . . . ?
; i ,
, 3 .. '1
. . s>
}}})
Homer C. Schmidt -
- Subscribed and sworn to before ne this h day of April 1982, 1 , . , -1,.
l s ~ t e .q'_1 -
, , 't t W A ..
DU
. .i. .:
i
- I k' i .
f '. ' ! !. ..'
+
*g . *
' j i ' [ t'& 1.
/ . ~. .
.', l -
. . ./.. i;
*j' .r .
* *>, ',1,.
I
,I ; , , ; ,}f ." ;
, ,j .I .
'i. .
.ij' if '! l l, :
i' ! -
': { ! 'i f D lt . l
; sl
-', f s
,t r . .t jl g., .
.. r..f
' /. -
, /,e' ,
. This document $- is a.*telecopy. Applicants. pill furnish, f.,'. ],.l.,/ -;.
.'tihe original'.by s~eparate cover.
' / ,' / , , ,',
;,, , / /,.
, . .-. ,/, ' , ,u. .. .. .. <t is, * *g ,( *
.o , * . .
- l, i ' - '
.! r . :! is,:
t ;, t i i, . e .
. e t . ,' t ) l , .
l
- l l
0 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD '82 (Pa 21 A9 :38 l In the Matter of ) . , ,
;i. 7
)
TEXAS UTILITIES GENERATING ) Docket Nos. 50-445 COMPANY,et- al. ) 50-446
)
, (Comanche Peak Steam Electric ) (Application for Station, Units 1 and 2) ) Operating License) CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing
" Applicants' Answers to CASE's Ninth Set of Interrogatories,"
in the above-captioned matter were served upon the following persons by overnight delivery (*) or by deposit in the United States mail, first class postage prepaid this 20th day of April, 1982: Marshall E. Miller, Esq. Chairman, Atomic Safety and Chairman, Atomic Safety and Licensing Appeal Panel Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. Kenneth A. McCollom Marjorie Ulman Rothschild, Esq. Dean, Division of Engineering Office of the Executive Architecture and Technology Legal Director Oklahoma State University U.S. Nuclear Regulatory Stillwater, Oklahoma 74074 Commission Washington, D.C. 20555 Dr. Richard Cole, Member Atomic Safety and Licensing David J. Preister, Esq. Board Assistant Attorney General U.S. Nuclear Regulatory Environmental Protection Commission Division Washington, D.C. 20555 P.O. Box 12548 Capitol Station Chairman, Atomic Safety and Austin, Texas 78711 Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 v v
4 1
- Mrs. Juanita Ellis Mr. Scott W. Stucky ,
President, CASE Docketing & Service Branch 1426 South Polk Street U.S. Nuclear Regulatory Dallas, Texas 75224 Commission i Washington, D.C. 20005 i o f,j.f. f . L4) = 2: _ ' N William A. Horin I I cc: Homer C. Schmidt Spencer C. Relyea, Esq. 2
. . . _ _ - . _ .}}