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Category:CORRESPONDENCE-LETTERS
MONTHYEARTXX-9924, Forwards Responses to Questions by NRC Re Application for Amends to Licenses NPF-87 & NPF-89,by Incorporating Changes Increasing RWST low-level Setpoint from Greater than But Equal to 40% to Greater than But Equal to 45% of Span1999-10-22022 October 1999 Forwards Responses to Questions by NRC Re Application for Amends to Licenses NPF-87 & NPF-89,by Incorporating Changes Increasing RWST low-level Setpoint from Greater than But Equal to 40% to Greater than But Equal to 45% of Span ML20217M5711999-10-20020 October 1999 Forwards Insp Repts 50-445/99-15 & 50-446/99-15 on 990822- 1002.Two Severity Level IV Violations of NRC Requirements Identified & Being Treated as non-cited Violations Consistent with App C of Enforcement Policy TXX-9923, Forwards Monthly Operating Repts for Sept 1999 for CPSES, Units 1 & 2,per Plant TS 5.6.4.No Failures of Challenges to PORVs of SV for Units Occurred1999-10-15015 October 1999 Forwards Monthly Operating Repts for Sept 1999 for CPSES, Units 1 & 2,per Plant TS 5.6.4.No Failures of Challenges to PORVs of SV for Units Occurred ML20217E7951999-10-12012 October 1999 Forwards COLR for Unit 1,Cycle 8,per TS 5.6.5 ML20212L2891999-10-0101 October 1999 Discusses Closeout of GL 97-06, Degradation of Steam Generator Internals. Purpose of GL Was to Obtain Info That Would Enable NRC to Verify That Condition of Licensee SG Internals Comply with Current Licensing Bases TXX-9922, Forwards Revised COLR, for Cycle 5 for Unit 21999-10-0101 October 1999 Forwards Revised COLR, for Cycle 5 for Unit 2 ML20216J5571999-10-0101 October 1999 Provides Final Response to GL 98-01,suppl 1, Y2K Readiness of Computer Sys at Npps ML20212G0721999-09-24024 September 1999 Forwards Rev 4 to Augmented Inservice Insp Plan for CPSES, Unit 1. Future Changes & Revs to Unit 1 Augmented Inservice Insp Plan Will Be Available on Site ML20212H0461999-09-24024 September 1999 Forwards Rev 6 to CPSES Glen Rose,Tx ASME Section XI ISI Program Plan for 1st Interval on 990820 ML20212F7481999-09-24024 September 1999 Forwards SER Authorizing Relief from Exam Requirement of 1986 Edition ASME Code,Section XI Pursuant to 10CFR50.55a(a)(3)(ii) for Relief Request A-3 & 10CFR50.55a(g)(6)(i) for Relief Requests B15,16,17 & C-4 ML20212F1041999-09-23023 September 1999 Requests That NRC Be Informed of Any Changes in Scope of Y2K System Deficiencies Listed or Util Projected Completion Schedule for Comanche Peak Steam Electric Station,Units 1 & 2 ML20212E6661999-09-21021 September 1999 Advises That Info Contained in Application & Affidavit, (CAW-99-1342) Re WCAP-15009,Rev 0, Comache Peak Unit 1 Evaluation for Tube Vibration Induced Fatigue, Will Be Withheld from Public Disclosure ML20212D9111999-09-16016 September 1999 Informs That on 990818,NRC Completed Midcycle PPR of CPSES & Did Not Identify Any Areas in Which Performance Warranted Insp Beyond Core Insp Program.Core Insp Plan at Facility Over Next 7 Months.Insp Plan Through March 2000 Encl ML20212A7601999-09-14014 September 1999 Forwards Insp Repts 50-445/99-14 & 50-446/99-14 on 990707-0821.Four Violations Occurred & Being Treated as Ncvs.Conduct of Activities Was Generally Characterized by safety-conscious Operations & Sound Radiological Controls TXX-9921, Suppls 981221 LAR 98-010 to Licenses NPF-87 & NPF-89, Clarfying Conditions of Use Re Analytical Methods Used to Determine Core Operating Limits,Per Telcon with NRC1999-09-10010 September 1999 Suppls 981221 LAR 98-010 to Licenses NPF-87 & NPF-89, Clarfying Conditions of Use Re Analytical Methods Used to Determine Core Operating Limits,Per Telcon with NRC ML20211P3761999-09-0707 September 1999 Ack Receipt of Ltr Dtd 990615,transmitting Rev 30 to Physical Security Plan,Per 10CFR50.54(p).No NRC Approval Is Required ML20211L9871999-09-0303 September 1999 Forwards Rev 31 to Technical Requirements Manual. All Changes Applicable to Plants Have Been Reviewed Under Util 10CFR50.59 Process & Found Not to Include Any USQs TXX-9915, Responds to 990701 & 0825 RAI Telcons Re Spent Fuel Pool Temp,Per LAR 98-008,which Requested Increase in Spent Fuel Storage capacity.Marked-up Page 4-1 of CPSES Fuel Storage Licensing Rept, Encl1999-09-0303 September 1999 Responds to 990701 & 0825 RAI Telcons Re Spent Fuel Pool Temp,Per LAR 98-008,which Requested Increase in Spent Fuel Storage capacity.Marked-up Page 4-1 of CPSES Fuel Storage Licensing Rept, Encl ML20211K2231999-08-31031 August 1999 Forwards Txu Electric Comments of Rvid,Version 2 ML20211J3801999-08-27027 August 1999 Forwards Corrected TS Page 3.8-26 to Amend 66 to Licenses NPF-87 & NPF-89,respectively.Footnote on TS Page 3.8-26 Incorrectly Deleted ML20211G7301999-08-26026 August 1999 Forwards Revs 29 & 30 to CPSES Technical Requirements Manual (Trm). Attachments 1 & 2 Contain Description of Changes for Revs 29 & 30 Respectively ML20211G1081999-08-26026 August 1999 Responds to NRR Staff RAI Re Util Mar 1999 Submittal for NRC Review & Approval of Changes to CPSES Emergency Classification Procedure ML20211G3441999-08-25025 August 1999 Forwards Response to NRC RAI on LAR 98-010 for Cpses,Units 1 & 2.Communication Contains No New Licensing Commitments Re Cpses,Units 1 & 2 ML20211B2861999-08-18018 August 1999 Forwards Insp Repts 50-445/99-13 & 50-446/99-13 on 990720- 23.No Violations Noted.Insp Included Implementation of Licensee Emergency Plan & Procedures During Util Biennial Emergency Preparedness Exercise ML20211C4661999-08-18018 August 1999 Discusses Proprietary Info Re Thermo-Lag.NRC Treated Bisco Test Rept 748-105 as Proprietary & Withheld It from Public Disclosure,Iaw 10CFR2.790 ML20210U3981999-08-17017 August 1999 Forwards Monthly Operating Repts for July 1999 for CPSES, Units 1 & 2,per TS 6.9.1.5.No Failures or Challenges to PORVs or SVs for Plant Occurred ML20211C0991999-08-17017 August 1999 Forwards Rev 3 to ASME Section XI ISI Program Plan,Unit 2 - 1st Interval, Replacing Rev 2 in Entirety ML20211C4571999-08-16016 August 1999 Forwards Omitted Subj Page of Contractor TER TXX-9919, Forwards Relief Request A-3,Rev 1 to Unit 1 ISI Program,Per Conversations Between NRC & Txu Electric on 9908021999-08-16016 August 1999 Forwards Relief Request A-3,Rev 1 to Unit 1 ISI Program,Per Conversations Between NRC & Txu Electric on 990802 ML20210R6561999-08-13013 August 1999 Forwards Response to NRR 990805 Telcon RAI Re License Amend Request 98-010,to Increase Power for Operation of CPSES Unit 2 to 3445 Mwth & Incorporating Addl Changes Into Units 1 & 2 TS ML20211A9501999-08-12012 August 1999 Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl ML20210S6411999-08-12012 August 1999 Informs That Wg Guldemond,License SOP-43780,is No Longer Performing Licensed Duties.Discontinuation of License Is Requested ML20210R2221999-08-12012 August 1999 Forwards Insp Repts 50-445/99-10 & 50-446/99-10 on 990510-0628.Violations Noted & Being Treated as Ncvs, Consistent with App C of Enforcement Policy ML20210N1101999-08-0404 August 1999 Provides Supplemental Info to Util 990623 License Amend Request 99-005 Re Bypassing DG Trips.Info Replaces Info Contained in Subject Submittal in Attachment 2,Section II, Description of TS Change Request ML20210L1461999-08-0303 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams ML20210J2301999-08-0202 August 1999 Forwards Amend 96 to CPSES Ufsar.Replacement of FSAR Figures with Plant Process Flow Diagrams Meets Intent & Requirements of NRC Reg Guide 1.70,Rev 2 ML20210J6071999-08-0202 August 1999 Forwards line-by-line Descriptions of Changes in Amend 96 to CPSES UFSAR Transmitted by Util Ltr TXX-99166,dtd 990802. Replacment of FSAR Figures with Plant Process Flow Diagrams Meets Intent & Requirements of NRC Reg Guide 1.70,rev 2 TXX-9916, Notifies NRC That CPSES Units 1 & 2,improved TS Implemented on 9907271999-08-0202 August 1999 Notifies NRC That CPSES Units 1 & 2,improved TS Implemented on 990727 TXX-9918, Forwards CPSES 10CFR50.59 Evaluation Summary Rept 0008,for 970802-990201 & CPSES Commitment Matl Change Evaluation Rept 0003,for 970802-9906301999-08-0202 August 1999 Forwards CPSES 10CFR50.59 Evaluation Summary Rept 0008,for 970802-990201 & CPSES Commitment Matl Change Evaluation Rept 0003,for 970802-990630 ML20210K2321999-07-29029 July 1999 Forwards Insp Repts 50-445/99-12 & 50-446/99-12 on 990530-0710.No Violations Noted ML20210G5861999-07-29029 July 1999 Forwards fitness-for-duty Program Performance Data for Six Month Period of Jan-June 1999 ML20210J0121999-07-27027 July 1999 Forwards Summary of Methodology for Determination of NDE Measurement Uncertainty,In Response to Recent Discussions with NRC Re LAR 98-006 Concerning Rev to SG Tube Plugging Criteria TXX-9917, Provides Info Re Augmented Inservice Insp Plan,Which Requires Periodic Insp of Rv Head & Internals Lifting Devices at CPSES1999-07-26026 July 1999 Provides Info Re Augmented Inservice Insp Plan,Which Requires Periodic Insp of Rv Head & Internals Lifting Devices at CPSES ML20210F3121999-07-26026 July 1999 Responds to GL 99-02, Laboratory Testing of Nuclear-Grade Activated Charcoal, ML20210D8231999-07-23023 July 1999 Forwards Safety Evaluation of Relief Requests Re Use of 1998 Edition of Subsections IWE & Iwl of ASME Code for Containment Insp ML20210D3211999-07-21021 July 1999 Provides List of Estimates of Licensing Actions,In Response to Administrative Ltr 99-02,dtd 990603 ML20210C2931999-07-21021 July 1999 Supplements 880323 Response to NRC Bulletin 88-02, Rapidly Propagating...Sg Tubes, Non-proprietary WCAP-15010 & Proprietary Rev 0 to WCAP-15009, CP Unit 1 Evaluation for Tube Vibration... Encl.Proprietary Rept Withheld ML20209H0111999-07-16016 July 1999 Forwards Relief Request C-4 to CPSES Unit 2 ISI Program for Approval ML20210C3331999-07-16016 July 1999 Forwards Exam Repts 50-445/99-301 & 50-446/99-301 on 990618- 24.Exam Included Evaluation of Six Applicants for Senior Operator Licenses ML20209H2551999-07-16016 July 1999 Forwards ISI Summary Rept for Fourth Refueling Outage of CPSES Unit 2 & Containment ISI Summary Rept for Fourth Refueling Outage of CPSES Unit 2,per ASME Boiler & Pressure Vessel Code,Section Xi,Paragraph IWA-6230 1999-09-07
[Table view] Category:EXTERNAL CORRESPONDENCE
MONTHYEARTXX-9914, Responds to 990525 RAI Re Renewal of Tpdes Permit Number 01854.Explanation & Response to Each Item,Listed1999-06-16016 June 1999 Responds to 990525 RAI Re Renewal of Tpdes Permit Number 01854.Explanation & Response to Each Item,Listed ML20206E7271999-04-29029 April 1999 Submits Original & Four Complete Copies of Application for Renewal of Permit to Discharge,Deposit or Dispose of Wastes Into or Adjacent to Water in State. with Three Oversize Drawings ML20045D3451992-06-16016 June 1992 Discusses Util Review of 920603 Ltr Outlining Thermal Science,Inc Field Surveillance of Application of Thermo-Lag 330 Fire Barrier Sys on Util Test Assemblies at Omega Poing Labs.Supporting Documentation Encl ML20091Q2891992-01-27027 January 1992 Forwards Rev 7 to Quarterly Plant Performance & Other Indicator Data for Fourth Quarter of 1991 & Gross Heat Rate Data Form for 1991 ML20070T7651991-04-0101 April 1991 Forwards 910327 License Amend Request 91-001 Re Addition of Spec 3/4.7.12 & Bases 3/4.7.12 for Safety Chilled Water Sys ML20073D1051991-03-29029 March 1991 Comments on Final Rept Addressing Scaling for Unit 1,dtd Feb 1991 Per Insp Repts 50-445/90-47 & 50-446/90-47.Concerns Raised That Util Selected Criterion XI Re Test Control as Sole Mgt Std to Control safety-related Activities ML20066A5711990-12-19019 December 1990 Forwards Update to ASME Section Iii,Div 1 Code Control Program Documents for Incorporation Into State of Tx Dept of Licensing & Regulation Controlled Manual CCPM-15,authored by Ebasco ML20056B3741990-08-21021 August 1990 Forwards Update to ASME Section Iii,Div 1 Code Control Program Documents for Incorporation Into State of Tx Dept of Licensing & Regulation Controlled Manual CCPM-15 ML20011E1521990-01-27027 January 1990 Forwards Addl Case Concern Repts 89-0025 Re Apparent Substandard Shop Applied Welds Internal to Secondary Side of Steam Generators & 89-0034 on Specific Wiring & Connection Method Damaging safety-related Electrical Wiring ML20248D0661989-09-21021 September 1989 Notifies Util of Case Position on Concerns & Problems in Scaling Calculation Program at Plant.Documentary Info Supporting Util Position on Aspect of Dispute Should Be Provided ML19332C7971989-09-14014 September 1989 Forwards Offsite Portion of Annual Emergency Preparedness Independent Review & Status of Corrective Actions Initiated, Per 10CFR50.54(t) ML19332E0011989-09-14014 September 1989 Forwards Offsite Portion of Annual Emergency Preparedness Independent Review Per 10CFR50.54(t) ML19332D4781989-09-14014 September 1989 Forwards Offsite Portion of Annual Emergency Preparedness Independent Review to Be Conducted Every 12 Months.Review Must Include Evaluation for Adequacy of Interfaces W/State & Local Govts ML19332C8171989-09-14014 September 1989 Forwards Offsite Portion of Annual Emergency Preparedness Independent Review & Status of Corrective Actions Initiated, Per 10CFR50.54(t) ML20246A0421989-08-18018 August 1989 Advises That S&W Notified by Util That Responsibility for Facility Code Control Program Will Be Terminated Effective on 890823.EBASCO Svcs,Inc Selected to Assume Responsibility for Code Control Program Effective on 890824 ML20247R7291989-07-28028 July 1989 Advises That Status of Suspect molded-case Curcuit Breakers, Identified in Initiative Element One Will Be Provided by 890815.Util Estimates That 750 nonsafety-related Breakers in Warehouse Stock Examined as Part of Initiative Element Two ML20247D2491989-07-12012 July 1989 Forwards Communications Repts Associated W/Design Control Review ML20247A9261989-05-11011 May 1989 Forwards State of Tx & Local Govt Objectives for Graded Exercise Scheduled for 890725-26 ML20245J3341989-04-0707 April 1989 Forwards Summary of Points of Agreement Reached at 890308 Meeting.Agreements Will Be Subj to Further Discussion Among Parties.W/Certificate of Svc.Served on 890427 ML20246H4791989-03-0606 March 1989 Forwards Communications Repts Associated W/Corrective Action Programs for Plant Independent Assessment Program Phases ML20206F7201988-11-14014 November 1988 Forwards Communications Rept Transmittal 47 Re Independent Assessment Program on All Phases of Conduit Support Design Review ML20151X2621988-08-19019 August 1988 Forwards Rev 4 to Independent Assessment Program:Conduit Support Design Review Issues List for Comanche Peak Electric Station - Unit 1 ML20154H6281988-05-21021 May 1988 Requests to Be Advised at Earliest Opportunity Whether Projected Schedule for Issuance of Phase IV Rept Available. Related Correspondence ML20147G2941988-03-0303 March 1988 Forwards Communication Repts Re Cable Tray Audits,Per Independent Assessment Program ML20147F8911988-03-0303 March 1988 Forwards Communications Repts Associated W/Piping/Pipe Support Audits ML20147H4891988-03-0303 March 1988 Forwards Communications Repts Associated W/Independent Assessment Program Conduit Audits ML20147G2261988-03-0303 March 1988 Forwards Communications Repts Associated W/Civil/Structural Audits ML20196F7451988-02-23023 February 1988 Forwards Surveillance Repts Associated W/Phase 4 Independent Assessment Program Obtained During Util Review ML20196D4541988-02-0909 February 1988 Forwards Rev 4 of Mechanical Review Issues List (Ril). Rev Includes Review Issue 10 Re Component Cooling Water Sys Butterfly Valve at Outlet of Residual Heat Removal Hx.Rev of Ril Reflects Info That Cygna Gained Prior to Dec 1987 ML20236X2701987-11-25025 November 1987 Forwards Communications Repts on Independent Assessment Program,Phase 4 Re Cable Tray,Civil/Structural & Conduit Audits ML20236S1281987-11-13013 November 1987 Forwards Communications Repts Associated W/Civil/Structural Audits.List of Communications Repts Encl ML20236R9531987-11-13013 November 1987 Forwards Communications Repts Associated W/Cable Tray Audits.List of Communication Repts Encl ML20236S3231987-11-13013 November 1987 Forwards Communications Repts Associated W/Conduit Audits. List of Communications Repts Encl ML20236R9361987-11-13013 November 1987 Forwards Communications Repts Associated W/Piping/Pipe Support Audits.Repts Also Listed in Attachment ML20236M3131987-11-0909 November 1987 Forwards Communications Repts Associated W/Cable Tray Audits,Per Communication Repts Transmittal 33 for Independent Assessment Program - All Phases.List of Encl Communication Repts Provided on Attachment 1 TXX-6932, Advises That Value of 7.43 Ph Units Reported in Performance Evaluation Rept DMR-QA Study 7 Re 1987 NPDES QA Program Incorrect Due to Clerical Error.Reported Value Should Have Been 8.43 Ph Units,Which Is within Acceptable Range1987-11-0606 November 1987 Advises That Value of 7.43 Ph Units Reported in Performance Evaluation Rept DMR-QA Study 7 Re 1987 NPDES QA Program Incorrect Due to Clerical Error.Reported Value Should Have Been 8.43 Ph Units,Which Is within Acceptable Range ML20235W3331987-10-10010 October 1987 Forwards Communications Repts Re Civil/Structural Audits,Per Independent Assessment Program,Phase 4 ML20235V4691987-10-10010 October 1987 Forwards Communications Repts Re Cable Tray Audits,Per Facility Independent Assessment Program,Phase 4 ML20235R4941987-09-30030 September 1987 Notifies of Confirmation That Util Given Extension Until 871026 to Respond to Case Motion to Compel Applicants to Supply Complete Answers to Consolidated Intervenors Interrogatories & Request for Production of Documents ML20235R1961987-09-18018 September 1987 Forwards Rev 4 of Pipe Support Review Issues List. Any Procedural Control Issues Associated W/Author Original Pipe Support Reviews of Gibbs & Hill Being Processed as Part of Ongoing Design Control Assessments ML20235R0571987-09-18018 September 1987 Forwards Communications Repts Re Cable Tray Audits ML20234B1451987-09-16016 September 1987 Forwards Rev 4 to Pipe Stress Review Issues List (Ril).All Technical Issues Associated W/Discipline Closed.Still Waiting for S&W Calculation 15454-NZ(B)-GENX-035,Rev 2 to Verify Completion of Commitments Associated W/Ril 11 TXX-6718, Forwards Listed Outstanding Documents Requested Through Audits of Ebasco Svcs,Inc1987-09-0404 September 1987 Forwards Listed Outstanding Documents Requested Through Audits of Ebasco Svcs,Inc ML20238E5591987-09-0303 September 1987 Confirms That Brazos Understanding of Phrase,As Set Forth in Objections & Responses of 870814,essentially Correct. Related Correspondence ML20237K7081987-09-0101 September 1987 Forwards Communications Rept Transmittal 28,transmitting Cable Tray Audits Re Independent Assessment Program - Phase 4 for Plant.Delay in Processing Telcons Noted Due to Word Processing Sys Conversion.W/O Encl ML20237K7931987-09-0101 September 1987 Forwards Communications Rept Transmittal 29,transmitting Piping/Pipe Support Audits for Independent Assessment Program Phase 4.W/o Encl ML20237J9981987-09-0101 September 1987 Forwards Communications Rept Transmittal 27,transmitting Conduit Audits Re Independent Assessment Program - Phase 4 for Plant.Delay in Processing Telcons Noted Due to Word Processing Sys Conversion.W/O Encls ML20237K0091987-08-11011 August 1987 Memorializes Recent Conversations & Resulting Agreement Re Extension of Time Until 870908 for Filing Case & M Gregory Response to Applicant 870713 Motion for Reconsideration of Board 870622 Order.Related Correspondence ML20237J1281987-08-10010 August 1987 Forwards Rev 14 of Cable Tray Supports Review Issues List. Rev Based on Info Provided in Util Rev 2 to Generic Issues Rept for Cable Tray Hangers,Transcripts of Public Meetings & Results of Cynga Audits Through 870731 ML20236D3271987-07-22022 July 1987 Forwards Rev 0 to Civil-Structural Review Issues List, Based on Ref Info,Transcripts of Public Meetings,Documents Provided by Util & Results of Cygna Audits Through 870613 1999-06-16
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C A (CITIZENS ASSN. FOR SOUND ENERGY)
March 29, 1991 Mr. W. G. Counsil Vice Chairman TV Electric 2001 Bryan Tower, Suite 1900 Dallas, Texas 75201
Dear Mr. Counsil:
Subject:
Scaling Calculation Dispute Comanche Peak Steam Electric Station (CPSES),
Jaita 1 an_d_L_Rogigt Nos. 50-445 and @ .443 Re: Office of Nuclear Reactor Reguletion, U. S.
Nuclear Regulatory Commission, Final Report Addressing Scaling for Comanche Peak Steam Electric Station (CPSES), Unit 1. Enclosure 1, dated: February 1991 CASE is in receipt of the referenced U. S. Nuc10er Regulatory Commission (NRC) final report encompassing:
- 1. the U. S. NRC letter to CASE President Mrs. Juanita Ellis, dated February 27, 1991, responding to the dispute regarding the scaling calculation issue at CPSES;
- 2. the U. S. NRC scaling calculation final report; and
- 3. the U. S. NRC Notice of Violation (NRC Inspection Report Nos. 50-445/90-47; 50-446/90-47), dated February 26, 1991, reporting NRC inspection results conducted Oecomber 14, 1990, through February 21, 1991, encompassing the scaling calculation program at CPSES.
The NRC inspection report identified "the failure to promptly identify and correct deficiencies with scaling documantation for initial setup and calibration of instrumentation loops." Additionally, the NRC was concerned that "significant involvement from a former employee and from CASE over an extended period of time" was required "before the deficiencies with scaling doeurnentation were adoQuately identified and corrected."
Tne Notice of Violation reported that TV Electric was in violation of 10 CFR Part 50, Appendix B, Criterion XVI, " Corrective Action," for the problems identified by the former employee during the 1986/1987 time frame which were not corrected to the satisfaction of ths NRC until 1990.
The NRC requested TV Electric to provida, within 60 days (of February 26, 1991), "a written explanation of how scaling activities will be performed for CPSES, Unit 2, to assure that documentation problems are prevented or I
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promptly identified and corrected. Also, because of our (the NRC's] concern with your (TU Electric's) delay in responding to an employee's concern in this instance, we (the NRC) request that you (TV Electric) provide a written response describing how employee concerns will be handled to prevent delays and to encourage prompt identification and correction of potential safety l 1ssues." j We are therefore providing, for your evaluation in responding to the NRC, what is intended to be constructive input resulting fron our review of the referenced report. Additionally, even though the NRC considers TU Electric's actions (in this instance) regarding the " corrective action" ;
issues to be acceptable, and has not required a written response, CASE feels obligated to address the matter of corrective action as well as the other violations of 10 CFR Part 60. Appendix B, reported in our final report of July 9, 1990.
The many-f aceted concerns raised in the CASE draft report of December 6, 1989, followed by the detailed CASE final report of July 9,1990, reported on both the safety-related and balance-of-plant programmatic and technical scaling issues for CPSES, Unit 1, as well as violations of 13 of the 18 criteria of 10 CFR Part 50, Appendix B. In CASE's view, the balance-of-plant programmatic and technical scaling issues also had safety-related implications.
As reported by the NRC in its inspection report, scaling concerns were initially raised (by Mr. Gary Bodiford) in the 1986/1987 time frame.
Additionally, these concerns were included in one of a few lawsuits which were outstanding at the time of the July 1988 CASE /TV Electric Settlement Agreement and CASE /TU Electric /NRC Staff Joint Stipulation. TV Electric committed to work with CASE to try to resolve Mr. Bodiford's concerns; these '
concerns, however, were still not resolved as late as 1990.
CASE, however, also recognizes and appreciates the efforts of TU Electric subsequent to the initial meeting of May 1989 between Mr. Bodiford, TV <
Electric, and CASE to investigate and rosolve the scaling concerns identified by Mr. Bodiford, CASE does not agree with the recently stated '
position of TU Electric that the scaling project was intendcd to be merely an " aid" to the I&C and Operations field effort. 'This was never CASE's .
' understanding of the purpose of the scaling calculation program at CPSES. Had that been the case .we would certainly not have devoted the
- massive amount of time, money, and effort to the identification, articulation, documentation, and resolution of Mr. Bodiford's concerns which we invested. Had that been the case, there were many other safety-related issues to which CASE could have, and would have, devoted its resources.
Further, even had that been the case, once a commitnent was made by TU Electric (beginning as early as 1979 with the inception of the scaling program conducted by Westinghouse) that the scaling calculation program was to be included and covered by the requirements of 10 CFR Part 50, Appendix B, from that point on the TV Electric inspection and audit program should 2
,e f
have come fully into play and nrpmptly identified and corrected the problems identified by Mr. Bodiford and CASE.
Additionally, CASE remains extremely concerned that TV Electric appears to have chosen to select Criterion XI. Test Control, of 10 CFR Part 50, Appendix B, as the sole management standard (irrespective of all others) to control and assure that the safety-related activities were effective in implementing the scaling calculation program. At a minimum, TU Electric has apparently disregarded equally important RERY9nL100 aspects of 10 CFR Part 50, A,npendix B, such as: assuring quality over cost and schedule and that an appropriate quality assurance progran is effectively developed, mtintained, and executed, including that of the contractor (s) (Criterion I, Organization); assuring that the quality assurance program is regularly reviewed for both status and adequacy (Criterion II, Quality Assurance Program); assuring that design bases are correctly translated into specifications, drawings, procedures, and instructions, and that deviations from such standards are controlled including verifying or checking the adequacy of design (Criterion III, Design); assuring that purchased services conform to procurement requirements (Criterion VII, Control of Purchased Haterial Equipment, and Services); and, that audits are carried out to verify compliance with all aspects of the quality assurance program (Criterion XVIII, Audits).
As previously stated, however, throughout CASE's involvement with Mr.
Bodiford and TV Electric, the scaling effort was always visibly administered as a safety-related project, attempting to implement (by process of the organizational and programmatic controls by both the contractor and TU Electric), the tenets of 10 CFR Part 50, Appendix B. Nothing else was expected, and nothing less should h6ve been achieved during the conduct of the program. Two previous vendors (Westinghouse and Gibbs & Hill) to the present organization (Stone and Webster Engineering Corporation, SWEC) were contracted by TV Electric in an attempt to achieve a satisfactory end product (scaling calculations) which required all the discipline and checks and balances included in 10 CFR Part 50, Appendix B. This was not achieved by the implementation of either the contractors' or the utility's Quality
< Assurance programs.
CASE does not agree that the only violation to 10 CFR Part 50, Appendix B, involved Criterion XVI, " Corrective Action" (although we certainly agree that Criterion XVI was violated). At a minimum, CASE suggests that TV Electric closely evaluate the Audit and Surveillance programs administered by both the contractors and TV Electric to evaluate why the many inspections conducted by these organizations failed to adequately follow-up on the concerns identified by Mr. Bodiford to: the contractor (SWEC) in the 1986/1987 time frame; the SAFETEAM in November of 1987; and by TV Electric in May 1988 (NE-19097). It is the assessment of CASE that each of these organizations totally failed to conduct critical examinations in accordance with Criterion XVIII, " Audits," which should have detected and corrected the various violations identified in the CASE roports. A dynamic, properly 3
implemented QA audit program has the capability of, and is relied upon for, detecting and correcting programmatic and implementation deficiencies and weaknesses associated with the other seventeen Criteria of Appendix B.
In fact. it is CASE's further evaluation that had the special audit (ATP 146S) not been performed with the significant planning input and in-process monitoring by CASE (i.e., Gary Bodiford and CASE Consultant Owen Thero),
the issues identified by the audit, which resulted in resolution of the many audit deficiencies / observations and the significant action plan developed by TU Electric, would not have occurred. This programmatic failure of the audit and surveillance programs, in CASE's assessment, must be evaluated as a potential root cause for the breakdown in the project's corrective action program.
It is also CASE's assessment that TV Electric should not take solace in the fact that the NRC (see Section VII. General Conclusions, NRC Final Report) states, in part:
". . . (B]ecause the scaling documentation was considered by the licenses to be an aid to the initial setup and calibration process, and not a primary design tool, the [HRC) staff does not consider the poor implementation of the scaling documentation process to be indicative of a pervasive breakdown of the QA program during the time period in question (1986 to 1988). . . .
The staff further concludes that, while the licensee's initial performance was poor in the development of the scaling-related documentation, the safety of plant operation was not compromised due to the corrective actions taken in the latter part of the licensing stage ( Anisled_hy_the effortLof the CASE or_gaJ111011QB) along with in-place testing of the 7300 series system by knowledgeable personnel and evaluation results obtained from hot functional and pre-operational testing." (Emphasis added.)
CASE basically agrees with the NRC and TV Electric that apparently a strong I&C and Operations program would and did uncover the majority (though not necessarily all) of the deficient conditions created by the deficiencies identified by Mr. Bodiford and as documented in the CASE reports / meetings.
That was not the primary issue in CASE's pursuing the resolution of Mr.
Bodiford's concerns.
Obviously. TV Electric did not purposely elect to poorly implement the scaling program just because they planned to manage and depend on a much stronger preoperational test program, any more than they would have purposely implemented a poor weld inspection and NDE program just because they planned to have and rely on a strong hydrostatic testing program for their piping system. Title 10 of the Code of Federal Regulations (10 CFR) requires / mandates a strong total approach to quality (10 CFR Part 50, Appendix B) when safety-related programs and controls are encountered by a
. 4
s licensee. This was not done by either the responsible contractors or TV Electric during the implementation of the scaling project for Unit 1.
Although it is gratifying to CASE to receive recognition for its work, the fact is that CASE is not part of the QA program for CPSES. Moreover, although CASE will continue to do what it can with its limited resources to assure public health and safety, it must be remembered that TV Electric is the licensee; as such, TV Electric has the greatest responsibility and must also shoulder its own burden in this regard to meet the goal of assuring the public health and safety. Of particular concern to CASE is the f act that CASE's role is scheduled to soon be over in some portions of the monitoring of Comanche Peak (notably the monitoring of audits under paragraph A.11 of the CASE /TU Electric /NRC Staff Joint Stipulation). CASE is still very concerned that the QA audit program mandated by 10 CFR Part 50, Appendix B, Criterion XVIII, is not achieving the purpose which was intended and which is necessary. A strong and critical QA audit program must be relied on to fulfill an essential and effective auditing responsibility. CASE implores TU Electric to assure that this critical evaluation encompassing audits /surveillances is developed and implemented to incorporate issues arising from lessons learned from Ur.it 1 activities, employee concerns, and other areas reported as being deficient (ONE/TUE forms, test programs, PIR's/LER's, trending, etc.) and that the results of the evaluation are incorporated into these assessment programs, and thereby utilized in a positive and constructive manner.
Also, since the audits /surveillances are a very brief snap-shot in time, incorporating a small evaluation sample, it is imperative that the functions be performed with a critical eye. " Adequate" cannot be acceptable when audit evaluations are concerned. Extreme caution must be exercised to determine when an audit-found deficiency is determined to be " isolated" and when an auditor allows a ONE/TUE form to be initiated by the audited organization rather than by the auditor, thereby mitigating the need to perform additional inspections and to perform a root cause analysis -- and thereby negating, in advance, much of the effectiveness of the audit progrom.
The exper16nce of the CASE Monitors has been that too often QA auditors who otherwise may be experienced, qualified, capable individuals appear to find it difficult or ispossible to bring themselves to take a hard line with the audited organization and to accept the role of what amounts to the internal policemen of the nuclear industry. CASE understands that no one wants to be disliked by the people one works with and that this is indeed a difficult position for the auditors to be in; however, it is also a necessary function of a QA auditor, and one which will ultimately be most beneficial to the audited organization. TU Electric, and the public health and safety. CASE urges that TU Electric do everything possible to turn around what we believe to be a continuing inadequacy in the QA audit function. CASE believes that this is an area where TV Electric upper management can be extremely helpful 5
in naking certain that both the auditors and the audited organizations fully understand what is expected of them and why.
Additionally, it is requested that TV Electric review all PIR's/LER's to determine if a deficient or enhanced scaling calculation could have prevented and/or mitigated the condition from occurring, and that any such enhancements be incorporated into the scaling effort for Unit 2.
It is also requested that the examples provided in the CASE final report for enhancements of the 1-SC-8800 Scaling Manual be evaluated for incorporation into the Scaling Manual for Unit 2.
CASE offers this assessment and these suggestions in the hope that TV Electric will consider them as constructive criticism and utilize them to improve the project's fulfillment of its audit responsibilities in complying with regulatory requirements, thereby protecting the public health and safety.
Sincerely, CASE (Citizens Association for Sound Energy)
M Hrs.) Juanita Ellis President cc: Mr. W. J. Cahill, Jr.
Executive Vice President TV Electric 400 North Olive Street. LB 81 Dallas, Texas 75201 George L. Edgar, Esq.
Newman & Holtzinger, P. C.
1615 L Street, H. W.
Washington, D. C. 20036 Ms. Susan S. Palmer Stipulation Manager TV Electric -- CPSES P. O. Box 1002 -- Highway $6 Glen Rose, Texas 76043 Mr. Christopher I. Grimes, Director Project Directorate IV-2 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 6 j
t Mr. T. P. Gwynn Deputy Director '
Division of Reactor Projects U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 '
Arlington, Texas 76011 Mr. Dennis Crutchfield Assistant Director of Special Projects U. S. Nuclear Regulatory Cocamission Washington, D. C. 20555 Mr. Joe Callan Director -
Reactor Safety Division .
4 ~ U. S. Nuclear Regulatory Commission '
Region IV '
611 Ryan Plaza Drive, Suite 1000 Arlington . Texas- 76011 Mr. Robert D. Martin Regional Administrator U. S.-Nuclear Regulatory Commiosion Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 Dr. Ausaf Husain, Chairman. .
Operations Review Committee (DRC)
TV Electric -
400 North Olive, LB 81 Dallas, Texas 76201 i
7
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