ML20127N082
| ML20127N082 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 06/28/1985 |
| From: | Renee Taylor NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20127N039 | List: |
| References | |
| OL, NUDOCS 8507010428 | |
| Download: ML20127N082 (55) | |
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g CORRESPONDENCA P
00LKETE0 USNRC
'85 JUN 28 P1 :43 UNITED STATES OF AMERICA NUCLEAR REGULATORY CCPMISSION 0FFicE OF SEchtiA.-
00CKETING & SERVlu BEFORE THE ATOMIC SAFETY AND LICENSING BOARDBRANCH In.the Matter of
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HOUSTON LIGHTING AND POWER COMPANY,
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Docket Nos. 50-498
_ET_ _AL.
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50-499
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(South Texas Project, Units 1 & 2)
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Testimony of Robert G. Taylor Q.1 Would you please state your name, business address, employer and position?
A.1 I am Robert G. Taylor, Project Inspector, Region IV, Nuclear Regulatory Commission. My business address is 611 Ryan Plaza Drive, Suite 1000, Arlington, Texas.
Q.2 What are your current duties and responsibilities in this position?
A.2 I coordinate safety-related inspection efforts relative to reactors assigned to me. My duties include coordination of Region IV construction inspection activities of Near Term Operating License Facilities.
85070104288506y6pgg PDR ADOCK 050 T
t o Q.3 Mr. Taylor, have your professional qualifications been admitted into evidence in this proceeding previously?
A.3 Yes. My professional qualifications appear following Tr. 9126, ff.p.64.
Q.4 Are there any changes in those qualifications that should be made?
A.4 Yes.
In 1984 I left the position of senior resident reactor inspector-construction, Comanche Peak, and became the project inspector for the Wolf Creek and River Bend Stations.
I continue in that position to the present day.
Q.5 Mr. Taylor, are you familiar with the " Design Review of Brown & Root Engineering Work for the South Texas Project," prepared for Houston Lighting and Power Company by the Quadrex Corporation and dated May 1981?
A.5 Yes. That document is referred to as the Quadrex Report.
Q.6 k' hat is the purpose of your testimony?
A.6 The purpose of my testimony is to evaluate and assess findings identified by the Board which are in the Quadrex Report, with regard to whether any of these findings were reportable to the NRC under the requirement of 10 CFR 50.55(e).
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. 0.7 Are you familiar with the Licensing Board's interpretation of 10 CFR 50.55(e) contained in its Memorandum and Order of February 26, 19857 A.7 Yes.
I have based my testimony herein on that interpretation.
Q.8 Have you examined and evaluated generic finding 3.1(a) of the Quadrex Report?
A.8 Yes.
In my view, the overall finding consists of four sub-items of concern with the B8R design process. They state that interfaces between the various engineerin.g disciplines are not effective, and that there is no overall plant criteria for separation of systems and components.
They also indicate that there is no interdisciplinary interpretation for the treatment of the single failure criterion and that the fire hazard analysis has not been converted into a control document for general design usage.
Q.9 Did you also review the documents referenced with the concern or finding to aid you in' understanding the basis for their finding?
A.9 In each instance where such a reference has been provided, it has been reviewed. References within these references, such as to drawings were not reviewed.
Q 10 Have you evaluated this finding and/or its subsets for potential violation of any of the criteria of Appendix B to 10 CFR 50?
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A.10 Yes.
I also used American National Standard Institute (ANSI) document N45.2.11 titled, " Quality Assurance Requirements for the Design of Nuclear Power Plants," as an aid.
I have attached a copy to this testimony.
Q.11 What is the status of this dccument within the NRC?
A.11 The NRC staff has endorsed the standard with clarification via Regulatory Guide 1.64, Revision 2, June 1976.
Q.12 Did you find that the. generic finding of any of its sub-items violate any of the requirements of Appendix B?
A.12 I have found no requirement in either Appendix B or N45.2.11 that would
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make an integrated systems level review a necessity.
I would note that the sub-item in regard to interdisciplinary interfaces was not supported by any reference. The same comment applies to the sub-item on interdisciplinary criteria for use of the single failure criterion. The other two sub-items appear to flow from the only reference, question H-6.
The Quadrex assessment of this question does not direct itself to whether the data provided by B&R was, or was not, found adequate; rather it states that there was no STP criteria for physical separation, with the reviewers making independent decisions on adequacy.
It further states that a subcontractor document was not converted into a control document but failed to indicate whether the B&R design was, or was not, adequate in regard to fire hazards.
The lack of factual
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.. support for the assertions has made it difficult to determine if a violation exists.
Q.13 Was the overall generic finding, or any subpart of it, required to have beenreportedunder10CFR50.55(e)?
A.13 In my judgment, such a report either as a potential reportable item or as a reportable item would have been inappropriate given the complete lack of factual data upon which to make an assessment.
Q.14 Is the fact that this Quadrex. finding was not reported under 50.55(e),
in your view, an indication of a lack of candor or truthfulness on the part of the management of HL&P?
A.14 No.
Q.15 Does the fact that it was not reported refle'ct an unwillingness to abide by regulatory requirements on the part of the applicant?
A.15 No.
Q.16 Does it in any way indicate an abdication of, or refusal to accept, the responsibility to protect the health and safety ~of the public?
l A.16 No.
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Q.17 Does the fact that HL&P did not report this Quadrex finding reflect adversely on its character or competence to operate a nuclear plant?
A.17 No.
l Q.18
-Mr. Taylor, have you reviewed and evaluated generic finding 3.1(b)?
i A.18 Yes, I have also reviewed the total of 23 direct and indirect references
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that apply to this finding.
Q.19 Does that generic finding represent a violation of one or more of the criteria of Appendix B?
A.19 The three individual items of the overall finding must be considered separately since there is no obvious synergistic relationship between the three items that would have safety impact. Taking the first item, the Quadrex position seems to imply that an engineering group receiving data from another group should check the reasonableness of the data. At face value, this would appear to be a reasonable position, but in actuality, there will be many instances where this is not possible because the receiving group has neither the information nor the l
capability to test the data for reasonableness cnd must place reliance i
l on the expertise of the group from which they received the data.
It could be argued that Criterion X " Inspection" might be applicable.
If this were the case, it would always require that the work of one group be inspected by another group. Criterion III, however, allows an
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. individual in the same work group as the originator to do the inspection which is referred to as check or verifying. Regulatory Guide 1.64 has placed a restricticn on this practice in that the verifier shall not be a party who had input into the design, nor shall the reviewer be the originator's supervisor except under defined circumstances. These apparent concessions to the general idea of independence recognize the fact that the necessary expertise to perform a meaningful review may be in only one group.
4 The second part of the first item also indicates that each group providing data to another group has a responsibility to monitor how the receiving group uses that data.
I have found nothing in either Appendix 8 or the subordinate documents that would imply this is a requirement. Criterion XVIII does require that a planned and scheduled
-series of audits be carried out by personnel competent to verify that the QA program for design is being effectively implemented. Such an audit should test a design group's use of data received from other design groups but it is doubtful that each group would be so tested with a frequency that would satisfy the Quadrex expectation of " consistency."
I have no knowledge of whether such audits were effectively implemented nor have I found any such information referred to in the parts of 1.he Quadrex report that I have reviewed. On this basis, I have found that there is insufficient factual information to conclude that a violation exists.
Q.20 Could you now move on to the next item in this generic finding?
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D A.20 The Quadrex statement indicates that their review has shown design verified calculations with errors occurring at a rate higher than should be encountered. A similar statement appears in the Quadrex assessment of question C-16.
Neither of the statements contain any quantification of what was found nor do they provide a baseline for an acceptable error rate. N45.2.11 recognizes that some errors will reside in designs throughout the entire life of the design work and may not surface until the plant is in actual operation. When errors are detected, they would be evaluated for significance and corrective action taken appropriate to the circumstance. The fact that the Quadrex finding states that there is an excessive error rate does not constitute a violation.
Q.21 k' hat are your conclusions as to the final item?
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A.21 The final concern in this finding can only be well understood by considering the the remarks which continue on the same page.
First of all, it indicates a dissatisfaction with the fact that B&R did not perform a design review of the work performed by Westinghouse and EDS, Inc. as a matter of policy. Although I have no specific knowledge of the contract arrangements involved, if Westinghouse were a contractor to the licensee, B&R would have no respoasibility to review the design work of Westinghouse unless specifically directed to do so by the licensee.
There is no evidence of such a request from Quadrex. Most A/Es that I have experience with, do not have the engineering expertise to effectively review the designs of a Nuclear Steam Supply System vendor.
Further, N45.2.11 effectively holds each group responsible for the
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9 quality of its own work. That would certainly include Westinghouse in these circumstarces. The same basic logic must be applied to vendors doing design work for the A/E. The rationale for this is quite clear in that the A/E usually does not have the in-house expertise to create each and every design. As an example, the suppliers of pressure vessels generally are required to do the design work at a detail level that will create a vessel that will perform the design mission dictated by the A/E and fulfill the requirements of the applicable Code involved, usually ASME Section III. To do this, the vendor acquires the necessary engineering expertise to do the design detail work, whereas the A/E may well not have the specialized talent to do an effective review. Again, N45.2.11 recognizes that fact and requires that each engineering organization be fully responsible for its own work. ASME Section III also recognizes this situation in that it requires the designer to certify that his design meets the Code and further that he must be a
-registered professional engineer.
uQ.22 Again, in your opinion, do any of the three findings in 3(b) represent a violation of Appendix B?
A.22 No.- Appendix B does not require the engineer to review the design work of other design organizations.
Q.23 In your opinion, should any of the findings have been reported to the NRC.
. o A.23 Taken generically and as defined by Quadrex, findings one and three are not deficiencies and could not be construed as reportable or potentially reportable.
Finding two might have been considered potentially reportable if Quadrex had provided a preliminary assessment of the significance of the errors. The report did not provide sufficient information to conclude whether the item was reportable and subsequent evaluation demonstrated this item to be not reportable.
Q.24 Is the fact that this Quadrex finding was not reported, in your view, an indication of a lack of candor or truthfulness on the part of the management of HL&P?
A.24 No.
Q.56 Does it reflect an unwillingness to abide by regulatory requirements on the part of the applicant?
A.25 No.
Q.26 Does it in any way indicate an abdication of, or refusal to accept, the responsibility to protect the health and safety of the public?
A.26 No.
Q.27 Does the fact that HL&P did not report this Quadrex finding reficct adversely on its character or competence to operate a nuclear plant?
. A.27 No.
Q.28 Have you reviewed and evaluated generic finding 3.1(c)?
A.28 Yes, but let me clarify this item. Although there is an interrelationship among the six paragraphs of the finding, in many ways it is better to consider that each of the paragraphs, except for the fourth one, are discussing somewhat different things. The first paragraph states that no written design bases are provided to designers as to what combination of events and plant modes are to be considered.
Consideration of degraded equipment performance was stated as having been ignored. This very strong statemcnt, however, appears to have been moderated by the second paragraph which indicates that the design bases, taken to be the same as criteria, have not been revised from the 1973-1975 time frame to reflect more recent industry experience. The NRC staff has not, in general, required a continual upgrading of the design bases of the power facilities after the construction permit has been issued to reflect various events within the industry except when a substantial improvement in public health and safety can be achieved.
This statement can be confirmed by reference to 10 CFR 50.55a which stipulates which codes and standards are acceptable for use in designing and constructing the reactor coolant pressure boundary.
In effect, codes and-standards in effect when the facility was given a CP may continue to be used as the standard throughout the entire process.
In paragraph 3, it is indicated that in one design area (HVAC), the only design bases considered was " normal plant operations" which, even in the
, 1973-1975 time period, probably would not have been acceptable since heat loads and/or air flow paths might not be the same for all conditions. The other element of this paragraph deals with what appears
.to be a calculational error that led B&R to believe the essential cooling water pond was correctly sized when it may not have been.
Q.29 Do you view either the problem in the HVAC or with essential cooling water pond (ECP) to be indicative of a significant breakdown in the design QA program?
A.29 In the absence of other information, it appears that both situations were a matter of engineering judgmental error.
I would expect that in the case of the HVAC situation, that thc error would have eventually been identified by a design reviewer and corrected. Had an NRC inspector found a large calculational error as with the ECP situation he might have issued a violation based upon either Criterion V or VI of Appendix B.
Based on the information provided in Question N-17 at the time of the Quadrex Report, the more likely course would have been to issue an " unresolved item" which would cause the licensee to provide more information; i.e., evaluation but no violation would have been assessed.
Q.30 Should either the HVAC or the ECP items have been reported to the NRC?
A.30 The HVAC problem was in fact reported to the NRC in a telephone call to Region IV on May 8, 1981.
Based upon my understanding of Question N-17,
. I believe it should have been reported as a potential item pending further evaluation. With regard to the ECP find,ng, please see my testimony below (pp. 44-45 infra).
Q.31 Should this particular generic finding have been reported?
A.31 No. To have been reportable as a generic matter, the two incidents would have to been construed as being indicative of a significant breakdown in the design QA program. As I have indicated previously, I view the incidents as individual errors in engineering judgment not stemming from the same root cause, if indeed these >;ere errors at all.
These are, in my opinion, not indicative of a significant QA program breakdown, as defined in the IE guidance.
Q.32 Please move on to the final two paragraphs of the finding.
A.32 Paragraph five-indicates that a partion of the HVAC system was designed as a nonsafety system and appears to be related to the previous HVAC issue although the connection is not firm. The issue of safety-related versus nonsafety-related is essentially the subject of generic finding 3.1(d).
I will talk about the generic issue in that context.
Q.33 The last paragraph in 3.1(c) indicates that postulated line cracks and breaks in piping are inadequate. What is your view of this item?
. A.33 This item appears to follow from the fact that B&R used design bases from the 1973-1975 time period, however, Quadrex personnel were applying standards extant in 1981. The imposition of these newer standards would be a backfit of NRC requirements if applied by the staff and would require justification for their imposition. The failure to voluntarily upgrade does not constitute a violation.
Q.34 Do either of these items violate Appendix B?
A.34 Based upon the information available, I find in one case an error in engineering judgment (HVAC) and.in the other case, a deliberate, but not necessarily incorrect, perception. As such I don't see a violation of Appendix B as having been shown.
Q.35 Do you believe that all or any part of these two sub-items to have been reportable?
A.35 As I stated previously, the applicant did report the HVAC problem to the NRC in accordance with 50.55(e) on May 8, 1981.
In the case of pipe crack and break problem, the apparent deficiency relates to the application by Quadrex of a later standard and, therefore, it would not have been reportable.
Q.36 Would you now address the reportability overall of the generic finding?
- A.36 If indeed there is a generic overall finding here it can only be that
~there is no written design base or at least that the design base is in error. The Quadrex Report does not provide sufficient information for a conclusion. There is no basis for saying that a generic problem exists.
As such, it would nct be reportable even as a potential deficiency as called for in the April 1980 guidance on 50.55(e).
Q.37 Is the fact that this generic Quadrex finding was not reported, in your view, an indication of a lack of candor or truthfulness on the part of the management of HL&P?
A.37 No. As noted above, the ECP issue was subsequently resolved as being not reportable and, as I have indicated, the HVAC situation was in fact reported.
Q.38 Does it reflect an unwillingness to abide by regulatory requirements?
A.38 No. There was no regulatory requirement being violated.
Q.39 Does it in any way indicate an abdication of, or refusal to accept, the responsibility to protect the health and safety o. the public?
A.39 No.
Q.40 Does the fact that ifL&P did not report this Quadrex finding reflect adversely on its character or competence to operate a nuclear plant?
, 1 A.40 ' No.
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Q.41 Have you reviewed and evaluated generic finding 3.1(d)?
A.41 I have.
The issue here is that in the Quadrex view, B&R has established very sharp distinctions between safety and nonsafety activities and that, as a result, various engineering activities are done differently in each class. Coupled with this concern is an attitude of B&R personnel, perceived by Quadrex, that they have only to do what the NRC requires.
Q.42 What is your view of this finding?
A.42 The NRC staff does not require the application of the quality assurance.
criteria of Appendix B to areas other than those that have a direct impact on safety, as in prevention or mitigation of a design basis reactor accident, or are required to be designed and built to protect and support the safety-related functions.
Q.43 Who determines what falls under Appendix B7 A.43 The licensee and his various agents, in accordance with Criterion II of Appendix B, develop a list of structures, systems, and components that fit into one or more of the combinations that I previously described.
Frequently, there will be components or subsystems connected to a safety system that have no safety function and are listed as well to show the
. distinction. These lists are included in the SAR, as recommended by Regulatory Guide 1.70.'
In addition, the piping and instrument diagrams generally centain flags that clearly show the safety classifications.
These diagrams are also included in the various SAR chapters to which they pertain.
Q.44 What is the NRC role?
A.44 The NRC tacitly ccncurs with these described lists and drawings when it issues the construction permit and/or the operating license. These lists and drawings are generally only changed when a significant error is found and then by amendment to the SAR.
Q.45 What about the seven sub-items or examples listed in the generic finding?
A.45 Items 1, 3, and 7 have been previously discussed as part of other generic findings.
Item (2) again relates to a calculational error; changed and somewhat more conservative criteria evolving from newer experience, and finally a concern that 88R did not use new criteria that they believed the NRC was going to promulgate in the near future.
Item (4) partains to engineering tools, computer codes, not having been subject to a formal verification program prior to use on safety design work.
I could not determine that Item (5) and (6) were related to the generic finding.
For item (6) I had the same problem as with item (5).
1 o Q.46 Do you consider that the generic finding or any of subfindings are violations of Appendix B?
A.46 The subitem dealing with the use of unverified computer programs would be a violation of Criterion VI. Even though such computer programs generally are not documents in the traditional form, they serve the same purpose and I feel they fit within the scope of the criterion.
Q.47 Do you believe that either the generic item or any of the sub-items should have been reported to the NRC?
A.47 The item on computer codes was reported to the NRC via a telephone call of May 8, 1981. The balance of items neither individually nor collectively, constitute reportable items.
Q.48 Is the fact that this Quadrex finding was not reported, in your view, an indication of a lack of candor or truthfulness on the part of the management of HL8P?
A.48 No.
Q.49 Does it reflect an unwillingness to abide by regulatory requirements?
t A.49 Nog
Q.50 Does it in any way indicate an abdication of, or refusal to accept, the responsibility to protect the health and safety of the public?
A.50 No.
Q. 5'1 Does the fact that HL&P did not report this Quadrex finding reflect adversely on its character or competence to operate a nuclear plant?
A.51 No.
Q.52 Have you reviewed and evaluated generic finding 3.1(e)?
A.52 I have.
It indicates that there are no written guidelines for the conduct of Failure Mode and Effects Analysis.
I also gather that the writer's position was that there should be relatively free standing documents with a title " Failure Mode and Effects Analysis" and that B&R was unable to provide him with same or even a listing of such documents.
I' there a requirement for perfonnance of Failure Modes and Effects Q.53 s
Analysis?
A.53 The title " Failure Modes and Effects Analysis" in 10 CFR 50.34(f)(2)(xxii) but that reference does not apply to this type of facility. Let me note, however, failure analysis at a structural,
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system and component level is a requirement of Part 50 for inclusion within the FSAR, however, the term Failure Mode and Effects Analysis is
4 not used except as noted. Another NRC inspector, at my request, examined the NRC's Standard Review Plan relative to use of the term and stated to me that he did not find it.
Q.54 What is the purpose of such failure analysis?
A.54 The essential purpose is to demonstrate that the single failure criterion, as defined in Appendix A to Part 50, has been met; i.e., the failure of no single active component in a system should cause the total failure of the system to perform its safety function. Typically, redundancy is a way to satisfy the single failure criterion if done properly.
There is an example referenced in the generic finding where the criterion was apparently not satisfied since an air supply system furnishing control air to valves of an otherwise redundant system and should the line have broken or become plugged, both systems would have failed to operate properly.
Q.55 Is either the failure to have written guidelines for Failure Mode and Effects Analysis or for the failure to generate free standing analysis, as you believe the Quadrex person thought was the case, required by Appendix B?
A.55 It might be argued that Criterion V of Appendix B would be applicable and that a " procedure" for failure analysis is a requirement.
It could similarly be argued this could be accomplished by drawings or instructions.
I would say, however, that such analysis is a fundamental W -
k-part of the practice design development and that such a procedure is not necessary. An engineer would gain the knowledge-as a part of his education and experience. N45.2.11 requires that _ failure effects and.
l the postulated condition to create failure must be part of the design input data for the design of structure, system or component. The designer and the design verifier have to consider the design inputs in their work. The personnel subsequently preparing the SAR must perform j
sufficient analysis to describe a given system or structure such that they can demonstrate to the NRC that the requirements of Part 50 and of
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Appendix A to Part 50 have been satisfied.
Further, the failure to have the free standing failure modes and effects analysis is not a requirement that I have been able to determine exists. No, I don't believe that a violation exists in either aspect.
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Q.56 Should this generic finding have been reported to the NRC under 50.55(e)?
A.56L For the reasons I have testified to above, it is my opinion that the item was not reportable.
4 Q.57 Is the fact that this Quadrex finding was not reported, in your view, an I
r indication of a lack of candor or truthfulness on the part of the management of HL&P?
4 A.57 No.
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a i Q.58 Does it reflect an unwillingness to abide by regulatory requirements?
A.58 No.
Q.59 Does it in any way indicate an abdication of, or refusal to accept, the responsibility to protect the health and safety of the public?
A.59 No.
Q.60 Does the fact that HLAP did not report this Quadrex finding reflect adversely on its character or competence to operate a nuclear plant?
A.60 No.
Q.61 Have you reviewed and evaluated generic finding 3.1(f)?
A.61 Yes. This item consists of observations that there appears to be no systematic mechanism to assure that the designs meet FSAR commitments nor conversely any mechanism to cause updating of the FSAR to represent the design.
Q.62 What is your evaluation of this finding?
A.62 First let me say that I have found that Quadrex has stated a number of times through these generic findings that the FSAR cannot be used as a design document.
I have found no basis for such a statement, since
a r there is no defined NRC position on this matter. Further, the FSAR must become a design control document at some point in the design effort since it frequently will become the only record of the results of the engoing design review by the NRC staff and the licensee. At yet a later time, the NRC Safety Evaluation Report becomes a design input dccument since it represents the final staff review and frequently requires the licensee to make changes in the facility design.
Q.63 Is the licensee required to maintain the FSAR current at all times?
A.63 No. 'However, the applicant is expected to periodically update the FSAR by amendment.
In recent years, the submittal of the FSAR often precedes the issuance of the operating license by a considerable period of years.
To have the FSAR always up to date would require perhaps thousands of amendments to the FSAR during this period which is not very practical.
More typically, a licensee will accumulate changes for a period such as 3 or 4 months and then file the entire package as an amendment.
I have experienced FSARs with as few as 15 amendments to as high as 50. The licensee is required to affirm in writing that the facility and the FSAR match, prior to OL issuance. One year after receiving the operating license the licensee is required to provide an updated FSAR and to update that document yearly.
Q.64 Was the licensee's failure to maintain the FSAR up to date a violation of Appendix B?
O A.64 In general no, but there may be exceptions. Since there are no cited c.xamples in the Quadrex generic finding to support the finding, I cannot det ine that a violation exists.
If it were determined by the NRC t.
e licensee's FSAR were deviated from the "as built," it would be evaluated to determine whether this failure resulted from oversight or inattention (possible violation) or merely the processing time between amendments (probably not a violation). The sedond part of the generic finding, dealing with the lack of centralized interpretation of Codes and Standards, does not relate to the above issue.
Q.65 Do you find that the lack of a centralized interpretation group to have been a violation of Appendix B?
A.65 In my understanding of the regulations, there is no requirement for centralized interpretation, therefore, there can be no violation.
Incorrect interpretation regardless of who made them could be a violation, but only on a case basis.
In the case of the one cited example, I can make no decision on whether there were or were not violations without considerably more information than is made available within the example Quadrex offers.
Q.66 Should either of the two generic findings or the cited example have been reported to the NRC?
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b A.66 Since there is no requirement applicable to the generic aspects of the finding, the licensee could not have been expected to report either of these.
Q.67 Is the failure to report this Quadrex finding, in your view, an indication of a lack of candor or truthfulness on the part of HL&P?
A.67-No.
Q.68 Does it reflect an unwillingness to abide by regulatory requireme6ts?
A.68 No.
Q.69 Does it in any way indicate an abdication of, or refusal to accept, the responsibility to protect the health and safety of the public?
A.69 No.
Q.70 Does the fact that HL&P did not report this Quadrex finding reflect adversely on its character or competence to operate a nuclear plant?
A.70 No.
Q.71 Have you reviewed and evaluated generic finding 3.I(g)?
.b A.71 Yes, but let me say that it is difficult accepting that there is one overall generic finding in this item.
I have attempted to list what I see as more-or-less separate issues within the stated overall issue.
They are:
- 1. Much of the plant design basis is rooted in engineering judgment with difficulty on retrieving the rationale to support the judgments.
- 2. No overall document controlling the interface information requirements.
- 3. Key front end documents apparently not developed and issued early enough.
- 4. Significant quality variations in the design review comments.
- 5. Uncertainty by B&R of the depth of review performed by H.
- 6. EDS not reviewing all B&R design changes.
- 7. E design basis carried over to B0P without confirmation of applicability.
- 8. Design basis of other PWRs used without confirmation of applicability.
4 9. No consistent requirement for the design basis margins to be used by
-c each discipline.
10.
B&R does not require use of design manuals or engineering log books.
Q.72 Have you drawn a conclusion relative to each of these items?
A.72 There is not enough information in the generic finding to indicate what Quadrex was concerned with on the first item although there may be a connection to item 10.
Item 2 is very similar to a concern voiced in generic finding 3.1(a) with neither comment being supported by factual information that would allow for analysis.
Item 3 is apparently rooted in the Quadrex philosophy that the SAR cannot be used as a design input document. My conclusion relative to that position was given in generic finding 3.1(f).
(See pp. 21-24, supra) Relative to 1. ems 4 through 8, I cannot offer a conclusion since there is no support for the statements.
Item 9 is supported by one example dealing with HVAC design but this is at least in part contradicted by another example in the civil engineering area. The statement is much stronger than the cited facts seem to warrant.
Item 10 is also difficult to assess since it states that B&R does not require the use of such manuals and log books, however, it does not state whether these exist and/or they are used.
Q.73 Would either the overall generic finding or any of the sub-items you have listed be violations of Appendix B?
. A.73 Since there is so little specificity to either the overall item or to most of the sub-items, I would be very hard pressed to consider them violations of any criterion of Appendix B, even with help of N45.2.11.
Q.74 Should either the overall item or its sub-items have been reported to the NRC under 10 CFR 50.55(e)?
A.74 The sub-items are not well defined and there is insufficient information on these items in the Quadrex Report to consider them as other than observations by the auditor.
i Q.75 Is the fact that this Quadrex finding was not reported, in your view, an indication of a lack of' candor or truthfulness on the part of the management of HL&P?
A.75 No.
Q.76 Does it reflect an unwillingness to abide by regulatory requirements?
A.76 No.
Q.77 Does it in any way indicate an abdication of, or refusal to accept, the responsibility to protect the health and safety of the public?
A.77 No.
. Q.78 Does the fact that HL&P did not report this Quadrex finding reflect adversely on its character or competence to operate a nuclear plant?
A.78 No.
Q.79 Have you reviewed and evaluated generic finding 3.1(h)?
A.79 Yes I have.
In summary, this finding involves a concern that B&R has apparently not developed and specified reliability requirements for electrical and mechanical safety-related equipment.
Let me say that the two examples given only partially support the contention. Question E-7 indicates that some parts of the question were satisfactorily answered while other parts were largely not answered, apparently because the design was not complete. Question E-8 does deal with the concept of reliability but at least in part via criticism of the lack of formalized failure modes and effects analysis. The last statement pertaining to the question does come directly to the point that B&R has not specified acceptance criteria for equipment reliability.
Q.80 Does B&R's failure to specify reliability acceptance requirements for equipment violate Appendix B or any other NRC requirements?
A.80 Criterion 21 of Appendix A to 10 CFR 50 requires that the reactor protection and reactivity control systems be of the highest functional reliability and shall have in-service testability.
Redundancy and independence... shall be sufficient to assure that (1) no single
. failure results in loss of the protective function and (2) removal from service of any component or channel does not result in loss of the minimum required redundancy unless the acceptable reliability of operation of the protective system can be oti;erwise demonstrated. The NRC has not to my knowledge, except for diesel generators, attempted to i
define or quantify reliability.
In lieu of quantification and demonstration of reliability, the NRC utilizes the dual concepts of relative freedom from the probability of single failure plus redundancy to provide reliability.
In short, I have found no requirement in the NRC regulations to cause B&R to establish a reliability acceptance standard other than that already stated.
Q.81 Should the licensee have reported this generic finding to the NRC?
A.81 Since I can find no requirement, it would appear that there was no actual deficiency involved and therefore, I would not expect such a report to have been issued.'
Q.82 Is the failure to report this Quadrex finding, in your view, an indication of a lack of candor or truthfulness on the part of the management of HL8P7 A.82 No.
Q.83 Does it reflect an unwillingness to abide by regulatory requirements?
. A.83 No.
Q.84 Does it in any way indicate an abdication of, or refusal to accept, the responsibility to protect the health and safety of the public?
A.84
'No.
Q.85 Does the fact that HL&P did not report this Quadrex finding reflect adversely on its character or competence to operate a nuclear plant?
A.85 No.
Q.86 Have you reviewed and evaluated generic finding 3.1(i): This item is considered that titled " Nuclear-Related Analysis" and identified in Quadrex report by one of two (j)s.
A.86 I have.
Q.87 What is your assessment of this item?
A.87 The exact thrust of this item is difficult to grasp. On one hand, if one reads the references at the bottom of page 3-12, you will find that they will take you to all of the other generic findings, which I don't believe was the point since the other findings wsuld not have been necessary.
I believe that this finding was intended to point out that B&R lacked expertise in those engineering areas that are more uniquely w -
. nuclear as opposed to those areas that are relatively common to any type of design engineering work carried out for the purposes of building a facility of any sort. When viewed in this light, the finding seems to be a caution to the licensee that he could experience delays in his design and licensing areas that he might not be awarb of.
I think that the statements that much less than adequate choices of analytical methods and assumptions have been made and the error rate in calculations was unexpectedly high, would lead to this conclusion of Quadrex intent.
Q.88 Does the situation that you believe Quadrex was discussing constitute a
-violation of Appendix B?
A.88 Appendix B is primarily a prescription for establishment of well disciplined management controls from the time period of conceptual engineering to full operation of the plant. Such controls recognize human, procedure, process and material fallibility by requiring controls, checks, inspections and testing. The purpose of the SARs is to allow the NRC to assess the design adequacy of the facility.
I believe that it would be very difficult for an NRC inspector to use the data provided as the basis for issuance of a notice of violation of Appendix B.
Q.89 Should this finding have been reported to the NRC?
O e
a
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. A.89 Without the references, this concern lacks the technical specificity to O
be reportable.
If the references were connected, it's more in terms of a feel that things were not going well, in the opinion of the contractor for this study, rather than specifically leading to a conclusion that the operability of the plant might be seriously affected.
In my view, this falls into the area of an observation by the auditor and does not suggest a reportable deficiency.
Q.90 Is the fact that this Quadrex finding was not reported, in your view, an indication of a lack of candor or truthfulness on the part of the management of HL&P?
A.90 No.
Q.91 Does it reflect an unwillingness to abide by regulatory requirements?
A.91 No.
Q.92 Does it in any way indicate an abdication of, or refusal to accept, the responsibility to protect the health and safety of the public?
A.92 No.
Q.93 Does the fact that HL&P did not report this Quadrex finding reflect adversely on its character or competence to operate a nuclear plant?
1 A.93 No.
Q.94 Have you reviewed and evaluated generic finding 3.1(j)?
A.94 Yes. This finding indicates that certain design verification actions will take place very late in the construction cycle and that there are no qualification requirements established for design verifiers and further that the errors in calculations occur too frequently.
Q.95 Would you consider that the finding in any way represent a violation of Appendix B7 A.95 Neither Appendix B nor Fa5.2.11 establish a requirement that would require the licensee or his engineer to establish minimum qualifications ~
for personnel performing either direct design work or for performing design verifications. These documents only suggest that these' people be competent to perform this work.
In the same context Appendix B and N45.2.11 contain only a requirement that each design be verified but neither establish a time in the overall design and construction sequence l
that the verification must be done.
It would seem prudent to have the verification accomplished prior to releasing the design for use but many factors bear on this such that the risk of using an unverified design might well be less than the benefits. The excessive errors in calculations has been previously reviewed in connection with generic finding 3.1(b).
. -Q.96 Should this generic finding have been reported to the NRC under 10 CFR 50.55(e)?
A.96 Since no deficiency appears to exist, a report to the NRC would have been inappropriate.
Q.97 Is the fact that this Ouadrex finding was not reported, in your view, an indication of a lack of candor or truthfulness on the part of the management of HL&P?
A.97 No.
Q.98 Does it reflect an unwillingness to abide by regulatory requirements?
A.98 No.
Q.99 Does it in any way indicate an abdication of, or refusal to accept, the responsibility to protect the health and safety of the public?
A.99 No.
Q.100 Does the fact that HL&P did not report this Quadrex finding reflect adversely on its character or competence to operate a nuclear plant?
A.100 No.
. Q.101 Have you reviewed and evaluated finding 4.1.2.1(b)?.
s A.101 Yes. Quadrex apparently was dissatisfied by a finding that the B&R civil / structural engineering group was not ascertaining the reasonableness of postulated missiles generated from within a component, in this case a pump. Although it does not so state, it is apparent that the postulated missiles from within the pump wbre postulated by another engineering group.
I would not expect that a civil engineer would have l
the expertise to challenge the reasonableness of the missiles that were
' postulated, perhaps by the designer of the pump. The Quadrex assessment to question C-9 indicates that civil / structural was handling the missiles that had been postulated in accordance with industry practice and the state-of-the-art. The remainder of the concern was that there was no evidence that the requirements of a document pertaining to determining and protecting against missiles had been implemented in design.
Q.102 Would you consider this finding to be a violation of Appendix B7 i
l A.102 I could not find that a lack of evidence in this area would be in violation of Appendix B.
In this case it would appear that question C-9 would not have caused BAR to demonstrate in design documents other than their procedure, the Technical Review Document'(TRD), how they have i
treated missiles.
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Q.103 Would this item have been reportable under 50.55(e)?
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. - -,. _,, _ _, _ _ _. _ _,, _ _. _ _ _... _.. _ _ _. _ _ ~ - _ _ _, - -.. _ _
_... _..._.. _ _. - ~... _ - -,
. A.103 More information would be needed relative to whether the requirements of the TRD document had or had not been implemented in construction use drawings such as the civil / structural drawings for the buildings.
I believe it's a very close call, but the item probably should have been reported as a " potential deficiency." This demonstrates the nature of engineering judgment and the subtle difference between those items that just meet the test of significance and those that are not.
Q.104 Is the failure to report this as a Quadrex finding as a potential deficiency, in your view, an indication of a lack of candor or truthfulness on the part of the management of HL&P?
A.104 No.
It may well have been that HL8P personnel were familiar with E8R's handling of missiles in actual design and were not concerned with the Quadrex comment.
i Q.105 Does it reflect an unwillingness to abide by regulatory requirements?
A.105 No.
Q.106 Does it in any way indicate an abdication of, or refusal to accept, the responsibility to protect the health and safety of the public?
i A.106 No.
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l l
. Q.107 Does the fact that HL&P did not report this Quadrex finding reflect adversely on its character or competence to operate a nuclear plant?
A.107 No.
Q.108 Have you reviewed and evaluated finding 4.3.2.1(a)?
A.108 This item relates primarily to Failure Mode and Effects Analysis, and the application _of the single failure criterion as did generic finding 3.1(e) with a somewhat greater emphasis on one example which is also part of 3.1(e)..My findings pertaining to 3.1(e) are also appropriate to this item.
Q.109 Have you reviewed finding 4.3.2.1(n)?
A.109 In summary, this finding indicates that B&R had not developed application guidance for their engineers in the use of various electrical isolation schemes.
Q.110 Is this lack of a guidance document a violation of Appendix B or any other NRC requirement that you are aware of?
A.110 I do not feel that a violation could have existed until a design had been developed that provided an application that in some manner violated design criteria. Let me say that application of fuses and relays to obtain electrical circuit isolation is nearly as old as the electrical
. and electronic industry. The newer photo-optical devices that have now been used for several years were originally developed by component level engineers / manufacturers who provided typical application data to the user, generally initially by catalogues. When a user bought the product, the user was provided with a data sheet providing more specific information. This practice has been largely' standard to a wide range of electronic products for long periods of time.
In summary, it would be entirely possible for a user engineer such as at B&R to develop entirely satisfactory final designs without the guidance document that Quadrex apparently felt was necessary.
~
Q.111 Would absence of such a guidance document have been reportable under 50.55(e)?
A.111 Since it is apparent in reading the Quadrex supporting information, that few if any design outputs had as yet been developed by B&R at the time of the audit, no deficiency existed within the meaning of 50.55(e) and, therefore, no report would have been required.
l Q.112 Is the failure to report this Quadrex finding, in your view, an indication of a lack of candor or truthfulness on the part of the management of HL&P?
l A.112 No.
Q.113 Does it reflect an unwillingness to abide by regulatory requirements?
l i
. A.113 No.
Q.114 Does it in any way indicate an abdication of, or refusal to accept, the responsibility to protect the health and safety of the public?
A.114 No.
Q.115 Does the fact that HL&P did not report this Quadrex finding reflect adversely on its character or competence to operate a nuclear plant?
A.115 No.
Q.116 Have you reviewed and evaluated finding 4.3.2.1(d)?
A.116 Yes.
I find it to be reflected in a portion of generic finding 3.1(a) coupled with a portion of generic finding 3.1(e) in that they deal with the single failure criterion and physical separation.
Q.117 Should the absence of formal methodology or documentation been reported to the NRC?
A.117 Again, the examples cited by Quadrex do not tell the reader that an actual or potential deficiency exists in the design. Therefore, a significant deficiency report in accordance with 10 CFR 50.55(e) would have been inappropriate.
. Q.118 Is the fact that this Quadrex finding was not reported, in your view, an indication of a lack of candor or truthfulness on the part of the management of HL&P?
A.118 No.
Q.119 Does it reflect an unwillingness to abide by regulatory requirements?
A.119 No.
)
Q.120 Does it in any way indicate an abdication of, or refusal to accept, the responsibility to protect the health and safety of the public?
A.120 No.
Q.121 Does the fact that HL&P did not report this Quadrex finding reflect adversely on its character or competence to operate a nuclear plant?
A.121 No.
Q.122 Have you reviewed and evaluated finding 4.5.2.1(b)?
A.122 Yes.
In essence, Quadrex found that B&R had used preliminary design input information from EDS and that EDS had not subjected it to the design review process.
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. Q.123 What is your evaluation regarding this item?
A.123 The Quadrex finding here is substantially the same as that contained in generic finding 3.1(j) only with more specificity.
I believe that my comments relative to that generic finding are appropriate to this finding.
I perhaps should supplement my comment to 3.1(j) to make it clearer what was meant by risk and benefits. Let me say first that I have been involved for about 25 years in heavy field construction of various types including both nuclear construction and earlier, ballistic missile launch site construction. Nearly all these projects have used a philosophy of nearly concurrent design and construction. As an example, the construction of building foundations may proceed well before the
}
final loads on the foundation are known. The foundation designer makes certain assumptions largely based on judgment of what these loads will ultimately be. Generally, the assumptions are so conservative that when the loads are finally available and the design verification process can begin, the foundation will be found to be substantially over designed or in other words, not loaded to the extent originally contemplated. The net effect is that the design margin for the foundation will turn out to be higher than would have been the case if the design had been delayed awaiting the final load values.
Q.124 Would this situation constitute a violation of Appendix B7 A.124 Not until a nonconservative design is found to exist.
. Q.125 Was a nonconservative design apparent or strongly suspected in this
' case?-
A.125 No. This was not shown.-
Q.k26 Is the fact that this Quadrex finding was not reported, in your view, an indication of a lack of candor or truthfulness on the part of the management of HL8P?
A.126 No.
Q.127 Does it reflect an unwillingness to abide by regulatory requirements?
A.127 No.
Q.128 Does it in any way indicate an abdication of, or refusal to accept, the responsibility to protect the health and safety of the public?
A.128 No.
Q.129 Does the fact that HL&P did not report this Quadrex finding reflect adversely on its character or competence to operate a nuclear plant?
A.129 No.
. Q.130 Have you reviewed finding 4.6.2.1(n)?
A.130 Yes.
It is a reiteration of a portion of generic finding 3.1(c) relative to the essential cooling water pond.
Q.131 Does the item constitute a violation of Appendix B?
A.131 As I indicated in my response to generic finding 3.1(c), based on the information presented, I would have made this an " unresolved item" for an NRC inspection report considering the 1980 guidance as interpreted in 1981. There is not enough information in the data reviewed to ascertain whether a formal violation of Appendix B existed. The unresolved item would have required the licensee to provide additional information in order to determine if a violation existed.
Q.132 Should the licensee have reported the item to the NRC7 A.132 As in my testimony with regard to generic finding 3.1(c), I believe that the licensee should have reported the item as a " potential" 50.55(e) item subject to further information gathering and evaluation.
Q.133 Was the problem with the ECP reported to the NRC?
A.133 Yes. The evaluated temperature of the ECP under certain conditions was confirmed by Bechtel analysis and reported as a potential 50.55(e) item on October 19, 1982.
It was subsequently withdrawn on December 9, 1982,
_.m.
_____._y.
. on the basis that all safety-related components would perform properly even though the cooling water supply to them was higher in temperature than originally contemplated.
Q.134 What effect has this report had on your analysis of the Quadrex finding?
A.134 I believe that there was sufficient information in the assessment of question N-17 to have caused the items to have been reported as a potential 50.55(e) item upon immediate review of the Quadrex report and therefore my conclusion has not been changed.
Q.135 Is the failure to report this Quadrex finding, in your view, an indication of a lack of candor or truthfulness on the part of the management of HL&P?
A.135 No. The decision to report or not report probably was very closely based upon all of the information contained in question N-17.
I think that my conclusion simply reflects a somewhat lower threshold relative to what is or'is not reportable.
Q.136 Does it reflect an unwillingness to abide by regulatory requirements?
A.136 No.
Q.137 Does it in any way indicate an abdication of, or refusal to accept, the responsibility to protect the health and safety of the public?
.- A.137 No.
Q.138 Does the fact that HL&P did not report this Quadrex finding reflect adversely on its character or competence to operate a nuclear plant?
A.138 In my opinion, no. As I stated previously, the difference between my conclusion and their initial decision was a matter of engineering judgment.
I would have selected the more conservative approach suggested by Quadrex. As a final outcome, however, the item was eventually dispositioned as not reportable.
Q.139 Have you reviewed and evaluated finding 4.7.3.1(a) and 4.7.3.1(b)?
A.139 I have. My analysis of each finding leads me to a common conclusion.
It is also necessary to consider the precursor statements for each item.
Q.140 What is your conclusion?
A.140 After reviewing the example cited in conjunction with each item, it appears that Quadrex was primarily concerned with the fact the B&R and/or EDS has not developed criteria that would be necessary to complete a final design of piping systems and that this might interfere with the licensing of the plant since it could be possible that significant engineering changes might have to be made to existing designs as the new information became available.
. Q.141 Would this lack of engineering information at the appropriate point in time be a violation of Annendix B7 A.141 No. Criterion III of Appendix B and the N45.2.11 both reflect that changes to design may well be necessary and that so long as the QA program for design activities provides appropriate controls for the changes, there would be no violation. The information contained in the Quadrex report subject to my review has not led me to believe that controls are inadequate.
Q.142 Should the licensee have reported either of these items to the NRC under 50.55(e)?
A.142 No. There was no design deficiency.
Q.143 Is the fact that this Quadrex finding was not reported, in your view, an indication of a lack of candor or truthfulness on the part of the management of HL&P.
A.143 No.
Q.144 Does it reflect an unwillingness to abide by regulatory requirements?
A.144 No.
1 I
. Q.145 Does it in any way indicate an abdication of, or refusal to accept, the responsibility to protect the health and safety of the public?
A.145 No.
Q.146 Does the fact that HL&P did not report this Quadrex finding reflect adversely on its character or competence to operate a nuclear plant?
A.146 No.
Q.147 Have you reviewed finding 4.7.3.1(k)?
A.147 Yes.
It seems to involve a difference of opinion between B&R and the Quadrex reviewer as to what is an adequate method to predict loads at those piping run points where there is a transition of seismic to nonseismic both in terms of analysis methods and means of support of the pipe. What is unclear, however, is whether the method outlined by B&R was described and justified in the SAR and whether, in fact, the B&R criteria were used in completed design work.
In the B&R response to question P-29, under the 3-25 date line, there is an inference that the criteria had not yet been used since the term "will be" is used twice.
The Quadrex reviewer also indicates that the B&R criteria was developed on the basis of engineering judgment by exportenced personnel which in turn constitutes a basic design assumption.
Q.148 Does this concern be represent a violation of Appendix B?
l
. A.148 No. As stated before, Appendix B is intended to establish certain basic management controls, in this case over the design process. The controls may have been completely in place, there is no information to indicate otherwise, and yet the resultant design may not be adequate, this is why the design review, construction process control, inspection and test
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provisions are provided.
0.149 Should the licensee have reported this matter to the NRC under the requirementsof50.55(e)?
A.149 I believe that the licensee probably should have made such a report as a
" potential" based mostly on the strength of the Quadrex reviewers assertion in the assessment of question P-29.
Q.150 Is the failure to report this Quadrex finding, in your view, an indication of a lack of candor or truthfulness on the part of the management of HL&P?
A.150 No. HL&P personnel may have had knowledge of the situation that would have subtracted from the strength of the Quadrex reviewers assertion.
Q.151 Does it reflect an unwillingness to abide by regulatory requirements?
A.151 No.
. Q.152 Does it in any way indicate an abdication of, or refusal to accept, the responsibility to protect the health and safety of the public?
A.152 No.
Q.153 Does the fact that HL&P did not report this Quadrex finding reflect adversely on its character or competence to operate a nuclear plant?
A.153 No.
Q.154 Have you reviewed and. evaluated finding 4.8.2.1(a)?
A.154 Yes.
First of all, let me note that (a) has been previously discussed in connection with generic finding 3.1(e) and was apparently intended by Quadrex to be separated from their concern with ALARA as indicated by the format of the paragraph. The balance of my answer is directed toward subparagraphs (b) through (g).
I would like to point out that the regulations regarding ALARA goes well beyond 10 CFR Part 20. As an example, Part 50.34(a) requires any application for a permit to construct a nuclear power reactor filed on or after January 2, 1971 to contain considerable information on how the facility will be designed to comply with the ALARA concept. Since STP was docketed in mid-July 1974, much of the design base to comply with ALARA was included and was accepted as evidenced by issuance of the CP at the end of 1975.
I would further note that 50.36(a) requires submittal of Technical Specification requirements relative to ALARA. The FSAR generally contains the
O
. licensee's recommendations for the contents of the Technical Specifications that will be appropriately modified by the NRC and becomes Appendix A of the OL. Appendix I to 10 CFR 50 also contains guidelines for assessing compliance to the previously indicated parts of Part 50.
In essence the NRC is heavily involved in assuring that a licensee does fulfill the ALARA concept both in the design of the facility and its later operation. Taken in this light, the Quadrex preamble to subparagraphs (b) through (g) is that their concerns are in regard to "licensability" rather than that the designs are actually deficient. My view after reading the support references is that the designs and verification thereof had in reality not progressed as far as Quadrex expected and that if BAR didn't do a better job, they would not provide input to the NRC that would satisfy the NRC sufficiently to allow an OL to be issued.
Q.155 Should any part or all of the issues contained in this paragraph have been submitted to the NPC under 50.55(e)?
A.155 It is my understanding that the licensee did identify that part of (d) related to the safety classification of shielding systems was a potentially reportable item on May 8, 1981, but later withdrew the report on the basis that further examination indicated that it did not fit the requirements of 50.55(e). On the basis that incomplete design does not necessarily indica,te deficient design, I find no condition in the Ouadrex findings that would fall within the purview of 50.55(e).
The only possible connection would be the comment that BAR had not
e established minimum qualifications for ALARA design reviewers.
I have previously noted that I have found no requirements for establishing a I
set of minimum qualifications for engineers within NRC regulations nor has such a requirement been found in adapted subsidiary standards.
Neither the matter of personnel minimum qualifications nor any of the Quadrex comments indicate to me that any part of the design QA program has been violated.
Q.156 Could you provide us with your assessment of whether you believe the entire Quadrex report should have been reported to.the NRC in accordance with the requirements,of 10 CFR 50.55(e) within the time frame required by the regulation?
A.156.As to my assessment of the reportability of the Quadrex report, I have a perception that the primary thrust of the Quadrex comments was that it found B&R to have little in the terms of documented design guidance for a group of engineers that the Quadrex people considered to be inexperienced in nuclear work and that the B&R groups were subject to fairly high turnover rates. There was a concern that newly hired engineers would have difficulty in determining what the design basis was without these higher level design guidance documents. Most of the engineering firms that I have any knowledge of have had design manuals that are generally promulgated by the immediate staff of each j
engineering discipline chief engineer for the use of engineers assigned i
to a project staff. The most important purpose of these manuals has been to provide a consistent design basis from project to project, j
l
l 3 particularly when several design projects are going forward at the same time.
For a one project A/E, these tranuals might be seen as unnecessary since the chief engineers could provide such guidance on a day-to-day basis. As pointed out previously, I have found no requirement that such manuals must exist as a prerequisite to performing design work.
Another perception on my part, was that the design development process had progressed far less than Quadrex thought was reasonable for the construction status of the project. My impression gained from reading the report was that Quadrex found that the design in such areas as HVAC, piping and pipe supports, and electrical had not yet started through the iterations necessary to make it final. Apparently what they expected to see was a mature engineering project and their comments are reflective of this condition. Tending to support this conclusion are many instances where the B&R response to the Quadrex questions are phrased in future tense which implies that the engineering has not at that time culminated in a substantially complete design.
If my perceptions of the condition of the design effort at the time of the Quadrex effort are substantially correct, then I would say that the report as a whole was not reportable. A deficiency within the context of 50.55(e) doesn't exist simply because the design work is substantially incomplete.
If the reverse logic were applied, it would then follow that the day the construction permit is issued, the licensee would immediately have to report that he had deficiencies in the design
1 because much of the design work would not have started at a detail level in many areas.
0.157 Is the failure to report this Quadrex report, in your view, an indication of a lack of candor or truthfulness on the part of the management of HL8P?
A.157 No.
Q.158 Does it reflect an unwillingness to abide by regulatory requirements?
A.158 No.
Q.159 Does it in any way indicate an abdication of, or refusal to accept, the -
responsibility to protect the health and safety of the public?
A.159 No.
Q.160 Does the fact that HL&P did not report the Quadrex report reflect adversely on its character or competence to operate a nuclear plant?
A.160 No.
Q.161 4r. Taylor, to what extent are the views you have expressed in your testimony influenced or based on the conclusion reached previously by the staff in NUREG-09487
I 1 A.161 They are entirely independent, since I did not review NUREG-0948 until after preparation of my analysis and testimony was substantively complete except for editorial changes.
I sought to analyze the Quadrex Report on the same basis as if I were the NRC inspector reviewing the licensee's actions regarding the Quadrex Report and its reportability immediately after the licensee had completed his review.
Q.162 After preparing the preceding testimony, have you reviewed NUREG-09487 A.162 Yes, I have.
Q.163 Is there any information or findings therein which lead you to believe that your previous testimony should be altered?
A.163 No. Given what information existed at the time tne Quadrex Report was originally presented, my views as to its reportability under 50.55(e) remain the same after reviewing NUREG-0948.
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