ML20205M278
| ML20205M278 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/30/1987 |
| From: | TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Gregory M GREGORY, M. |
| References | |
| CON-#287-2939 CPA, NUDOCS 8704020327 | |
| Download: ML20205M278 (17) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION DOCKETED USNRC before the ATOMIC SAFETY AND LICENSING BOARD '87 MR 30 M1 :31 0FFICE CF ':E d.t'I AR Y 00CKETihG & SEEv1CL BRANCH
)
In the Matter of )
)
TEXAS UTILITIES GENERATING ) Docket No. 50-445-CPA COMPANY et al. )
)
(Comanche Peak Steam Electric )
Station, Units 1 and 2) )
)
)
PERMITTEES' FURTHER1 RESPONSES.
TO "MEDDIE GREGORY'S INTERROGATORIES AND j REQUEST FOR PRODUCTION OF DOCUMENTS (SET 5)"
Pursuant to 10 CFR 55 2.740, 2.740b and 2.741, the I
Permittees respond herein to "Meddie Gregory's Interrogatories and Request for Production of Documents .
1 (Set 5)." i l
The Permittees have ignored the definitions and -
i guidelines in the paragraphs labelled "a" through "e,"
inclusive, as contained in the document entitled "Meddie Gregory's Interrogatories and Request fer 1
By agreement of the parties, the Permittees are continuing to respond to these Interrogatories as their investigation with regard to each issue is completed.
8704020327 870330 PDR ADOCK 0500044S
- g PDR 1)S@
Production of Documsnta (Sat 5)," insofar cc tho sema
. are contrary to the Rules of Practice.
Interrogatory 1:
When did' Applicants first receive notice of the issues identified by the NRC's TRT Reports and SSERs, and in what form did that notice come (i.e., NCR, IR, audit report, memorandum, consultant's report, etc.)?
i Interrogatory 2:
For each item identified in Interrogatory 1, identify what response was taken to the problem and by whom.
. Interrogatory 3:
i If the answer to Interrogatory 2 is that no action was taken, explain the reason that no action was taken. If I
that reason is because Applicants relied on a "second opinion," identify the individuals or organizations who .
j provided that opinion.
l Interrogatory 4:
)
Identify how each " finding" identified.in Interrogatory 1 was integrated into consideration of the subsequent findings by others. (For example, how were the findings by the NRC in 1978 and 1979 integrated into 3
Applicants' response to the findinge by the Management ,
Analysis Corporation (MAC)?)
l 4 ,
i - l PERMITTEES' RESPONSES
- (ISSUE
- FLEXIBLE CONDUIT TO CABLE SEPARATION):
1 At page J-42 of SSER 7 dated January 1985, the TRT found:
that the installation of certain safety- or i
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- l nonacfoty-ralatcd cables insida control room ptn21s, which wara in dirset contcet with 3
. safety-related flexible conduits associated
! with the other redundant trains, was ,
I inconsistent with engineering drawings and i regulatory requirements. Because
, acceptability of tha flexible conduit as a barrier was not established by analysis, as 4
required by Section 5.6.2 of IEEE Standard 384, the cables must be separated from the conduits inside the panels by a minimum distance of 6 inches, as required by Section 5.6.2 of IEEE Standared 384.
)
l Permittees believe that the TRT letter of 9/18/84 4
was their first notice of this issue, to wit: the qualification of SERVICAIR flexible conduit as a l " barrier." The cases of cables being in direct contact with the SERVICAIR flexible metallic conduit identified by the NRC are not reflected in the project cable h
separation requirements delineated on Drawing i .
l i
2323-EI-1702-02, " Cable and Raceway Separation Typical '
- Details." The main concern expressed by the NRC TRT is
- j that the SERVICAIR flexible metallic conduit used in 1
j the control room panel has not been shown by analysis j to qualify an a barrier.
I j IEEE 384-1974, "IEEE Trial-Use Standard Criteria for Separation of Class 1E Equipment and Circuits,"
IEEE 420-1973, "IEEE Trial-Use Guide for Class 1E I Control Switchboards for Nuclear Power Generating I
j Stations," and Regulatory Guide 1.75, Revision 1, l " Physical Independence of Electric Systems," are generally accepted as the documents governing r
4
4 electrien1 caparation requirsmtnts. Thacs documsnto
, are applicable to the CPSES Project. They indicate that within electrical panels and cabinets, " metallic conduit" is an acceptable separation barrier in lieu of physical separation. As a result, rigid metallic j conduit has been recognized by the nuclear industry as j an acceptable barrier inside electrical panels.
After obtaining IEEE 323-1974 and IEEE 344-1975 environmental and seismic qualification data for the SERVICAIR flexible metallic conduit and after 4
discussions with the supplier of the control boards (Reliance Electric Company), TUGCO issued design change documents (DCA-8830 dated 10/22/80) at Comanche Peak y i specifying the use of SERVICAIR flexible metallic '
conduit as a barrier.
i Initially, the use of SERVICAIR flexible metallic i
conduit was limited to the main control boards. Their use was expanded in October 1980 to include all panels supplied by Reliance Electric Company (procured under .
Purchase Order CP 0605 to Specification 2323 MS-605).
This includes their use in the control room control boards and veritical ventilation panels. In November 1980, Design Change Authorization (DCA-9086, Rev. 1) 1 l was issued to the Electrical Erection Specification 1
l 2323-ES-100. It listed SERVICAIR flexible conduit as l
1 metallic conduit, thereby allowing its use as a i
f i
scparation barrier in all elsctrical penals.
Permittees believed SERVICAIR flexible metallic conduit to be an acceptable barrier in accordance with all applicable standards and therefore undertook no specific effort to qualify this material as a barrier.
On 9/18/84, however, the NRC letter to TUGCO notified TUGCO of the TRT finding. Subsequently, the CPRT was formed and ISAP I.b.2 (Flexible Conduit to Cable Separation) and ISAP I.b.1 (Flexible Conduit to Flexible Conduit Separation) were issued to address the SSER finding with regard to demonstrating the adequacy of SERVICAIR flexible metallic conduit as a barrier, i
I (ISSUE: GUIDELINE 3 FOR ADMINISTRATION OF QC INSPECTOR -
QUALIFICATION PROGRAM):
At pages J-57 and 58 of SSER 7 dated January, 1985, .
- the TRT concludes
I
...[T]here is evidence to indicate that the i
electrical QC inspector qualification program
) lacked programmatic controls, which may be indicative that the required level of -
! qualification was not obtained for some
- electrical QC inspectors. Specifically, the lack of programmatic controls to assure that suitable proficiency is achieved and j
maintained (as required by 10 CFR 50, Appendix B) was found in:
l l
- The supportive documentation of qualifications, as required by i procedures and regulatory requirements l in training and certification. I i e The testing program for level II qualification. !
- i 4
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- -Tha recartificaticn program requirsmants in electrical quality instructions.
l In addition, in a related finding at page 0-111 of SSER 11 dated May, 1985, the TRT stated:
In the non-ASME training and certification program', the TRT found n lack of programmatic controls to ensure that the program achieves and maintains requirements as set forth in 10 CFR Part 50, Appendix B. Problem areas were:
(1) in the documentation for qualification, including verification of education and experience; (2) in the training and certification program; (3) in the recertification program; and (4) in the certification testing program.
Applicants believe the TRT letter of September 18, 1984 was their first notice of these particular issues v regarding inspector training and certification programs. However, it can conceivably be urged that ,
the Applicants had notice of the potential for deficiencies in the QC Inspector program education, training and qualification / certification procedures at the time of the "Lobbin Report" (issued on 2/4/82).
Although Mr. Lobbin stated that he had "no reason to -
believe that the program [was] not being carried out in accordance with the requirements of the TUGCO QC Program", interviews he conducted revealed concerns with inspector level of experience, and TUGCO's failure to perform an audit of inspector qualifications.
Additionally, Mr. Lobbin felt that inspector training remained an open issue.
6
Although incptctor qualifications waro routinoly 4 -
examined incidental to audits of safety related activities, TUGCO initiated a QA Audit to examine the Lobbin Report concerns specifically with regard to i training. The Audit, conducted on March 8-12, 1982 l l
] resulted in Audit. Report TCP-36. The report presented ;
]
only one concern related to non-ASME QC Inspector qualifications. This concern stated that additional clarification was needed regarding inspector i certification levels, functional responsiblilties, and
! technical direction authority for non-ASME
- certifications.
1 In light of these findings, Corporate and Site QA ,
f
! supervision personnel promulgated plans regarding the Y 1
- administration of Level II examinations, clarification i
- of technical direction authority for Levels II and III inspectors, and revisions to the inspector certification procedures as consistent with these newly 1
j promulgated plans. (TUGCO Site QA Supervisor memo to TUGCO QC Manager, TUQ-1266). The concerns raised in the audit report were closed, in the following QA Audit i.
4 Report, TCP-56, which confirmed the implementation of I
the aforementioned plans.
A follow-up audit covering training for QA/QC ASME, i
non-ASME and Engineering Personnel was performed on 1 November 8-12, 1982. Findings relating to non-ASME l
- inspection personnel were as follows
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- no ennual rsvicw of ingpactor certifications or on-th3-job training instructor certifications concerning the
. correlation between the certification and the activities performed as an inspector or instructor existed; no detailed instructions requiring training / certification records to be complete, legible and identifiable to the item involved existed; and more attention should be given to i documenting assigned reading requirements j for training. (TCP-56)
TUGCO Site QA Supervisor provided responses for the report's findings: Review of inspector certification would be annual for the first three years, procedures were implemented to assure adequate legibility, .
- completeness and identifiability of I 4
i
?
training / certification records, and the General I Training Outline was revised to delineate the required j reading material. (TUQ-1497, 2/21/82). Accordingly, -
- the TUGCO QA Manager closed the concerns of TCP-56.
In April, 1983, the Construction Appraisal Team (CAT) conducted an inspection of a broad range of CPSES activities, including the QA program and an examination of procedures and records. CAT reported that: (1) some QC inspectors had been certified with less experience than required by Regulatory Guide 1.58. (Four examples 1
were cited); and (2) inspection records were prepared i and accepted by L-I inspectors as " inspector of record" 1 I
I I
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rath0r then by en L-II "insp ctor of rccord" co required by ANSI N45.2.6.
In preliminary evaluation of the CAT report, TUGCO determined that in regard to both CAT findings, TUGCO was in compliance with the " intent" of both Regulatory Guide 1.58 and ANSI N45.2.6. (TUQ-1647, 5/4/83)
In further response to the CAT findings, another Q1.
Audit was conducted in July 1983, TCP-78. Three deficiencies with regard.to QC inspector experience were identified: (1) OJT Record Sheets from selected personnel files were reviewed and found to be inconsistent in documenting required information; (2) review of qualification files indicated no documented -
evidence that three individuals were I '
qualified / certified to perform as inspectors for the '
identified procedure; and (3) Procedure CP-QP-2.1, Rev.
12 did not address an annual reevaluation of all inspectors to assure that they had performed inspections in only those areas in which they were qualified.
Responding to the Audit findings, the TUGCO Site QA Supervisor stated that the inconsistencies in the OJT Record Sheets had been corrected, qualification l information for inspectors in question with regard to correlating certification and inspection procedures had been provided, and CP-QP-2.1 was revised to require annual certification. (TUQ-1807, 9/22/83).
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Tho TUGCO QA M ntgar found that tho first two of these responses addressed the symptoms of the problem and not the problem itself, thus these issues remained 1
l open. The response with regard to CP-QP-2.1, however, l was felt to be adequate and this concern was closed. ,
i (QTQ-520, 12/6/83).
Ultimately the two open issues of TCP-78 were closed. This was done by explaining that the qualification files in question were processed prior to the implementation of the procedures called for in the responses to QA Audit TCP-56 and that no commitment had been made at that time to correct previously processed files. In response to the failure to document ,
qualifications for certain inspectors with regard to the procedures they inspeeted, " objective evidence" as ,
to their qualifications was provided and future
~
certification procedures clarified.
As to the CAT finding that L-I " inspectors of record" substitution for L-II " inspectors of record" is ;
in violation of ANSI N45.2.6, NRC Region IV and the . j TUGCO Site QA Supervisor agreed that this was a matter of opinion and the CAT's interpretation of ANSI N45.2.6 had not been imposed on the industry by the NRC. (NRC l Region IV Reactor Project Branch I Chief, Letter to TUGCO Executive Vice President and General Manager).
Thus the issue was closed. (10/3/83) l l
1
- lo - I
At this tina, TUGCO considarsd all problems relating to non-ASME QC inspector training and certification to be solved.
On 9/18/84, the NRC letter to TUGCO notified TUGCO of the TRT findings. Subsequently the CPRT was formed and ISAPs I.d.1 and I.d.2 were issued to address the TRT findings.
(ISSUE:
JOINT TEST GROUP APPROVAL OF TEST DATA):
At page J-118 of the SSER 7 dated January, 1985, the TRT found that:
during a review of HFT completed test data that the Joint Test Group (JTG) did not approve the 4
- data until after cooldown from the test. The tests are not considered complete until this f i
approval is obtained. In order to complete the ,
i j proposed post-fueling, deferred preoperational HET, the JTG, -
or a similarly qualified group, must l
' approve criticality.
the data prior to proceeding to initial The TRT did not find any document providing assurance that TUEC is committed to do this.
The TRT letter of September 18, 1984 was'the Permittees' first notice of this TRT issue. Applicant's response (as j
- recorded in SSER 7, p. J-77) was to inform the TRT that the Station Operation Review Committee (SORC) would review deferred preoperational test data.
Subsequently, the CPRT was formed and ISAP III.a.2 ("JTG Approval of Test Data")
was issued to address and resolve the TRT's concern.
SORC was formally given responsibility for the review of
! the test data in Amendment 54 to the FSAR. The issue raised l
l l
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by tha TRT with rsgard to JTG spproval of HFT dato io now
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considered by the Applicants to be resolved.
4 (ISSUE: VALVE DISASSEMBLY):
! At page 0-120 of SSER 11 dated May 1985, the TRT found:
i a
' the interchange of valve parts did occur and effective programmatic corrective action was'not implemented to identify the problem and to prevent 1
the loss, damage and interchange of valve parts.
l Specifically, it was alleged that site personnel l
interchanged parts of unidentified diaphragm valves during
] site disassembly and operations. Part traceability to the i
valves were lost and the operability of the valves may be
) affected. (Allegation #AQ-52). -
i 4
E' Permittees believe that the TRT letter of 9/18/84 was +,
their first notice of this issue.
However, it can conceivably be urged that the first isolated indication of .
the potential of a systemic problem in the valve i
disassembly / reassembly process was the filing of the first j NCR which identified missing parts on valves. This NCR, i
initiated by the TUGCO QA staff, was documented as NCR M-1457 on May 23, 1979. It was dispositioned by obtaining and installing new bolting from the warehouse with appropriate heat trace markings for the valve in question.
l On 8/6/79, in response to the potential problems which j
NCR M-1457 might indicate with regard to valve part i
traceability during valve disassembly and reassembly, TUGC0 i
] i j
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QA initintsd a Correctivo Action R2quoct (CAR S-36). This CAR required Construction to address the possible problem of a
future misplacement of parts during valve disassembly and i
reassembly. Construction committed to maintain a controlled
- inventory of nuts and to issue NCRs on missing components in the field. In addition, Construction committed to add a ;
step in the procedures contained in work travelers to '
I i include a list of materials added or deleted for QC ;
, verification.
Approximately four years later, in response to the i
issuance of six NCRs and a number or Permanent Equipment Transfers (PET) documenting the replacement of missing parts or parts with missing data markings issued during the intervening years, TUGCO revised the procedures resulting .
} from CAR S-36. In June, 1983, a new procedure, CP-CPM-9.18,
" Valve Disassembly /Reansembly" was issued for which QA issued a corresponding inspection procedure, QI-QAP-11.1-39A. This procedure specified use of a checklist which required the recording of body and bonnet identification numbers upon disassembly and verification of j the proper numbers upon reassembly. With the promulgation i
of these new procedures, TUGCO considered any problems associated with valve disassembly and reassembly to be i
j solved.
On 1/08/85, however, the NRC letter to TUGCO notified TUGCO of the TRT finding. Subsequently, the CPRT was formed i
l
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. l l
cnd ISAP VII.b.2 (Valva Diensecmbly) cnd ISAP VII.o.1 l
' l (Material Traceability) were issued to address the TRT finding with regard to part traceability during the disassembly / reassembly
, process.
I (ISSUE: EXIT INTERVIEWS):
At page 0-240 of SSER 11 dated May 1985, the TRT found that:
[a]1though, still in its infancy, the exit interview i
questionaire and followup, which were reviewed by TRT,
, do not appear to meet the program objective.
Permittees believe that the TRT letter of 1/08/85 was their
- first notice of this issue. It can conceivably be urged, however, that the first indication of the potential of a systemic 6(
i problem in the exit interview process was recognized in August 1983 with the issuance by the NRC of Notice of Violation EA 83-64 -
which was based on the alleged transfer and termination of an 9
, employee as a result of writing nonconformance reports. In response to the Notice cf Violation, TUGCO initiated an eight point program to reaffirm its committment to an effective and 1
independent QA/QC program. The eight points included the ^
initiation of an exit interview program to ensure that QA/QC s
employees have the opportunity to state their concerns regarding quality at CPSES prior to dissociation with the QA/QC department.
i (TUGCO letter to NRC dated September 28, 1983). The exit interview program was formally initiated and exit interviews conducted as early as October, 1983.
i
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In November 1983, TUGCO also contracted the professional services of an Ombudsman to strengthen efforts to solicit and respond to employee concerns. All employees were advised of the program by a memorandum in December 1983 and all termine. ting employees were interviewed via the program. (TUQ-1887, 12/14/83).
The Ombudsman was present through May 1985 with his principal function being to assist utility management with the implementation of the exit interview program.
In an effort to improve communication on potential quality concerns between employee and management, TUGCO contracted the services of SAFETEAM from Utility Technical Services (now SYNDECO Inc.) in December 1984. Established on site January 14, 1985, j SAFETEAM's purpose is to provide a program that will identify and investigate concerns of all CPSES employees. Toll-free telephone '
numbers, independent interviewers, confidentiality and follow-up ,
investigations of concerns are the key components of the SAFETEAM program.
4 On 1/8/85, the NRC letter to TUGCO notified TUGCO of the TRT -
finding. Subsequently, the CPRT was formed and ISAP VII.a.6 (Exit Interviews) was issued to address the TRT finding with regard to exit interviews.
i i
a 8
i DOCKETED CERTIFICATE OF SERVICE USNRC I, William S. Eggeling, hereby certify that on M g h d S0 lW G1 I made service of the within document by mailing copies thereof, OFFICE 0F SEGtiARY postage prepaid, to: DOCKEiiNG & SEFV;CI.
BRANCH Peter B. Bloch, Esquire Mr. James E. Cummins Chairman Resident Inspector Administrative Judge Comanche Peak S.E.S.
Atomic Safety and Licensing c/o U.S. Nuclear Regulatory Board Commission U.S. Nuclear Regulatory P.O. Box 38 Commission Glen Rose, Texas 76043 Washington, D.C. 20555 Dr. Walter H. Jordan Ms. Billie Pirner Garde Administrative Judge Midwest Office 881 W. Outer Drive 3424 N. Marcos Lane Oak Ridge, Tennessee 37830 Appleton, WI 54911 i Chairman Chairman ,
4 Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission -
Commission Washington, D.C. 20555 .
Washington, D.C. 20555 j Lawrence J. Chandler, Esquire Mrs. Juanita Ellis Office of the Executive President, CASE Legal Director 1426 S. Polk Street U.S. Nuclear Regulatory Dallas, Texas 75224 Commission Washington, D.C. 20555 i
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I O
Renea Hicks, Esquire Ellen Ginsberg, Esquire Assistant Attorney General Atomic Safety and Licensing Environmental Protection Division Board Panel P.O. Box 12548, Capitol Station U.S. Nuclear Regulatory Commission Austin, Texas 78711 Washington, D.C. 20555 Anthony Roisman, Esquire Mr. Lanny A. Sinkin Executive Director Christic Institute Trial Lawyers for Public Justice 1324 North Capitol Street 2000 P Street, N.W., Suite 611 Washington, D.C. 20002 Washington, D.C. 20036 Dr. Kenneth A. McCollom Mr. Robert D. Martin Administrative Judge Regional Administrator 1107 West Knapp Region IV Stillwater, Oklahoma 74075 U.S. Nuclear Regulatory Commission Suite 1000 611 Ryan Plaza Drive Arlington, Texas 76011 Elizabeth B. Johnson Geary S. Mizuno, Esq.
Administrative Judge Office of the Executive
- Oak Ridge National Laboratory Legal Director
(
P.O. Box X, Building 3500 U.S. Nuclear Regulatory Commission -
Oak Ridge, Tennessee 37830 Washington, D.C. 20555 Nancy Williams .
Cygna Energy Services, Inc.
101 California Street -
Suite 1000 San Francisco, California 94111 1 2 W1111. S.
Egg.pg j