ML20205R393

Forwards Permittees Further Responses to M Gregory Interrogatories & Request for Production of Documents (Set 5),per NRC Rules & Regulations.Certificate of Svc Encl. Related Correspondence

ML20205R393
Person / Time
Site:	Comanche Peak
Issue date:	03/30/1987
From:	Eggeling W ROPES & GRAY
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
CON-#287-2994 CPA, NUDOCS 8704060333
Download: ML20205R393 (8)

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ropes & GRAY 22S FRANKLIN STREET BOSTON, MASSACHUSETTS O2110

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PROvictNCE.R.L 02903 f tLEX NUMBER 95i973 ROPES GRAY 3Sel (403) 821-8400 WAS HING TO N, CL C. 2 O O37 f tLECO PIERS' (SIF) 423 2377 . (4171423 744:

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U.S. Nuclear Regulatory Commission 2 N-Mashington, D.C. 20555 "

ATTENTION: Docketing and Service Branch .

Re: Texas Utilities Electric Company, et al.

Docket No. 50-445-CPA Dear Sir Pursuant to the Commission's Rules and Regulations, there is enclosed herewith for filing in the above-entitled matter one signed and two conformed copies of "Permittees' Further Responses to 'Meddie Gregory's Interrogatories and Request for Production of Documents (Set 5)'" with Certificate of Service attached.

Very truly yours, L. , .

William S. Egg ng Enclosures cci Certificate of Service i

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of )

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TEXAS UTILITIES GENERATING )

COMPANY et al. Docket Ifo. 50-445-CPA

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(Comanche Peak Steam Electric )

Station, Units 1 and 2)

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PERMITTEES' CURTHER1 RESPONSES.

TO "!!EDDIE GREGOP.Y'S INTERROGATORIES AND REQUEST FOR PRODUCTION OF_ DOCUMENTS (SET S}"

Pursuant to 10 CITR $$ 2.740, 2.740b ar.d 2.741, the Permittees respor.d herein to "Med'ie Gregory's  %

E Interrogatories and Request for Productitin of Documents (Set 5)."

The Permittees have ignored the definitions and guidelines in the paragraphs labelle,d "a throug's "s,"

inclusive, as contained in the dacument oatitled "Meddi e Gregory's Interrogatorien and Reque% for Preduction of 1

By agreement of the parties, the Permittees nr4!

continuing to respond to these Interrogatories.as their investigation with regard to each issue is completed.

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' Docum:nto (Sst 5)," insofer as tho etmo cro centrary to the

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, Rules of Practice.

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Interrogatory 1:

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e 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, racmorandum, consultant's report, etc.)?

( ' Interrogatory 2:

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j Tor-each item identified in Interrogatory 1, identify what 4

, respon'se was taken to the problem and by whom.

, -Ir.terrogatory 3:

j If the answer to Interrogatory 2 is that no action was

taken, exp?. min ths reason that no action was taken.. If that '

j reason is'because. Applicants relied on a "second opinion,"

j identify the opinion.. individuals or organizations who provided that

Interroaatory 4 . i Identify how each " finding" identified in Interrogatory 1 was by integrwted others. into Mensideration of the subsequent findings (for example, how were the findings by the NRC l

in 1978 and 1979 integrated into Applicants' response to the I findings by the Management Analysis Corporation (MAC)?)

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-PERMITTEES' RESPONSES l

(TRT ISSUE

PREOPERATIONAL TESTING) l;

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i At pages J-13 and J-14, respectively, of SSER 7 dated January, 1985, the TRT found n

i &/ stem test engineers (STE's) were not on controlled

!, 4istribution for design changes applicable to systems to

! which'they were assigned; rather, they were required to i

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- obtain thin information on their own initiative from.the I

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g dscument centrol centor prior to starting a toot end were then required to incorporate that information, as applicable, into the test, procedure. While the TRT did not identify any specific ~ problems as a result of this practice, it considers this practice to be weak since it relies too heavily on the motivations and initiatives of test personnel to ensure that they have current design information before when they conducting are developing test procedures and tests. Typically, these are periods i

when they could be under more than normal pressure.

Additionally, because of the number and nature of the problems found in the document control system by the TRT QA/QC Group, the TRT could not reasonably conclude that the document control system problems identified did not affect testing activities.

The TUEC startup group relies heavily on the accuracy and completeness of the design documents, which are included in the document control system, in its preparation testing. of test procedures and during the conduct of A number of problems were identified in the document its review.control system by the TRT QA/QC Group during While the TRT Test Program Group did not .

find that these problems adversely affected those -

portions of the testing program that it included in its review, the TRT cannot conclude with reasonable assurance that the document control system problems had no adverse effect on testing activities., ' 1 In summary, the TRT reviewers' concerns were twofold:

(1) that the requirement for STE's to review system drawings and applicable design changes may rely too heavily on their own motivation and initiative at a time when they are under more than normal job pressure and as a result the STE's may start testing activities without possessing the latest i design information; and (2) that the problems identified by' the TRT QA/QC Group with the Document Control Center (DCC) for construction activities may have adversely affected the testing program.

Permittees believe that the TRT letter of September 16, 9

1984 was their firct notice of the potsntici existance of the " engineers' initiative" issue, and that SSER 7 dated i

January, 1985 was their first notice of the potential for DCC problems adversely affecting the testing program.

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Prior to April, 1983, the control and distribution of design documents was centralized in the main DCC facility.

The STE's found this burdensome since the DCC was remote from their work location. In April, 1983, DCC satellites were established at convenient locations relative to work sites to improve access to design documents. The first DCC satellite was established in the Startup facility. The .

STE's were initially provided with controlled-distribution drawings. This system, however, proved to be both cumbersome and an administrative burden. After approximately one year, DCC and Startup supervision decided to eliminate controlled-distribution drawings to individual STE's due to the administrative burdens that distribution placed on both organizations.

So as to prevent the STE's from testing without the latest design information, Startup and DCC supervision elected to: (1) provide libraries of controlled-distribution drawings to those Startup groups performing similar activities; (2) provide independent user libraries within the facilities; and (3) expand the reference facilities near the Startup DCC satellite area.

The controlled-distribution drawings and design change documents within these libraries

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'sinco havs bacn maintcintd current by DCC octallite personnel.

TUGCO believed that this system established adequate measures to provide assurance that STE's and other responsible test personnel are provided with current controlled design documents and changes. During the period of concern to TRT, the STE's did use current design >

documents in the conduct of both preoperational and.

prerequisite testing activities. i Following notification by TRT of this irsue TUEC formed the CPRT and issued ISAP III.d (Preoperational Testing) to address the TRT findings as stated in SSER 7. In addition to investigating the history of Startup and DCC organizational interface as described above, the CPRT investigated the potential for DCC problems to have adversely affected the testing program.

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4 CERTIFICATE OF SERVICE I, William S.

Eggeling, hereby certify that on March 30, 1987, I made service of the within document by mailing copies thereof, postage prepaid, to:

Peter B. Bloch, Esquire Mr. James E. Cummins Chairman Resident Inspector Administrative Judge Atomic Safety and Licensing Comanche Peak S.E.S.

Board c/o U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission P.O. Box 38 Washington, D.C. Glen Rose, Texas 76043 20555 Dr. Walter H. Jorden Ms. Billie Pirner Garde Administrative Judge Midwest Office 881 W. Outer Drive

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Oak Ridge, Tennessee 37830 3424 N. Marcos Lane '

Appleton, WI 54911 Chairman Chairman Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel U.S. Nuclear Regulatory Board Panel Commission U.S. Nuclear Regulatory Commission Washington, D.C. Washington, D.C. 20555 -

20555 Lawrence J. Chandler, Esquire Mrs. Juanita Ellis Office of the Executive President,~ CASE Legal Director U.S. Nuclear Regulatory 1426 S. Polk Street Dallas, Texas 75224 Commission Washington, D.C. 20555 E% 58 93 0 d'

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4 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

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Anthony Roisman, Esquire Mr. Lanny A. Sinkin Executive Director Christic Institute i

Trial Lawyers for Public Justice 1324 North Capitol Street 2000 P Street, N.W., Suite 611 Washington, D.C.

Washington, D.C. 20036 20002 Dr. Kenneth A. McCollom Mr. Robert D. Martin Administrative Judge Regional Administrator 1107 West Knapp Region IV Stillwater, Oklahoma 74075 U.S. Nuclsar Regulatory Commission Suite 1000 611 Ryan Plaza Drive Arlington, Texas 76011  !

l 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 i Cygna Energy Services, Inc.

101 California Street Suite 1000 San Francisco, California 94111 O

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William S.

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