ML20209E582
| ML20209E582 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/02/1987 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
| ML20209E547 | List: |
| References | |
| NUDOCS 8704300078 | |
| Download: ML20209E582 (161) | |
Text
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0iG NE UhITED STATES O
NUCLEAR REGULATORY COMMISSION IN THE MATTER OF:
DOCKET NO: 50-445 50-446 COMANCHE PEAK RESPONSE TEAM PROGRAM l
l l
l O
LOCATION:
DETi!ESDA, MARYLAND PAGES:
1 - 101 DATE:
Tl!URSDAY, APRIL 2, 1987 I
ACE-FEDERAL REPORTERS, INC.
Officialikporters 444 North Capitol Street
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1 UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION MEETING BETWEEN NRC AND TU ELECTRIC COMANCHE PEAK RESPONSE TEAM PROGRAM l
4 DOCKET NUMBERS 50-445 AND 50-446 5
6 Nuclear Regulatory Commission Room P-110 7920 Norfolk Avenue 7
Bethesda, Maryland 8
Thursday, April 2, 1987 9
10 The mooting convened at 12:30 p.m.,
Christopher Grimes presiding.
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1 PROCERD I NGS 2
MR. GRIMES:
I will convene this meeting.
My name 3
is Christopher Grimes and I am director of the Comanche Peak 4
project division.
This meeting is being held for two 5
purposes:
One is at the request of the Staff we asked for an 6
overview of Comanche Peak response team activities in order 7
to provide an 3ntroduction for new NRC Staff that have been 8
assigned to the Comanche Peak project division, and to 9
provide a refresher for NRC Staff that had formerly worked on 10 the project and are now working in this division as to the 11 course and direction of the CPRT activities.
12 In addition, Texas Utilities asked for a forum to O
13 discuss engineering function evaluations, which would be 14 performed by Stone & Webster in place of third-party reviews 15 that are referred to in the Staff's safety eval.uation report 16 on the Comanche Peak program plan.
17 I would like to introduce the staff that are here 18 today representing the office of special projects.
The 19 director is Mr. James Keppler; deputy director is Jane 20 Axelrad; I have Jim Lyons, who will be the assistant director 21 for technical programs in the Comanche Peak project 22 division.
Van Shirling, who will be the assistant director 23 for projects.
24 We also have Charlie Trammel, who is the project 25 manager for Comanche Peak in the old organization, and Annett l' l Acn FeonRAL REPORTERS, INC.
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1 Cook, who is the old project plan engineer in thu old 2
division.
She will be working onLthe Comanche Peak project 3
in the future.
I won't go through and introduce each of the 4
Staff because I wil] end up spreading myself around too much, 5
but we have as many of the new organization here today as 6
were available.
I would like to instruct speakers to 7
identify yourself for the benefit of the reporter and speak 8
clearly and please try to avoid interrupting the speakers, to i
9 make the transcript as readable as possible.
~
10 I want to make it clear that this is an 11 information-gathering 'eeting.
We don't intend on making any m
12 decisions today.
We will ask Texas Utilities to highlight 13 certain major features of this discussion during our public.
14 meeting next Tuesday in Dallas to provide this information in 15 a more complete way.
By that time we hope to have a reaction-16 and be able to start providing Staff positions with respect 17 to CPRT activities now and in the future.
18 During the course of the meeting, there are 19 several things I.would like~to cover.
One is I would like.a i
20 clear explanation of the purpose and objective of the 21 Comanche Peak response team.
I would like an explanation of 22 how those activities will integrate to achieve its 23 objective.
I would like to understand what Texas Utilities' 24 perspective or purpose is on the use of third-party reviews, 25 particularly in relation ~to the concept of the engineering ACE-FEDERAL REPORTERS, INC.
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functional evaluations.
I would also like you to explain 2
what measure of independence you feel is appropriate, 3
vis-a-vis the objective of these engineering functional 4
evaluations and even the engineering assurance program as 5
Stone & Webster applies it.
I would also like you to explain 6
what documentation you would intend to submit to the NRC in 7
relation to the engineering functional evaluations and some 8
sort of overview schedule and when they would be conducted so 9
that we can begin planning the Staff review of those 10 efforts.
11 With that, I would like to turn the meeting over 12 to Mr. Counsil and his staff from Texas Utilities to make fsb 13 their presentation.
14 MR. COUNSIL:
Thank you, Chris.
We are happy to 15 be here to hopefully enlighten NRC and NRC Staff about the 16 activities ongoing at Comanche Peak today.
By way of 17 introduction on who I have with me today in the room, 18 opposite me and Icading the discussion today will be Larry 19 Nace, vice president of engineering construction.
On my 20 immediate 3 eft is John Beck, the vice president of' nuclear 21 engineering and also chairman of the senior review team for 22 our ongoing efforts.
To my right is Jim Muffett, executive 23 assistant to Larry.
At the head of the room, Terry Tyler, 24 director of nuc3 ear projects.
To his left is John Streeter, 25 director of quality assurance.
To his left, I hope, is John ACE FEDERAL REPORTERS. INC.
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1 Krechting, director of engineering.
Yes, he is.
Back of_the 2
room is Don Woodlan, supervisor of docket licensing on the 3
Comanche Peak project.
We have various other members here 4
who will introduce themselves from the Stone.& Webster 5
Engineering Corporation for the engineering functional 6
evaluation at the appropriate time.
7 With that, I would like to turn it over to Larry, 4
8 and we will go on with the program.
9 MR. GRIMES:
While Larry is setting up I would 10 also like to note for the benefit of the attendees that.we 11 have Ms. Billie Garde here in attendance representing 12 Intervenor.
We also have Herman Alderman ~here representing O
13 the advisory committee for reactor safeguards.
14 MR. COUNSIL:
I suppose in furtherance of that 15 also, I should mention that I believe every member of the 16 senior review team is present in the room, in addition.
17 MR. NACE:
The agenda for this afternoon's 18 presentation includes three group topics, the first having to 19 do specially with the CPRT background, the second havingLto 20 do with the corrective action programs that we currently have 21 ongoing at Comanche Peak in response to issues which have 22 been identified through the CPRT effort.. The third item on H
l 23 the agenda is the Stone & Webster engineering functional 24 evaluation which Mr. Grimes talked about.
We believe we have 25 the answers to the questions you mentioned at the start of i
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the meeting contained within the body of these.
2 presentations.
We can discuss the specific question when it 3
comes up in the presentation, or after, at your choice.
We 4
have also broken that-third bullet down, the engineering 5
functional evaluation discussion, into-a summary part, and 6
then a detail part, looking to the advance information we had 7
that perhaps Mr. Keppler might need to. leave early.
8 The discussion on the Comanche Peak response team
]
9 background will be led by Terry Tyler,_ director of nuclear 10 projects.
What we a're going to do here is explain the events I
?
11 and circumstances that led to the formation of the Comanche 12 Peak response team and ultimately initiated the corrective i
13 action programs which are currently ongoing.
14 The corrective action programs themselves will be 1
15 discussed by John Krechting, my director of engineering.
He j
16 is going to describe the corrective action program, convey to 17 you while it will provide the required assurance that 18 installed structures, systems and components meet licensing 4
19 commitments.
20 Following that, Mr. Bill Eifert, the chief 21 engineer from Stone & Webster's engineering assurance program-22 will lead a discussion on the Stone & Webster evaluation.
23 Participating in those three discussion topics, on l
24 first topic, Mr. John Beck will also discuss the current CPRT 25 senior review team participation and how various parts of the 14CE. FEDERAL REPORTERS, lNC.
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I program are tied together, and participating in the 2
discussion on the corrective action program will be Mr. John 3
Streeter, and discuss some effects of the TU Electric quality l
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4 assurance program.
5 I do have copies of the slides that are being used I
I 1
6 for this presentation that have been passed out and will be i
7 made a part of the record.
Terry.
8 MR. TYLER:
Thank you, Larry.
My name is Terry 9
Tyler, director of nuclear projects.
Before anyone jumps to 10 conclusions asking why am I talking about Comanche Peak
{
11 response team, up until three weeks ago, I was the Comanche 12 Peak response team program director responsible for the 13 day-to-day coordination of CPRT activities, reporting 14 directly to and taking direction from the senior review 15 team.
16 I would like to go back in time just slightly to 17 talk about what initiated the Comanche Peak response team.
18 As most of you are aware, CPRT was formed in 19 direct response to the NRC technical review team 1
20 investigation findings.
The TRT was formed, or announced to 21 be formed, in an early 1984 NRC Commissioners' briefing on 22 near-term operating license dockets.
It was stated that the 23 effort would commence in the near term, and it did, indeed, 24 in April, on-site, culminated in the late summer of 1984.
25
}
The first findings from the TRT investigation were ACE-FEDERAL REPORTERS, INC.
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1 presented to TU Electric management in a meeting held here in 2
Bethesda in September of 1984.
3 Immediately upon return to Texas, Mr. Michael 4
Spence, president of the generating division of TU Electric, 5
formed the Comanche Peak response team.
6 I would like to talk briefly about the structure 7
of the response team in September of 1984 and the staffing.
8 The CPRT structure was controlled by program plan.
The 9
program plan was the controlling document establishing the 10 goal of the program, the methodology by which various 11 investigations would be performed, the policies and the 12 operative features of the program.
13 Yes, ma'am?
14 MS, GARDE:
Could I ask, when you are referring to 15 it as CPRT will you refer to which revision you are talking 16 about so we can write it on our slide.
17 MR. TYLER:
This is Revision 0.
18 MS. GARDE:
I understand that.
I think you are 19 going to be going from that forward.
20 MR. TYLER:
I think you will see we talk about 21 Revision 0, 1 or 2 or 3.
This is Revision 0 we are talking 22 about at this point in time.
In addition there was a 23 commitment contained in Revision 0 to thoroughly investigate 24 all issues raised by the TRT and the generic implications 25 thereof.
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The specific issues were investigated through a 2
series of issue-specific action plans, called ISAPs,.that I
3 describe the specific courses of action to investigate the 4
specific-TRT findings.
5 CPRT organization and staffing.
CPRT had a 6
governing body, the senior review team, members which are 7
here today.
It's equivalent to a board of-directors.
They.-
8 establish the policy, approve key staffing personnel, approve 9
the action plans and results reports.
Immediately beneath i
10 the senior review team is a group of review team leaders, who i
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11 were the key individuals approved by the senior review team, 12 the scope staff and implement the investigations. -At this
()
13 point in time the program was staffed principally with TU 4
14 Electric personnel.
i j
15 The initial CPRT program, Revision 0, was i
16 submitted to the NRC in October of 1984.
In two meetings 17 that took place again here in Bethesda, and a principal i
10 concern was that the program lacked independence, or 19 objectivity.
4 4
20 So at this point in time, the basic scope of the 21 CPRT program issue-specific. action plans,.this is a 22 simplistic, one-dimensional view of the typical functions 23 that take place in building a nuclear power plant,-design, 24 construction process, combining both craft and CQ, testing 25 process.
The specific TRT concerns were in the area of ACE FEDERAL REPORTERS, INC.
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- 1 con s truc' tion, tes ting, and a t' this point in time, some 2
limited issues with the QA/QC program.
3 Immediately upon return from-the meeting here in 4
Bethesda, the decision was made to change the staffing of the 5
CPRT from TU Electric personnel to third-party.
During the 6
same time period, the program plan was-evolving, the a
7 remainder of the NRC TRT issues or concerns were provided to
~
8 TU Electric and subsequently to the Comanche Peak response 9
team.
In addition, there was a decision made on 10 recommendation from the senior review team to include two 11 self-initiated activities':
design adequacy program or design 12 an assessment of the quality of construction at the hardware i
13 of the plant.
I will discuss those in more detail in.just a 14 moment.
15 In addition to this' time ~ frame, the SRT decided to r
16 use sampling as an investigatory technique.
17 MR.-KEPPLER:
Excuse me, Jerry, was all of--this 18 stuff that you were doing approved by NRC at-the time?
i 19 MR. TYLER:
The only official response we have-1 20 reviewed from NRC was on Revision 3 of the program plan as 21 contained in SSER 13.
There were numerous series of 22 correspondence back and forth regarding questions on Revision 23 2 that the CPRT subsequently answered and then embody =the 24 bases of the responses in Revision 3 of the program plan.
l 25 But there was never an official SSER or official i
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pronouncement from the Staf f on Revision 0, 1 or 2.
2 MR. KEPPLER:
Okay.
3 MR. TYLER:
As I stated, there were comments 4
provided on Revision 2 from the NRC Staff that basically led 5
to Revision 3 of the program plan as we know today, 6
three-inch book that most of you have seen sitting on various 7
and sundry desks around here and at the job site.
8 Some key points from Revision 3, there was a 9
commitment to identify the open issues out of the atomic 10 safety and licensing board, the open issue that independent 11 assessment concerns, the open case concerns and open NRC 12 concerns and previous inspections that had been taken place.
13 The CAT, SIT, TRT in Region 4, and to assure thorough 14 implementation of the issue specific actions plans that were 15 properly addressed.
16 In summary, Revision 3 of the CPRT program 17 contains a series of action plans aimed at resolving the 18 specific TRT concern.
Those are action plans, series I 19 through VII-B series.
The program plan index also contains 20 the quality of construction, sample reinspection program, 21 which is issue-specific action plan VII-C, and the two-prong 22 design assessment program which is both an overview of the 23 corrective actions that TU Electric had decided to implement 24 on piping and pipe supports, and on cable train conduit 25 supports as direct overview by the CPRT, and a self-initiated ACE-FEDERAL REPORTERS, INC.
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design assessment program on the balance of the i
2 safety-related design of the plant.
3 This leads up to the fall of 1986, or last fall, i
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design adequacy program investigation at this point in time l
5 was essentially complete, indicated inadequate documentation 6
of the design.
I don't want to mislead anyone that it was a
{
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paper problem.
There have been hardware problems identified, 8
and we have been keeping everyone appraised of those through 1
9 the normal 50, 55-E reporting process.
10 In addition, the issue-specific action plan, 11 quality of construction investigations, were essentially 12 complete.
Results were in the evaluation process, results x
13 were in the process of being completed, and the indication 14 was that there were some hardware and programmatic issues as 15 a result of those evaluations.
16 MR. NORKIN:
Terry, you just said design adequacy 17 investigation program was complete.
I want to come to that a 18 little later because that program has been stopped, but it 19 really wasn't complete based on original scope identified.
I 20 understand there were areas, technical armas that were to be 21 gone into that were to be detailed.
So in that sense it 22 wasn't 100 percent technically completed.
23 MR. TYLER:
John.
24 MR. DECK:
Don, in about one more slide I will 25 address your issue.
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1 MR. NORKIN:
Okay.
2 MR. TYLER:
Continuing the fall of '86 assessment, 3
I believe that the CPRT program had been very successful in 4
investigating the issues and identifying the areas of concern 5
that existed with the design or exist in the design 6
documentation, installed structures, systems and components, 7
and programmatic activities at Comanche Peak.
8 From a project perspective, however, problems were 9
encountered in positioning the CPRT findings on a 10 single-issue basis due to the complex interrelationships 11 between the hardware, the design configuration, and the 12 design-basis documents themselves.
7sb 13 This situation led to the decision by TU Electric 14 management to initiate the corrective action program that 15 Mr. John Krechting will describe to you, after Mr. Beck 16 presents where CPRT and the senior review team are today.
17 MR. BECK:
This is an opportunity.in the 18 presentation to cover some of the questions that Chris raised 19 a moment ago and an issue that Don Norkin put on the table 20 with regard to the design adequacy program and exactly where 21 we are.
22 Let me restate what the senior review team's 23 objective 13.
That is a very simple and at the same time 24 obviously complex charge, to make a statement to Mr. Bill r~3 25 Counsil, the responsible executive officer at TU Electric, O
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that Comanche Peak has been designed, constructed, tested and 2
can be operated in accordance with NRC regulations.
It's a 3
requirement of the law obviously and it's a charge the SRT 4
has been given.
5 In order to do that, as Terry went through, we set 6
up and evolved through three revisions to'date, the CPRT 7
investigative-phase, which was very specific in some regards 8
as to how things would proceed given certain findings.
9 Late-last summer:Mr. Counsil, in his evaluation of 10 preliminary results, in the design adequacy area, made a 11 determination to initiate the corrective action programs 12 which you will be hearing about in more detail in'a.few
~
13 moments.
Our original scope of effort in the design-area was.
14 one that, quite frankly, was_ set up to be flexible.
15 Our anticipation was that the degree of findings 16 that we would ultimately end up with could be dealt with 17 within the specified framework in the program plan.
18 Mr. Counsil's decision to initiate the corrective 19 action programs which, in essence, are a 100-percent ~
20 verification ~of critical design parameters at Comanche Peak, 21 obviated the necessity to continue in certain areas in the 22 design adequacy program, and as Don Norkin alluded to'a 23 moment ago, led to what, in essence, is a truncation of some 24 of the continued investigative activities.
25 It also led to a circumstance where, in our view, i
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with the SRT, certain requirements for generic implication 2
studies and investigations have been moot or are moot at this 3
point.
4 Since the corrective action programs are 100 5
percent in their coverage, there is nothing left to 1
6 generically implicate.
7 I will get, in a moment, to how we are going to 8
resolve this and make very clear to all interested parties 9
how Revision 3 has been slightly modified in' order to take.
I 10 into account this 100 percent verification effort.
11 Let me go back for a moment to the CPRT 12 investigative findings.
O 13 Part of the program requires.that the project 14 respond to the findings.
These findings in the design' area 15 came out in the form of DIRs, with which you are all 16 familiar.
We are asking that the SRT, review team leaders, 17 not only in the design area, but in other areas as well, 18 determine and provide to us formal confirmation that the
(
19 project has been made aware of each and every finding, that l
20 the project acknowledges receipt of each and every finding, 21 and that the project is committed to resolve each and every 22 finding.
j 23 The SRT, in satisfying its charge and objective 24 that I stated earlier, is responsible-for overviewing project 25 response to all of these findings.
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1 An overview is going to take place in two very 2
important fashions.
One, we are going to take advantage of 3
the comprehensive effort on the part of the QA technical 4
audit program, which Mr. Streeter will discuss in a moment, 5
as a window into the effective resolution of all issues that 6
have come out of the investigative phase.
7 We are also going to take advantage of the Stone &
8 Webster engineering functional evaluation program which will 9
be looking, in some instances, at the same 2reTs, and in 10 other instances, independently at other aspects, other 11 projects' response to CPRT findings.
12 If necessary, the SRT will direct additional O
13 efforts in order for us to achieve that final reasonable 14 assurance with regard to the design, construction and testing 15 of Comanche Peak.
16 In the course of our overview, we will continue to 17 produce CPRT results reports.
We have some 30-odd in the 18 approval stage, most of which have been distributed at the 19
-this juncture.
We will finish most of those results 20 reports.
Some will be consolidated, and that consolidation, 21 that difference, if you will, in Revision 3, and what our 22 intentions are today, as well as some other exceptions to 23 what Revision 3 contains in the way of third-party 24 requirements, will all be spelled out in a letter that the r"
25 SRT will provide to Mr. Counsil shortly.
We do not intend to b}
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1 issue Revision 4, but,.rather, this letter to Mr. Counsil in 2
Revision 3 will make very clear, beyond any question, exactly 3
how we are going to proceed to satisfy the requirements that 4
are put on the SRT by the program plan.
So there won't.be 5
any doubt in anyone's mind precisely where things are going 4
6 to be executed-slightly differently.
7 The-intent is the_same, the_ necessity for project i
j 8
response to findings is unchanged.
It's merely the' mechanism
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9 that will be used to' satisfy those requirements and 10 objectives, 11 If there is any question, I will be happy to 12 answer wit',i regard to the. specific _ issues you put on the O
13 table, Chris.
I 14 MR. GRIMES:
Is this letter that you are going to 15 send to Mr. Counsil going to identify each and every 16 variation from what was originally envisioned by the plan?
17 MR. BECK:
Correct.
18 MR. GRIMES:
Are we going to find traceability 19 back to all the original issues and'all the intended 20 actions?-
21 MR. DECK:
Exactly.
22 MR. NORKIN:
Don Norkin again.
Alluding to my 23 original question, I think you said, if I interpret 24 correctly, that the need to complete all of each and every 25 one of the technical items in the original design adequacy
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program scope has been obviated by the 100 percent review by 2
the corrective action program; right?
3 MR. BECK:
In many instances, yes.
4 MR. NORKIN:
I am just saying from the NRC 5
standpoint, we will be testing some cases of things which 6
weren't completed by design adequacy programs, specific 7
technical things in each area, civil, mechanical, et cetera, 8
originally labeled as homogeneous design activities.
If such 9
an activity was not completed, you would test the corrective 10 action program to see if it was executed under that program.
11 We would anticipate that you would have a mechanism for 12 enveloping such activity.
7-(
13 MR. BECK:
I am confident that the corrective 14 action programs go far beyond the programs of the program 15 plan in the design adequacy area.
I am sure Mr. Nace 16 welcomes the opportunity to specifically point out in every 17 instance where that is true.
18 MR. NORKIN:
Okay.
19 MR. BECK:
If there are no other questions, we 20 will get on with the show.
21 MR. KRECHTING:
I am John Krechting, director of 22 engineering for Comanche Peak Engineering.
I want to 23 describe to you today the corrective action program that TU 24 Electric has established.
25 Corrective action program has, as its mission, to ACE-FEDERAL REPORTERS, INC.
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demonstrate that existing systems, structures and components 2
are in compliance with the licensing commitments, or if they 3
are not, to develop modifications which will bring the 4
systems, structures and components into compliance with the 5
licensing commitments.
6 The plan also ensures that we will develop 7
procedures, an organization and documentation to maintain 8
compliance to licensing commitments throughout the life of 9
Comanche Peak.
10 At the heart of the corrective action program is 11 what we call the design-basis consolidation program.
It is 12 the fundamental element of the corrective action program.
13 What is the design-basis consolidation program?
14 It's a program which has as its purpose, when completed, to 15 provide assurance that the design of systems, structures and 16 components will comply with the licensing commitments.
It 17 will ensure the configuration of systems, structures and 18 components are in accordance with the design.
Therefore, in 19 accordance with the licensing commitments.
It will insure 20 that we have documentation in place, an organization in place 21 and procedures in place that will assure compliance with 22 licensing commitments in the future.
23 The elements of the design-basis consolidation 24 program that we will use to resolve the various issues are 25 the generic issue report, the design-basis documents, the
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design validation package and the final project report.
2 What is the generic issues report?. Generic issues 3
report presents and identifies those issues from external 4
sources such as TRT, CYGNA, CASE, CAT, et cetera, and those 5
internally generated issues that had been identified by TERA-6 and ERC.
The generic issues report are where the various 7
corrective actions have been issued, and the NRC has copies 8
of those.
The generic issues report also presents the 9
corrective action methodology, which is the design-basis 10 consolidation program, for resolving the identified issues as 11 well as validation of the design basis.
12 Design-basis documents.
The design-basis document o
13 is a controlled document that contains.the current design s
14 criteria which embodies the licensing commitments, codes and-15 standards, and NSSS interface criteria, system and component 16 design parameters.
It is, if you will, the rules of the 17 game.
It is the licensing commitments and the design bases i
18 which support those licensing commitments.
It is the very i
19 beginning where we will start the corrective action program.
20 MR. GRIMES:
Where would I find those?
f 21 MR. KRECHTING:
They are the internal documents f
22 that are being developed, some of them are developed, and 1
23 they are in our files.
l 24 MR. GRIMES:
What procedure docyou use to insure 25 that they are ultimately reflected in the FSAR?
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1 MR. KRECHTING:
It's sort of the other way 2
around.
We take the FSAR and use that as the basis to 3
develop the design-basis documents.
In other words, we 4
extract the commitments from the FSAR, relate those to the 5
design criteria that are identified in the design-basis 6
documents, to insure that that criteria will make sure that 7
we meet our licensing commitments.
So they embody, if you 8
will, the licensing FSAR commitments.
9 MR. GRIMES:
In the course of identifying plant 10 changes or design changes or corrective actions, how do you 11 insure that you don't develop an inconsistency through 12 implementation?
3 l
13 MR. KRECHTING:
Because the design-basis documents 14 are, in fact, identify the commitments, and all these design 15 modifications that take place will be in accordance with its 16 design-basis documents or the licensing commitments.
17 I have a slide here at the very end, I don't want 18 to bring up now, which will tie all of this together and I 19 think maybe help you out.
We are sort of going through each 20 one of the individual parts of it.
I will tie it all 21 together for you at the end.
22 The design validation package.
The design 23 validation package is a module or scope of work, if you will, 24 that the various corrective action programs are broken down 25 into.
They form a logical way, if you will, to scope out and ACE FEDERAL REPORTERS, INC.
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1 divide the various pieces of the corrective action program.
2 If you think in terms of vertical slices as one example of 3
systems, take a total vertical slice for an entire system.
4 It also will break up into structures, components of a S
structure.
There might be special programs that could be an 6
individual module design evaluation package such as 7
interaction program, equipment qualification programs, which 8
are broad across all systems.
9 It will identify as part of those packages within 10 the scope interfaces with other packages, so that, in fact, 11 the interfaces are recognized and nothing is lost in the 12 vertical cut, you also look horizontally through that O
13 interface mechanism to make sure we pick up any of the work 14 that would be required in other design validation packages.
15 The design validation package also at'the end, 16 when we are all done, will represent the proof of the 17 pudding, so to speak.
It will be the documentation, the 18 results of all of the work that is done to form the 19 validation for that package.
It will contain the design 1
20 documents, the specifications, calculations and drawings 21 which form the basis of the design.
It will present and 22 identify the evaluations that were done.
It will tell you 23 exactly what we did.
24 Yes, Don?
25 MR. NORKIN:
Reflecting on the last two slides, 1
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the design-basis documents and the design validation package, l
2 I think, if this is an appropriate time, I would be l
3 interested in your interpretation as to how these constitute j
4 100 percent review and to what degree of a review you really 5
have over here.
6 MR. KRECHTING:
If you could wait, Don, when I get 7
into the overall slido, I think it would be a good time for 8
you to ask that, if that's okay.
9 MR. NORKIN:
Okay.
Whenever.you think it's 10 appropriate.
11 MR. KRECHTING:
If I can get into that slide, it 12 will help you out.
s 13 It will also demonstrate, by virtue of the 14 documentation, the evaluations that were done, that the 15 design documentation complies to the design basis and 16 therefore to the licensing commitments.
17 It will represent the document design basis, the 18 configuration management base line, if you will, from which 19 future design work will be based.
It will form -- it will be 20 the basis that this is the design basis for this plant that 21 meets the licensing commitments, and all future work from 22 that point on will be done using this as a starting point.
23 MR. CHANDLER:
John, this is Larry Chandler.
To i
24 the extent that the last bullet there might reflect a change 25 from your design-basis documents which you indicated are i
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derived from your FSAR, does that mean you go back into the 2
FSAR with a suitable amendment to that?
3 MR. KRECHTING:
If that is necessary, yes.
The 4
final project will be a set of individual final project 5
reports.
There are 11 corrective action programs, if you 6
will, that are formulated along the lines of disciplines, the 7
example would be large-bore pipe, small-bore pipe, paper tray O
hangers, conduit, IC, AHAV, equipment and qualification.
9 Each one of those design-basis consolidation programs will 10 have a final report.
That report will define how the 11 objectives of the corrective action program were met, it will 12 report on how all the issues were resolved, all the external O
]
13 issues, all the internal issues identified and any other 14 issues that may have been identified as part of the 15 corrective action program.
It will identify those, as I 16 said, indicate how they were resolved.
17 It will also identify preventive action to ensure 18 that similar problems do not occur in the future.
19 MR. GRIMES:
Excuse me, I want to go off the 20 record for just a minute.
21 (Discussion off the record.)
22 MR. GRIMES:
Now we will go back on the record.
23 Would you continue.
24 MR. KRECHTING:
Yes, Larry.
25 MR. CHANDLER:
You indicated that the slide should O
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%.)
1 read " final project reports."
2 MR. KRECHTING:
To be absolutely right, you are 3
correct, Larry.
There will be 11 of them.
4 MR. CHANDLER:
Will there be a compilation of them that in particular the third element gets synthesized?
5 so 6
MR. COUNSIL:
I will take that one.
Bill 7
Counsil.
At this point in time, Larry, we have not exactly l
8 decided on how to handle that submittal.
It will either then 9
be an overall report to NRC or a compilation of the reports 10 and the findings of the reports.
I am right now leaning 11 toward a report from me that summarizes the future actions of 12 everything that has been in fact found the organizational O
13 aspect, the configuration management program, which includes 14 all policies, procedures, the whole tear down.
15 MR. CHANDLER:
There would be an integration of 16 the lessons learned from the 11 disciplines?
17 MR. COUNSIL:
At some point, yes.
But I have not 18 sat with my management committee or members from the SRT on 19 how to handle that.
I wish to do that.
I hope to report in 20 the near future to you but not so near as the 7th meeting.
21 We will probably report on that within about 30 days.
22 MR. NORKIN:
This line over here reported how well 23 the issues were resolved.
I know John Beck talked about the 24 SRT being responsible or holding somebody to resolve the 25 DIRs.
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or is there some mechanism to show traceabilities and 2
resolution on the hundreds of DIRs.
3 MR. KRECHTING:
The report will not have attached 4
to it the DIRs.
What it will do is identify the DIRs 5
associated with the given issue.
As a reference the DIHs are 6
being responded to on a one-for-one basis.
They will be part 7
of the backup documentation, if you will.
8 Don, I think I will get into this.
After I 9
finish, if you still have the question that you had before, 10 we can then talk about i t.
11 MR. GRIMES:
Excuse me, may I interrupt?
j 12 Unfortunately, this swap is going to have to occur at a time 13 that is convenient with the other party too.
14 MR. KRECHTING:
This is a good time.
15 MR. GRIMES:
Go off the record, please.
16 (Discussion off the record.)
17 MR. GRIMES:
We will now reconvene this meeting.
18 If you will proceed with your presentation, please.
19 MR. KRECHTING:
We had an opportunity, before we 20 stopped, to identify the various elements of the corrective 21 action plan and the design-basis consolidation program, put 22 together this flow chart to bring it all together, and 23 hopefully give you a better appreciation of how it works, and 24 also hopefully answer Don's questions.
If not, I will answer 25 the specific questions.
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To start off, we talked about identifying the 2
design validation package scope.
We said that was a module 3
or a way to group the design validation into vertical slices, 4
the interfaces into the other design validation packages to 5
make sure we pick up the interfaces and any of the issues 6
horizontally through the design package.
7 Put these down into identifying the critical 8
design parameters.
Before I can talk about that, we need to 9
go up here.
We identify the licensing commitments here.
10 From the licensing commitments, as we discussed, we developed 11 the design-basis documents.
The design-basis documents are 12 the design criteria, which insure that the system, structures 13 and components will meet the licensing commitments.
14 Feed that in to identify the critical design 15 parameters.
The critical design parameters are those 16 parameters of the design that are critical in the sense that 17 you must meet that criteria to insure that the licensing 18 basis or licensing commitments are satisfied.
19 There are -- as you all know, there are design i
j 20 criteria for systems, structures or components that are not 21 necessarily critical to insuring that the licensing 22 commitments are met.
23 In fear of -- I don't want to think any of you are i
24 ignorant but let me give you a simple sampling, maybe a 25 little facetious, but I think it will help you out.
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(_/
1 may be a design criteria that says paint all the piping 2
systems pink.
That is not a critical design parameter from 3
the standpoint of assuring that we meet our licensing 4
commitment.
We do not have that commitment.
5 However, a critical licensing parameter may well 6
be the constitution, the chemical properties of that paint, 7
1.e.,
the chloride, fluoridt
'atever else that could 8
affect the design of that piping system which forms the 9
pressure boundary for a safety-related system.
We will 10 identify the critical parameters, be they flow, pressure, 11 electrical requirements, structural requirements, allowable 12 stresses in piping systems.
That's what we are talking about O
13 when we say we will identify the critical design parameters.
14 MR. CHANDLER:
John, Larry Chandler.
Then in 15 other words, if there are design basis commitments, I hate to 16 use the word " commitments" instead of " documents," but if 17 there are commitments in the design-basis documents which you 18 decide are not critical design parameters, the project will 19 not necessarily assure that those commitments are complied 20 with?
I am putting a question mark here.
21 MR. KRECHTING:
They will not be validated.
That
)
22 is exactly right.
There is in the design-basic document a 23 design basis that we want to meet as part of the design, but 24 it is not cri tical, to insure that the licensing commitments 25 are met --
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MR. COUNSIL:
No, let me take that one.
What you 2
were talking about, I think, Larry, I want to clarify.for 3
John, he is kind of new to this arena, all right.
You were I
4 talking a licensing commitment, the_ upper right-hand box, I 5
believe.
4 6
MR. CHANDLER:
Right.
)
7 MR. COUNSIL:
As opposed to, say, a docume,nt that 8
is a specification not in the FSAR but on the --
9 MR. CHANDLER:
No.
10 MR. COUNSIL:
You were talking specifically with-11 that upper right-hand box.
12 MR. CHANDLER:
I was trying to move from the upper-l 13 right-hand box, Bill, into the middle box and then into-the 14 central box.
i 15 MR. COUNSIL:
I understand, a licensing commitment 16 identified in the PSAR is a critical design parameter, i
i 17 automatically, always.
18 MR. CHANDLER:
If that commitment, to use John's 19 example --
I 20 MR. COUNSIL:
That would not have been.
If it l
21 were, I would change the FSAR because there is no reason to 22 have pink paint in the FSAR.
We are starting off as the FSAR 23 is the licensing commitment of this plant, all right.
- Now,
{
24 there are other things that go into a design-basis 1
25 consolidation program, specifications that we give to a ACE FEDERAL REPORTERS, INC.
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1 vendor that may not be a commitment in the FSAR.
2 For instance, when we specify steam generators, 3
the NSSS supply, we would specify how to ship the steam 4
generators, how to package them.
We would also spec how they 5
will be unpackaged and lifted.
They do not need to be in 6
this program because they are already installed in the 7
plant.
8 I submit to you at some future date if I have to 9
replace steam generators.
That would obviously be a 10 commitment on how to go about it.
11 MR. NORKIN:
You are saying a critical parameter 12 is one that needs to be met in order to meet a licensing 7sb 13 commitment?
14 MR. COUNCIL:
Absolutely.
15 MR. NORKIN:
That's your definition.
16 MR. COUNSIL:
Absolutely.-
So don't get crossed on 17 licensing commitments.
Now, we may find, and we have found 18 in some areas, that the FSAR did need update to today's 19 criteria.
We have, in fact, done that.
That may result 20 also.
That will, in fact, happen.
21 MR. CHANDLER:
There will be a process by which 22 someone can understand the selection of the critical design 23 parameters; is that fair?
24 MR. COUNSIL:
The process and the procedures are 25 available for an NRC audit and how exactly we are doing it.
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1 MR. CHANDLER:
Not necessarily processing the 2
procedures.
If we go through, say, package by package, can
'3 one understand, or will one be able to understand, for a 4
specific area, how you have gone about including some or 5
excluding others?
6 MR. KRECHTING:
Yes.
7 MR. COUNSIL:
But, again, that upper right-hand 8
box is a licensing commitment.
9 MR. CHANDLER:
I am moving over to the central box 10 now.
11 MR. COUNSIL:
Okay, once we have identified the 14 critical design parameters, we come down and perform the 15 validation.
There are also inputs into the validation box 16 before we can complete the validation.
We talked about 17 identification of the issues, the external issues, the 18 internal issues.
They are represented add defined in the 19 generic issues report.
That's input into the validation 20 process.
We must resolve those issues.
The as-installed 21 condition of the plant, another input into the design 22 validation process.
We are not only going to validate the 23 design of the documentation, the critical design parameters, 24 we are going to validate the as-installed condition for the 25 critical design parameters.
That does not mean we are going ACE FEDERAL REPORTERS, INC.
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to do a total as-built of the plant.
2 Our review will verify in fact those parameters of 3
the as-built-condition that are critical,_are important to 4
assure that'that system meets its_ licensing commitments, they 5
will be validated.
6 Perform the. validation.
Out'of that validation, 7
we will potentially-identify noncompliance with the-design 8
basis.
There is a decision box here,.I'll push it down, I 9
think you can read it, it says is there an effect on design 10 documentation?
If the answer is yes, we will redesign the 11 documentation.
Let me come back to here.
12 What we don't show, somebody asked the question 13 and we answered it, if by revising that design documentation,-
14 we will then do a sanity check, if you will, or verification, 15 that in fact the licensing commitments.are still satisfied.
I 16 If not, if part of that design documentation change would 17 require a request to change a licensing commitments, we would 4
18 do that.
19 We then come down to the next, it is decision 20 point, which says, is there an effect on system structures or 4
21 components?
If the answer is yes, we will modify the system, t
22 structures or components.
According to our existing 23 procedures, that rework, that design work, construction work, l
(
24 would be QA inspected in accordance with the Texas Utility, 25 TU Electric QA program.
\\
l i
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An important point to remember here is the that 2
the generation of these design modifications will be done by i
3 the organization that is doing the validation.
Therefore, 4
there is the integration of any changes into the design 5
documentation and review process, so we don't have someone 6
unilaterally or independently making design modifications 7
that the person responsible for its design is not aware of.
8 Again, there will be another check with the licensing 9
commitments after the modifications to insure that we still 10 comply with the licensing commitments. _Again, there is 11 always the one-for-one alignment that the licensing-u 12 commitments meet the design commitments, meet the O
13 as-configured condition.
14 We then complete the DVP, design validation 4
15 package.
As I said this represents the documentation.
It is 16 the design, the calculations, the procedures, the drawings, 17 and the record of the evaluations that were done.
It will 18 describe exactly what we have done.
It may include test 19 procedures.
We may, in fact, validate a critical design i
20 parameter, such as a pump flow, by reviewing test procedures 21 to insure that the flows were actually obtained in the plant 22 to meet the design requirements.
If we do that, the test 23 procedure will be part of the design validation package.
At-24 least it will be referred back and we will reference back 25 that that forms a particular basis for that validation.
That l
{
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is a way to validate the configuration.
l 2
MR. CHANDLER:
John, Larry Chandler again.
You-j 3
indicated that if they go back into modifications of 4
structures or system, structures or components, those will be 5
accomplished under the Texas Utilities Electric QA program.
6 The process preceding these steps, will those be 7
accomplished under appropriate appendix B, QA-type 8
provisions?
9 MR. KRECHTING:
Yes, sir.
10 MR. CHANDLER:
Whose would those be?
11 MR. KRECHTING:
QA program.
12 MR. CHANDLER:
For the whole program?
fs
(_)
13 MR. KRECHTING:
Everything.
14 MR. CHANDLER:
Or if I go above that there, is 15 this the organization or under TU Electric.
16 MR. NACE:
The answer is yes, it's in accordance 17 with TU Electric quality assurance, appendix B program.
If 10 it is done by a contractor, we have approved that 19 contractor's QA program.
20 MR. KRECHTING:
Once we have completed the design 21 validation package, have all the documentations, we will then 22 write the final report for that particular part of the 23 corrective action program.
We said, there are 11 sections or
]
24 portions of the corrective action program, there will be 11 25 final reports.
It will describe what we did, how the issues O
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are resolved, and preventive actions to assure that any 1
2 similar problems do not happen in the future.
i 3
Don, did I answer your question?
l 4
MR. NACE:
If I might interrupt, John.
Larry 5
Nace,.again.
On the subject of that final project report, we 6
will most likely be issuing interim project reports along the 7
way to keep you abreast of the progress.
Yes.
j I
8 MR. MIZUNO:
Geary_Mizuno.
So far the corrective
{
l I
9 action program as you described is focused solely on design.
10 However, in your slide regarding the program at present fall 11
'86 assessment, you indicated there were some hardware and 12 programmatic issues that were identified as a result of the o
13 implementation of the ISAP and QLC program.
I would like to 14 know, how are you going to be addressing the resolution of 15 those programmatic issues, is it going to be part of-this 16 corrective action program or something else that you are not 17 describing here?
18 MR. KRECHTING:
No.
It is part of the corrective l
19 action program.
20 MR. MIZUNO:
Can you explain how you are going to 21 address those hardware and programmatic issues?
22 MR. NACE:
Larry Nace, again.
Let me take an 23 example.
In fact, there are some examples most of the people 24 in this room are already aware of.
One of the corrective 25 action programs is the large-bore pipe and pipe support l
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program.
Coming out of the quality inspection activities was 2
a series of recommendations reluted to removable hardware on 3
pipe supports, things that may have been installed at one 4
time, may possibly have been removed during testing.
Or wo 5
may have had some questionable control procedures regarding 6
disassembly and reassembly.
We have taken all of those 7
quality construction recommendations and folded them into the 8
final walkdowns, inspections and reconciliations of the 9
large-bore pipe pipe supports.
10 So, one by one, the programmatic or the specific 11 hardware question gets folded in under that as-installed 12 conditions box and is used as a necessary ingredient for O
13 developing the total corrective and preventive actions 14 regarding that set of commodities or that discipline in the 15 corrective action program.
Does that help?
16 MR. MIZUNO:
That helps some.
I have several 17 other questions on the as-installed conditions block but I 18 think I will hold off until next week's meeting to ask that.
19 MR. TERAO:
I have -- a very fundamental 20 programmatic question that now I am getting a little confused-21 about.
That is with the corrective action programs, 22 apparently being implemented by different organizations, 23 Stone & Webster, EBASCO and so on.
Is this design-basis 24 consolidation program separate from that program?
Is it done 25 by different people or is the design-basis consolidation ace-FEDERAL REPORTERS, INC.
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\\m) 1 program a definition of the implementation of the corrective 2
action program?
3 MR. KRECHTING:
It is a definition of how the 4
corrective action program will be done, and the principles of 5
it are going to be done whether the work is going to be done 6
by Stone & Webster, IMPELL or EBASCO.
7 MR. TERAO:
So the implementation of the 11 8
corrective action programs is the design-basis consolidation 9
program?
10 MR. KRECHTING:
That's correct.
11 MR. CHANDLER:
John, Larry Chandler.
One more 12 question for you while you are on your little spider O
13 diagram.
The box off to the right that is sort of standing 14 by itself, as-installed.
15 MR. KRECHTING:
Conditions.
16 MR. CHANDLER:
Is that a VII-C box?
17 MR. KRECHTING:
It could be as Larry described.
18 We certainly, for VII-C items that have identified or raised 19 issues, concerning the construction or the as-built 20 condition, then, yes.
While they would be identified here, 21 they really are in an installed condition that represents an 22 input to this that we must resolve.
They don't necessarily 23 have to be a VII-C issue.
24 MR. CHANDLER:
As I understand where you are 25 today, you have 11 of these charts sitting around for each of i
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the activities under the CAP, which have derived from the 2
design issues.
VII-C is not yet complete.
Would they see 3
something like this, or is it too early to anticipate?
Is 4
this what would happen to VII-C, if its findings warrant?
5 MR. NACE:
Larry Nace again.
Let me answer that.
6 The answer is yes.
Any issue relative to hardware that comes 7
out of the VII-C program will be factored in there jus t as 8
another issue.
Now, the reason John says that it could be.
9 With respect to the as installed condition, that is a 10 necessary ingredient of a 1986-87 design validation' process, 11 wherein the engineer has to be able to say, based upon 12 whatever evidence is needed, that the hardware as installed O
13 in the plant meets the intent of the design.
14 Now, if that requires an engineering walkdown, 15 looking at, as an example, large-bore pipe supports, function 16 and orientation of the pipe support, if it requires some 17 additional inspections that have not yet been done, they will 18 be specified.
19
'If there is a necessary set of conditions that can 20 be validated by virtue of the third-party quality of 21 construction work, it is possible also to use that 22 information.
23 MR. CHANDLER:
Said a different way, though, at 24 this time, VII-C is not yet in this program, in this process 25 as described on this chart?
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x-1 MR. COUNSIL:
Bill Counsil.
That is not true.
2 Even as preliminary results have been coming out of the VII-C 3
program as early as 1985, we have included any deficiencies 4
found from the VII-C program in our project-type procedures.
5 For instance, I want to go back to one of the first and 6
foremost large-bore pipe supports.
All right.
There were 7
some 12, don' t hold me to that number, some 12 8
significant-type findings of the inspections through the 9
VII-C program and others of large-bore pipe supports.
For 10 instance, missing cotter pin could have been safety 11 significant to allow the hanger become uncoupled and 12 therefore drop out the snubber.
In the hardware validation O
13 program, which we indicated, I think it was two weeks ago, 14 loud and clear, that we are reinspecting all pipe supports, 15 whether we have modified them or we haven't modified them.
16 There is 100 percent reinspection going on of all large bore 17 pipe supports.
18 We are looking at all attributes of pipe supports 19 with the singular exception of volumetric inspections where 20 we already have radio graphs available and that's what was in 21 fact called for for that pipe support.
Coming out of 7-C, 22 Jock nuts missing, nontorqued lock nuts, are cotter pins 23 missing, just some of the examples.
They have all been j
24 included.
Hardware validation program that is ongoing right 25 now today, from large bore pipe supports, even though the 4
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1 VII-C program results are not out.
These are preliminary l
l 2
findings.
We on the project decided to go with it.
We are i
3 going to do 100 percent.
There are many others like that.
1 4
MR. NACE:
Larry Nace, again.
You might recall, i
5 Larry, that was a program that we unfolded to the Staff in I
6 the August 1986 time frame.
As information has been coming 7
out, we have been using it.
8 MR. CHANDLER:
It would cover more than typing, 9
presumably other areas as well.
10 MR. COUNSIL:
There are other meetings going on 11 today on-site between the ERC personnel, project personnel, l
12 about their. preliminary findings and trying to incorporate f
13 these things in project reinspections that are ongoing 14 today.
15 MR. TRAMMELL:
Charlie Trammel.
I am sure this is j
16 not correct, but I am left with the impression that that box 17 that says identify critical design parameters is a screen 18 which is somehow eliminating licensing commitments.
t
(
19 MR. COUNSIL:
On the record, Charlie, that is not
{
I 20 true, categorically, from me.
It is not true.
21 MR. TRAMMELL:
I know we have discussed this 1
(
22 before.
When the plant is ready for licensing, it's true to 23 say that the FSAR and the plant will be together?
24 MR. COUNSIL:
Absolutely correct.
25 MR. TRAMMELL:
Why is this word " critical design"
(
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1
-- why is it worded like that?
2 MR. COUNSIL:
Bill Counsil again.
- Because, 3
Charlie, there are other design parameters that do not exist 4
in the FSAR.
We are looking at everything.
I want you to 5
understand that, what "everything" means, Charlie.
It's 6
specifications, it is purchase orders, it is vendor 7
documenta tion.
It's all that other stuff that does not exist 8
in the FSAR.
9 MR. TRAMMELL:
I understand that, but --
10 MR. COUNSIL:
All of those will develop the 11 critical design parameters.
12 MR. TRAMMELL:
If it said identify critical design 13 parameters and licensing commitments, we wouldn't be having 14 this discussion, but it doesn't.
It looks like it's a 15 definite screen where things can be considered by you to be 16 critical or noncritical and that's the way I read it.
17 MR. COUNSIL:
I will take your criticism.
May we 18 add on the record "and licensing commitments" to that center 19 box.
20 MR. TRAMMELL:
Fine.
31 MR. NACB:
Larry Nace again.
One other hand 22 grenade back to Charlie.
There are licensing commitments 23 where you make a verbal commitment to some rule or subject, 24 which you need a hell of a lot of detail to find out how it 1
25 is you are going to do it.
That additional detail is also in O
w/
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1 the design-bases documents and folds into critical design 2
parameters.
3 So you need that, not necessarily screen, it may 4
be enforceable as well.
5 MR. MIZUNO:
Mr. Mizuno again.
Following up on 6
the discussion in response to Mr. Chandler's question.
How 7
are you going to document the final closeout or final 8
resolution of the hardware and programmatic issues?
Right 9
now, all I see is a design verification and a program and a 10 final project report which, at least from the slides that-I 11 have seen before, talk only to design and do not, for 12 example, say that these are the VII-C issues, or these are 13 the things that we found out as a result of the ISAP and our 14 generic implications review.
This is the project commitment 15 to resolve those things.
This is the way that we implemented 16 it.
Therefore, this gives us assurance that these particular 17 hardware questions are put to bed.
18 How are you going to document that?
19 MR. NACE:
Larry Nace again.
Several ways.
20 Number one, the working-level documentation, by and large, j
21 out of the CPRT, can broadly be categorized into three 22 pieces.
It's either the ISAP, I-S-A-P, or it's DIRs, out of 23 the design adequacy program, plus some follow on related 24 evaluations, or it's in the population reports for the 25 quality of construction program.
Each one of those generates ACE-FEDERAL REPORTERS, INC.
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quality assurance paper on the project.
DIRs, for example, 2
are individually answered by themselves as a stand alone 3
document.
Their resolution is also summarized in what we are 4
showing as the final project report, and will also be used as 5
a -- either a content or backup to the ultimate third-party 6
results report.
But in most cases you get at least two 7
controlled means to close every issue.
8 MR. GRIMES:
Geary, can I interrupt for a minute.
9 The purpose of the whole initial part of this was to try to 10 provide some refresher, to things that I thought the Staff 11 already unders tood.
At our present pace we are never going 12 to get to the very important part of the meeting that g
\\_)
13 concerns the application of the engineering assurance 14 program.
I would like to suggest that we hold questions on 15 the overview of the CPRT activities.
Let's just run through 16 the material and get to the engineering assurance.
We will 17 arrange a separate meeting at a later time to go back over 18 this material.
19 Mr. Counsi], I would like to suggest that from the 20 nature of the questions from people who have worked on this 21 project for over two years, I think it's evident the 22 confusion, and the level of detail of the explanation that 23 you have to go into on what is or is not in this prcgram 24 indicates to me that its explanation and documentation are 25 not clear.
We will arrange a separate meeting to go into the ACE FEDERAL REPORTERS, INC.
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CPRT activities in detail, we will get an agenda that is 2
sufficiently comprehensive that will address all these facets 3
of what it is supposed to do and where we are supposed to 4
find them, and we will set up a meeting in the near future, 5
maybe the public meeting to follow the 7th meeting.
6 Could you go on with your presentation, please.
7 MR. KRECHTING:
In summary, the corrective action 8
program assures that the design documentation is controlled 9
and acceptable.
By " acceptable" means that the documentation 10 exists to validate or verify that the licensing commitments 11 are satisfied.
12 It will assure that the configuration of systems, O
13 structures and components is in compliance with the licensing 14 commitments.
It will assure that all issues are resolved, be 15 they external issues or issues that may have been brought to 16 light as part of the corrective action program.
They will 17 all be identified in all results.
18 It will provide the documentation, organization 19 and procedures to insure that the documentation, organization 20 and procedures are in place to maintain compliance with 21 licensing commitments in the future.
22 That's the end of my presentation.
If there are 23 no further questions, I will ask John Streeter to come up and 24 talk about the Texas litilities technical audit program.
25 MR. STREETER:
I am John Streeter, director of I
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30428.0 COX 45 1-1 quality assurance for TU Electric.
2 To perhaps clear up any misunderstandings at this 3
point, before I get into my piece, what we have got is a 4
corrective action program consisting of 11 individual 5
corrective action plans.
Each corrective action plan has a 6
design-basis consolidation program associated with it.
As 7
John pointed out, the completion of this so-called DBC plan, 8
design-basis conso]idat. ion program, completion of that 9
satisfies the provisions of the corrective action plan.
10 I would also like to start out by defining what a 11 technical audit program or technical audit means to me and i
12 means to TU Electric.
It's an audit comprised of personnel 13 having the necessary technical expertise to assess the 14 adequacy of technical decisions.
Most often that means that 15 these individuals will possess engineering degrees but, in 16 some cases, and they are limited, that will not be the case, 17 In late last year, or early this year, recognizing d
18 the importance to the project of this corrective action 19 program, it was decided by TU Electric to initiate a 20 technical audit program dedicated to this effort.
The reason 21 I say dedicated, is because technical audits aren't known to 22 TU Electric.
We have been using them for at Icast two 23 years.
But in this case, what we decided to do was to 24 greatly expand that effort, transferring some personnel 25 within the audit department, and supplementing that staff by O
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1 outside engineering expertise.
t 2
I would also like to say at the outset that this 3
is different from the EFE, or the engineering functional 4
evaluation that was briefly described earlier and will be 5
described in more detail by Mr. Eifert and his associates.
6 The EFE, engineering evaluation effort, is designed to be an 7
independent effort of Stone & Webster under the auspices of 8
Larry Nace.
The technical audit program, that I am going to 9
discuss today, although in many instances it's similar to the 10 EFE effort, it's conducted under the aunpices of the quality 11 assurance department of the TU Electric quality assurance 12 department.
That's my responsibility.
I report to John 13 Reck, who's the vice president of nuclear engineering, who in 14 return reports to Dill Counsil.
15 Recognizing, as I said before, recognizing the 16 importance of the corrective action program, it was decided 17 to dedicate a staff to this effort for a two-fold purpose.
18 It was to go in and to evaluate the adequacy of the 19 execution, both from a programmatic standpoint and from a 20 technica] utandpoint of these corrective action plans.
1 21 Simply how we do this is we take this action, this DHCP i
22 effort, and we audi t this ac tivity.
In some cases we will 23 take what we call a vertical slice, by starting up at the i
24 top, on scoping the design validation package, and following 25 it through completion t.o the final project report, including O
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1 verification that any issues identified by the CPRT are 2
folded into the validation effort, they're accomplished, any 3
revision of the documentation is accomplished, and the 4
modifications, by tracing those down.
5 For example, that might include the scope of an 6
effort in a, let's say, conduit support area, the scope might 7
he a room.
We might take several of those supports in that i
8 room and track them down this process.
1 J
9 In other cases, we would go horizontal and look at 10 actually how this design validation scoping activity is a
11 accomplished.
12 In addition to that, we have what I will describe 13 more of an umbrella effort of all of these cor.*ective action 4
14 plans.
Someone asked ear]ier about the various e
15 organizations, conducting these under their quality assurance 16 program under - above the block you entitled " identify i
17 noncompliance with design basis."
18 What we do 3s the quality accurance department, 19 under this technical audit program, looks at the interfaces i
20 of these organizations to see how they communicate design 21 information that might affect other organizations and make 22 uure we are ti<3d together in that respect.
But not only 23 Lying together SWEC, IMPELL and EBASCO, principally, but also 24 tying together our Comanche Peak organization under the 25 sponsorship of John Krechting to make sure they unders tand or ace-FEDERAL REPORTERS, INC.
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are controlling the process of the contractors.
2 This next slide summarizes basically what I have 3
said, extracting three bullets f rom that detail diagram that 4
you saw previously.
There are two important things I would 5
like to emphasize here.
Carrying out this program, we are 6
interfacing with the quality engineering assurance 7
organizations of the various contractors to maximize the 8
coverage of the corrective action program and to minimize the 9
duplication of effort.
10 The reason I am using the term " quality assurance 11 organization," " engineering assurance organization," those 12 organizations basically are doing the same things here.
()
13 For example, in SWEC, the organization doing the 14 auditing activity that we communicate with on a monthly basis 15 through meetings to coordinate our individual audit 16 activities, EA does that audit activity for that 17 organization.
TU Electric, the audit activity is conducted 18 by the qua13 ty assurance department.
't 19 The second important aspect of this is the tie to 20 the SRT.
The SRT is intimately familiar with this process, 21 the development of it.
They are also kept abreast of the 22 program changes and the activities carried out under the 23 program by being on the control distribution list for the 24 manuals; and, secondly, as audits are conducted, and intend 25 to be conducted, the SRT is notified of these plans and later
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on is informed of the results through the audit reports.
2 Subsequently, they also get any follow-up documentation on-i 3
the resolution of findings in those areas.
q 4
It emphasizes the principal aspects of this.
It's 5
managed by TU Electric.
I want to tell you personally, I see
}
6 this as an opportunity to demonstrate what we as TU-Electric l
7 can do, we are managing that activity, staffing it by degreed i
j 8
and experienced full-time engineers.
Presently we have i
9 somewhere around 12 to 13 people staffing that.
We expect 1
10 that level to at least double before we are finished with q
11 this, hopefully in six months.
We supplement that staff by 4
12 engineering specialists from outside organizations,=one that
!O ta e=t 9e vie re c 111 r ~1'a, e a ve beee e ieu cer e e 14 time and also continuing to use them.
We are also i
15 supplementing our staff by engineers on the quality.
16 engineering staff and the engineering assurance staff under 17 John Krechting.
10 I would like to summarize this by saying that we I
19 have a list of the various efforts that are under way that i
l j
20 gives us some Icvel of assurance of the quality of the j
l 21 corrective action program effort.
They are the individual l
22 contractors that we are interfacing with, have QA/EA audits.
I 23 We have audits, surveillances, the QA technical audits that I 24 have explained.
We also had the EA reviews that come out of 25 John Krechting's organization and finally the engineering
.j 4
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30428.0 COX 50 m
1 functional evaluation that will be described in more detail 2
by Bill Eifert and his folks.
3 I would just like to conclude with what I have got 4
by saying, as a director of QA, I have been giving the 5
responsibilities for conducting this program.
I have been 6
given the authority to discharge those responsibilities and 7
the resources to accomplish my job.
That's it.
8 MS. VIETTI-COOK:
May I ask a question?
On the 9
contractor QA/EA audits, is that you're overlooking, doing 10 like an engineering assurance of the SWEC, EBASCO, IMPELL?
11 Is that what that means?
12 MR. STREETER:
It turns out that SWEC, what they 13 call that organization is engineering assurance.
But it's an 14 audit by SWEC of their activities under this DHCP, 15 design-basis consolidation program -- I am sorry.
What we do i
16 is interface with them, we get the results of their efforts, 17 so this technical audit program-can stay abreast of what they 18 are doing to maximize coverage, minimize duplication.
We 19 look at those results and also follow up actions to resolve 20 problems.
I will also say those are provided to the SRT so 21 they can see the full scope of what is going on.
The 22 technical audit plan, this schedule that we have, if you look 23 at it, it has plugged in there these efforts, these efforts, 24 these efforts, these efforts.
You can differentiate between 25 all of those efforts by looking at the plan.
Did I answer O
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your question?
2 MS. VIETTI-COOK:
That was SWEC.
Where does 3
EBASCO and IMPELL fall under?
4 MR. STREETER:
Let me take IMPELL first.
IMPELL 5
is similar, I believe their organization is called QA in that 6
case, same concept.
We integrate their efforts into this 7
overall plan.
EBASCO.
Theirs is a QA program, same thing.
8 We integrate their efforts in this overall plan to maximize 9
the coverage of the corrective action program.
All of these 10 efforts, the conduct of the audits, the results of the audits 11 and follow-up operations are all related to QA technical 12 audit program.
13 MS. VIETTI-COOK:
Okay.
14 MR. TERAO:
Let me understand, this technical 15 audit program, is this covering design or design in 16 construction?
17 MR. STREETER:
It would cover design and 10 construction.
By that I mean, David, if you look at this 19 chart up here, we really see construction activities being 20 assessed here on an as-installed, or you might call it 21 walkdown efforts that were accomplished.
Or there might be 22 some walkdown efforts accomplished hereby the CPRT as a 23 result of VII-C fed in through these generic issues reports, t
24 So, in that sense, it's covering construction as 25 well as design.
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MR. NACE:
Larry Nace again.
If a modification F
2 comes out to a piece of hardware by virtue of that 3
modification block, the second decision point on the chart, 4
if there is a modification that comes out of that, then that 5
also receives its 100 percent QC, which is also Mr.
6 Streeter's responsibility.
}
7 MR. STREETER:
Inspectors would be inspecting 8
this.
It would also be subject to this technical audit s
j 9
program to verify it was properly implemented.
There would i
i 10 be twofold coverage.
I don't. feel like I answered your i
i 11 question, David.
j 12 MR. GRIMES:
He will have plenty of
()
'13 opportunities.
If I might interrupt at this point, I notice i
14 that we are going to go from here into the engineering
.{
15 functional evaluation.
I would like to take a five-minute 1
16 break at this point.
We will organize the next half hoar, 17 which is the last amount of time that I have to do something I
i l
18 real productive, and then get into something else.
We will j
4
}
19 take a five-minute break.
We will reconvene promptly at 14 I
j 20 minutes after 2:00 and go from there.
1 21 (Recess.)
j 22 MR. GRIMES:
I would like to reconvene the i
23 meeting.
We will start off with clarification that r
j 24 Mr. Streeter wants to make on his presentation.
4 1
25 MR. STREETER:
John Streeter.
I may have I(:)
\\
}
i j
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1 indicated that all of the results of QA and QE audits by the 2
individual contractors had been provided to the SRT.
What I 3
meant to say is they will be provided to the SRT, so they 4
don't have those documents at this time.
5 MR. GRIMES:
Thank you, Mr. Streeter.
Ms. Garde's 6
schedule will cause her to leave in the middle of the next 7
presentation.
Rather than interrupting at that point, I 8
would like to offer her an opportunity at this point to raise 9
any comments or questions that she has for the record.
10 MS. GARDE:
Thank you.
As I see the next part of 11 the presentation, it really goes into more of the areas that 12 Juanita Ellis is reviewing.
I will have to leave in the 13 middle of that presentation, I appreciate the opportunity to 14 make these comments.
I kind of restructured what I was going 15 to ask into statements.
Let me run through them.
I don't 16 have very many, actually.
First of all, I want to say a lot 17 of what I am hearing today is new or it's being presented in 18 a way which either clarifies or changes the understanding 19 that I had from reading the documents that have been made 20 publicly available, and the transcripts of the meeting in 21 January I wasn't able to attend, that went into some of these 22 things.
Chris, you were right when you said there were a lot 23 of new things that are on the table nere.
24 One of the biggest concerns that I have is that 25 what I now I am hearing is that the CPRT program that we have O
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1 kind of all been focusing on since early '04 has almost 2
become superseded, and I don't know if that is the correct 3
term.
But superseded by the 11 generic issue reports, and 4
that the CPRT has now become a source of information fed into 5
the generic issue reports, as opposed to an end product in 6
and of itself.
If that is wrong, I would like someone to 7
correct that or to clarity that for me.
8 One of the things that I want to make a* request 9
for on the record, to be able, to myself be able to 10 understand a lot better what is going on here, is the 11 parameter documents which formulate the critical design 12 parameters that were referred to during the presentation used 13 on the flow chart.
I think the comment was made that those 14 documents are available on-site for NRC audit.
I can and I 15 will pursue them in a licensing hearing in discovery, but it 16 seems to me that these documents now take the role of the 17 checklists'I pursued for a year and a half, and that they 10 contain the basic assumptions of how the work is being done 19 and what is going into the work that is being done in order 20 to make some determinations on whether those assumptions, on 21 the design basis, is accurate.
I would like to request that 22 those documents be made available.
23 I also think that there must be a set of 24 implementing procedures f or these programs that do not match 25 the types of checklists and procedures that have been made O
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available through the CPRT program or the regular site 2
procedures, but there must be implementation documents which 3
walk through this program that would help clarify and explain 4
exactly how everything fits together.
Since Jose isn't here, 5
I will now ask his question, and ask about the auditable 6
trail of problems, because what one of the things, looking at 7
the flow chart, that I don't see, and correct me if I am 8
wrong, please, is that when the DVPs are completed, that that 9
is going to contain the auditable trail on the things that 10 were looked at.
What I want to understand is does that 11 auditable trail in the DVP include everything that was done 12 under the original site QA program, was everything that. was 13 done and identified, you believed, the various aspects of the 14 CPRT, including VII-C.
If I came in and pulled a DVP, would 15 I have every deficiency that was ever identified by any 16 program that you have been involved in or any revision of 17 that program?
18 Since the beginning of construction, or does the 19 DVP start from a certain point and put together an auditable 20 trail that starts at some midpoint, 1982, 1985, the beginning 21 of the program.
Is there some source point from which the 22 DVP goes forward.
In order to get back to the actual --
23 everything that was actually done on a particular component 24 or system, that you have to go to another set of site 25 documents and another set of CPRT documents.
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I don't want to belabor this point.
What I am i
j 2
trying to explain is if I went to the vault a year from now, i
j 3
and I pulled a DVP that you stood on in licensing in making a i
4 point that your reasonable assurance is now based on this 1
i
~
DVP, will I get every scrap of paper that ever existed 5
I j
6 regarding that component; and, if not, where is it and where 1
i 7
else would you have to go, where the NHC would have to go to
}
8 be able to tell the true story'of what really happened with i
l 9
that system, s tarting in 19747 i
10 Now, another thing that I don't see, based on the 1
}
11 flow chart, Larry asked a question, and I just want to i
j 12 clarify that, you say you identified noncompliances with the i
- ()
13 design basis as one of the blocks under performed design 14 validation.
15 When you identify those noncompliances, what are 16 the deviations from?
Are they deviations from the original i
17 FSAR commitments, or are they deviations from the new 18 critical design parameters that have been prepared, and are i
19 the noncompliances with the~ design basis actually just design l
t i
20 deviations or do they go into the construction of the system,
(
l l
21 so that's another question which I wanted to take beyond the j
t l
22 inuue whether or not it's covered under the TU QA program.
f i
i 23 There are a lot of elements to that, that that could mean.
24 There's a lot that it~ could not.
I want to know whero those l
25 noncompliances come from.
i
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V 1
The other point that I wanted to make is I am 2
going to leave this meeting under the assumption that the DVP 3
has become or is going to be an integrated document which 4
allows the utility to have assurance on both design and 5
construction and to state that there is no generic 6
implications on -- coming out of that DVP, that have not been 7
fully resolved and fed back into the program.
If that's not 8
the case, I would like to see that clarified, because that's 9
the understanding that I now of.
Anything that you found 10 along the way is now fed into the DVP.
You are going to 11 stand on the DVP to give reasonable assurance.
12 MR. GHIMES:
Thank you, Ms. Garde.
The points 13 that you made are well taken.
They are certainly things that 14 I think are appropriate in the context of another meeting 15 that I suggested earlier that we need to have in order to 16 fully understand what the current state of the Comanche Peak j
17 activities are.
So I will make sure that those issues'are 18 addressed in the agenda.
19 Mr. Counsil, I would like to offer you an 20 opportunity to respond, if you would like, to any of the 21 ques tions or points that she has made, or would you prefer to 22 wait and we will organize that as part of the agenda at a 23 subsequent meeting?
24 MR. COUNSIL:
I would prefer to wait for a 25 subsequent meeting.
We will address whatever issues you
- O 1
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desire us to address.
2 MR. GRIMES:
All right.
Thank you.
Therefore, we 3
will go on with the next part of the presentation and sec if 4
we can get a good overview of the engineering functional 5
evaluations over the next 20 minutes.
6 MR. EIFERT ' Thank you, Chris.
I am Bill Eifert, 7
chief engineer of the engineering division at Stone &
8 Webster.
Just as a matter of production, what I.am going-to 9
do, forgive me if I speak quickly, but I will try to give an 10 overview of the engineering functional evaluation in about 11 20, 25 minutes.
Then we will follow that with a more 12 detailed description of some of the specific aspects of it so
()
13 that you will get a good understanding of both the depth of 14 the evaluation and how we intend to document it.
15 Also, while I am describing the overview, what I 16 encourage you to think about is what role the NRC could play 17 in overseeing our program where you could get involved in 18 looking at it, in its implementation, its planning and in its 19 implementation.
We will be sugges ting in the second part of 20 the presentation some specific points in the process where we 21 see that you could actively partic2pate.
22 With that introduction, it is the SWEC engineering f
23 assurance, engineering functional evaluation.
As John 24 Streeter indicated, this is something that is over and above 25 and independent of the quality assurance activities and O
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1 initiatives by Texas Utilities.
2 The purpose of the engineering functional 3
evaluation really has two purposes.
4 The first purpose is to provide assurance that the 1
5 engineering validation and completion activities that are
{
l i
6 under way at the current time for the Comanche Peak plant are l
l 7
being effectively implemented, all of the programs that we 8
heard about this morning that formed the overall response 9
that Comanche Peak is having to the issues.
10 The second phase is a' programmatic look at the 11 controls, programs that Texas Utilities has put in place or 12 is now putting in place, to insure that activities during
()
13 operation of the Comanche Peak units are adequately 14 controlled, such as the design basis is maintained.
You are 15 going to be hearing today about the-two phares of the program I
l 16 in that light.
This depicts it in a little different 17 fashion, design completion activities, and the activities 18 during operations.
19 The design completion activities are the 20 corrective action programs, validation that he heard about 21 today, any redesigns that are coming out of the validation, 22 any modifications that are currently being in process to i
23 complete the Comanche Peak units to make them complete and 24 ready for licensing.
Also from a design standpoint, Ewe 25 include in this aspect of the program, utilization of the ACE-FEDERAL REPORTERS,'INC.
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(' ~#
\\
1 design da ta in testing, maintenance and operations.
2 On the operations activities during operations, 3
the module there really is looking at what we call a 4
prospective action plan, is Texas Utilities from a program 5
standpoint ready to maintain the design basis of the units 6
after operation.
We will be looking at such things as the 7
organization has been established and responsibilities and 8
charges identified, have they established a modification 9l process, with appropriate reviews and data base systems and 10 so forth such that they will be able to manage the design 11 process after operation.
To some extent, we will be looking 12 at implementation of this, to the extent that it is being
()
13 implemented as a phase-in process prior to operation of the 14 plant.
15 The approach for the design completion activities 16 is a vertical in-depth technical audit, very much styled 17 after what the NRC has used as the integrated design 18 inspection approach on the near-term operating plants in many 19 respects also very similar to the safety system functional 20 inspection approach that is now used on the operating 21 plants.
22 We are going to have documentation as an audit.
23 We will have a detailed plan with stated objectives and 24 approach, detailed review plans, attributes.
Technical 25 attributes that are fully annotated to document provide an
/'%
l V
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1 audible trail of what we do.
The approach also will utilize 2
walkdowns, our team will use walkdowns first to get familiar l
3 with the plant and the area of the physical plant that we are i
1 4
looking at from a design standpoint, and also to validate 1
5 certain aspects that are readily able to look at them by 6
going into the field.
We will use what we call an' action s
7 item, audit finding observation form, uith full resolution 8
and follow-up in identifying cause and needed corrective 9
action.
10 We will further demonstrate the vertical nature of 11 this.
Licensing commitments through to the testing, the 12 operating procedures, maintenance program and data and the
()
13 training.
He will be looking through the entire process,,and 14 from an in-depth technical standpoint, you will see that the 15 entire completion activities here are being effectively 16 inplemented.
We will be looking to see that the design 17 methods are appropriate design methods, that design criteria 18 )
and the design-basis documents requirements are being 19 appropriately evaluated and decisions being properly made in 20 this validation package process.
21 We will be selecting a sample, the design sample.
22 We wi]1 be picking a system or portions of systems that I
23 represent cross-discipline activities, so we get a full cross 24 section of the technical-discipline activities.
We will be 25 using identified past problems at Comanche Peak in our ACE-FEDERAL REPORTERS, INC.
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s 1
approach to sampling.
Make sure the technical systems serve 2
as a safety function.
We will look at the plant design with 3
emphasis on an area of the design that involves an interface 4
with the NSSS so that that interface is identified, make sure 5
that our system represents multiple components, multiple 6
system interfaces and multiple operating modes.
What this is 7
really saying is we are going to make a fairly complex system 8
to be the primary basis for this evaluation.
9 MR. NORKIN:
Will you supplement this to depict 10 other systems that this system doesn't contain?
11 MR. EIFERT:
That is our usual technique.
If we 12 pick a system that doesn't have a certain aspect that we feel
()
13 is necessary to make our true evaluation complete, we go into 14 another system.
For example, in this type of auditing in the 15 past, we needed to go to another system to get a class 1 16 stress ana]ysis to look at.
17 We will give a quick description of the scope.
18 This identities the primary lead contractors and identifics, 19 briefly, their scope and identifies two columns here, 20 in-depth evaluation by our engineering function of evaluation i
21 or whether we will be looking at it primarily from an 22 interface, design interface-only basis.
This decision l
l 23 process here is made that if another part of the organization 24 is the part -- another part of the CPRT is looking at this in 1
25 an in-depth fashion, then we don't intend to look at it in j
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depth as part of the function but we intend to look at the 2
interface only.
3 I will describe that by -- in the Stone & Webster 4
scope, where this activity is currently being looked at quite 5
intensively for the final closeout by TENERA, what we will do 6
is look at it from a standpoint making sure that any 7
information coming out of the design validation packages only 8
on a system basis or other aspects of that program, are being 9
fed into this program, and that they are being utilized.
So 10 it's more than just a transmittal of information.
We will be 11 looking at the work on this side to make sure that they are 12 utilizing the validated design basis.
()
13 That completes the overview of the activities and 14 the approach that we will use on the design completion 15 activities.
16 For operations, the approach will be a little bit 17 different.
It's a programmatic look to see if the program is la in place.
Our approach here will be to develop a list of 19 activities, that from our experience we require an 20 engineering involvement to support the operation of a nuclear 21 power plant.
22 We will also develop a list of the specific 23 generic issues from the CPRT that relate directly to the 24 control and the operating phase, and also add to that NRC 25 operating plant industry concerns, things primarily that have
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been coming out of the safety system functional inspections, 2
as concerns that have occurred elsewhere with respect to
'3 control of the design of operating plants.
4 We will then evaluate the programs that Texas 5
utility has put in place to control its design to see that it 6
is addressing those kinds of issues and reflects what is a 7
complete program to reflect the design and control of the 8
operating plant.
9 The process will be effectively controlled similar 10 to an audit with checklist and documentation of what we have 11 looked at, and where we found it to be effective, or where we 12 found concerns.
We will use an action item, resolution
()
13 follow-ups in a form similar to an audit process again.
In 14 addition, we will be doing some limited implementation 15 auditing of that process, as I indicated earlier, to the 16 extent that it is implemented prior to operating the plant.
17 A little more detail on this, the design 18 activities during operations, this is a partial list of the 19 kinds of things we are going to be looking at in this 20 process.
Is the organization established, have they 21 established responsibility to the organization, identified 22 the interfaces with the other organization, Texas Utilities 23 is in the process of establishing their own engineering 24 assurance program.
We will be looking at that program and 25 its charter and at how they are implementing it, getting it A
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effectively implemented.
Computer software, we will take a 2
very good look at the qualification and documentation 3
requirements that Texas Utilities has established for the 4
software that is under control of the engineering 5
organization.
I won't go through all of them.
The 6
organization interface is a very important one.
If you are 7
really tracking the safety system functional inspection l
8 system, there are a lot of individual findings that are 9
significant in themselves for the basic trend-that I am l-10 seeing from that program is that the -- many utilities really 11 are not integrating its engineering tests, operations, I
12 maintenance organizations, to work and interface together to
()
13 maintain the design basis.of the plant.
We will be 1ooking 1
14 that Texas Utilities has established those interfaces.
15 We will prepare a-detailed report that 16 demonstrates the depth and extent of the evaluation.
It 17 describes what we did.
We will identify the action items, 18 how they were resolved, and what the follow-up_ action was.on 19 that.
We will draw conclusions as to the adequacy of the 20 implementation of the completion activities and the adequacy t
21 of Texas Utilities' program.for operations in our report.
22 On the schedule, essentially, we are in the detail 23 planning stages now.
We expect to be moving ahead very 24 quickly.
What we are saying is the design completion 25 activities are these activities.
We plan to proceed with
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1 looking 'at the -- irt a various design validation package of 2
the various contractors in this period, followed by an 3
integration of that, where this would really reflect the full 4
vertical approach, where we integrate. the various outputs and 5
inputs between the contractors, at the end of which what we 6
would do is provide an analysis of all the. findings we have 7
had throughout the process'to determine and draw our 8
conclusions.
9 In parallel, but'after it starts is where we take 10 and look at the testing operation and maintenance.to vary 11 specifically, and we put this out in here so that we can 12 trail this through.
So we will~be looking at the aspects of
()
13 the physical plant in these programs from the same design 14 that we are looking at here, same system or set of systems 15 that we select here, we will be looking at the testing and 16 the operation of maintenance for it.
17 MR. GRIMES:
Excuse me, I have a question about-18 your schedule.- I can view that one of.two ways.
Either the 19 SRT review and the NRC report never stops or the SRT started 20 two weeks ago, we are going today.
Do you want us done 21 before the blue box starts?
22 MR. EIFERT:
No.
These were points in time.
We 23 met a couple weeks ago with the senior review team and' 24 described our approach.
This is only to identify this 25 meeting.
That's what it means.
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1 If I can just describe briefly what you should-be 2
thinking about is how you might oversee this, get involved in 3
this, and we will have a detailed phase.1 schedule, we call 4
it,.in the second part of the presentation.
But think in 5
terms of involvement in the front area, looking at our. scope, 6
looking at our approach and methods, how we are going to be 7
documenting that and feel'it's a valid approach.
Sometime 8
during implementation, coming in after we have done a fair.
9 amount of assessment, we have action items, for example, we.
10 can come in and see how we_are doing that, how well we are 11 doing that, what depth we are doing, and something late in 12 the process to see and assess how well we are following up,
()
~
13 are we making great judgments whether we accept corrective 14 action responses from the various' organizations and so 15 forth.
16 MR. GRIMES:
What way do you get. feedback from the 17 SRT group?
18 MR. EIFERT:
We didn't establish a formal 19 process.
We had the.one meeting.
We agreed.there would be 20 additional discassions with the SRT,. but not a formal 21 schedule setup.
They did indicate that they were' going to be j
22 specifically looking and watching this program.
l l
23 MR. GRIMES:
You do not expect any kind of formal j
l 24 approval from the SRT?
25 MR. BECK:
John Beck.
Approval in the form of
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I 1
making sure the SRT is satisfied with'the scope and breadth.
2 of the EFE program will certainly be transmitted back-to the 3
-EFE people through Larry Nace.
As I indicated earlier, we-4 are using this as one window in conjunction with the 5
technical QA audits to assure ourselves that all areas are.
~
6 being covered in adequate depth.
They will certainly be 7
communicating with them on those points frequently.
8 MR. CHANDLER:
John, to follow up, this is Larry 9
Chandler again.
Will an approval belgiven to this' program by 10 someone on behalf of Texas Utilities?
11 MR. NACE:
Larry Nace will answer that, first of J
12
-all, me.
The proposal has been made here for the Staff to-
. ()
13 figure out-what degree of involvement they want.
There would u
I 14 he some additional discussions there.
Mr. Beck and-I still 15 have some unfinished business, exactly.how we are going to 16 dovetail this into the SRT..It will be one of the windows 17 John describes of what information'the SRT uses to make their 18 final decision.
19 MR. EIFERT:
Any other questions on the schedule.
20 Just briefly, we will describe this in more detail in a few 21 minutes.
But the criteria for selecting'and staffing this, 22 we look for senior people, people that have experience, i
23 people who are -- who have not been involved in doing design 24 work or reviewing the design of Comanche Peak.
It will be 25 multiple-discipline teams.
We will have several people, i
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1 right now, I believe, four is the number, who our people have 2
had in that technical audit for experience on the similar 3
assessment.
We are also making a part of this joint 1
4 contractor team.
It's a SWEC program but we are asking 5
EBASCO and IMPELL to provide experienced people who have not 6
been involved with Comanche Peak to augment our team.
7 MR. NORKIN:
What is the number of people?
8 MR. EIFERT:
For the design completion activities, 9
I think we will probably have approximately 26 people.
We 10 are using four people for the basic program, operations and 11 the implementation of that, until we see what is available 12 for implementation, we haven't really been able to scope.
()
13 Our organization and what this shows -- I am sorry 14 we made this so dark.
Thi s shows our organization response, 15 engineering functional relationship to Texas Utilities.
16 There is a dotted line relationship here between Charlie 17 Zappile, who will be our manager, and Larry Nace.
The basic 18 organization is that I am responsible for the program as 19 chief engineer of engineering assurance for Stone & Webster.
20 Of course I take quality assurance and direction from our 21 vice presidents of quality assurance.
22 Charlie Zappile will be our engineering functional 23 evaluation manager.
Just very briefly, Charlie's most recent 24 assignment he completed was as project engineer of Stone &
25 Webster's work for the Niagara-Mohawk and Nine Mile 2.
He O
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1 comes with great experience on recently completing a plant.
2 He is currently or was manager of our power. division or 3
. discipline in our Cherry Hill office.
We pulled him out of 4'
that division to head up this effort at this time.
5 We'will have two team leaders.
Dick Twigg, who is 6
here today, is'on my staff in Boston, Dick has. led similar 7
vertical in-depth audits with the NRC and depth oversight for-8 both Nine Mile 2 and-for Beaver Valley 2.
9 For the-design operations site, Al Benecchi is t o' i
10 be my team leader.
Al is a senior. engineer on my -- AlLhas l
11 been my interface with Stone & Webster's engineering 12 activities for plants for.some time.
He has been involved in
()
13 design and review control programs,. utility design control 14 programs before, and is in the process of doing one at-this 15 time, and he will be leading that aspect of the design 16 program very quickly.
This approach brings to the table.the 17 in depth audit technique, which is a true test of the design 18 process, in this case a true test of the effectiveness of 19 implementing the activities to complete Comanche Peak.
The 20 vertical approach really evaluates the in-depth way the 21 integration and interface between the Texas Utilities and its 22 contractors.
The approach uses the benefits of the design 23 inspection and safety system functional approaches.
They, I 24 feel, have demonstrated their real value in determining.if a 25 process is being controlled.
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1 We believe we have a basis here that you could 2
define as a method for overseeing this program so that you 3
could get assurance and the confidence that you need as an 4
alternative to fully defining an in-depth design assessment 5
program that the NRC would conduct on your own, it has that 6
potential.
7 Final slide.
Very briefly, I have indicated a 8
couple of times that we have done this before.
I just wanted 9
to stress that so that you realize that I am not saying 10 something new and I don't know what I am talking about.
I 11 think I know what I am talking about.
On these four jobs 12 that we implemented what we called our technical in-depth
()
13 audit program at Stone & Webster, it was self-initiated, 14 really, prior to the integrated design inspection program by 15 the NRC, Millstone, Nine Mile and Beaver. Valley, they were 16 accepted by the NRC as alternates to IDIs or IDBPs as NRC 17 oversights.
We used technical senior people, headquarters, 18 site interface, technical adequacy with the primary thrust 19 being the interface and integration of all the design 20 process.
21 That's the completion of the overview.
Any 22 questions at this point?
23 MR. GRIMES:
May I suggest a five-minute break to 24 try to clear the air in here again.
25 (Recess. )
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1 MR. GRIMES:
I would like to reconvene the meeting 2
now.
We will go on to engineering functional evaluations.
3 MR. ZAPPILE:
My name is Charles Zappile.
I am 4
the program manager to the EFE.
In the second half of the 5
presentation on the EFE we will be developing in greater-6 detail some of the items that Bill Eifert touched on earlier 7
in his management review.
In particular we will be looking 8
at the makeup of the team, the qualifications, the discipline 9
breakdown.
We will take a closer look at the schedule.
In 10 particular, we will be reviewing the-first three months of.
11 the schedule, and in answer to one of Mr. Grimes' earlier 12 questions, we will also have some suggested interface points
()
13 where we would expect to get quite a bit'of NRC involvement 14 so they can maintain an appropriate overview of the program.
15 We will also be getting into some of the 16 techniques we will be using in conducting our technical 17 overview, and we will go through an' example of a power item 18 and a structural item, such that you can get an appropriate 19 feel for the depth and the quality of the effort that is 20 going to go into this~ program.
Basically, we set down a 21 listing of criteria for the. personnel that will be taking.
22 We will be taking into this team.
'At this point 23 in time we are reviewing several people for their 24 qualifications against this listing here.
One item, we are 25
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1 Comanche Peak project.
We are no't going'to use anyone on the 2
team and any area they evaluate where they have done some 3
work or done some reviews of an effort in that area.
4 We prefer PE registration although.it's not 5
necessary.
We would expect that quite a bit of the team 6
would be registered.
7 Experience, that's a very key word here.
We are 8
definitely going to have very experienced engineers, at least 9
five to 10 years or more.
We are looking for people that can 10 do calculations, have done several calculations in the past.
11 They definitely will be_able to look at assumptions made, see 12 that they agree.
They will evaluate techniques used to.see
(}
13 that they are appropriate techniques used in the engineering 14 industry.
15 The next three items are key items in that we are 16 not only looking for technically qualified _ people, because we-17 expect a lot of interface from the NRC'and other possible-18 outside parties.
We want to have-fellows that'can-3 19 communicate very well both orally and in writing.
We do 20 expect them to be challenged in every area, and they have to 21 be able to explain very clearly what they are doing.
22 MR. NORKIN:
Excuse me, I want to ask.one quick 23 question --
24 MR. ZAPPILE:
Sure.
25 MR. NORKIN:
-- relative to experience O
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2 MR. ZAPPILE:
Yes.
3 MR. NORKIN:
It's a very important item here.
4 Precedent was set for the design adequacy. program.
I just 5
want to mention it really pertains to this.
The program that
~
6 was administered by TENERA.
They actually went;through a 7
process of confirming, each guy would be in an. area where he 8
had hands-on design experience.
Do you intend to do the same 9
thing with respect to confirming experience commensurate with-10 senior level assignments?
11 MR. ZAPPILE:
We have not yet discussed that'as 12 far as doing anything other than having their resumes on 1
- ()
13 file, any further documentation.
That's something I am sure.
14 we would address.
15 MR. TWIGG:
The people who will be used will be_in 16 their expertise, if that answers your question.
]
17 MR. NORKIN:
I would like it answered more 18 specifically, because you know what I am looking at.
19 MR. ZAPPILE:
You are looking for something more 20 than the fellow's resume?
21 MR. NORKIN:
More than a civil guy looking at 22 civil.
A guy looking at stuff he has done.
23 MR. ZAPPILE:
In other words, structural steel?
24 MR. NORKIN:
Yes.
25 MR. ZAPPILE:
To give you an idea of the 2
C:)
1 1
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1 discipline makeup here, 26 people, we are looking_for two 2
power engineers, experience and safe shutdown system 3
interaction.
We are looking for some' experience there.
We 4
talk about lead 1cvel capability.
At least one of the 5
individuals should have what we call lead level capability.
6 That's a gentleman who has supervisory capability, someone 7
who has quite a bit of experience, knows a lot of the 8
interfaces required, to appropriately design a power system.
9 We_will be using an HVAC engineer to review much 10 of EBASCO's work.
You see many other items down the list.
11 You will see that all disciplines are appropriately l
12 represented here on this list.
Just to mention, nuclear
(~)
13 technology and rad protection, we will be using two fellows V
14 there.
Much of their work will be involved with looking at-15 radiation environments, humidity environments, pressure
~
16 environments and cubicles.
Much of of the data that is used 17 in the QE program.
18 MR. GRIMES:
The column that-is marked " additional 19 criteria," do you have base criteria in terms of the 20 experience or hands-on capability, for example, for an HVAC 21 engineer.
What do you require of an HVAC?
22 MR. ZAPPILE:
Basically what we would be looking 23 for, five to'10 years design experience of doing heat release 24 calculations, ventilation calculations, basic chiller design, 25 things like that.
That's the type of individual we would be i
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looking for there.
Someone that has physically done that.
2 type of work in the past.
3
-MR.
GRIMES:
Do you have these criteria explained 4
in a document somewhere to follow as a rule?
5 MR. ZAPPILE:
No.
We don't have them written down 6
anywhere at this point.
7 MR. EIFERT:
What we have done is establish this, 8
and this is a copy, this graphic is a copy of what we wrote 9
down as needs for the team, and the additional criteria, I
10 because we know what we need in a specific area.
11 Our practice at Stone & Webster-~is that each 12 individual maintains a very detailed experience record that
()
13 we look at, when we get people..
We also, in our experience i
14 in the past, in many cases, Dick or I know the individual, 15 possibly because we have used him before.'on an audit or 16 possibly because we have audited him in the past.
So we use 17 that as information establish whether we believe he is the i
i 18 right person for the team.
We will be going through a 19 similar questioning process when we get the needs from both-2 1
20 EBASCO and IMPELL.
21 But at this point we hadn't planned on going i
22 further than that in documenting selection criteria or 23 selection rationale.
That is something that we could discuss l.
24 further, and what we could do -- I was not aware that TENERA I
25 did anything more.
We can look at that and will.
Certainly j
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1 this is something that you could look at when and if you 2
choose to oversee this and look at the qualifications and 3
individuals.
4 MR. NORKIN:
One suggestion I would make, one of 5
the things we do review is resumes.
It would be helpful if 6
the resumes indicated what the guys were going to do in the 7
review and what they have done in the way of experience, to 8
match up what they are going to do.
9 MR. ZAPPILE:
As a minimum, that might be a good 10 approach.
11 MR. TWIGG:
We have these resumes.
They do 12 describe that information.
We have traditionally made them
(}
13 available to anybody who wants to take a look at those 14 people.
I would like to point out that the additional 15 criteria mentioned on the slide is additional to that which 16 was mentioned in the first slide.
Again, I think the point 17 should be made that you just can't look at the resume and 18 find the appropriate person for one of these teams.
These 19 are select people.
You can have the finest engineer in the 20 world doing these, but unless he can communicate what he did 21 and what he looked at, it's not going to do any good.
So 22 there is a lot of experience goes in selecting who you can 23 have on the team to do a good job.
24 MR. ZAPPILE:
We have been through this selection 25 process before.
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MR. EIFERT:
The approach that the NRC has used in I
2 the past has been not to rely on words on the resume or on j
3 preestablished criteria.
The approach they used in the past l
4 was having their technical, the technical NRC people on the 5
oversight team questioning, discussing the area with the r
6 auditor, and in that way determine that we had a qualified 7
team.
8 MR. ZAPPILE:
Hasically all the engineers will 9
have degrees.
One exception you may see in the test and 10 startup area, this is the area we will be looking at test and 11 operating procedures for appropriate input.
These fellows 12 may not necessarily be degreed, but expect the other members
()
13 of the team have the minimum B.S. degrees in their 14 appropriate areas.
15 I would like to focus a little closer on this 16 schedule, phase 1 area here.
I prepared a slide and broke 17 this down into several facets.
It's about a 13-week effort.
18 I have got this broken up into three basic parts, the slide.
19 One is location, two, an activity, and, three, duration.
20 Basically, the way you read this, is we would expect that the 21 first three weeks after the team is assembled, they spend 22 three weeks in Boston.
Key activities that will be performed 23 in that time would be in training, and that training is in 24 relation to the auditing techniques and documentation.
Of 25 course, we are going to have experienced engineers, but quite
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)
1 assuredly some of the fellows may not have "any experience,"
2 so we are going to spend some time training them on how to 3
document the audit and the type of approaches that have been l
I 4
taken in the past.
They will develop what we call review 5
plans.
A little later we will go into more detail on what we 6
mean by review plans.
7 Basically, it's writing down how you are going to 8
approach reviewing your specific area, the documents you are 9
going to review, the types of questions you are going to be 10 asking, things you will be looking at, in very specific 11 detail.
We'll be requesting information from the project 12 from IMPELL, from EBASCO, in SWRC, from that time, trying to
()
13 collect some of the items that we will be reviewing.
14 After the review plans are complete, this is a 15 very key document, it kind of sets the audit on the course.
16 In the past, we had the NRC come in and review those raview 17 plans.
They actually sit down with our fellows and go 18 through it very closely with them and they may challenge them 19 on the scope and the nature of the review.
We like to have 20 that type of review plan done here.
21 The final two weeks we will really start getting 22 into the review.
Those are the design criteria, prepare to 23 break the team into various segments, to visit the various 24 appropriate areas.
For pretty much Boston would be the CAP 25 effort, a large team in the Boston office doing much of the O
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' design validation.
Some of the team, particularly the HVAC 2
. area, will probably visit EHASCO in New York, possibly.
3 Others may go to the site to take a look at IMPELL and EBASCO 4
efforts being conducted on theLsite.
May visit Cherry Hill i
j 5
for some of the small-bore pipe efforts.
l 6
Behind that, most of the_ fellows will go to the 7
site, take a look at the CAP efforts being conducted by the 8
site engineering group at the site.
9 Where we would expect an NRC interface, about a 10 nine-month schedule on the program, we would expect that an 11 initial NRC review of.the review plans would occur 12 approximately May 11.
That is consistent with the last slide T
$ ()
13 I have just shown you.
Would also suggest a thorough 14 review.
Once we get into the implementation of those review i
15 plans, we would expect that we would generate quite a few 16 action items and have the review well under way and be ready 17 for something like that by about mid-June.
18 Last, toward the end of the whole review process, 19 where we have closed out the 85 or 90 percent of the action 20 items, to have you fellows come in and^take a look at our 21 resolutions to see that they,are appropriate,-that you agree i
22 with the resolutions, that they are adequate.
23 MR. NORKIN:
What percentage of the program would 2
24 have been implemented ~by June 15?
1 25 MR. ZAPPILE:
I would say probably 30 percent, 25 4
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1 percent.
It's really the beginning.
It's probably the first 2
point in time you will be able to actually see how we are 3
implementing this program.
You may decide you want to come 4
in again, in here, between here and here.
That's very 5
possible.
It would be up to you to evaluate that.
6 But I would say we are just starting to get into 7
the heart of it, just starting to develop our action items.
8 Maybe comething like 20 percent complete by then.
9 MR. TWIGG:
A little bit more than that.
10 MR. ZAPPILE:
In that range.
But the key to that 11 is you will be able to see quickly how we are implementing 12 it.
If it's something you are concerned about or you feel
()
13 not on firm ground, it would be good to address it to us at 14 that time and we can mash it out.
That's really the purpose 15 of that.
16 Next, in the area of the technical reviews 17 themselves, basically three very key elements of what we are 18 doing.
One is I discussed-the review plan.
Very thorough 19 review of technical detail by experienced people.
We will be '
20 generating action items which identifies problems or 21 questions that all get tracked and resolved.
22 I will be spending some time going through each of 23 these in a bit more detail so you get an appreciation of what 24 we are talking about here.
25 In the technical reviews -- you have seen this (O
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I slide before, Bill had it up.
Basically, what we tried to do l
2 here, as simple as possible, is show the basic elements of 3
the engineering process, how they fall in the design.
4 Basically we will start with licensing commitments, see that 5
they have been appropriately factored into a design criteria, 6
and start looking at the engineering products, calculations, 7
specifications, et cetera, also look at the output from there 8
into the testing, technical procedures, operating procedures, 9
for example.
It may be an example, follow through on this 10 chart right now, take a typical power fluid system.
We will 11 start with licensing commitments.
12 In your FSAR you would identify code commitments.
()
13 Three code safety class, 1,
2, 3,
probably have from rate 14 guide commitments on that system.
We would take a look at 15 those, of course, by going through that FSAR very closely, 16 assuring ourselves that they had been f actored into the 17 design-basis documents, they are a part of the design 18 criteria.
Design criteria should say this system is class 3, 19 class 1,
et cetera.
We will take a look at interface from 20 NSSS, which could be part of their licensing commitments also 21 and your licensing commitments.
They may have required 22 certain flows, temperatures, timings, things 3ike that, and 23 insure those have been included in the design-basis 24 documents.
25 Then we will start looking at how this has been (V)
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implemented in the design of the plant.
Look at a flow 2
diagram and a drawing.
Are they consistent?- Is it 3
representative of what has been shown back there in the 4
FSAR?
5 We will take a look at the calculations, fluid 6
system typically, NPSH calculations, design pressures, design 7
temperatures, any transients the system might experience.
We 8
will look at specifications, have those specs appropriately 9
identify the equipment necessary.
That calculation may say 10 that you need a pump that delivers 500 gpm at 200 feet.
Was 11 the pump speced out that way?
Is the data sheet in the speck 12 up-to-date?
Is it consistent with the calculations?
Pake a I'd 13 look at the vendor drawing, is it consistent with the specks,
\\._/
14 did they give us a pump that delivers that gpm?
15 Interfaces.
Basically, this calculation will 16 define design pressures, temperatures, possibly transients in 17 the system.
Have those things been given to the pipe stress 18 people who need it for their analysis, their pipe stress 19 analysis and support design?
Is'that all consistent and 20 up-to-date?
21 We will look at the interfaces in the opposite 22 direction, a fallout of pipe stresses on the equipment in the i
23 specification.
Have those loads been addressed back to the 24 vendor.
Can the equipment handle the loads?
So we will 25 close the loop on that information.
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~.
1 Go to the field and look at any design changes 2
they have approved, nonconformances they have approved.
3 There may be nonconformances on minimum wall violations out 4
there.
If they have been been accepted, is that an 5
acceptance on the design criteria that has been verified 6
here.
That design criteria would have to be considered in 7
the approval of this change, et.ange or acceptance, one or the' 8
other.
9 Last we will be looking at the feedback into other 10 areas, in the test area.
We wil1~ be looking at set points, 11 power.
We will have developed calculations for input into i
i 12 the set point program, maximum pressures, maximum
()
13 temperatures.
Is that all consistent?
We will take a look 14 at the tech specs, operating procedures.
Basically in the 15 test program, one thing we will look at very closely, the 16 acceptance criteria used in the pre-op test procedures, 17 pre-op test procedures should have requirecents to tests, 18 again, pumps or valves or timing, things like that, for 19 specific flows, specific heads, has that all been addressed l
20 appropriately in the pre-op test procedures?
We will go to 21 the operating procedures.
Is it a function of the up-to-date i
22 design?
Similarly in the training and maintenance area.
23 That's basically the way we would approach a typical power 24 system problem and a brief overview.
i 25 MR. NORKIN:
One question.
You didn't say whether 1
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you were going to look at the adequacy of the selection of 2
design parameters.
3 MR. ZAPPILE:
I don't want to say I am-going to 4
ignore that, but I think I am going to say we are going to 5
ignore that.
As far as I am concerned, critical design 6
parameter doesn't exist.
I'm not even trying to interpret 7
what that means.
I am going to look at this system to see 8
that it works and that it's a function of the_ design.
9 MR. NORKIN:
Isn't this an overview-of the 10 design-basis consolidation program?
11 MR. ZAPPILE:
It's an overview of the technical 12 adequacy of the system or component we are looking at.
()
13 MR. NORKIN:
The question I have is, who going to 14 be the conscience of the selection process that the SWEC CAP 15 goes through to decide what the critical parameters are?
We 16 spend a lot of time talking about that, and where is the 17 third party review of that?
18 MR. EIFERT:
If I may, Charlie started to say, we 19 are going to look at it as if that definition isn't there.
20 The way that the project answered questions today, is our 21 understanding of critical design par ameters.
Essentially 22 everything necessary to meet licensing commitment.
23 So, we are going to, in our sample, think of-it in 24 terms of everything necessary to meet licensing commitments, j
25 and do our own look-through, and not really look at whether j
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')
I they did or did not select it.
We are not going to just look 2
at what they selected and validate what they have 3
incorporated.
We are going to select our own basis right 4
from the licensing commitments for our given system sample.
5 MR. NORKIN:
Suppose there's a critical design 6
parameter which they have failed to identify, something over 7
and above licensing which is needed to meet a license 8
committment.
We said it's licensing commitments plus other 9
critical parameters.
10 MR. EIFERT:
Then when we started with licensing 11 commitments.
12 MR. ZAPPILE:
That should fall out of our review, r) 13 We are looking at licensing commitments and technical
(
14 adequacy as to what has been done here.
We are looking at 15 what has been done and say where, yes, that justifies the 16 design.
It meets the licensing commitments, the system will 17 function, period.
18 At this point I would like Dick Twigg get up and 19 show you a discussion of a structural sample and review 20 action items and review plan.
21 MR. TWIGG:
I will try to be very brief.
In 22 addition to picking a fluid system, as we have gone through 23 here we will be picking electrical systems and structural 24 systems.
When I talk about a structural system I am talking 25 about a building.
We will take one building and we will look O
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'COX 87 N
1 at the design of the building right from the very beginning.
2 You will see we follow the same basic process.
We will be 4
e 3
going to the designs.
We will look at,the design basis-to seewhetherit'sinconfhrmancewiththelicensing
)
4 5
requirement.
We will look at the seismicianalysis; we will.
1 I
6 look at the natural phenomena that the plan.is committed to, 7
earthquake, tornado, flooding.
We will be looking at_the'.,
i 8
environmental conditions that the b.uilding has to see.-
1 a-i 9
These are materials -- if it was a containmenti i
l 4
10 building, we will'be looking at the containment l
11 temperatures.
We would be looking to see that, one,.the 12 other portions of the review, whether the containment q
({}
13 tenperatures are valid or not.
We would'then look to see 14 that those temperatures have been appropriately included
~
15 within the design analysis.
Same thing with internN ly 16 generated miseiles or high-energy line break.
When you have 17 a target inside a building, for instance, a structural door.
18 We would look to see that those parameters were included I
19 within it.
20 We will be look'ne ar concrete design',,s teel '
21 design, miscellaneous strtaturm; details.
We would also be 22 looking at the load-tracking program or load tracking for a 23 particular building.
What I'mean by that is that when the' 24 building is initially designed, various loading conditions 25 are put in there for live loads and for other loading that 7
+
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would be expected in the plant.
As the plant is designed 2
with pipe stress, pipe supports, conduit supports, loadinas 3
from these areas affect the structure.
We will be looking at 4
the program to insure that the loadings that have come out of 5
these other programs have been. included or have been 6
evaluated for the acceptability of the structure itself.
7 I think that one of the important things about the 8
operation is that we use an integrated team.
The team works 9
together, the structural people, the power people, would all 10 have daily meetings to input information from one another so 11 that we thoroughly address the interface between disciplines 12 and the interface-between different organizations.
We will f~)
13 be looking at penetration designs, stability analyses, and so v
14 f or th.
I could go on, but that's the type of depth we are 15 going on in our review for the structural buildings.
16 After we have gotten through in doing a major 17 portion of our design evaluations, we are going to take the 18 input from those and we are going to give it tests into these 19 other organizations to see that not only the information was 20 received by these organizations, but the information was 21 appropriately used, if you are talking abo'it a training 22 program or you are a simulator.
The particular parameters 23 that are important to the design and operation of the plant 1
24 from an engineering standpoint has been factored into that.
25 The same philosophy applies to the other parameters there.
f~)
(/
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1 This is a slide that talks a little bit about 2
review plans.
Essentially, the three different types of 3
documents that are involved in the evaluation.
One is a 4
review plan, which we have mentioned before.
The key thing 5
is that the systematic approach to evaluating the design, 6
prepared by discipline, they are prepared by the individual 7
who is going to be doing the review and approved by the audit 8
team leaders.
Not only is it an organized approach, but it 9
is a place where the results of the evaluation are 10 documented.
11 Some of these may seem repetitive, but the point 12 we just want to show is that review plans normally would
{}
13 consist of the flow of information in the design process.
In 14 addition to that, we would have special review plans for 15 areas like hazard analysis, where we are looking at 16 high-energy line breaks, system interaction, seismic 2 over 17 1,
internally generated missiles; these types of analyses 18 require interfaces from all disciplines and they are handled 19 better within a special review plan.
20 Because the effort is so extensive you can't wait 21 until the end of the program to identify what your problems 22 are.
An action item is the device that is used to describe 23 problems, potential problems, or if information isn't readily 24 available, it is the device that we are able to use and track 25 in getting that information.
O v
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It is also the forum that is used to resolve the l
l 2
action items.
As the action items are written, it is 3
immediately sent to the particular project.
They are 4
responsible for getting back to the team to identify the 5
cause of the problem, the extent of the problem, and any 6
corrective or preventive actions that are required.
7 Also, they are required to identify the 8
significance.
9 After the work has been accomplished, as far as 10 accepting their responses, the follow-up would also be done 11 within the action item forms to insure that the corrective 12 actions have been prevented.
In other words, the audit team 13 will verify that these actions and preventive actions have 14 been accomplished.
15 There is a question over here.
16 MR. MIZUNO:
Yes.
Mr. Mizuno.
How is this 17 process of in-process identification and resolution of these 18 concerns which were identified by the engineering team going 19 to be folded into the normal Appendix B type of system of 20 processing nonconformances.
Is there any kind of action 21 or --
22 MR, TWIGG:
Larry.
23 MR. NACE:
Larry Nace.
I will answer that.
In 24 the process of evaluating an action item, wherein a problem 25 is I had find that falls into the definition of Ov l
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1 nonconformance report, deficiency report or project 2
corrective action report or significant deficiency report 3
relating to 10 CFR 50.55-E, those appropriate processes will 4
be triggered.
5 MR. MIZUNO:
Are there going to be procedures that 6
are written to control that interface between this process 7
and the ongoing project?
8 MR. NACE:
Those procedures already exist relative 9
to any review activity on the part of the Comanche Peak 10 project.
It is not required specifically for this program.
11 MR. TWIGG:
This is what I was just referring to 12 to show some of the other items that the action item does.
[v')
13 The final item we will talk about is the report.
14 As I mentioned earlier, the report is a very critical part of 15 this phase of the whole program.
We will describe in detail 16 the scope and by discipline.
As I mentioned before, the 17 people not only have to have if technical capability, but 18 they are going to have to describe what they do.
So it's 19 important to us to show and describe what we have done in 20 detail and the report will do that.
We will identify all the 21 action items that were identified during the audit, and for 22 the -- where we have the resolutions of those action items, 23 we will describe the resolution of the problems within the 24 report also.
25 The conclusions of the report, we will make up the ACE-FEDERAL REPORTERS, INC.
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[~h
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conclusion about the technical adequacy of the systems that I
2 we have been looking at and therefore we will be able to~make 3
an overall assessment of whether we feel that corrective 4
action programs have been implemented effectively.
5 We can make a conclusion, as far as compliance, 6
effectiveness of CAP, as I mentioned.
These conclusions, 7
really, are based on an overall evaluation of all the action 8
items that we have identified.
9 As I mentioned before, each of the action items 10 will be resolved individually and followed up in this -- in 11 the conclusions.
We take all of these action items and we 12 identify causes, corrective actions, preventive actions,
()
13 appropriate disciplines, and we throw that all together to 14 see, do we have any area that has any systematic weaknesses.
15 If there are systematic weaknesses identified within this 16 evaluation, this final evaluation of all of the action items, 17 these will be identified back to the projects and followed 18 appropriately.
19 Are there any questions?
20 MR. GOWER:
George Gower.
Ilas there been an 21 estimate made of any of these reports that will be 22 generated?
23 MR. TWIGG:
Action items?
)
24 MR. COWER:
No, evaluation reports.
25 MR. TWIGG:
There will be one report.
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1 MR. GOWER:
For the total plan?
2 MR. TWIGG:
That's correct.
3 MR. EIFERT:
That's our current plan.
I would 4
like to keep up the option of possibly breaking it into more 5
than one report, one for completion of the activity and one 6
for the ongoing activities and support operations.
We may 7
break it up.
8 MR. TWIGG:
I am sorry.
That will be two 9
reports.
That will be one report for the technical aspect, 10 the functional aspects of the system.
11 Any other questions?
12 MR. STREETER:
John Streeter.
Don Norkin asked a 13 question earlier about who would be looking at the process of 14 compiling the design parameters.
Because that is part of the 15 design-basis consolidation program, the TU Electric design 16 audit program will have that as part of their review.
17 MR. NORKIN:
We could probably do it in the NRC 18 review.
We wouldn't want to be the only ones doing it.
19 MR. TWIGG:
It is important we are going to be 20 doing that within these reviews.
When we go in and look at a 21 system, we are looking at the validated design.
If we go in 22 and look at the design, and it is not identifying what we 23 consider to be all the parameters that are required for 24 licensing and the proper operation of the plant, then it will 25 indicate that they have not effectively done their job.
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1 So we will be testing the program.
I think all of 2
these reviews that we are talking about are results oriented 3
reviews.
In other words, did some system work?
Not whether 4
they have identified a list of parameters.
People can go in 5
and say, well, I see this list of parameters that they looked 6
at.
The proof of the pudding, when you look at a 7
calculation, you can develop individual parameters for each 8
calculation you looked at.
9 So that you have to really go look and make the 10 evaluation.
Did that calculation address all of the 11 licensing commitments?
So if we see the licensing 12 commitments that are not met, that it will say they didn't
()
13 effectively do their program.
14 MR. EIFERT:
Don, if I may, we share your 15 skepticism.
In fact, Dick, Charlie and I had a meeting in my 16 office yesterday and discussed just this issue and tried to 17 understand the concepts of critical parameters.
I think even i
18 today I share your gray understanding of what that in.
I 19 That's why I say we are not going to use that as any kind of 1
20 a limiting condition.
They have explained their concept of
)
l 21 critical parameters.
They have explained it's not a sampling i
22 approach, it's not a screening approach.
Today I take that 23 as what their understanding is.
We will test that by a 24 process that we start from the licensing commitment.
We are 1
25 not starting from the DVA, we are not s tarting f rom their
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I selection of critichl parameters.
2 MR. NORKIN:
I interpret the critical parameters 3
as a judgment process.
You can say oh, yes, there are 4
commitments by definition, but then there are all the 5
others.
That's where the judgment comes in.
I think we all 6
have to look to see whether there is something that's 7
critical that's been missed.
That's the only point I am 8
trying to stress.
9 MR. EIFERT:
I think in our approach, we will 10 definitely do that.
We will confirm that their process is 11 adequate or identify that it isn't.
12 MR. TWIGG:
Any other questions?
Chris, do you
[',)
13 want to sum up, or does anyone else want to comment?
u 14 MR. NACE:
This finishes our planned presentation 15 in response to your early on questions.
I would ask now 16 whether you feel we haven't answered the questions you asked 17 at the start and some of the follow-up questions which we 18 deferred to a later meeting.
19 MR. GRIMES:
Yes, thank you.
Further questions on 20 the CPR activities we will defer to a later meeting.
With 21 respect to the engineering functional evaluation, if you told 22 me, I missed it, in terms of what you thought a third-party 23 review was and how this effort achieves that.
At least in a 24 more succinct fashion.
25 MR. COUNSIL:
Let me take the first shot, all V('h ACE FEDERAL REPORTERS, INC.
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30428.0 COX 96 s
1 right.
One misnomer, at the start of the meeting, I made a l
'~
2 note to myself.
When you opened the meeting, you said the 3
engineering functional evaluation is in place of third-party 4
reviews.
That is not entirely correct.
5 The SRT is still third-party.
TENERA is being 6
utilized for selected third-party overview of the programu 7
ongoing by the corrective. action-type programs.
Those 8
programs will, in fact, be selected by SRT as to which 9
aspects they want to be reviewed on the corrective action 10 program.
So there will be TENERA review and/or other third 11 party-type individuals.
12 John, I think, very clearly stated, and I will try
()
13 to change my words, John Beck expressed my words on what I 14 meant.
He said he was using the TU technical audits beyond a 15 normal QA plan, and he was using the engineering functional 16 evaluations as a window into the project to see what we are 17 doing.
18 I am quite certain that that window wil] give him 19 adequate aspects of what else he would like to look at, 20 either by third-party persons or by SRT directly, because 21 there will be SRT overview directly of what the project is 22 doing.
23 Now, to take that a step further, since it is not 24 a direct total substitution of third-party overview, why 25 would I view the engineering functional evaluation as "a O)
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third-party" type of look?
I think that the engineering 2
assurance personnel of Stone & Webster adequately described 3
that they are selecting people that have no involvement 4
whatsoever from SWEC in this project, period.
I think it has 5
adequately been demonstrated on the Millstone 3 docket as an 6
example, but that is totally adequate.
It is also third 7
party and has been accepted.
It has been accepted on two 8
other documents that I am familiar with.
We have no 9
intention of changing how that is going to be accomplished or 10 why it was accepted as " third party."
11 So, I do believe that we are demonstrating, 12 through the Stone & Webster people, and those people that are
()
13 going to augment the Stone & Webster people in the EBASCO and-14 IMPELL area, that, in fact, they are third party.
Not 15 capital I " Independent," but little i " independent."
16 MR. NORKIN:
You say EFE is the third-party 17 review, then?
18 MR. EIFERT:
I am saying I am treating them as an 19 independent review.
I believe you used the words of 20
" third-party review."
21 MR. HECK:
Bill, John Beck.
Let me go a little 22 further, Chris, if I may.
" Third party" is a euphemism for 23 objectivity.
24 MR. COUNSIL:
You are right.
25 MR. BECK:
As far as I personally am concerned --
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30428.0 COX 90 0
~
If I don't, I 1
I think I can speak for the rest of the.SRT.
2 am sure I will-be brought up short, they view the technical 1
3 QA audit program as it is. supplemented by outside i
4 individuals, and John Streeter didn't add, when he indicated l
l 5
that some of the technical experts would come from R.L. Cloud
~l 6
& Associates, that some of the technical experts in that QA 7
audit plan are going to'come from TENERA Corporation, and 8
areas where it needs to be supplemented, in particular people l
l 9
who are familiar with what has transpired to date.
10 I view, as a matter of fact, equating " third 11 party" to objective evaluations, the entirety of the Stone &
12 Webster effort was third party, full.
So what we have got
()
13 are a number of layers of objectivity that goes far beyond 14 where we started from in 1984 with the CPRT effort.
15 MR. NORKIN:
The Stone & Webster CAP effort, in 16 one way of thinking about, it almost becomes a substitution.
17 for Gibbs & Hill, the original designer.
18 MR. DECK:
In the context they are going to review j
19 the design or the evidence of the design that is in place at l
20 this point in time, it will.
21 MR. NACE:
Larry Nace.
Let me help also.
You
.I 22 have been very right.
One of the questions I kind of l
23 expected someone would ask here toward the end, as we started 24 out the presentation a couple hours ago expressing difficulty l
25 at this time and how we were having trouble putting issues to O
l l
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1 bed one by one, and at the close of the discussion on the 2
engineering functional evaluation you get down to action 3
items and putting away the issues one by one.
Nobody has 4
raised that question as a, gee, isn't that strange.
5 What we have gone through here is a project, very 6
comprehensive set of project reviews dealing with the CPRT, 7
with the design adequacy program, with the quality 8
construction program, the CYGNA review of earlier time frame, 9
where virtually everything in the project has been gone 10 through with a dust brush.
We have all the issues on the 11 thble.
We have now massive corrective action programs under 12 way to resolve those programs and to give us a plan that we 13 are all confident of meets the licensing criterion, and the 14 necessary current day documentation behind that plan, such 15 that at the end we can resolve remaining issues one by one.
16 But all of the effort that is currently ongoing in 17 the project is independent of any work that transpired prior 18 to the -- some date certain in 1984.
19 MR. GRIMES:
Mr. Counsil, I promised when this 20 meeting started that we weren't going to give you any 21 conclusions today.
22 MR. COUNSIL:
- Okay, 23 MR. GRIMES:
I will take your explanation as best 24 I can and try to sort out in my own mind who it His that I am 25 going to go look to for a response on objectivity and/or tw
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finding the efficacy of the process, and I will figure that 2
out when I get down to Comanche Peak and start going and 3
looking for people.
It's certainly something I think we need 4
to talk more about in terms of have you got layers of 5
assurance or have you got. layers of coverage that hides 6
things, that's the kind of perception that I bring into this 7
with my fresh but regulated mind.
8 So, we will continue with this discussion as we 9
get further and further into the review.
10 I want to thank all of you for coming today.
11 These are Cc>manche Peak meetings much larger than I am used 12 to.
(m) 13 MR. C O llN S I L :
One further comment bef ore you close m -
14 the meeting, when you speak of independence, the three 15 officers si tting in this room from Til Electric had nothing to 16 do with the original design or QA, QC, period, nor did any of 17 the department heads who are here with me today.
So if one 18 speaks of independence or objectivity or new look, I can 19 assure you, this plant has had a thorough new look from all 20 parties.
21 MR. GRIMES:
I hope we will be able to find the 22 material that we need to agree with your conclusion.
If not, 23 I am sure we will tell you what is lacking.
24 MR. COllNS II,:
I look forward to that, Chris.
25 Thank you, sir.
Thank you all, gentlemen.
The meeting is e
ACE FEDERAL REPORTERS, INC.
202-347-3XO Nationwide Cmcrage 800-33MM6
30420.0 COX 101 1
now adjourned.
2 (Whereupon, at 3:50 p.m.,
the meeting was i
3 adjourned.)
4 5
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8 l
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1 11 1
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i ACE FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Coverage 800-336-6646
CERTIFICATE-OF OFFICIAL REPORTER f3 V
This is to certify that the attached proceedings before the UNITED STATES NUCLEAR REGULATORY COMMISSION in the matter of:
NAME OF PROCEEDING:
COMANCHE PEAK RESPONSE TEAM PROGRAM DOCKET NO.:
50-445, 50-446 PLACE:
BETHESDA, MARYLAND
(~
(_)/
DATE:
THURSDAY, APRIL 2, 1987 were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission.
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WENDY S. COX official Reporter ACE-FEDERAL REPORTERS, INC.
Reporter's Affiliation O
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1 TU ELECTRIC MEETING WITH i
NRC l
i
- THURSDAY, APRIL 2, 1987 l
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l AGENDA TOPICS o
COMANCHE PEAK RESF0NSE TEAM CPRT 1
o CORRECTIVE ACTION PROGRAM CAP i
)
o ENGINEERING FUNCTIONAL EVALUATION EFE o
QUESTION AND ANSWER l
i o
COMANCHE PEAK RESPONSE TEAM CPRT I
EXPLAIN EVENTS / CIRCUMSTANCES THAT LED TO FORMATION OF CPRT AND ULTIMATELY INITIATED THE CORRECTIVE ACTION PROGRAM (CAP) l o
CORRECTIVE ACTION PROGRAM CAP DESCRIBE CAP AND WHY IT WILL PROVIDE REQUIRED
)
ASSURANCE THAT INSTALLED STRUCTURES, SYSTEMS l
AND COMPONENTS MEET LICENSING COMMITMENTS l
o ENGINEERING FUNCTIONAL EVALUATION EFE INTRODUCE EFE CONCEPT AND DEMONSTRATE HOW EFE l
WILL PROVIDE ADDITIONAL ASSURANCE OF ADEQUACY 0F ENGINEERING EFFORT 1
NRC TRT TECHNICAL REVIEW TEAM o
INVESTIGATION AND INSPECTION o
9/84 MEETING WITH FINDINGS o
FORMATION OF COMANCHE PEAK RESPONSE TEAM (CPRT)
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3 CPRT STRUCTURE i
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CONTROLLED BY PROGRAM PLAN i
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ISSUE SPECIFIC ACTION PLAN (ISAP) i I
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CPRT ORGANIZATION / STAFFING j
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o SENIOR REVIEW TEAM (SRT) i i
o REVIEW TEAM LEADERS I
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o STAFFED PRINCIPALLY BY TU ELECTRIC PERSONNEL 4
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1 i
INITIAL CPRT PROGRAM REV.
O PRESENTED T0 i
NRC 10/84 o
PRINCIPAL CONCERN
" PROGRAM LACKS INDEPENDENCE" 1
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i CPRT EVOLUTION REV.
1 AND REV.
2 10/84 2/85 o
STAFFING CHANGED FROM
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TU ELECTRIC TO THIRD PARTY i
o NEW TRT ISSUES GIVEN
)
TO TU ELECTRIC
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o TU ELECTRIC DECISION T0 INCLUDE SELF-INITIATED o
DESIGN ADEQUACY PROGRAM (DAP) o QUALITY OF CONSTRUCTION (Q0C) i
)
o SRT DECISION TO USE SAMPLING AS AN INVESTIGATORY TECHNIQUE l
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CPRT PROGRAM AT PRESENT REV.
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IDENTIFY ISSUES l
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ASLB CYGNA CASE (INTERVEN0R) 3
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NRC (CAT / SIT /TRT/RIV) l o
ASSURE THROUGH IMPLEMENTATION OF l
ISSUE SPECIFIC ACTION PLAN (ISAPs) l AND DISCIPLINE SPECIFIC ACTION PLAN l
(DSAPs)
THAT ISSUES ARE PROPERLY l
ADDRESSED i
I l
1
CPRT PROGRAM AT PRESENT (CONTINUED) o ISSUE SPECIFIC ACTION PLANS (ISAPs)
I THROUGH VII.s RESPOND TO TRT ISSUES l
o QUALITY OF CONSTRUCTION (Q0C)
ASSESSMENT OF HARDWARE AND QA/QC PROGRAM THROUGH SELF INITIATED REINSPECTION PROGRAM AND EVALUATION OF OTHER ISAP RESULTS o
DESIGN ADEQUACY PROGRAM (DAP) 0VERVIEW 0F CORRECTIVE ACTIONS IN THE AREAS OF PIPING AND PIPE SUPPORTS (DSAP IX),
CABLE TRAY l
AND CONDUIT SUPPORTS (DSAP.VIII)
AND
^
SELF-INITIATED EVALUATION OF BALANCE OF DESIGN (DSAPs VIII, X AND XI).
r FALL 1986 ASSESSMENT o
DESIGN ADEQUACY PROGRAM INVESTIGATION COMPLETE INADEQUATE DOCUMENTATION OF DESIGN IMPLICATED o
ISAP AND 00C INVESTIGATION ESSENTIALLY COMPLETE o
INDICATION OF SOME HARDWARE AND PROGRAMMATIC ISSUES AS A RESULT OF ISAP AND 000 EVALUATIONS 1
t l
FALL 1986 ASSESSMENT (CONTINUED) 8 CPRT PROGRAM VERY SUCCESSFUL IN INVESTIGATING ISSUES AND IDENTIFYING AREAS OF CONCERN THAT EXIST IN DESIGN DOCUMENTATION, INSTALLED STRUCTURES, SYSTEMS AND COMPONENTS AND PROGRAMMATIC ACTIVITIES AT CPSES.
O PROBLEMS WERE ENCOUNTERED BY PROJECT IN DISPOSITIONING CPRT FINDINGS ON A SINGLE ISSUE BASIS DUE TO COMPLEX INTERRELATIONSHIPS BETWEEN HARDWARE, DESIGN CONFIGURATION, AND DESIGN BASIS DOCUMENTS.
s s
0 SRT OBJECTIVE O
CPRT INVESTIGATIVE PHASE O
PROJECT RESPONSE TO FINDINGS O
CPRT RESULTS REPORTS 0
OVERVIEW BY SRT OF PROJECT ACTIVITIES TECHNICAL QA AUDITS SWEC EFE PROGRAM t
l CORRECTIVE ACTION PROGRAM (CAP) 1 I
o MISSION DEMONSTRATE EXISTING SYSTEMS, STRUCTURES AND COMP 0NENTS ARE IN COMPLIANCE WITH LICENSING COMMITMENTS OR DEVELOP MODIFICATIONS WHICH WILL BRING
- SYSTEMS, STRUCTURES AND COMP 0NENTS INTO COMPLIANCE WITH LICENSING COMMITMENTS DEVELOP PROCEDURES, ORGANIZATIONAL PLAN AND DOCUMENTATION TO MAINTAIN COMPLIANCE TO LICENSING COMMITMENTS THROUGH THE LIFE OF COMANCHE PEAK
DESIGN BASIS CONSOLIDATION PROGRAM (DBCP)
IS THE FUNDAMENTAL ELEMENT OF THE CAP I
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DESIGN BASIS CONSOLIDATION PROGRAM (DBCP)
PROGRAM WHICH HAS AS ITS PURPOSE, WHEN COMPLETED, TO PROVIDE ASSURANCE THAT:
I o
THE DESIGN 0F SYSTEMS, STRUCTURES AND COMP 0NENTS COMPLIES WITH LICENSING COMMITMENTS o
CONFIGURATION OF SYSTEMS, STRUCTURES AND COMP 0NENTS IS IN ACCORDANCE WITH DESIGN o
DOCUMENTATION, ORGANIZATIONAL PLAN AND PROCEDURES ARE IN PLACE THAT WILL ASSURE COMPLIANCE WITH LICENSING COMMITMENTS IN THE FUTURE
e ELEMENTS OF PROGRAM AND RESOLUTION OF ISSUES o
GENERIC ISSUE REPORT GIR o
DESIGN BASIS DOCUMENTS DBD DVP o
DESIGN VALIDATION PACKAGE FPR o
FINAL PROJECT REPORT i
I GENERIC ISSUE REPORT (GIR) t o
PRESENTS ISSUES IDENTIFIED FROM EXTERNAL SOURCES (TRT,
- CYGNA, CASE,
- CAT, ETC.)
AND ISSUES IDENTIFIED BY TERA AND ERC o
PRESENTS CAP METHODOLOGY (DBCP)
FOR RESOLVING THE IDENTIFIED ISSUES AS WELL AS VALIDATION OF THE DESIGN BASIS i
I t
DESIGN BASIS DOCUMENTS (DBD) o CONTROLLED DOCUMENTS THAT CONTAIN CURRENT DESIGN CRITERIA WHICH EMB0DY LICENSING COMMITMENTS, CODES AND STANDARDS, NSSS INTERFACE CRITERIA, SYSTEM AND COMP 0NENT i
DESIGN PARAMETERS i'
DESIGN VALIDATION PACKAGE (DVP) 1 l
CONTAINS DESIGN DOCUMENTS (SPECS /CALCS/ DRAWINGS)
AND EVALUATIONS DEMONSTRATES COMPLIANCE OF DESIGN DOCUMENTS TO DESIGN BASIS REPRESENTS THE DOCUMENTED DESIGN BASIS (CONFIGURATION MANAGEMENT BASELINE)
FROM WHICH FUTURE DESIGN WORK WILL BE BASED i
'l FINAL PROJECT REPORT $(FPR) klI o
REPORT ON HOW OBJECTIVES OF CAP WERE MET i
o REPORT ON HOW ALL ISSUES WERE RESOLVED o
IDENTIFIES THE PREVENTIVE ACTION TO ENSURE l
SIMILAR PROBLEMS DO NOT OCCUR IN THE FUTURE
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IDENTIFIED CENERIC PERFORM DESICN AS - INGTALLED 1
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ISSUES ISSUES REPORTS VALIDATION CONDITIONS r
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IDENTIFY NON COTLIANCES WITH CESICN 8 ASIS
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PROJECT REPORT b
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CAP ASSURES o
DESIGN DOCUMENTATION IS CONTROLLED AND ACCEPTABLE i
o CONFIGURATION OF SYSTEMS, STRUCTURES AND COMP 0NENTS IS IN COMPLIANCE WITH LICENSING COMMITMENTS o
ALL ISSUES ARE RESOLVED j
o DOCUMENTATION, ORGANIZATION AND PROCEDURES ARE IN PLACE TO MAINTAIN COMPLIANCE WITH LICENSING COMMITMENTS IN THE FUTURE i
TECHNICAL AUDIT PROGRAM THE TECHNICAL AUDIT PRO' GRAM WAS DEVELOPED TO EVALUATE THE ADEQUACY OF THE TECHNICAL AND PROGRAMMATIC EXECUTION OF THE CORRECTIVE ACTION PLANS.
THIS IS ACCOMPLISHED BY AUDITING THE DESIGN VALIDATION PROCESS INCLUDING:
t O
COMPILATION OF DESIGN BASIS DOCUMENTS AND VERIFICATION OF CRITICAL DESIGN PARAMETERS O
PREPARATION OF DESIGN VALIDATION PACKAGES O
DESIGN VALIDATION EFFORTS INCLUDING RESOLUTION OF ITEMS IN GENERIC ISSUE REPORTS AND PROGRAMS TO OBTAIN "AS-INSTALLED" INFORMATION
i TECHNICAL AUDIT PROGRAM STAFF-I I
o STAFFED BY DEGREED AND EXPERIENCED FULL-TIME ENGINEERING SPECIALISTS o
STAFF SUPPLEMENTED BY ENGINEERING SPECIALISTS FROM OUTSIDE ENGINEERING ORGANIZATIONS o
STAFF SUPPLEMENTED BY TV ELECTRIC QUALITY ENGINEERING AND TU ELECTRIC ENGINEERING ASSURANCE i'
l ASSURANCE OF PRODUCT QUALITY I
o CONTRACTOR QA/EA AUDITS o
o TV ELECTRIC QA TECHNICAL AUDITS o
ENGINEERING FUNCTIONAL EVALUATION o
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i SWEC ENGINEERING ASSURANCE 4
i ENGINEERING FUNCTIONAL EVALUATION l
e i
i l
e ENGINEERING VALIDATION AND COMPLETION ACTIVITIES ARE BEING EFFECTIVELY IMPLEMENTED e PROGRAMS FOR THE CONTROL OF ENGINEERING ACTIVITIES DURING OPERATIONS ARE ADEQUATE TO MAINTAIN THE DESIGN BASIS
ENGINEERING ASSURANCE PROGRAM l
ENGINEERING FUNCTIONAL EVALUATION SCOPE I
I I
DESIGN COMPLETION DESIGN ACTIVITIES ACTIVITIES DURING OPERATIONS e
DESIGN CORRECTIVE ACTION e
PROSPECTIVE ACTION PLAN e
DESIGN VALIDATION
- MANAGEMENT AND ORGANIZATION
- MODIFICATION PROCESS e
DESIGN MODIFICATIONS
- DESIGN PROCESS e
UTILIZATION OF DESIGN DATA
- REVIEWS
- TESTING
- RECORDS MANAGEMENT
- MAINTENANCE
- DATA BASE MANAGEMENT
' - OPERATIONS e
IMPLEMENTATION
DESIGN COMPLETION ACTIVITIES EVALUATION TECHNIQUE o
VERTICAL IN-DEPTH TECHNICAL AUDIT e
REVIEW PLANS - DETAILED ATTRIBUTES e
SITE WALKDOWNS e
ACTION ITEMS, RESOLUTION AND FOLLOW-UP i
- l
l LICENSING COMMITMENTS NSSS DESIGN BASIS DOCUMENTS (DBD)
INTERFACE i
(----------------------
g g
g RESOLUTION OFl i
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DESIGN DIAGRAMS l
l l
,[I"_D]NGS_____]
I I
CHANGES CALCULATIONS I
I SPECIFICATIONS I
I I
DRAWINGS I
DESIGN I
I I
VENDOR DOCUMENTS I-- V ALID ATION I
I I
AS - CONSTRUCTED DOCUMENTS I
PACK AGE (DVP) 1 I
I INTERFACES l
I I
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4 TESTING TECHNICAL OPERATING TRAINING MAINTENANCE SPECIFICATION PROCEDURES DATA DATA 1
l DESIGN COMPLETION ACTIVITIES i
l SAMPLE SELECTION e
DISCIPLINE ACTIVITIES e
KNOWN PAST PROBLEMS
'e SAFETY FONCTION - DESIGN e NSSS AND BALANCE OF PLANT l
e MULTIPLE COMPONENTS f
e MULTIPLE SYSTEM INTERFACE e
MULTIPLE OPERATING MODES
u s
SCOPE DESIGN COMPLETION ACTIVITIES DESIGN IN-DEPTH INTERFACE ORGANIZATION ACTIVITY / GROUP EVALUATION ONLY SWEC CORRECTIVE ACTION PROJECT (CAP)
X PIPE SUPPORT ENGINEERING (PSE) i LARGE BORE X
SMALL BORE X
EBASCO SYSTEM INTER ACTION X
CABLE TRAY SUPPORT X
CONDUli SUPPORTS X
- TRAINS A B & C (OVER 2" DIA)
HVAC x
IMPELL CONDUlT SUPPORTS X
- TRAIN C (2" AND SMALLER)
FIRE PROTECTION X
SEISMIC & ENVIRONMENTAL X
QUALFICATION EPM FIRE SAFE SHUTDOWN ANALYSIS X
FIRE PROTECTION DATA SYSTEM (FPDS)
X CABLE AND RACEWAY SCHEDULE (CARDS)
X TU ELECTRIC TEST PROGRAM X
TU ELECTRIC OPERATIONS / MAINTENANCE X
i l
DESIGN ACTIVITIES DURING OPERATION EVALUATION TECHNIQUE
)
e DEVELOP LIST OF ACTIVITIES REQUIRING ENGINEERING INVOLVEMENT l
e DEVELOP LIST OF CPRT GENERIC ISSUES AND NRC OPERATING PLANT INDUSTRY CONCERNS i
e ASSESS COMPLETENESS OF TU ELECTRIC PROSPECTIVE ACTION PLAN AND PROCEDURAL SYSTEM e
ACTION ITEMS e
RESOLUTION e
FOLLOW-UP SELECTED IMPLEMENTATION ASSESSMENT
i DESIGN ACTIVITIES DURING OPERATION 1
t l
DEPTH OF EVALUATION i
e ORGANIZATION CHARTERS e
CHANGE IDENTIFICATION o
ENGINEERING ASSURANCE o
MODIFICATION PACKAGES e
REGULATORY REPORTING e
COMPUTER SOFTWARE o
QUALITY RECORDS i
e ACCELERATED CHANGE SYSTEM e AS-BUILT SYSTEM e
DATA BASE SYSTEMS e
RELEASE FOR OPERATIONS i
e ORGANIZATION INTERFACE o
SPARE / REPLACEMENT PARTS i
e OPERATIONS REVIEW COMMITTEE e
DESIGN VERIFICATION
i I
i l
REPORTING 4
e DEMONSTRATE DEPTH AN.D EXTENT OF EVALUATION e
IDENTIFY:
- ACTION ITEMS
- RESOLUTION
- FOLLOW-UP I
o DRAW CONCLUSION TO THE ADEQUACY OF DESIGN PROCESS AND INTERFACE WITH TESTING, MAINTENANCE AND OPERATIONS
SCHEDULE - ENGINEERING FUNCTIONAL EVALUATION l427 Wes
~
3 4
5 6
7 8
9 10 11 12 1
,2 3
READY SRT REVIEW FINAL PROJECT REPORT LOAD FUEL l
NRC REVIEW FINAL EVALUATION REPORT PHASEI PHASE 11 PHASEW DBCP DVP/ DISCRETE DBCP TRENDING DESIGN ACTIVITIES INTERFACE DESIGN STING COMPLETION ACTIVITIES OPERATION &
MAINTENANCE 7
PERFORMANCE FOLLOW-UP D
O TION 1
TEAM PERSONNEL e
SENIOR EXPERIENCED ENGIN<
91NG PERSONNEL l
e INDEPENDENCE FROM DIRECT COMANCHE PEAK ACTIVITIES e
MULTIPLE DISCIRLINES e
PERSONNEL WITH IN-DEPTH AUDIT EXPERIENCE i
e JOINT CONTRACTOR TEAM i
~
1, SWEC e
EBASCO e
~'IMPELL
- e.
~
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PROJECT MANAGEMENT ENGINEERING QUALITY ASSURANCE i
VICE PRESIDENT VICE PRESIDENT VICE PRESIDENT Q A POLICY '
__J ENGINEERING ASSURANCE CAP PSE PROJECT PROJECT CHIEF ENGINEER MANAGEMENT MANAGEMENT W M EIFERT l
t TECHNICAL POLICY ENGINEERING 4
DIVISIONS l
PROJECT PROJECT ENGINEERING TEXAS UTILITIES ON ENGINEERING ENGINEERING g
ON
~~~
ENGINEERING /
]
MANAGER CONSTRUCTION C ZAPPILE L D NACE i
I j
i i
DESIGN COMPLETION DESIGN ACTIVITIES ACTIVITIES DURING OPERATIONS TEAM LEADER TEAM LEADER R W TWIGG A J BENECCHI I
I j
TECHNICAL SPECIALISTS SPECI ALISTS l
BENEFITS e
IN-DEPTH AUDIT TECHNIQUE - TRUE TEST OF DESIGN PROCESS 8
VERTICAL APPROACH EVALUATES INTEGRATION OF TU ELECTRIC AND CONTRACTOR ACTIVITIES e
CONSISTENT WITH NRC DESIGN INSPECTION APPROACH APPLIED TO ALL NT0L PLANTS AND SAFETY SYSTEM FUNCTIONAL INSPECTIONS 4
0 PROVIDES BASIS FOR NRC TO OVERSEE TU ELECTRIC SELF INITIATED PROGRAM AS AN ALTERNATIVE TO NRC DESIGN INSPECTION 8
l IN-DEPTH TECHNICAL AUDITS j
e RIVER BEND, MILLSTONE, NINE MILE PT2, BEAVER VALLEY 2 0
SERIES OF TECHNICAL / VERTICAL AUDITS S
ASSESS DESIGN BY TECHNICAL EVALUATION d
8 SENIOR EXPERIENCED ENGINEERS 0
HEADQUARTERS AND SITE ENGINEERING ACTIVITIES 0
TECHNICAL ADEQUACY e
INTERFACE I
e l
l 8
GENERAL CRITERIA EA ENGINEERING FUNCTIONAL EVALUATION TEAM PERSONNEL ASSIGNED TO THE ENGINEERING ASSURANCE ENGINEERING FUNCTIONAL EVALUATION TEAM SHALL MEET THE FOLLOWING GENERAL QUALIFICATION CRITERIA AS WELL AS ANY SPECIFIC REQUIREMENTS IDENTIFIED ON THE ATTACHED LIST:
1.
INDEPENDENCE FROM WORK TO BE EVALUATED (NO PREVIOUS WORK FOR COMANCHE PEAK IN THE FUNCTIONAL AREA) 1 2.
P.E. REGISTRATION PREFERRED 3.
EXPERIENCE / CAPABILITIES COMMENSURATE WITH SENIOR LEVEL ASSIGNMENTS 4.
ABILITY TO INTERFACE WITH THE NRC 5.
ABILITY TO INTERFACE WITH TEST PROGRAM AND OPERATIONS PERSONNEL 6.
ABILITY TO COMMUNICATE EFFECTIVELY IN WRITING AND ORALLY 7.
PWR' EXPERIENCE PREFERRED 8.
ABILITY TO ENTER PLANT AND PARTICIPATE IN WALKDOWNS
EA ENGINEERING FUNCTIONAI. EVAI.IIATTON TEAM NEEDS l
t No.
Required Discipline Additional Criteria 2
Systems Engineer o
Safe shut down systems interaction experience (Power) o Lead level capabilities 1
HVAC Engineer I
Welding / Materials i
Engineer 1
Nuclear Technology o
Experience in accident analysis Safeguards Engineer 1
Radiation Protection Engineer 1
Structural Engineer o
General Civil / Structural experience o
Lead level capabilities 1
Engineering Mechanics o
Systems Interaction /HELB/ IGM / Seismic II/I experience Seismic Qualification experience Engineer o
2 Engineering Mechanics o
Small bore pipe stress analysis and pipe support Engineer design experience 2
Instrument & Control o
Combined experience to cover instrumentation Engineers applications, logics, and elementaries o
One designee should have lead level capabilities t
1 Electrical Engineer o
Strong analytical background AC and DC systems experience o
Part Time
1 EA ENGINEERING FUNCTIONAL EVALUATION TEAM NEEDS No.
Required Discipline Additional Criteria 1
Electrical Engineer o
Strong installation specification and construction interface experience Note:
one of the above should have lead level capabilities, and one should be experienced in the environmental qualification of Class IE equipment 4
Test and Startup o
Level III certification in accordance with Engineers ANSI N45.2.6 4
Operations and Maintenance Engineers Familiar with design control procedures, SWEC EAPs 4
Engineering Assurance o
Engineers
l SCHEDULE - ENGINEERING FUNCTIONAL EVALUATION l
3 4
5 6
7 8
9 10,
11 12 1
2 3
l READY l SRT REVIEW l FINAL PROJECT REPORT TO LOAD l
I FUEL NRC REVIEW FINAL EVALUATION REPORT PHASEI PHASE 11 PHASEm DBCP DVP/ DISCRETE DBCP TRENDING DESIGN ACTIVITIES INTERFACE i
DESIGN ING COMPLETION ACTIVITIES
.l OPERATION &
MAINTENANCE 4
PERFORMANCE FOLLOW-UP DU GO T10N 4
i
i i
I DETAILED PHASE 1 SCHEDULE FOR DESIGN COMPLETION ACTIVITIES i
BOSTON (CAP)
NEW YORK (EBASCO)
COMANCHE PEAK (IMPELL),(EB ASCO)
LOCATION BOSTON BOSTON BOSTON COMANCHE PEAK,CHOC (SMALL BORE PIPE)
COMANCHE PEAK (CAP) l o BOSTON TRAINING o DEVELOP REVIEW PLANS NRC o REQUEST fog REVIEW OF REVIEW DESIGN DETABLED TECHNICAL REVIEWS EVALUATION OF INFORMATION PLANS CRITWINA OF DVPs SITE ACTIVITY ACTIVITY.
DUR ATIO N 3 WEEKS 1 WEEK 2 WEEKS 4 WEEKS 3 WEEKS i
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l EXPECTED NRC INTERFACE 1
l REVIEW PLAN IMPLEMENTATION FOLLOW-UP DEVELOPMENT ACTION ITEM l
CLOSURE
, s e s
- )
(p, 5 7 5 7 i
4/13 5/11 6/15 11/2 i
e
l i
KEY ELEMENTS OF DESIGN VALIDATION l
l e
REVIEW PLAN 1
l
.o REVIEW OF TECHNICAL ADEQUACY i
e ACTION ITEMS i
I l
I a
LICENSING COMMITMENTS l
NSSS DESIGN BASIS DOCUMENTS (DBD)
INTERFACE l
i
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/OTHER DESIGN DIAGRAMS I
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I CHANGES CALCULATIONS I
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SPECIFICATIONS I
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DRAWINGS I
DESIGN I
I l
VENDOR DOCUMENTS I-- V ALID ATION I
I I
AS - CONSTRUCTED DOCUMENTS I
PACK AGE (DVP) l I
I INTERFACES I
I I
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I TESTING TECHNICAL OPERATING TRAINING MAINTENANCE i
SPECIFICATION PROCEDURES DATA DATA ~
l
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)
UTILIZATION OF ENGINEERING DATA e
INPUTS FROM DESIGN EVALUATION l
e EVALUATE TEST PROGRAM, OPERATION, MAINTENANCE i
l TEST PROCEDURES l
OPERATING PROCEDURES TECHNICAL SPECIFICATION i
TRAINING PROGRAM i
i MAINTENANCE PROCEDURES 4
l
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REVIEW PLANS 1
J i
I i
I ARE A KEY ELEMENT OF THE EVALUATION PROCESS e
e ARE DEVELOPED FOR EACH EVALUATION SUBJECT, i
i BY DISCIPLINE e
PROVIDE THE ATTRIBUTES / CRITERIA TO WHICH THE EVALUATION IS PERFORMED i
i j
e PROVIDE A STEP - BY - STEP, SYSTEMATIC APPROACH TO PERFOR. MING AND DOCUMENTING THE RESULTS OF EACH EVALUATION
{
l e
IDENTIFY ~ HE ACTION ITEMS INITIATED TO RESOLVE POTENTIAL GONCERNS/ APPARENT DEFICIENCIES
i i
REVIEW PLAN SUBJECTS l
WILL TYPICALLY ADDRESS
~
e CONSISTENCY BETWEEN DESIGN & FSAR 4
e COMPLIANCE WITH NSSS CRITERIA l
1 o
CALCULATIONS e
DRAWINGS l
o DIAGRAMS l
e SPECIFICATIONS i
l e
VENDOR DOCUMENTS l
e CHANGE DOCUMENTS SUCH AS DCAs, NCRs, etc.
e SPECIAL AREA.S SUCH AS EQUIPMENT QUALIFICATION, l
HIGH ENERGY LINE BREAK ANALYSIS, INTERNALLY l
GENERATED MISSLES, etc.
j e
SELECTED DESIGN VALIDATION PACKAGES i
i l
ACTION ITEM OBJECTIVES i
j e
TO PROVIDE "IN-PROCESS" IDENTIFICATION OF POTENTIAL f
CONCERNS / APPARENT DEFICIENCES e
TO PROVIDE FORMAL REQUESTS FOR INFORMATION THAT
)
IS NOT READILY AVAILABLE i
e TO ACCOMPLISH EARLY RESOLUTION OF CONCERNS /
l l
DEFICIENCES e
TO " BOUND" VALID CONCERNS /DEFICIENCES e
TO ESTABLISH THE FOUNDATION FOR CORRECTIVE AND PREVENTIVE ACTIONS e
TO PROVIDE INSIGHT INTO EVALUATION PROGRAM ADJUSTMENTS THAT MAY BE NEEDED e
TO PROVIDE A CLOSED - LOOP SYSTEM FOR RESOLUTION l
OF CONCERNS /DEFICIENCES i
i i
ACTION ITEMS i
j e
REQUIRE UNIQUE IDENTIFICATION, INDEXING, STATUSING I
AND TRACKING TO CLOSURE FOR EACH ACTION ITEM e
REQUIRE DOCUMENTATION OF CONCERNS /DEFICIENCES i
e REQUIRE FORMAL RESPONSE TO EACH ACTION ITEM INITIATED, INCLUDING ROOT CAUSE, EXTENT OF CONDITION, AND CORRECTIVE / PREVENTIVE ACTIONS, WHERE APPROPRIATE e
REQUIRE FULLY DOCUMENTED EVALUATION OF EACH l
RESPONSE
l e
REQUIRE FORMAL FOLLOW - UP AND VERIFICATION OF l
CORRECTIVE / PREVENTIVE ACTIONS l
l EVALUATION REPORT l
i e
SCOPE AND SUMM ARY BY DISCIPLINE i
l e
ALL ACTION ITEMS i
e RESOLUTIONS OF VALID ACTION ITEMS e
CONCLUSIONS TECHNICAL ADEQUACY 1
{
COMPLIANCE WITH LICENSING COMMITMENTS
(
)
EFFECTIVENESS OF CAP PROJECTS i
ACTION ITEM CATEGORIZATION SYSTEMATIC WEAKNESSES i
t I
.