ML20214P086

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Further Answers to Interrogatories (Comanche Peak Response Team Sets 1-7).* Applicant Suppls Responses to Certain Interrogatories Propounded by Case,Per Board Orders Rendered on 861215.W/Certificate of Svc.Related Correspondence
ML20214P086
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 05/28/1987
From:
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Citizens Association for Sound Energy
References
CON-#287-3622 OL, NUDOCS 8706030201
Download: ML20214P086 (18)


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                                    '87 JUN -1 P2 35 FILED: May 28, 1987 h)h:Li.h.        

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

                                                 )

In the Matter of )

                                                 )

TEXAS UTILITIES ELECTRIC ) Docket Nos. 50-445-OL COMPANY, et al. ) 50-446-OL

                                                 )

(Comanche Peak Steam ) Electric Station, ) Units 1 and 2) )

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                                                 )

FURTHER ANSWERS TO INTERROGATORIES (CPRT SETS 1-7) INTRODUCTORY STATEMENT Pursuant to the orders of the Board rendered in open court on December 15, 1986, and without waiving its objections heretofore interposed, the Applicants hereby supplement their responses to certain interrogatories propounded by CASE. SUPPLEMENTAL ANSWERS SUPPLEMENTAL ANSWER TO SET 3, QUESTION 1 The decision to develop a program to respond to the NRC-TRT requent for information was made by Mr. Michael D.

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i Spence, Generating Division President, TU Electric (formerly TUCCo). Mr. Spence announced this plan in his closing remarks at the September 18, 1984, meeting with the NRC wherein he stated, "we intend to get on it right away and to promptly develop and [ sic) action plan to address all these issues." (Tr. 57 9/18/84). After that decision was made, Mr. Spence held a meeting on September 22, 1984, to assign to his senior management the responsibility of developing the program. As discussed below in response to Set 3, Question 4, it was in this meeting where development of the Comanche Peak Response Team (CPRT) Program Plan began. Senior Review Team (SRT) meetings were held frequently, and it was in these SRT meetings where the " policy level" discussions regarding the content of the Program Plan took place. Therefore, these persons who participated in discussions which impacted the development of the CPRT Program Plan are listed below in response to Set 3, Question

2 as attendees at SRT meetings.

Mr. Spence's decision is further documented in his September 24, 1984, memorandum where he states, "At my direction, we have recently established the Comanche Peak i Response Team. . . . SUPPLEMENTAL ANSWER TO SET 3, QUESTIO.1 2 Listed below are the meetings between July 1, 1984, and October 1984, wherein the response to the September 18, i

1 e i 1984, TRT letter was discussed. Also noted are the attendees at the meetings and their employer, if known. Meeting Attendee Attendees' Employer 1 i Sept. 18, 1984 Michael D. Spence TUGCO (w/NRC) Billy R. Clements TUGCO Joe B. George TUGCO l John W. Beck TUGCO Lou F. Fikar TUGCO Jack D. Redding TUGCO Homer C. Schmidt TUGCO Nick S. Reynolds BLCP&R H. Levin TERA T. Ippolito NRC D. Eisenhut NRC J. Calvo NRC A. Johnson NRC S. Burwell NRC J. Youngblood NRC J. Stefano NRC l L. Shao NRC l R. Keimig NRC . l A. Vietti NRC J. Collins NRC l R. Wessman NRC S. Gagner NRC W. Smith NRC D. Jeng NRC T. Langowski NRC C. Hoffmayer NRC H. Denton NRC E. Case NRC B. Hayes NRC l J. Landers NRC  ! R. Hutcheson NRC J. Saloto NRC R. Philleo NRC l l l t As of the date of the meeting. 3-

I( i Sept. 22, 1984 Michael D. Spence TUGCO (SRT) Lou F. Fikar TUGCO Billy R. Clements TUGCO Joe B. George TUGCO John W. Beck TUGCO John C. Guibert TERA Sept. 27, 1984 Lou F. Fikar TUCCO (SRT) Billy R. Clements TUCCO Joe B. George TUCCO John W. Beck TUCCO John C. Guibert TERA John T. Morritt TUGCO W. Iven Vogelsang TUCCO Larry M. Popplewell TUGCO S. P. Martinovich G&H Mike R. McBay TUGCO l C. Randy Hooton TUGCO l Antonio Vega TUGCO Mike Warner B&R D. Pantankar G&H Scott Harrison TUGCO O. Bennett Jones TUGCO Sterling Franks IMPELL Richard E. Camp IMPELL , H. Alan Lancaster TUCCO Ronald G. Tolson TUCCO Claude K. Moehlman TUGCO l Sept. 29, 1984 Michael D. Spence TUGCO I (SRT) Lou F. Fikar TUCCO Billy R. Clements TUGCO Joe B. George TUGCO John W. Beck TUGCO l John C. Guibert TERA John T. Morritt TUGCO October 2, 1984 Lou F. Fikar TUCCO (SRT) Billy R. Clements TUCCO John W. Beck TUCCO John C. Guibert TERA John T. Morritt TUCCO Larry M. Popplewell TUGCO C. Randy Hooton TUGCO Richard E. Camp IMPELL Claude K. Moehlman TUGCO Antonio Vega TUGCO Ronald G. Tolson TUGCO October 4, 1984 Lou F. Fikar TUGCO (SRT) Billy R. Clements TUGCO Joe B. George TUGCO

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4 l l [ . i l i John W. Beck TUCCO John C. Guibert TERA John T. Merritt TUGCO . October 19, 1984 Michael D. Spence TUGCO (w/NRC) Billy R. Clements TUGCO Joe B. George TUCCO John W. Beck TUGCO Lou F. Fikar TUGCO Jack D. Redding TUGCO John T. Merritt TUGCO Larry M. Popplewell TUGCO ' C. Randy Hooton TUGCO Mike R. McBay TUGCO , Antonio Vega TUGCO j i Richard E. Camp IMPELL i John C. Guibert TERA I Nick Reynolds BLCP&R  ! l l Harold Denton NRC i Jose Calvo NRC  ! Larry Shao NRC i Richard R. Keimig NRC , t I D. R. Hunter NRC Bob Heistfman NRC Vincent S. Noonan NRC Darrell Eisenhut NRC Bob Martin NRC , I Dick Bangart NRC ' Oscar NRC Jack Booth Dallas Times Herald Al Johnson NRC Ward Smith NRC John Kopeck NRC Dick Weissman NRC  ! Joe Scinto NRC l S. Treby NRC C. Pouluany NRC  ! Joe Youngblood NRC i R. C. Tang NRC l Annette Vietti NRC i Ron Hutchinson NRC , October 23, 1984 Joe B. George TUGC0 l (W/NRC) John W. Beck TUCCO John T. Merritt TUCCO , i Mike R. McBay TUCCO  ! Richard E. Camp IMPELL C. Randy Hooton TUCCO Frank Dougherty TERA R. Wessman NRC i Vincent S. Noonan NRC  ; H. Livermore NRC  ! 1-

4 R. E. Philleo NRC Larry Shao NRC R. R. Keimig NRC Charles Hofmayer NRC Billie Garde OAP Jim Landers Dallas Morning News Susan Bremmer Dallas Times Herald Jose Calvo NRC Adele Cosell NRC David Jong NRC i Bob Foyo NRC Charles Hofmayer NRC l Individuals attending the above meetings on behalf of TU Electric who are currently employed by the TU System have , been polled. No documents responsive to the document l I request have been identified other than documents contained in the CPRT Working Files. ' SUPPLEMENTAL ANSWER TO SET 3,-QUESTION 4 Applicants created Rev. O to the Program Plan in  ! response to Mr. Spence's directive of September 18, 1984, , forming the Comanche Peak Response Team to respond completely and thoroughly to each TRT issue identified as of l that date. l Mr. Spence formed the Senior Review Team four days later, on September 22. The SRT met that same day and, in consultation with Messrs. John Guibert and Frank Dougherty l of TERA, agreed upon the general features and content of the . CPRT Program Plan. They decided that the CPRT effort should respond meticulously to every question raised by the TRT, and that the CPRT effort would receive from Applicants all

a a the resources needed to carry through with their assignment. The general directive received from Mr. Spence was for the CPRT to investigate the TRT issues and correct any deficiencies. The September 22 initial meeting of the SRT was followed by a two-week period of intense efforts to develop a CPRT Program Plan consistent with the general directive of designing a team effort that would cerrect any deficiencies j that would preclude issuance of an ojeratin7 license. For i that reason the Program Plan was made flexible enough to respond to additional concerns beyond the TRT issues. Mr. Spence charged the SRT with their roles and responsibilities in a memorandum dated September 24, 1984 (copy attached). A team headed by Mr. Merritt then began an intensive effort to develop the general directives for the CPRT Program Plan and to prepare carefully thought out Issue Specific Action Plans to formulate responses to the initial twenty-four (24) issues raised by the TRT. The SRT met again on September 27, 1984. At that meeting they critiqued presentations received from Review Team Leaders and Issue Coordinators. They reviewed the l development of these documents once more in a September 29, 1984, meeting. The draftsmen returned with drafts of the Program Plan and ISAPs. The SRT subjected these drafts to review in two five-hour meetings held on October 2 and October 4, 1984. The October 2 meeting

I 4 e i focused on the CPRT Program Plan and the October 4 meeting on the ISAPs. After incorporation of the SRT's editorial and substantive comments into the Program Plan and ISAPs, Rev. O was submitted to the NRC on October 8, 1984. The participants in the meetings referred to in this l ) Supplemental Answer are identified in Supplemental Answer to Set 3, Question 2. SUPPLEMENTAL ANSWER TO SET 6,_ QUESTION 27 Listed below are the individuals identified in the CPRT Program Plan, Issue / Design Specific Action Plans and/or Results Reports as advisors to the CPRT. This list does not include those individuals who have been retained as Review Team Leaders, Discipline or Issue Coordinators, or Group Leadern and who work as an integral part of the CPRT, nor does it include any additional (1 3., other than in a l consulting or advisory role) involvement by the personnel listed as Review Team Leaders or the like. There were no unique reasons for the selection of these i advisors and the selections were made at the discretion of the Review Team Leaders. Also included is a notation regarding the involvement each advisor had regarding the development of the ISAP/DSAP and/or Results Report for which the individual participated in as an advisor. l

i e Donald G. Anderson - Participated as a member of the Special Evaluation Team (SET) as discussed in ISAP 1.d.1 and had no involvement in the development of this ISAP. L.D. Bates - Mr. Bates participated as a third party advisor as described in the following ISAPs and/or Results Reports: Reviewed and supervised the pullout test procedure as described in ISAP !.a.2. Reviewed the AMP qualification data package as described in Results Report I.a.3. Prepared test procedures, supervised tests, issued report of test results, reviewed circuit evaluation as required and as described in Results Reports I.b.1 and I.b.2. Reviewed the report compiling the C&ll criteria as described in Results Report 1.b.3. l Mr. Dates was identified in ISAP I.b.4 as third party advisor. John M. Bioqs - No involvement in the development of the ISAPs/DSAPs or Results Reports issued to date. C,1. Browne - Mr. Browne's involvement included participation as a third-party reviewer on ISAP V.e. Prior to completion of the results report, Mr. Browne and his firm R.L. Cloud Associates were requested to assist the project i organization in various areas including piping / supports and cable tray / supports as discussed in Results Report V.e. R.L. Cloud Associates work has been reviewed in detail by TERA. j l

i i R.L. Cloud - Mr. Cloud's involvement included participation as a third-party reviewer on ISAP V.e. Prior to completion of the results report, Mr. Cloud and his firm R.L. Cloud Associates assumed responsibilities assisting the project organization in various areas including piping / supports and cable tray / supports as discussed in l Results Report V.e. Prior work has been reviewed in detail by TERA. M.L. Curland - Mr. Curland participated as a member of the SET as discussed in ISAP !.d.1 and Results Report I.d.2 l and had no involvement in the development of this ISAP. , Will_iam_ Hall - Dr. Hall has made technical contributions to the resolution of ISAP VI.b and had no involvement in the development of this ISAP. l M.J. IIolley - Dr. Ifolley has made technical l l contributions to the resolution of ISAPs !!.c and V.b and DSAP VI!! and had no involvement in the development of these ISAPs/DSAP or the Results Report for ISAP !!.c. 0=orge Howard - Dr. Howard's involvement initially ! included participation as third party in the development of DSAP VI!!. Prior to completion of the implementation of this action plan Dr. Iloward and his firm, ANCO, were requested to assist the project organization and their contractors with testing services and consulting.  ; pr. Paul !banet - Dr. Ibanez's involvement initially included participation as third party in the development of , 1 DSAP VIII. Prior to completion of the implementation of this action plan Dr. Ibanez and his firm, ANCO, were requested to assist the project organization and their contractors with testing services and consulting. l l Timo Karppinen - Mr. Karppinen consulted in the 1 development of DSAP IX and also participated in the execution of DSAP IX. Dr. Edwardo Kausel - No involvement in the development of the ISAPs/DSAPs or Results Reports issued to date. Mr. O. Lagledger - Mr. Lagledger provided testing and inspection services as doncribed in Results Report !!.b and

   !!.c and ISAPs !!.e and V.b and had no involvement in the development of these ISAPs or Results Reports.

Dr. W. Munse - Dr. Munse participated in the activities described in ISAP V.b and had no involvement in the development of this IDAP. William Rice - Mr. Rice took over DSAP XI discipline coordinator responsibilities from M.B. Jones and participated in the execution of DSAP XI. Everett_Rodabaugh - Mr. Rodabaugh consulted in the development of DSAP IX and also participated in the execution of DSAP IX. Gerald _01agi,s - Mr. Slagis consulted in the development of DSAP !X and also participated in the execution of DSAP IX. i

F, Mr. J.W. Sutton - Mr. Sutton participated as a member of SET as described in ISAP !.d.1 and Results Report I.d.2 and had no involvement in the development of this ISAP or Results Report. Dr. D. Veneziano - Dr. Veneziano provided statistical input into Results Report !!.b and had no involvement in the development of this ISAP or Results Report. Dr. Fred _ Webster - Dr. Webster provided the statistical input into the ISAPs/DSAPs and Results Reports as noted therein. _ SUPPLE.MEtiTAte AliSWER__TO__ SET.._6_, . . QUESTION 3 9 During the course of completing the various QA/QC Action Plans the QA/QC Review Team personnel who require documents, information or support services from the project follow the guidance provided in CPP-012 "QA/QC Interface with Constructor /TUCCO." The Unit 1 Project Manager, R.E. Camp, is the main liaison between the CPRT effort and the project. To facilitate certain requests the CPRT Projects group was established. This group reports to R.E. Camp through Fred Burgess. QA/QC Review Team identified out of scope observations l l and deviations are proconsed in accordance with ERC Project Procedures. These conditions are then reported to TUCCO project personnel for processing in accordance with l l

1-CP-QP-16.3, " Processing CPRT Deviation Reports /Out of Scope Observations." Additional project procedures require that a disposition for corrective action be provided by Engineering and approved by the Director of Engineering or provided and approved by the Construction Representative. The individual is specifically identified on each resulting NCR. In addition, project procedures / instructions require the

Discipline Engineer reporting to the Director of Engineering i

l to make a determination if the item identified on the NCR is considered potentially reportable under the guidelines of NEO-CS-1. That individual is specifically identified on the NCR. Further processing, as necessary, is accomplished in , accordance with approved engineering procedures. SUPPLEMENTAL ANSWER TO SET 6, QUESTION 60 The following project procedures are currently being used and explicitly address CPRT activities: CP-QP-16.3 " Processing CPRT Deviation Reports / cut of Scope observations" THE-AD-9 " Review Inspection Attributes, Accept / Reject Criteria and Instructions used in CPRT Reinspection Activities" Other project procedures currently in effect may contain references to CPRT but have not been issued explicitly to address CPRT activities. 13 - l

Io l Procedures. These conditions are then reported to TUGCO , project personnel for processing in accordance with CP-QP-16.3, " Processing CPRT Deviation Reports /Out of Scope l Observations." l Additional project procedures require that a disposition l for corrective action be provided by Engineering and approved by the Director of Engineering or provided and approved by the Construction Representative. The individual is specifically identified on each resulting NCR. In addition, project procedures / instructions require the i Discipline Engineer reporting to the Director of Engineering to mako a determination if the item identified on the NCR is considered potentially reportable under the guidelines of j NEO-CS-1. That individual is specifically identified on the NCR. Further processing, as necessary, is accomplished in accordance with approved engineering procedures. SUPPLEMENTAL ANSWER TO SET 6, QUESTION 60 The following project procedures are currently being l l used and explicitly address CPRT activities: ' l l t CP-QP-16.3 " Processing CPRT Deviation j Reports /Out of Scope Observations" l TNE-AD-9 " Review Inspection Attributes, Accept / Reject Criteria and Instructions used in ) i CPRT Reinspection Activities" l Other project procedures currently in effect may contain references to CPRT but have not been issued explicitly to address CPRT activities. l l I f ! s i Field Verification Methods TNE-FVM-CS-010 and I TNE-FVM-CS-016 have also been developed by the project to respond to CPRT issues. Copies of these documents will be made available to CASE for inspection and copying upon request.2 a In addition, at the time Applicants filed their original answer to CPRT 7, Interrogatory 2, there was an additional procedure responsive to that Interrogatory. That grocedure, CP-QAP-16.1 (" Control of Nonconforming Items ), no longer is in effect. l

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MAY 11 '87 17:38 ROPES GR/617-350-5051 PAGE.16 i SIGNATURE I, Terry G. Tyler, being first duly sworn, do depose and say that I am familiar with the information contained in the CPRT files and available to CPRT third-party personnel, that I have assisted in the preparation of the fer going answers, and that the foregoing answers are true, except insofar as they are based on information that is available to TU Electric or the CPRT (third-party personnel) but not within my personal knowledge, as to which 1, based on such information, believe them to be true. I

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                                                        '87 JUN -1 P2 :35 CERTIFICATE OF SERVICE 6Ffle .- _ i . i;.

I, R. K. Gad III, herebycertifythatonMahb;[fl98.73Emade service of the "Further Answers to Interrogatories (CPRT Sets 1-7)" by mailing copies thereof, postage prepaid, to: Peter B. Bloch, Esquire Mr. James E. Cummins Chairman Resident Inspector Administrative Judge Comanche Peak S.E.S. Atomic Safety and Licensing c/o U.S. Nuclear Regulatory Board Commission U.S. Nuclear Regulatory P.O. Box 38 Commission Glen Rose, Texas 76043 Washington, D.C. 20555 Dr. Walter H. Jordan. Ms. Billie Pirner Garde Administrative Judge GAP-Midwest Office 881 W. Outer Drive 104 E. Wisconsin Ave. - B Oak Ridge, Tennessee 37830 Appleton, WI 54911-4897 Chairman Chairman Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Lawrence J. Chandler, Esquire Mrs. Juanita Ellis Office of the Executive President, CASE Legal Director 1426 S. Polk Street U.S. Nuclear Regulatory Dallas, Texas 75224 Commission Washington, D.C. 20555  ! 1 i i

o Renea Hicks, Esquire Ellen Ginsberg, Esquire Assistant Attorney General Atomic Safety and Licensing Environme;;.tal Protection Division Board Panel P.O. Box 12548, Capitol Station- U.S. Nuclear Regulatory Commission Austin, Texas 78711 Washington, D.C. 20555 Anthony Roisman, Esquire Mr. Lanny A. Sinkin Suite 600 Christic Institute 1401 New York Avenue, N.W. 1324 North Capitol Street Washington, D.C. 20005 Washington, D.C. 20002 Dr. Kenneth A. McCollom Mr. Robert D. Martin Administrative Judge Regional Administrator 1107 West Knapp Region-IV Stillwater, Oklahoma -74075 U.S. Nuclear Regulatory Commission Suite 1000 611 Ryan Plaza Drive Arlington, Texas 76011 Elizabeth B. Johnson Geary S. Mizuno, Esq. Administrative Judge Office of the Executive Oak Ridge National Laboratory Legal Director P.O. Box X, Building 3500 U.S. Nuclear-Regulatory Commission Oak Ridge, Tennessee 37830 Washington, D.C. 20555

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Nancy Williams Cygna Energy Services, Inc. 101 California Street Suite 1000 San Francisco, California 94111 ( t . / \

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