ML20237G278
| ML20237G278 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/30/1987 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20237G245 | List: |
| References | |
| NUDOCS 8708130385 | |
| Download: ML20237G278 (137) | |
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8 I 9 l 10 11 TU ELECTRIC PUBLIC MEETING 12 JULY 30, 1987
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, 13 14 VOLUME II 0F II 15 16 17 18 19 20 21
.22 23 24 Taken by: Carmen Gooden, CSR, RPR July 29, 30, 198T 25 efjB1303e5e70eo4 ADOCK 05000443 ly _ _ _ _ _ _ _
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l 1 ER0CEED1N6S l
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2 MR. GRIMES: Good morning, ladies and gentlemen. t I
-3 We're going to now reconvene the meeting between the Nuclear 4 Regulatory Commission and TV Electric to discuss corrective j 5 action programs at Comanche Peak.
6 I'd like to indicate our desire is that we would j 7 start off with clarifying comments. Both Texas Utilities and 8 CASE have indicated a desire to clarify some statements that 9 Here made yesterday, so I would intend that He would start the 1
10 meeting Hith those clarifications.
11 We Hill then proceed with the other agenda items. TL 12 Electric can make presentations on those agenda items and He i 13 Hill ask questions as necessary.
14 Fo11 ohing that, at the end of the agenda He Hill 15 break. The NRC staff Hill 90 off to another meeting room that 16 has been made available so He can caucus and collect our 17 comments, questions and the results of our two days here. We 18 Hill then reconvene the meeting, present those findings and 19 then close the meeting.
l 20 So that's the plan for today. I'd like to start off 21 with Mr. Couns11. If you will please present Hhatever 22 clarifications you would like to make, t
23 MR. COUNSIL: Thank you, Mr. Grimes. First off, I 24 Hould like to announce that the management, or the owners of i
25 this complex of buildings, have apologized profusely to us for j
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i the disruotion yesterday, that~it was not a fire drill and 2 that it was an actual clarm. .They. don't know what set it off. f l 1 l 3 Hopefully, it will not happen again today.
4 Before proceeding with clarifications, we would like L
5 to comment on your presentation of agenda item number 2 6 yesterday, andthosecommentswillbegivenbydyself,Mr.
7 Beck and Mr. Nace. j 8 Following that, I would like to clarify some specific ;
i 9 statements made yesterday, and at that point I'll turn it back i
-j' 10 to you, Mr. Grimes.
11 Regarding your flow chart, as well as your 12 description of yesterday, we feel overall that you have i 13 captured the essence of our program, specifically in the 2 l 14 description as given yesterday. We would also like to take 15 advantage of the offer that you have made to help redraw the 16 flow chart of agenda item number 2 such that it may be 1 17 ottached to the staff letter to us when it is issued, and we 18 will start that effort next week.
19 MR. BECK: I'd like to address a couple of points. ;
20 One, Chris, you indicated a question with regard to the CPRT I 21 published reports and a discrepancy that you picked up in 22 Revision 4 to the Program Plan, I'd like to refer you, first 23 of pil, to the foreward to Appendix A on page 1 where it 24 indicates in Rev 4 that we have not gone through and modified ,
i 25 the DSAP's. But for clarification purposes page 5, 6 and 7 01
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4 Appendix A specify the Results Reports that will be published 1
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2 in the DSAP area. Those are a Results Report for large-bore l 3 pipe supports, a Results Report for cable tray hangers, a 4 Results Report for conduit supports, Trains A and B', and C l
5 greater than two inches. Those three are th'e ones that were J
6 referred to in our response to your letter for the DSAP's. I I
7 In the collective evaluation area we will' publish onE 8 Collective Evaluation Report that will cover QA/0C quality of 9 construction and also address testing. That's the document j 10 that we anticipate publishing October 1.
11 Collective significance will include not only the 12 broad considerations of all 0A/0C and design-related
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i 13 activities but will also be our collective evcluation, if you 14 will, of third-party activity in'the design' area, 15 understanding, of course, that the large program on the 16 project side and the PSR's will contain the essence of that 17 result, rather than Collective Significance Reports.
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18 So those are the ones that will be coming from third 19 party.
20 I'd also like to touch briefly on the TU Electric 21 Technical Audit Program and the Engineering Functional 22 Evaluations, and I will be talking more about that 23 subsequently this morning.
24 In essence those two scopes combine as an overview 01 1
25 all TV Electric design-related activity. We feel that it's
5 1 more than sufficient to provide a comprehensive documented 2 support for the adequacy of those design-related activities, ;
3 and, in fact, the SRT, as we have indicated before, will be 4 using both of those audit programs as one or two of our l 5 windows, if you will, into that particular area of activity.
l 6 And we'd encourage the staff to do the same, to use them as or 7 audit lever, if you will, in those areas.
! 8 MR. NACE: I Just have --
l 9 MR. GRIMES: Before you begin, I'd like to clarify 10 something that Mr. Beck just said. As I understand what you 11 were telling us, the collective evaluations, the extent to 12 which you have looked into root causes, generic implications
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, 13 and trends related to design activities will be reflected in 14 the Corrective Significance Reports and to a more direct 15 extent in the PSR's.
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16 MR. BECK: The first part of your statement is 17 correct. The second part, the PSR's will contain all the 18 facts and all the data in those 11 areas. ;
19 MR. GRIMES: Will they look at generic implications 20 in the specific disciplines? For example, mechanical: will 21 they address programmatic kinds of findings or Just, we found 22 this particular problem and produced this particular 23 resolution?
24 MR BECK: Yes, a
25 MR. GRIMES: Is the yes to both of those things?
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I 1 MR. BECK: Yes. I should have said yes twice, or l 2 squared.
3 MR. GRIMES: And the Quality of construction issues )i 4 including their generic implications and broad programmatic l
5 findings Hill be in a Corrective Evaluation Report for those 6 000, QA, 0C and testing?
l 7 MR. BECK: Correct. And that will also be viewed 8 once again in the corrective significance. piece.
9 MR. GRIMES: And we'll see that -- I believe the i
10 schedule was late fall; December, January, sometime?
I 11 MR. BECK: The date that was on the screen yesterday 12 for corrective significance, the final third-party document,
, 13 was January. That's our goal.
14 MR GRIMES: Thank you. ,
l 15 MR. NACE: I have three minor clarifications, and 1 16 perhaps it's really only clarification on my part on what you 17 meant by some of your descriptions.
18 Number one, when you talked about the design 19 validation process, I believe you characterized it as your 20 understanding that He're validating everything-on the'0 list
, 21 as the NRC uses the Q list. I think that was your Hord.
22 MR. GRIMES: That's correct.
23 MR. NACE: That should be clarified. If you 24 remember our description of the scope of the CAP in the ansHer i
25 to your May 12th letter, we described it as hundred percent.01
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i 1 the safety-related design With two exceptions, exceptions !
2 being the NSSS and equipment vendor design work, except that 3 the interface Hith the balance of the plant Was being
- 4 validated. So technically, if an item is on the 0 list, for !
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l l 5 example, Westinghouse-supplied, we are not validating the l l
l 6 Westinghouse work, only the interface of the Westinghouse !
7 product With the balance of plant.
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I 8 MR. GRIMES: The point is well taken. We did l l
9 recognize that and understand that. It goes beyond Just 1
10 Westinghouse, though; any accepted vendor --
! 11 MR. NACE: Yes. -
12 MR. GRIMES: -- is qualified with either N stamp or
,~ 13 Whatever other quality assurance Hould be excluded except for 1
14 the interfaces.
1 15 MR. NACE: Yes.
16 The second point of clarification in the upper i 3
17 left-hand corner Hhere you described the project documents, i 18 the Specific Technical Issue Report, STIR. I believe you 19 described it as a nonconformance document, and that is not 20 quite on center. It's a technical document used only With the 21 Stone & Webster corrective action project to communicate 22 technical information solutions back to the third party. And 23 specifically it's really in answer to ISAP issues as opposed
- i 24 to DSAP issues, but it is not a nonconformance document in the 25 sense of criterion 15.
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J 1 MR. GRIMES: The point is taken. I believe thatlI 2 sort of. skipped across it as 1rtument project sends back.to 3 the third-party review. Sim11arl'y, with the Corrective Actior 4 Request, except that it's unfortunate the Corrective Action 5 Request is a criterion 16 kind of document, but that also is 6 used as a vehicle to propose corrective actions to the third 7 party related to 00C findings; is.that correct?
8 MR. NACE: Yes. It's'a very fine distinction perhaps.
l 9 The STIR is used to commit an Action Plan which Hould be 10 something that Hould not Quite pass the threshold of a l 11 criterion 16 program.
12 Given our QA Program in effect, if you Were l
l i 13 addressing a STIR issue that-warranted criterion 16 treatment.
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14 then it Hould also be treated as a CAR. j u
15 And the final minor comment relative to your i 16 . characterization of the DBCP and the RIP on your diagram, we 1
17 do feel that they are part of the same program as opposed to :
I l 18 two separate entities.
19 Alternatively, He understand how you have.to show 20 them separately to make the diagram Hork.
21 MR. GRIMES: Any suggestions you'd like to make_in cl. ,
22 better Hay to capture that, I'd be happy to accept.
23 MR. COUNSIL: We'll attempt to do so next week.
i 24 NoH, for further clarification and to help refresh 25 memories, we Hish to comment on some statements of
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1 yesterday -- and, please, it is in the spirit of total i 2 cooperation. Specifically, that which we wish to comment on, 1
3 is that TU Electric introduced a Reinspection Program, or the 4 HVP, PCHV, whatever acronym you wish, for the first time ;
5 yesterday. Let me point out that the following information, 6 as either docketed information or on the public record througt l
7 transcript of public meetings, has been provided. This is by 8 no means an extensive list. It only went back through 1986.
9 Item 6 in our 6-25-87 response directly discussed the 10 Hardware Validation Program. The reference for the Staff is ;
11 TXX-6500. i 12 In our 4-7-87 public meeting we discussed the
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i 13 Reinspection Program for pice support and the engineering 14 Halkdown for seismic conduit supports, specifically, on pages 15 38, 39, 43 and 44, 16 In the 4-2-87 public meeting the Reinspection Prograni 17 was discussed with respect to pipe supports and also discussec 18 in the Design Basis Consolidation Program and the Design 19 Validation Program in quite depth. Those pages are 36, 37, 20 39, 40, and specifically in 57, 21 And I would also like to comment on the fact that Ms, i
22 Garde commented on those programs, pages 53 through 57, and I l 23 would like to quote on page 57, if I may. !
24 "The other point that I wanted to make is I am i
25 going to leave this meeting under the assumptior!
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1 that the Design Validation Program has become or 3 1
2 is going to be on integrated document Which 3 allows the Utility to have assurance on both-design and construction, and to state that there 4;
5 is no generic implications on -- coming out of
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6 that Design Validation Program that have not
/ been fully resolved and fed back into the 8 program. If that's not the case, I.Hould like l
l 9 to see that clarified, because that's' the 10 understanding that I now liove. Anything that yot 11 found along the Hay is 00H fed into the Design 12 Validation Program. You are going to stand on
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the DVP to give reasonable assurance."
l 14 Now, going on, on 3-13-87 in a public meeting the 15 Reinspection Program for pipe supports-Has. discussed on pages j 16 22, 23, 24.
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17 On 3-12-87 in a public meeting the entirety of the )
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18 Hardware Validation Program was discussed -- correction -- the ;
i 19 Hardware Validation Program was discussed with respect to pipe i i 20 supports on page 12.
21 On 2-1-87 copies of the HVP procedures.for pipe 22 supports were submitted and copies to CASE. That reference is ;
23 TXX-6259, 24 On 12-22-85 the Design Basis Consolidation Program i ,
25 was submitted via reference TXX-6182.
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1 On 10-16-86 He discussed the' Hardware Validation.
2 Program in the corrective action to SDAR86-63 on pipe 3 supports, TXX-6027.
4 On 9-17-86 we discussed the reinspection effort for 5 cable tray hangers via TXX-4987 and our second progress 6 report.
7 On 1-27-86 in Rev 3 to the Program Plan He discussed 8 the As-Built Program for cable tray hangers.
9 As I indicated, this is not an all-inclusive list. I 4 ,
10 can also recall in a public meeting in December standing up 11 and apologizing for a stop Hork because we were incorrectly 12 carrying out our own procedures on the hundred-precent i 13 validation of cable tray hangers, and He subsequently went 14' back and reinspected all.
15 There are many other references in the 1985 time l
16 frame in addition.
17 That ends my -- oh, wait. I do have one more 18 clarification comment. I'm sorry.
19 Yesterday also, very early in the. day, He heard that 20 people didn't understand 00S0 as an acronym. It's an out-of-21 scope observation. The 00S0, if I may, was initiated by the 22 Quality of Construction per Comanche Peak procedure 020 23 entitled Out-of-Scope Observations, copies of which Here 24 provided for the CASE organization in September 1986.
a 25 All 00S0's and all other raw deficiency data coming
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i- 12 1 out of the CPRT Program result in a project NCR. All NCR's 2 have been provided to CASE since February of 1986.
3 MR. GRIMES: Thank you, Mr. Counsil.
4 Mrs. Ellis or Ms. Garde, would you like to present 5 your clarifying remarks and/or additional comments?
6 MS. GARDE: Yes. Apparently, Mr. Counsil, you 7 misunderstood my comments. I acknowledged that it is implicit ~
8 in the past several months, maybe past year, that you were i
[ 9 taking some action under a Hardware Validation Program. I've l 10 read and I'm familiar with the references that you gave. What 11 I said yesterday was that I had never seen a whole program, 12 integrated program, laid out_under the Post Construction
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i 13 Validation Program as you put it on the screen.
14 I also implicitly understood that TU Project was 15 doing something to resolve the deficiencies identified in the 16 CPRT. I said that yesterday.
17 I now understand that the program you put on the 18 screen is that program and that it contains all of these 19 miscellaneous one-page reference, two-page reference, l
20 explanation to a question. My offense was the fact that we 21 come here and see for'the first time the integrated program or i
22 the screen instead of seeing the whole integrated program.
23 I know that you have certain plans for pipe supports, 24 that you have certain plans for large- and small-bore piping, i
25 and I understand implicitly that the Hardware Validation
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l 1 Program was a part of those. What has been presented is kind
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2 of individual efforts -- this we're going to 90 to a hundred 3 percent, this we're going to 90 to a hundred percent -- but ir !
4 terms'of laying it out as the answer, this is TU Project's 5 program, I hand't seen it before. Maybe I missed it. Maybe ] )
6 missed a document, but I don't think any of.the references q 7 that you Just gave said, we put forth the integrated program 8 including the name, including all the procedures, we put it 9 out on the street and said this is what we're going to do, j
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10 until yesterday. That's what I was offended by. I understocc 11 as of 4-2-87 that you had a whole other ball game. That's whs ,
i 12 I put the brakes on our writing the Summary Judgment Motion tc
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1 i 13 Rev 3, because it was clear to me on April 2nd that was j 14 completely irrelevant. And nothing that I have heard since 15 then makes it not irrelevant.
16 But what we have to decide is where to 90 from here.
17 and if the scope of this Post Construction Verification I
18 Program stems out of all the work, the reinspection work, done 19 under Rev 0, 1, 2 and 3, then we may have to do a Summary l 20 Judgment Motion.
21 It's very integrated. You can't look at them one 22 piece or another. You're not -- you don't want the NRC to 23 look at it. CASE can't look at it and make an intelligent 24 decision on the strategy to proceed until we have the full ti 25 program, and I Just saw it for the first time yesterday. ,
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14 1 On the out-of-scope observation, if your 2 representation is that each 00SO, even though I don't have
.3 that 00SO, is in a Deficiency Report or on NCR, which I have 4
received and that I can look on those documents and see as a 5 source document an 00SO, I'll accept your representation, 6 because I think we have gotten all the NCR's. And I 7 appreciate that.
l 8 But I have not seen on 00S0.
9 That's all I want to say. That's my clarification.
I 10 Did you understand my clarification?
11 MR. COUNSIL: Yes.
12 MR. GRIMES: Mrs. Ellis, did you want to make some
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13 comments?
14 MS. ELLIS: Yes, I'd like to make a clarification 15 obout some of the things that were said yesterday afternoon.
16 In particular, I wanted to be very clear as to what Ms. Garde 17 was talking about regarding the Nonconformance Reports and the 18 other items that are used, or have been used in the past, and 19 possibly presently, at the plant for documenting nonconforming 20 conditions, other than Nonconformance Reports.
21 I have a few copies. I didn't have time to run very 22 many, but I do have a few copies for the Utility and for the 23 NRC. So I con give you some of these. They are things which 24 you all have access to, so it's nothing really new. It's jusi
'25 to give you an idea of some of the specific things.
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1 What I'd propose to do, rather than giving this to 2 the court reporter, copies of all of these, I made a listing 3 of them so we con have Just one page attached so everybody 4 Hill know in the record what we've been talking about.
5 And specifically, I Hant to point you to -- briefly, 6 while these are still being handed out, what I have given you 7 are some pages from six different documents; one of them a cal 8 report, and especially pages II-16, II-17, III-6 through 9 III-9, IX-1 through IX-10, cnd then attachments A,'B and C 10 to CASE's 10-30-84 response to the applicant's Motion for 11 Summary Disposition on Design QA.
12 The others are letters, Board notifications, ,
i 13 Inspection Reports and SSER-11. And especially I'd like to 14 call your attention to a portion from SSER-11, pages P-30 and 15 P-31, and on P-31 it states: {
i 16 "The TRT QA/QC Group also noted that !
I 17 approximately 40 different forms and !
18 reports (other than NCR's) Here used for 19 recording deficiencies. Many of these
- 20 forms and reports did not appear to provide 21 information entry into the corrective i
22 action system to prevent problem 1
23 recurrence.~ '
I 24 So I believe Ms. Garde indicated about 18, so l i '
25 apparently there Here more than that.
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i f 1 1 And in the attachments, three attachments, A through 2 C to our 10-30-84 response to the applicant's Motion for 3 Summary Disposition on Design QA, there were three documents, 4 communications reports, from CYGNA to the Utility, and in 5 there they refer to various methodologies which have been usec 6 for design documentation deficiencies, or design deficiencies.
7 And some of the things that we are concerned about and we were 8 talking about yesterday are specifically we know from two of i 9 these documents that according to what CYGNA was told, there 10 were CMC's used, component modification cards, and at the time 11 of one of them, which is 5-3-84, the actual number issued was 12 86,294; 20,300 DCA's, Design Change Authorizations, and
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i 13 DCDDA's -- I'm not sure what that stands for -- have been 14 issued to date.
15 And on attachment C, which is dated 5-15-84, at that 16 time the Utility was estimating that there were in excess of 17 150,000 IR's, or Inspection Reports, which had been issued.
18 So this is the kind of thing that we were talking I 19 about, and I wanted to be real clear with everyone what we l 20 were discussing and what we meant.
21- There is one further clarification I'd like to make. ,
22 I will not get very heavily into the welding issues at this 23 point in time. I would, however, point out that the hearings 1 l
24 that we had were regarding concerns raised by two welders, one f
25 of which was later a quality control. inspector, as well, and i
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17 1 the concerns that Here rcised during those proceedings Here 2 the concerns that those two individuals had. And even then 3 all of their concerns were not allowed to be addressed during 4 the proceedings.
5 In addition, I'd like to point out -- I believe Mr.
6 Counsil mentioned that I was frankly a little surprised to see 7 him talking so authoritatively since he was not on board at 8 the time that happened. I Has, and'I'd like to point out thal 9 he mentioned that there was a Motion for Reconsideration whict 10 He filed, Hhich I assume he was referring to CASE's Motion for l
11 Reconsideration, which was denied. I'd like to point out 12 that'1t's my recollection -- though I haven't had time to
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i 13 research this yet; I'll let you know if I. find out to the 14 contrary -- that the Utility found enough problems so that 15 they filed an appeal with-the Appeal Board regarding some of 1
16 the things said in the Board Order. 'So they were concerned j 17 enough to that extent, that there was enough information in 18 the record Just from those proceedings, they were that .
19 concerned. That also was denied.
20 And He Hill be getting back to some more specific 21 details. As I went through these pages, you'll notice that 22 there are some things that do have to do with Helding, which 23 Mhile I was at it, I Just went ahead and copied it and put t
24 them in, so there is some Helding information in here, 25 One other thing is that in looking through all of the i
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18 I i
1 Helding. concerns, our concerns were based not Just on
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2 information from these two individuals. Through the years we 3 had many welders who spoke with us who were very concerned 4 about the plant. Unfortunately, by the time'we came to )
5 hearings, many of them had moved on, we had lost contact with 6 them. But we have consistently heard about problems with the l 7 welding at the plant. So our concerns stem not Just from the 8 concerns of those two welders but from the continuing concerns 9 that we have heard over the history of the plant, and I wantec l
10 to make that clear, i
11 And I wanted to make Clear the limitations of the 12 hearings that we had.
i 13 MR. GRIMES: Thank you, Mrs. Ellis, 14 MS. ELLIS: One further thing. I think Ms. Garde 15 wanted to mention one thing.
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1 16 MS. GARDE: The only other comment that I wanted to l i
17 make was that there are so many new people here that it's harcl 18 to keep continuity, but the basis of our'getting into the 6
19 harassment and intimidation docket was because it was CASE's 20 contention, and it still is, that there was an atmosphere of 21 harassment and intimidation at the site such that all 22 nonconforming conditions never made it to any deficiency 23 paper; not that the scope of deficiency paper that exists is 24 the scope of everything that was found. And that's one of the t
25 reasons why the comprehensiveness of any Reinspection Program
1 19' 1 is so of interest to us, because we think had we gone forward
' with writing findings on Docket 2 that we would have prevailec 2 i i
3 on our key issue, which was that the atmosphere of harassment 4 and intimidation set up an atmosphere where people didn't 5 write Nonconforming Reports or any other kind of deficiency 6 paper, that they Just kept things to themselves. That's the 7 basis. Now, that has never been briefed. There's never been 8 findings written or conclusions reached, but ultimately when 9 we 90 back to hearings we understand that that issue will be 10 in the final arguments to the Board, and that the record 11 created will be in the final record to the Board.
12 So to the extent that their program now has to l
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, 13 resolve those things, it has to operate on everything that was 14 in the past, not just a narrow scope.
15 Thank you.
16 MR. GRIMES: Thank you, Ms. Garde.
17 I'd like to make a point before we continue with the 18 rest of the presentation. I want both applicant and intervenor 19 to understand that our purpose here is to evaluate a plan by 20 which we're going to evaluate technically what is occurring ir i 21 these programs, what assumptions they make about either 22 existing conditions or the record of the design, as we refer 23 to it the design packages, including the OA/0C inspection l 1
24 documents; the documentation trail by which you're going to.
25 establish that the plant con operate safely. _l
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20 i
1 Irrespective of what issues are eventually litigated 2 or otherwise dealt with by the Board, we have to make our t
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l 3 technical finding. We're looking for what all the pieces of 4 that technical argument there are. And so we'll try to keep j i
l 5 that separate from the litigation process for the purpcse of l 6 our evaluation. l 7 We do understand that CASE has concerns regarding thE l
i 8 er. tent to which Texas Utilities is going to rely on past work l
l 9 or on samples of inspections as opposed to a hundred-percent 10 inspection, and that necessarily has to be c'part of our l
l l 11 e.'aluation about whether or not the Corrective Action Programs ;
12 are sufficiently comprehensive.
, 13 With that, I'd like to go on with the rest of the 14 agenda, and I believe that -- Mr. Co'uns11/ do'you have any '
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15 otheradditionsorclarificationsto(agendaitem2,or'areyot 8 .
16 poing to go directly into agenda item'6? ,
17 MR. COUNSIL: We'regoin.[qNe'ctlyintoagendc/ item
' y' ' 4 18- 6.1, and Mr. Beck Hill present. , ,'
19 '
MR. BECK: Before I respond,'l this l'!nl on the
, j I,.
,, 20 agend7, let me
, :' qualify the n,ature /# this segment of our 21 presentation. The initial phrase of the agenda item, quote, 4
22 basedonCPRTresults,endquote,istpebasisandreasonfor
- 23 the qualification. $ j t., 4
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24'l -
r The collective CPRT resultshregarding the-QA/QC t
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';orogra:rj d5,you heard yesterday,. ,,.arenotinyet-[',( .
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. 1 21 I
1 Consequently, although He expect to publish those results in 2 October, because of this fact and the obvious importance of j 3 not preempting or predicting what the Review Team leader and 4 the Senior Review Team Hill ultimately have to say at the 5 completion of that work, I'm going to talk'about process and 6 some other important collateral items of interest. I will 7 talk about some of the results. They they Hill be labeled 8 tentative. They're labeled. tentative because we haven't 9 published a final document.
10 So with that qualification, let me get right~into the l 11 response.
12 MR. GRIMES: Excuse me, Mr. Beck. I'd like to make i 13 clear that the phrase that we used, " based on CPRT results,"
14 1s intended to indicate that our view is that tha l 15 investigations have found substantial and varied deficiencies, i 16 and that that necessarily raises a question about whether or l 17 not the QA/QC program is being implemented adequately, either i 18 in the past, the present or the future.
I understand, and I:think we'll address 'l 19 MR. BECK:
20 that fully'as I go forward.
l 21 I apologize for the busyness of the slide, We'have 22 handouts so people will have it in' front of them and can read l
I if they're not close enough to see the screen.
23 J 24 First of all, chapter'17 in the FSAR is required to
, d 25 describe in that chapter the Quality Assurance Program in 4 l
22 i i
1
- sufficient detail to allow a determination as to how the l i !
2 requirements of Appendix B will be satisfied. I 3 The level of detail consists of statements regarding 4 the application of Appendix B criteria and NRC-approved I 5 quality assurance standards, are che delineation of 6 organizational elements responsible for implementing various 7 parts of the QA program.
8 Details of the managerial and administrative controls 9 necessary to implement the QA Program are not included, nor l
10 are they required to be included in chapter 17. Such details 11 are the subject matter of the TU Electric Quality Assurance 12 Program documents and policies and procedures.
-7 i 13 Chapter 17 has been modified once to incorporate a 14 CPRT Results Report recommendation. Amendment *1 changed the ,
15 description of the responsibilities of the Djrector of Qualits 16 Assurance, Mr. Streeter, from monitoring the Quality Assurance I 17 Program to auditing the Quality Assurance Program.
18 No other changes to the Quality Assurance Program 19 descript$on contained in chapter 17 have been required as a 20 consequence of Results Reports issued to date. However, t
21 changes have been made since the initiation of CPRT in
, 22 Amendments 55, 56, 57, 59, 60, strike "and 61" and add 62, to l
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23 clarify existing commitments, and to reflect organizational 24 and administrative process changes.
I 25 Let me illustrate the nature of these changes, if I
$ t 23 1 may, and I would like to add that not only are He addressing 2 our view of potential deficiencies in the past. program and, of 3 course, the entirety of the CPRT effort is directed toward I
4 understanding and correcting any deficiencies that may have {
l 5 existed, but also I want to point out that the QA organization 6 that I'm going to get into in some detail today is striving tc 7 be the very best that we can be. We're not satisfied with 8 minimum requirements. And I will illustrate what I mean as He 9 90 forward.
10 First, He have made significant management changes tc i 11 increase the breadth and depth of nuclear experience in all i 12 facets of the Project. We have established a Quality i 13 Assurance Overview Committee, which I will get to in more l 14 detail in a moment, to provide an objective assessment of the 15 adequacy and effectiveness of the QA Program implementation by 16 management above or outside the QA organization.
17 We've established a hierarchy of policy statements i
18 and implementing procedures te consolidate and clarify j 1
19 direction from executive management regarding QA program
)
20 activities.
l 21 We've consolidated quality assurance organizations
- 22 und,er the director of QA to maximize coordination of. audit ancl l 23 surveillance activities and insure uniform implementation of 24 departmental responsibilities.
25 We moved the Dallas-based quality assurance
i 24 1
1 organization to the site to increase awareness of important I l
2 issues and project status, and thereby enhance the audit 3 process. We consolidated design engineering functions under 4 the Vice President of Engineering and Construction, Mr. Nace.
5 We established a quality training group under a qualified and j 6 experienced quality training supervisor. We verified the 7 background credentials, education and experience of all 8 condidates for certification to fully support the. level of 9 capability granted.
10 We improved the quality assurance -- quality i 11 control -- inspector training by upgrading the training 12 program, by using detailed lesson plans for classroom l -
i 13 training, establishing a computerized bank of questions for 14 testing purposes, develop comprehensive and detailed l 15 on-the-Job training task lists, administered practical field 16 examinations which demonstrate a candidate's proficiency in 17 his Job.
18 We've increased the emphasis on certifying qualified 19 inspectors to Level II to increase the inspection 20 effectiveness, 21 We have upgraded quality control inspection- l 22 supervision to provide a higher level in nuclear quality .
J 23 control.
24 The nuclear quality control experience was emphasizeCl ,
a 25 for additions to the quality control staff. l
- o- . .
25 l
1 We upgraded the experience levels in the audit !
- t y' 2 organization to provide additional technical expertise on 3 audit teams, and I'm going to be talking further about that ir 4 the TU Technical Audit Program in a moment.
, 5 he revised administrative procedures applicable to 6 the audit process to strengthen the existing administrative 7 controls.
8 Fa have developed and implemented on overall j 9 surveillance program in the areas of engineering, operations, i
10 inspection, construction and records to complement the audit 11 program.
12 And we have developed a separate vendor compliance !
, 13 group that's responsible for all vendor qualification,
- 14 surveys, surveillance, audit and inspection to provide a consistent approach to vendor activities. I
, 15 L i 16 We've consolidated the Comanche Peak procurement l
L 17 activities at the site to be more responsive to project needs. )
i 18 once again, and to reduce interfaces.
i h 19 We've consolidated several project nonconformance L
l j 20 systems into a single improved nonconformance system, a-j 1 l 21 subject that came up earlier. :
p 22 We have initiated on improved records management t 23 system to consolidate records management responsibilities l ~
I 24 Hithin the QA organization, as well as other places.
li '
25 We've improved the engineering design control l
e . .
26 1 procedures, developed and implemented a detailed engineering 2 interface procedural system which you heard about yesterday.
3 Commenced development of configuration management 4 procedures.
5 And finally, commenced development of an improved set 6 point control program.
7 We have initiated improved engineering calculation 8 control procedures.
l 9 We have changed the responsibility for generating l
10 inspection checklists for the shop / receipt inspection from QA 11 to engineering to provide added assurance that important 12 design attributes are inspected prior to acceptance of i 13 hardware.
14 We have initiated a program to revise procurement 15 specifications to provide additional confidence that procured 16 items meet the design requirements.
17 We've revised erection specifications to be ,
18 consistent with the validated design to better control the l 19 erection processes and specify quality assurance requirements.
8 20 We revised construction and quality control 21 procedures to be consistent with the validated erection specs; 22 We consolidated QA procurement document review withir' 23 quality engineering to assure consistency in application of 01, 24 requirements in procurement documents, e
25 Developed a trending program to analyze data from i
o . .
I 27 l 1 engineering, startup, operations, construction and QA to -
l 2 identify problems and potential problems for prompt i, l I 3 correction.
l 4 We've formed the engineering assurance section withir .
i i
5 the TU Comanche Peak engineering organization to assure that l f
6 engineering activities are performed in accordance with 7 applicable regulatory and quality requirements.
8 We revised a number of procedures dealing with such 9 matters as the inspection and maintenance of seismic ,
10 separation gaps and the installation and inspection of cable 11 butt splices.
12 Finally, we have Joined recently the coordinating i 13 agency for supplier evaluations to strengthen capability in 14 procurement quality assurance.
l l 15 To illustrate the Senior Management Quality Assurance 16 Overview Committee, the purpose, as I indicated earlier, is tc' 17 keep senior management advised of the overall adequacy and i 18 effectiveness of the QA Program. The committee members-are 19 all the vice presidents reporting to the Executive Vice 20 President of Nuclear Engineering and Operations, Mr. Counsil, j 21 as well as the Director of Quality Assurance, in an ex-of ficic 22 capacity.
23 From time to time additional meeting attendees are iri l 24 accordance Hith this list, depending on the issues being If i 25 discussed at the meeting. We have a requirement to have l .
1
)
28 1 meetings at least quarterly; hoHever, they may be Called at
! 2 the reauest of any committee member. In practice of late the 3 meetings are being held on at least a monthly basis, i
4 You have heard hierarchy of documents discussed. To 5 remind you, our Hierarchal Procedure Program started in j l 6 September of 1985, and it starts from the Code of Federal l
7 Regulations and runs all the way down to the detailed t
8 implementing procedures and the operating engineering 9 construction, nuclear engineering, and administrative l
l 10 departments in the company. They're consistent and feed one 11 from the other, 12 If there are any questions with regard to these
, i 13 issues, I'd be happy to --
14 MR. KEPPLER: Let me ask a question about this 15 engineering assurance. This seems to come up with Stone &
16 Webster projects a lot. At TVA they have the engineering 17 assurance group under the quality assurance organization. Is 18 there a reason why you have it in the engineering organization l l 19 here?
)
1 20 MR. BECK: I'd like to usk Mr. Nace, in whose 21 organization the Engineering Assurance Group is located, to 22 respond to that question.
23 MR. NACE: To answer the question, perhaps my i
24 background drives me to the conclusion that you get the better 25 of several worlds by organizing it that Hay. Number one, by
29' 1 putting it within the engineering organization, you enlist 2 total involvement of the engineering organization within the 3 Quality Program. At the some time, you can't make it totally 4 independent because of the Appendix B requirements. So they-5 are subjected to QA overview in the performance of their i
6 activities.
7 In my experience, and that's all it's based on, when 8 you take it outside of the organization, it doesn't work quite 9 as well because of routine organizational behavioral issues.
10 In my history I have always favored putting it inside 11 the engineering organization. That gives you the best of both 12 worlds, i 13 I have a clarifying comment here. On TVA I'm told 14 engineering assurance also reports to the director of t 15 engineering.
l 16 MS. AXELRAD: But on their QA' function they report to 17 the director of QA, with regard to the actual -- although 18 they're placed organizationally within engineering, the l
l 19 engineering group --
20 MR. NACE: Yes. '
l 21 MS. AXELRAD: -- the quality of their QA work, they
- 22 are responsible to the director of QA.
23 MR. NACE: Some here; same here,
, a 24 Now, I caution, the engineering assurance function at ll 25 Comanche Peak is not fully recognized within our QA Program i
L. .
1 l 30 1 yet, i.e., they do not have any independent responsibilities 2 for quality. They are in line assistance to us within 3 engineering for the implementation of QA programs, policies, 4 requirements; however, all of engineering is subject to the
! 5 overview, independent audit of the quality assurance 6 department. Does that help?
,t 7 MR. KEPPLER: I'm not sure.
8 MR. BECK: Let me restate it. Engineering assurance l 9 in the engineering and construction organization has no direct k
! 10 QA function today. It is a new organization and the degree tc- l 11 which that's going to transition with direct GA 12 responsibilities is a matter for the future. It is there,
~
l
, 13 however, and it is in its initial functioning state, j 14 MR. KEPPLER: I assume, though, because you put it as t
15 part of your QA program changes you Here trying to make a 16 point H!th us, and now you're telling me it really isn't a 17 part of your QA program.
18 MR. NACE: No, sir. What we're trying to tel) you is 19 He have an additional effort in place, maybe fledgling to 20 date, growing, to involve the engineering organization in the 21 QA Program H1 thin the topical, if you will, or Hithin chapter 22 17. We don't take credit for it. That's all. It's an 23 additional effort.
24 MR. KEPPLER: I guess I don't know what you mean wheri i
25 you say you don't take credit for it. You're taking credit
l 31 l
1 for it in the sense that you're depicting this as a OA program l
! - i 2 change. Maybe -- I don't want to overmake the point. I took 3 this to be some improvement in your QA Program, and now you're l 9 l 4 telling me it really isn't part of your QA Program.
l l
I 5 MR. BECK: I think it's fair to say that it's l 6 certainly an improvement in the quality of the product, even though it's not an official QA -- I 7
l 8 MR. KEPPLER: I'll accept that statement.
l 9 MR. BECK: Any other questions on 6.1?
10 MR. SCHIERLING: Aside from chapter 17, where else 11 is the program described in more detail?
12 MR. BECK: In all of the QA program procedures,
~
i 13 documents, et cetero, I'll ask Mr. Streeter, Who is the 14 director of the QA Program, to give you more detail 15 MR. STREETER: Two things that I'a like to mention.
16 I want to make it clear in all these changes that we 17 put up here He have called them changes to the Quality 1
18 Assurance Program. We don't mean to indicate by that that 19 it's changes to the Quality Assurance Program as you might be 20 thinking of, not a document. Changes to this Quality 21 Assurance Program means the Quality Assurance Program 22 document, the quality assurance manual, and all the 23 implementing procedures on the site, Hhether it's OA 24 procedures or engineering construction procedures. All of i
25 those mechanisms He have to ensure the quality of the project,
32 1 So when we talk about the engineering assurance 2- organization not being a part of the quality assurance 3 organization, we treat it as any other engineering function.
~
4 They do not audit as some engineering assurance organizations 5 do on other projects and within Stone & Webster. They do not 6 do any pure QA functions. j 7 MR. BECK: Anything else on 6.1?
8 Agenda item 6.2 is to explain the overall Audit 9 Program and interfacing between the various elements (vendor l
10 audit, Texas Utilities Technical Audit Program, the 11 Engineering Functional Evaluation, and the overview quality 12 team).
~
i 13 The overall Audit Program for the investigation phase l
l 14 of CPRT activity is as follows:
l 15 First, I want to make the point unequivocally that 16 the Comanche Peak Response Team. Quality Assurance Program 17 satisfies the appropriate provisions of Appendix .B to 10CFR 18 Part 50, period. The Comanche Peak Response Team principal 19 contractors, Evaluation Research Corporation and TENERA 20 Corporation, conducted audits to verify compliance with the 21 CPRT Quality Assurance Program. Evaluation Research 22 Corporation's quality assurance organization conducted audits 23 in the CPRT program areas of quality of construction, 00C, 24 non-00C, QA/QC Action Plans, and the electrical and testing i
25 action plans. There's a documentation trail, by the way, thai
33 1 covers the NRC's evaluation and SSER 13 subsequent follcH up 2 questions, our responses and the ultimate approval by the NRC 3 staff of our adherence to all the applicable provisions of 4 Appendix B of 10CFR 50 and the implementation of the CPRT 5 program.
6 TENERA Corporation's quality assurance organization 7 conducted audits in the CPRT program areas of Design Adequacy 3 and Civil, Structural and Mechanical Action Plans.
9 The OvervieH Quality Team, 00T, reviewed the conduct 10 of ERC and TENERA audits and determined that the CPRT Quality i
11 Assurance Program Has effectively implemented. Their l 12 determinations Here in'the form of periodic reports that Here
~
l i 13 provided to the SRT and at the same time to Mr. Counsil, all 14 of which are in the records at the site.
15 The overall Audit Program for TV Electric and 16 non-CPRT contractors and vendors.
17 The TU Electric Audit Program and the contractors' 18 audit programs satisfy the requirements of Appendix B of 10CFF; 19 50, 20 TU Electric conducts audits, first, to verify that 21 organizations Horking under the TU Electric Quality Assurance 22 Program are complying with that program.
23 Second, to verify that contractors' and vendors
- 24 Quality Assurance Programs meet the requirements of Appendix L r
25 to 10 CFR 50 and TU Electric procurement documents.
34 l
l l 1 And, third, to verify that organizations working 2 under their own Quality Assurance Program are complying with 3 that program.
4 In turn the contractors and vendors conduct audits tc )
- l 5 verify that work performed under their program is in 6 compliance with it.
7 And finally, the Joint utility management audit is 8 conducted annually to assess the performance of the TU 9 Electric quality assurance department.
10 I have a matrix that illustrates the interactions anc 11 the depth of coverage, depth and breadth of coverage, of the 12 overall Audit Program.
~
. 13 The shaded area, the first four items on the side and 14 the five -- excuse me -- six covered areas, organizations 15 being audited, are part of the investigative phase of CPRT.
16 The rest of the matrix is the corrective action phase of CPRT, 17 I would point out that the Overview Quality Team, the 18 first asterisk, indicates the overview of TENERA and ERC QA 1
t 19 audit activities. That the TU Electric QA program includes l 6
20 vendor compliance, internal audit, and the Technical Audit
\ .
21 Program, i
22 I'd like to speak more directly to the Technical 10 23 Audit Program. I indicated earlier that we're trying to be 24 the best that we Can be, and I would use this as a good 25 example of what I'm talking about. I think it's a model for
35 l
1 the industry.
!' 2 First of all, this Audit Program was developed to l
3 evaluate the adequacy of the technical and programmatic 4 execution of the Corrective Action Program in its entirety. i 5 It's managed by TU Electric QA. The staff includes 6 degreed and experienced full-time engineering specialists, 18
! 7 of them. It includes other auditors, 13. We supplement that l
l 8 full-time staff by engineering specialists, some 30, from 9 a their outside engineering organizations who are or, call 's >
! 10 specific disciplines are needed in the execution of the Audit l 11 Program; and they are essentially at this phase of the 12 corrective action implementation full-time people as well.
i 13 And additionally, supplemented by TU Electric quality 14 engineering and TU Electric engineering assurance personnel, 15 some 10 more people who are close to full-time at this point.
16 The Engineering Functional Evaluation is the effort 17 that is being implemented primarily by Stone & Webster 18 Engineering Corporation, but covering the other architect 19 engineers who are involved in the Corrective Action Program as 20 well. It's an integrated, independent evaluation of the 1
21 Corrective Action Program. It evaluates the effectiveness of 22 the TU Electric corrective and preventive actions. It is a j k
23 vertical in-depth evaluation of portions of systems that have '
24 gone through the corrective action validation process, a test l
25 of the end point.
I
Io .
36 1 The evaluation Hill include electrical, structural 2 and fluid systems and related activities. It extends from 3 licensing commitments at the very top through the chain of 4 design to the utilization of data Hithin the test operations 5 and maintenance organizations. It's conducted by a team of l
6 contractors, senior engineers and specialists who are 7 independent of Comanche Peak activities. They're not involvec 8 in the Corrective Action Program implementation.
f 9 As I said earlier, directed by Stone & Webster 10 Engineering Corporation, Engineering Assurance Division.
11 MR. GRIMES: Excuse me, Mr. Beck, before you leave l 12 that point, to what extent -- What's the scope of the vertica]
,,- 13 in-depth evaluation?
14 MR. BECK: The scoping document has been published, 15 it's available. I don't have it all here in my squash, but 16 it's available on site at any time for your in-depth detailed 17 review.
18 MR. GRIMES: Could you try to characterize it?
19 What I Hant to get to is, this relates very closely to agenda 20 item 7,4, the question about the extent to which you believe 21 that these efforts, particularly the EFE, provides an IDVP, as 22 it's classically referred to on other plants, but particularly 23 the extent to which or the depth of a vertical evaluation.
24 MR. BECK: Let me -- 3 25 MR. GRIMES: And to what extent -- excuse me. And
37 l 1 let me add also, to what extent does it address both design 2 and construction?
3 MR. BECK: Let me back up a step before we 4 specifically answer that question. In my view the Corrective 5 Action Program, the design validation process of all 6 safety-related designs at Comanche ~ Peak, is a one-hundred 7 percent breadth and depth IDVP in and of itself. It's being 8 done-by engineering organizations that had no previous 9 involvement in the design processes at Comanche Peak. The EFE 10 program is frosting on that cake of IDVP, if you Hill. It's c 11 look by another, yet another, independent look at this 12 entirety of the evaluation process.
i 13 MR. GRIMES: If I may -- humor me.
14 MR. BECK: I will try-.
15 MR. GRIMES: Consider that He Hould find the 16 Corrective Action Program architect-engineer functions'to be 17 Just that. They're redesigning, so now I'll consider the 18 Corrective Action Program to be the original design.
19 Now, in addition to that, EFE provides some HindoH 20 into the redesign, validation of the design, as you're going l 21 to request a license for it. To what extent does EFE, What 1 1
22 kind, what size Hindow, do we get into the redesign activity?
23 MR. NACE: The EFE was, in fact, patterned after 24 IDVP's, I guess, that Here covered -- done on some other 4
25 projects; however, more importantly, on Comanche Peak the war i
38 l j
I 1 it has been structured is to serve us as if it were an 2 independent design inspection as well as factoring in the l 3 safety systems functional evaluation aspects in the way that~
4 the NRC sometimes looks at NT0L plants. ]
5 So what they are doing is taking -- doing a typical c )
6 vertical slice, taking a system, giving that system a very 7 thorough going over for those aspects of the integrated desigrl 8 that are not included in that particular system. Typical 9 example: a fluid system very seldom contains cable tray 10 hangers. They look at other pieces of the. design so they. car l 11 say they have done a true vertical slice, as well as done a 12 true in-depth evaluation of this 'one particular system.
~
, 13 In addition, we picked up the industry trend on l
14 safety systems functional evaluation and carried the design I
15 base, the design documentation, all the way through the 16 engineering construction activities into testing. If you 1006 ,
t 17 at the EFE Program Plan, you will see that the final module 18 involves testing. How well is the plant-tested to the design 1 19 Do the test results get factored back into the right part of 11 20 the design for a design confirmation?
21 The EFE also is doing one of the task forces under 22 that safety system functional umbrella, is to take a looK at-23 the development of our procedural system with respect to 24 mission 3 of the Corrective Action Program, the demonstration l
25 that we are developing the programs necessary to maintain this
4
. . )
39 1 plant in accordance with licensing commitments for the 2 lifetime of the plant. 4 3 So it's very much patterned after IDI and safety 4 system structural evaluation. ,
5 MR. GRIMES: Yesterday I made a comment, and I am 6 going to try to repeat it. I want to make sure that the polni 7 is clearly understood because I think it's very important to 8 our planning in terms of what level of detail He need to 1
9 review to for various areas of the activities that you have 10 ongoing. !
11 What I said was that our perception of the 12 Engineering Functional Evaluation was that it has a smaller
~
i 13 scope than typical but greater depth than typical. And by 14 that I mean, would involve fewer numbers of systemt but would 15 go into more detail on the level of analysis, the extent of l 16 as-built work that's been done; as you mentioned, would get 17 into testing, which is not typical. And that is our 18 understanding of EFE. Is that in your view a fair l
19 characterization?
20 MR. NACE: Let me try and see if we're saying the 21 same thing. The design validation process is, in my mind.,.a 22 combination of an across-the-board IDVP on each system, as '
i 23 Hell as then fixing or resolving any issues that have evolved 24 during the review of that system. So the Corrective Action
,i 25 Program or the design validation process is an
^ ^ A ^X^ m A.m n M _.m o AA mama
i 40 i
i 1 across-the-board IDVP of each system, as well as fixing l
l ' 2 anything that was found during that review.
3 The EFE is like -- can be very much likened to an ID1 4 wherein, I think by your own rules, you pick one or two ;
5 systems and then do a very thorough in-depth review of those 6 one or two systems.
7 MR. GRIMES: Mr. Nace, please forgive ma, but the 8 explanation, I think, is confusing the issue more than it's 9 explaining it, because IDI's are what NRC does. IDVP's are 10 What the industry does. I want to separate out the design 11 validation and consider that to be a typical AE function and 12 then look at Hhat assurance beyond that is provided that that li 13 system works. One way to do that is to take a vertical slice, 14 take a system, 90 from front to back Hith another set of 15 folks, pick all the pieces out, see if they fit the 16 requirements, fo11oH the procedures-and meet the design 17 specifications, and on that basis make a Judgment about the 18 design process, in this case the redesign process. Maybe a l 19 simpler way of asking the question is, in EFE how many systems )
l 20 are you -- how many complete systems are you going to revieH?
21 MR. NACE: We're going to review one complete )
22 system, plus other parts of the design, which gives us the 23 breadth coverage of every design interface on the plant.
24 MR. GRIMES: What systam are you going to review?
ls 25 MR. NACE: It's golng to be the containment spray.
I
i
=c. ;
- 41 l l
i l
1 MR. GRIMES: And can you characterize the relcted 2 systems that you're going to review along with that?
3 MR. NACE: I can, but I can't here. They are in the
! 4 Program Plan.
5 MS. AXELRAD: Can you tell us what portions of the l 6 system you're going to look at and what portions of the sy. sten 7 you're'not going to look at? because it says that you're goins l
! 8 to Just look at portions of the corrective validation process.
9 MR. STREETER: The word " systems" in that slide 10 refers to the systems that we're -- the word " systems" as 11 indicated on the slide, the third bullet, refers to the 12 selection of the containment spray system, the structure that i 13 houses that system, the safeguards building, as well as also 14 selecting the heating, ventilation and air conditioning unit 15 of the control room for applicability purposes. So those l 16 three elements, those systems, are.the ones that are the
}'
17 subject of the EFE as it's scoped now.
k 18 MS. AXELRAD: But you're going to'look at all of tho l
i 19 parts of that system as you Just described it.
i I
20 MR. STREETER: Including supporting systems such as l
21 electrical, instrumentation and control--
L 22 MR. COUNSIL: If'I may, I.'d like to introduce Mr. Ed 1 23 Siskin, Vice President of Stone.& Webster Engineering ;
24 Corporation, and would you mind directing your questions to <
i 25 him? EFE does not report to Mr. Siskin; however, he is the f
t - _ _ _ _ _ __ _
l 42 I 1 corporate sponsor for the whole Corrective Action Program, anc 2 I believe he can answer in much more' detail than we presently 3 can today. )
l 4 (A-break Has taken.) I j
5 MR. GRIMES: Can He reconvene the meeting, please? l
(
6 Mr. Siskin, would you explain in your characterization how a 7 vertical evaluation and the EFE relate to an IDVP, or give us 8 some explanation of the scope, the depth, of that review?
9 MR. SISKIN: My view of the evaluation being
]
10 performed on this project is that in breadth as well as in 11 depth it exceeds any IDVP that has been performed to'date. The 12 present scope right now from a manpower standpoint is roughly
, 13 50,000 manhours of very high powered technical talent that has 12 14 been brought together not only from Stone & Webster but from 15 EBASCO and from IMPELL.
l 16 I would characterize it someHhot differently than a 17 single system review. Basically, there are three systems tha1 18 are being addressed on a vertical basis. Those three systems i
l 19 are the containment spray, the safeguards building as a i 20 system, and the control room heating, ventilation and air J 21 conditioning system.
1 22 In addition, in reviewing and putting this program 23 together, He have attempted to address every facet of design l
24 construction and testing that is addressed in a plant so that l
25 each particular area is addressed in multiples and so that He
-- _ . _ --- --- -. . -- i
49 1 are getting from a breadth and from a depth standpoint a 2 complete overall view.
3 The program is being conducted under the direction of 4 our director of engineering assurance, who does not report to l 5 me. He's reporting basically up an entirely separate chain.
6 To a great extent, while I am responsible for Stone & Webster f
7 project -- Stone & Webster work on this project., I have no P interface directly Hith this other than to provide information l 9 or clarification to his effort.
10 We have provided information in detail on this scope, 11 and He would encourage NRC to review that and, in fact, 12 observe the performance of the team in action. I think He Car i i 13 all be proud of the magnitude of this effort and the 14 independence that's being provided.
15 MR. GRIMES: I'll note that He've already visited the 16 offices of Stone & Webster, EBASCO and IMPELL in order to try ;
i 17 to plan an audit of those activities. The purpose of my !
l 18 question was to try to understand the nature of a vertical l 19 slice, and in that regard you mentioned that this evaluation 20 is going to look into construction. Our understanding of how 21 the revieH is done is one that looks more at the paper. Woulcl 22 you characterize how it looks at the construction of the 23 facilities?
24 MR. SISKIN: Clearly the records associated with the i .
25 design process, how they're processed through construction oncI l
__m _m-- _ m m __ __
- l. ..
1 the various documents-that come back, characterize to some 2 extent the construction process. Also, involvement in the l 3 revieH of the testing that's done to confirm the adequacy of 4 construction of the system also addresses the construction.
5 It does not supercede the Quality of Construction Program or 6 anything else, but it is a very detailed -- a vertical slice.
7 MR KEPPLER: Tjoes it include walkdowns? '
8 MR. SISKIN: Yes.
9 MR. GRIMES: Thank you, Mr. Siskin.
10 MR. BECK: If there are no further questions, I have 11 included in your handouts the qualifications and essentially P
12 the experience base of the 00 team members. I won't go
. 13 through each one of those in detail. They're there for 14 completeness, and you con certainly see that these gentlemen i
15 are eminently qualified to perform the function that He. asked I
16 them to do.
17 If there are no further questions, Chris, He'll move 18 on. I i
19 MR. GRIMES: No, He have no further-questions. Woulcl 20 you proceed with the next agenda item, please?
21 MR. COUNSIL: Mr. Nace Hill cover agenda item 7,1. ;
22 MR. NACE: Agenda item 7.1 requested us to give o' 23 perspective on one of our statements made in the answer to Mr.
24 Grimes's letter of May 12 in which we said that the safety 25 significance evaluations performed by the third party played ,
}
l
.I 1 no substantive role in the design area.
2 Now, I think that perhaps that question stems from R 3 two different aspects, or possibly two different aspects, I'm 4 going to discuss next.
5 We think -- first of all, your concern that we might 6 be screening something out because we're not taking this 7 information into effect, we will address that. Possibly, in 8 addition, you're concerned that because of this name, safety 9 significance evaluation, it may be confused with regulations 10 under 10CFR10 50.55(e), and we will address that.
11 We put together this very simplified flow chart for 12 showing how documentation is passed between CPRT and the
,- 13 project. It will also perhaps clarify some information that 14 was discussed earlier in the presentation relative to the 15 alphabet soup, which was described as alphabet soup, of paper t
16 documentation.
17 The CPRT investigatory findings are processed in two 18 paths. The path to the right is as required by Appendix E of 19 the CPRT Program Plan, which processes that paper in.
20 accordance with the Program Plan, 21 In parallel, they're passed to the project for.
22 treatment in accordance with our Appendix-B-QA program. To 23 clarify this, the QOC documentation of Discrepancy Reports, 24 the out.of-scope observations, come to us in the form of 25 Nonconformance Reports. The Results Reports recommendations
-l l
i o---.- n _,- ncn n-- . - . . -- --- -
- 46-1 come to us in the form of Corrective Action Requests.
2 On the design adequacy side the DIR's come to us as 3 an IDR,.and you'll find within our project procedures we have 4 recognized the DIR as a quality document that is individually 5 dispositioned. The IRR itself is treated only as summary-type 6 information from giving us thL ability to summarize several 7 different DIR's under one category.
8 But each and every one of those piece of paper makes 9 its way to the Project, either in a Nonconformance Report, o 10 Corrective Action Request or a DIR by itself.
13 11 On the CPRT Program Plan side, the third-party 12 activity, if you Hill, that documentation goes through the (i - 13 third-party safety significance evaluation. Perhcos in 14 retrospect we Hould prefer to call that something else, but 15 'what this really is is a mechanistic process for evaluating j 16 the deviation and making a decision on the third-party side 01
, 17 where the CPRT investigation should be expanded.
18 So it's really an evaluation for investigatory- I 19 expansion purposes. It goes through a screen to see if there !
20 is a safety significance evaluation'as defined-in the Program 21 Plan. If it is, it results in sample expansion. If it is not
'j
.t 22 safety significant in itself, it'does 90 through an adverse- !
23 unclassified trending evaluation, which either resultsLin.no 24 further action or an expansion of CPRT investigations.
25 Recommendations to the project come out of this
~
l 47 1
1 block, so He feel in our interface between the third party anc l
I,-
2 the project we have the best of both worlds. We get the rah l
r 3 data Hhich we're obligea to treat in accordance with our I 4 Appendix B program, in addition to getting recommendations of 5 the third-party deliberations.
6 As I said the safety significance evaluations are 7 performed solely for the purpose of conservatively evaluating 8 the findings and'to assess the need for expanding the 9 investigatory effort on the third-party side, performed in 10 accordance With CPRT Program Plan requirements and has no 11 direct relationship.to 10CFR 50.55(e), even though the name 12 might suggest otherwise.
l
,~ 13 The safety significance evaluations, I Hould Caution, 14 are performed on the quality of construction portion of CPRT.
15 Safety significance evaluations are not performed on findings 16 in the Design Adequacy Program themselves, primarily because 17 of our commitment to take extensive corrective action in the 18 design area.
19 Our rationale for not using the results of the safet) 20 significance evaluations in the TU Electric QA Program is, !
1 21 one, recognizing what the intent of that safety significance 22 evaluation was in the first place, 23 In the second place, regardless of the genesis of the l
24 third-party finding, it is evaluated on the project in 25 accordance with our QA Program. It is dispositioned, it.1s 2 s
~
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e
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,1 I; individually disdopitioned, evolucte0/9r determinationCof, l '
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12 ' a corrective and preventive acti'n, o evaluated for deportability r
i , s 3 under 19CFR 50.55(e), and evaluated for inclusion in the' Post
! ) ,
4 Construction Hardware Validation Program, >
A 3
5 As I pointed out yesterday, trit.) recommendations that I
) '3 l 6 come out of 000 also get factored intcivost construction i 97 pardware validation. ,
8 e
'Aryyquestionsi c
9 c,'
MNl. GRIMES: Thank you, Mr. Nace. l l$ 3 10 I would like to ask at this point that in order to
/ H try to make sbre that H4)have wf ficient time to caucus, coult s s
$2 youtellmehowlong,yokJexpectthenextthreeitemsHilltakt
(,- 13 in your presentation?
i l 14 1MR. COUNSIL: We are only going to present item 7.2 15 and 7.3, He believe, although He may summarize later item 7.4 16, p in that item 7.4 was covered in item 5.1. So He're going to
/f
- 17 irererit formally item 7.2, 7.3, af ter or during the caucus anc l i
?8 " He'll -- He Hill see if we have anything more to add in 19 clarification of item 5.1 which could encompass 7.4.
20 MR. GRIMES: And how long do you expect 7.2 and 7.3 21 Hill take? I l 22 1R. BECK: 7.2, if I talk fast, is probably no more 1
23 than five minutes, but it depends on your questions. i i
24 MR. NACE: Fifteen minutes on 7.3.
- i 25 MR. GRIMES
- Would you proceed, Mr. Beck?
i l _ ---- )
a c -
49 1 MR. BECK: Agenda item 7.2 is TV Electric to explain 2 the procedure to assure that 00C sample expansions address all 3 relevant attributes, i.e., adequacy of root cause evaluation 4 vis-a-vis safety significance.
t
! 5 Let me go through the flow chart of how we evaluate 6 findings in the 00C program.
7 , Step number one is to do the sample inspection, and 8 if it produces a deviation, that deviation is then evaluated 9 for safety significance in accordance with the Program Plan 10 and the trend analysis is also done at that step.
11 It results either in a construction deficiency, an 12 adverse trend or an unclassified trend or a finding of no t i 13 safety significance.
14 In any event, os Larry Just pointed out, each one of l
15 these deviations 90 to the Project for evaluation in 16 accordance with all of our QA requirements on the project sidt 17 of the house. This is strictly third-party evaluation process 18 on this chart.
19 Step number three, a root cause evaluation is done i 20 Hhich Will lead, in some cases, to a corrective action for the
- 21 attribute in which the deficiency, adverse or unclassified 22 trend has been identified.
23 The next step is to exoand the corrective action to
)
24 other attributes by virtue of generic implications if, in 25 fact, it's applicable on on intrapopulation basis: in other l
= _ _
1 o
- j 1
1 50 l
1 Hords, Hithin the population from which the initial deviation l
j' 2 emerged.
3 Step number five is to do an interpopulation generic l 4 implication analysis, so we need to expand the corrective 5 action to other populations.
6 Steps four and five I'll get into in a little more 7 detail on the next slide --
14 8 MR. GRIMES: Before you get into four and five, I'd 9 like to ask a quick question on step three. If a deviation is 10 found not to be safety significant, do you do a root cause 11 evaluation?
12 MR. BECK: No,
~
i 13 MR. GRIMES: If the safety significance evaluation is 14 deficient, then you would miss an expansion on the population 1 15 MR BECK: That is a possibility. I would add, 16 hoHever, that each , deviation, as I sold, goes to the project 17 where it goes through the normal QA evaluation process. We l 18 really have a double check on all of them, One within the 19 third-party evaluation and one on the project side in 20 accordance with all of our QA requirements. The likelihood, 21 in my opinion, is very small that we would have a safety 22 significance deficiency missed in that process.
23 In more detail with regard to evaluation of findings, l 24 first, the sample data are collected for safety-related i
25 attributes in 32 populations. Those populations have anywhere
)\
k__._________ ._
u 51 !
i 1 from 5 to 25 attributes and 60 samples of each attribute are
~
l l 2 drawn. That's an important point, to get the size of the l
3 sample.
4 Second, each deviation is analyzed for safety 5 significance. The deficiencies are identified, the trend 6 analysis identified as adverse or unclassified trends.
7 And third, the root cause analysis determines the 8 reason for the deficient attribute in the population or the ,
l 9 stratum that's being looked at. Corrective action is 10 recommended for that attribute.
11 Fourth, for each root cause generic implications for 12 other attributes of the population are considered and j
13 corrective action is expanded as appropriate if the 14 implication does exist.
15 And fifth, the implications to other populations are 16 considered in the original assessment if sufficient 17 information is avc11able or is performed in the collective 18 evaluation phase where further assessment is required. I i
19 This is a summary of findings from the VIII.c j 20 program. We found 19 construction deficiencies, 11 adverse 21 trends and 19 unclassified trends, for a total of 49. The 22 corrective action recommendations, depending on how you count, 23 is somewhere in the 84 to 87 range. In some cases where it's 24 a matter of procedures and/or training, you count it as one or
~
25 two. That's why I'm being uncertain there.
52 1
1- Nonetheless, all these findings have been )
2 communicated to the project, and there is agreement between 3 the project and the third party on the corrective actions to' 4 be taken. l l
5 This report, since I'm Quoting numbers, I'd like to 6 put a tentative on that. The collective evaluation is not 7 finished yet. That could Hell lead to some additional 8 findings. So this should have a big asterisk on it. We're l 9 not finished. Until the collective evaluation is done, VII..c 10 is truly not in a publishable form. We anticipate having that-i 11 process brought to completion'in October .
12 Let me give an example, a couple of them. Populatior, I
, 13 of structural steel He made a finding that there was a 14 construction deficiency for lack of Jam nuts. Notice'the 15 asterisks and the tentative nature. Failure -- the root cause 16 is identified as a failure to backfit previously installed 17 structures.
18 The generic implication is that other changes to l
19 structural steel specs may not have been evaluated for j 20 backfit, and the recommendation accepted by the project was to .
l l 21 establish a program to review all structural steel design 22 change documents to determine which requirements, if any, have 23 not been implemented and to take Hhatever action is 24 appropriate once that review has been done. i
!I 25 Another example: In the area of cables the finding 1
' O I
. i 53 1 was that there was an adverse trend for slack less than
' i 2 specified minimum. There was a minimum requirement for slack 3 in the cable trays that cables came out. And although the 4 specific issue where a violation of that minimum requirement 5 was evaluated as not safety significant, the question was : l 1
6 raised that perhaps elsewhere it could be. And therefore it 7 became on adverse trend.
8 The root causes was a lack of clarity determined in 9 the specification. The generic implication was fo'r all other i
i 10 cable attributes, and the recommendation was to review the 11 erection specifications and procedures and take whatever j 12 corrective action is necessary as a result of that review, i
)
, 13 That finishes the presentation for 7.2, subject to 14 questions.
15 MR. LYONS: On the recommendations -- are there 16 any -- implementation on the recommendations: Are they 17 documented in the PSR's? Where Hill they be documented?
18 MR. BECK: In every instance that's the case.
I 19 MR. LYONS: Okay.
20 MR. GRIMES: Mr. Beck, Hould you like to 90 on noH 10 21 agenda item 7.3.
22 MR. BECK: We certainly do, and Mr. Nace is going to 23 pick that one up.
24 MR. NACE: Agendo item 7.3 requested an explanation 25 of the potential for commitment changes during the Corrective
54 1 Action Program efforts and the approval process of those 2 changes.
3 We've broken the presentation into three parts to 4 fully address the question.
5 The first part is to give you some additional 6 information on what we have developed and are implementing on 7 the project, a commitment tracking system and how that aids 8 the design validation process.
9 We'll talk about the FSAR change processing in 10 accordance with our procedures. and also give you an assessmen1.
15 11 of the potential for changes coming out of the Corrective 12 Action Program.
We have
, 13 First, on the commitment tracking system.
14 started to develop, and the activity has been under way now 15 for nearly a year, a system of capturing the licensing 16 commitments from the FSAR licensing correspondence and 17 transcripts from such things as ASLB and public meetings and l
18 to be able to track each commitment to closure.
19 With this tracking program we can correlate, Just for 20 management purposes, management of the information, correlate 21 the commitnients to systems, structures, programs and 22 discipline design basis documents. That's Just a mechanistic 23 process for assuring ourselves that an individual commitment 24 is translated to the right group that needs to be cognizant 01 25 that commitment and ultimately gets into the appropriate
__J
, .o ,
55 1 design basis document.
2 Design documents then, including the design basis 3 document, are also correlated, as you know, by Design 4 Validation Packages.
5 The design validation process ensures that'the desigr 6 documents contained in the Design Validation. Package implement 7 commitments contained in the design basis document itself, J
8 which came from the parent commitment. tracking list.
l 9 Post construction hardware validation assures that '
10 the hardware meets the validated design requirements and 11 therefore commitments.
12 With respect to how we process FSAR changes
,- 13 themselves, I think first He need to address ourselves to'the '
14 types of FSAR changes which the industry encounters and which 15 He have encountered in the past and in the future Hill 16 encounter. It can be broken down into editorial, typos; 17 updates to reflect current as-built,. drawing, programmatic and 18 factual information; a correction of errors or. inconsistencies 19 between different sections of'the FSAR; and a clarification 01 20 text, which coulf be misinterpreted. There is also a 21 potential revision category.
22 MR. SCHIERLING: What do you mean by " revision 23 category"?
24 MR. NACE: Revision category Hould be what we would 25 call a substantive change.
56 L
1 With respect to nonsubstantive changes, we do have a 2 procedure in place, Bill Council's NE0 4.03. Basically, the 3 process involves, from your standpoint, two transmittals to 4 the NRC which 90 out approximately the same day. The first 5 contains an affidavit, instructions and amended pages, the l
L 6 traditional transmittal. And the second is a page-to-page 1
7 description of change, the type of change and Justification of 8 the change. Both of those transmittals, by the way, do go on 9 the service list.
10 I think the real question in your agenda item was to 11 assess the potential for changes coming out of the Corrective l
12 Action Program.
~
, 13 At this point in time He have substantially completec 14 design revieH aspect of the design validation process and, in 15 fact, expect the basic validation process itself to be drawint 16 to a conclusion in the early fall time frame.
17 Based on information we have to date, He do not 18 anticipate any of the revision-type FSAR's. However, as 19 you're nHare, He are routinely submitting FSAR submittals
, 20 which involve the editorial, correctinn, update and 21 clarification -- or clarification-type changes.
22 We feel these changes are normal and are to be 23 expected and they're consistent with the Staff's drive to make 24 the FSAR a living document.
I 25 Not requested in your -- directly in your agendo item L__________________
-. i.
58 1 MS. GARDE:
Well, before too far_from item 7.2 and 2 7.3, I had a-few brief comments.
3 MR. GRIMES: All right. Just a minute. Let me Hork 4 out the logistics and I will let you make your comments, j 1
What I'd look to suggest is that He're going to 1 5
6 caucus before we make Mr. Schierling present NRC explanations.
7 our understanding of the status of pending licensing actions.
8 We Hill put that off so He can ensure that He get through the l 16 caucus and provide you Hith our comments or get'any additional 9
10 Questions that He require before He have to end the meeting. 4 11 And so first I will offer Ms. Garde two minutes to i
12 comment on agenda item 7, and then He will break for the NRC
,- 13 staff caucus.
14 MS. GARDE: On agendo item 7.2, in the examples that l
I 15 Here given coming out of the VII.c,.I would like to point out 16 that in both of the examples given that CASE has some l 17 questions on how the root cause and generic implication and ,
18 recommendation actually do what it claims that it's doing, ancI 19 I want to give this example.
i 20 In the first example on structural steel, the generic l
21 implication is that other changes to structural steel 22 specification may not have been evaluated for backfit. Just 23 on the face of this document, I don't understand'Hhy the root 24 cause Hould not lead to a generic implication regarding 25 structures other than structural steel. Now, maybe in the l
- p. 4 i
i __. 59
/
1 documentation that supports this you have analyzed c Hay why-2 that problem would not apply to everything else, but it seems 3 that the genaric implication and recommendation are much 4 narrower than I would expect when I saw VII.c to deal Hith 5 that problem, 6 And that goes to the cables also.
7 The other thing that seems to be missing in this-8 chart but may be in VII.c'is an analysis of why TU originally 9 denied or didn't find the problem. In other Hords, once the 10 problem was brought to TV's attention and it was originally.
11 dispositioned, why was that original disposition in error?
12 Because I know for the cable problem that that has come up
,- 13 before, and TU's position was that it was not a~ problem. I 14 hope that He Hill see what broke down in the analysis of that 15 problem the first time.
16 In the types of FSAR changes that Here discussed in 17 7.3, the two categories, correction errors and clarification, 18 clarify text which could be misinterpreted, seem to me to be' l 19 huge loopholes which allow for substantive changes which, as ]
l 20 understand it, you think substantive changes ~only is 21 revisions; and I would hope-that there is a procedure or a j 22 methodology by which it's audit 1ble, that there was a :
23 determination made that a correction, or if a clarification, ;
24 was not a substantive change and did not result in substantive 25 discrepancies. That is referenced here. That would be my i
I -__
I 60 1 concern on that point.
!' 2 I have one other comment.
Do you want me to do that
! 3 as a general matter or Just wait?
l l 4 MR. GRIMES:
Why don't you go ahead since you already l 5 have the microphone?
6 MS. GARDE: The only other comment that I have, 7
although Mrs. Ellis and I intend to put stuff in writing B
following this, is going back to the agenda item 5.1 yesterdas 1
9 when we talked about the reinspection required. For point of 10 clarification, I'm looking at slide 5.1-50.
11 l It seems to me that the number of N's in that i 12 category is an extremely critical piece of information that HE
- ,- 13 would request TU put in the public arena in some way very 1
1h quickly, even if it isn't absolutely complete, because if {
15 we're dealing with a very small number -- I think you used thE 16 number 20 percent -- we may be able to look at that 20 percent 17 as a real point of contention or not point of contention basec:
18 on how big it is and what they are. And so as soon as I 19 possible I would request that TU turn over to the NRC or 20 docket more specific information on what is not beir' 21 reinspected and the procedures by which the reinspection are 22 being done or the determination is being made.
23 MR. COUNSIL: As a point of clarification, is that 24 page 5.1, not 5.0?
25 MS. GARDE: 5.1-50. I Just am referring to that in
- . 61 l
1 terms of what I'm speaking. There's no --
2 MR. NACE: There's no N's --
l 3 MS. GARDE: -- N's on that page.
4 MR. NACE: That's correct. There are no N's on'that l
5 page.
6 MS. GARDE: I know.
7 MR. GRIMES: Thank you, Ms. Garde. We'll take a 8 break now and the Staff will 90 caucus.
9 MR. COUNSIL: If I may suggest, could that caucus be 10 approximately an hour and a half in case He Hish to Comment
! 11 either further on 5.1 and/or 7.4 prior to Staff comment? I I
12 would like to be able to get together with my. staff.
,- 13 MR. GRIMES: Just a' moment. Mr. Counsil, in order l 14 for members of the Staff who have flightcconnections to moke 15 this afternoon be appropriately involved, He Would like to 16 suggest a 45-minute break for the caucus. We'll continue the 17 meeting with smaller staff thereafter.if you Want to take 18 another break and develop your comments more fully.
19 MR. COUNSIL: I don't think that is going to give us 20 enough time to reevaluate the entirety of this proceeding, I .;
i 21 respectfully submit or request that we be given at least one 22 point five hours to get together and talk this over prior to ,
23 the. Staff making their final comments, or. closing comments.
24 MR. GRIMES: Under the circumstances we'll take the i
25 information. and we may not be able to make closing comments.
i
- =
62 1 We'll simply 90 back and complete our evaluation Hith it.
2 We'll reconvene this meeting then at 1:30.
3 MR. COUNSIL: Thank you.
l 4 (A break Has taken.)
l 17 L
5 MR. GRIMES: Mr. Counsil, are you ready to begin?
6 MR. COUNSIL: I am.
! / MR. GRIMES: Mr. Keppler and Ms. Axelrad had to' 8 depart to make their flights back to Washington. We Hill 9 continue in their absence. I'd like to suggest that He Hill 10 start by having Mr. Schier11ng present his explanation of the 11 status of licensing act.1vities. I Hill then ask Hhether or 12 not Texas Utilities or intervenor Hont to make any additional i 13 comments and then I'll make closing remarks on behalf of the 14 Staff.
15 Mr. Schierling?
16 MR. SCHIERLING: I think it was item number 11 in 17 our letter to you in May that He requested additional 18 information specifically regarding hoH What He'd like to refer 19 to as routine licensing items, hoH they interface with your 20 CPRT. You provided two tables-in your. response, and the firs 1 21 table identifies about 23-items for Hhich the NRC'has the 22 action, and the other table'is 32 items where He are expectin0 23 additional information from TU Electric. HoHever, I think 24 there's a lot of overlap as to Hho has the action on specific i
25 items.
63 1
l l 1 I Hant to mention that all of the items are in our !
2 internal tracking system, and on many of these items action is 1
3 ongoing. As you also knoH that on a number ~of occasions-we 4 have discussed With your licensing staffuon what the specific 5 status is on those items. The last one we had, I think, was 6 last week with Mr. Woodlan of your staff.
7 I think in general we have a very good understan'ing d
8 and concur with your characterization on what action has to be 9 taken and what the status is, specifically, to the tHo tables 10 that are provided in your response. We believe there are a 11 few items that were not included, and maybe you briefly-want 12 to address those.
~
13 The first one is the ISI Program for both Unit 1 and l
14 2, where action should be ongoing at this time.
15 Secondly, I think it is in SSER 12 He identified as l
16 an outstanding number 25 the need or the addition for 17 additional solid Haste storage capacity for Unit 2.
18 And a third item is in SSER 12 -- it's identified as l 19 outstanding item number 30E, more specifically -- the need for 1
20 detailed control room design review.
f 21 Those are additional items Hhere we think action is 22 required and then on a closecut at this tine.
23 Could you address those or -- l 24 MR. BECK: Mr. Don Woodlan Hill speak tu that.
i !
25 -MR. WOODLAN: Mr. Schierling, let me'take those in i
a 4 4 65 f 1 it on our tracking list as an item that He are actively l _
2 pursuing. We did not revieH this as an issue that needed to l 3 be resolved for the licensing of Unit 1. We do recognize that 4 it's important to have this resolved in ample time to perform
- 5 the first ISI, which is required approximately the first 6 refueling outage, and He are scheduling our work to ensure 7 that He get you the information and there's ample time for 8 review before the first ISI program testing is required.
9 MR. SCHIERLING: Okay. If there's anyone on the 10 Staff Hho Hunted to comment on any of the discus 1.on ongoing, 11 please do so.
12 Also, looking through your table, both of your tables
~
13 that you presented, in only four cases did you identify an 14 interface betHeen the specific licensing item and the CPRT.
I' 15 We intended the question to be broader than strictly related 16 to the CPRT. We envisioned it to cover the Corrective Action 17 Program and all its ancillary activities. And in that light j 18 He believe that there are a number of other items that do 19 indeed -- specific licensing items -- that do indeed interface 20 with that activity. And the reason I want to point that out 21 is because while we are pursuing specific licensing items, it 22 is important that He interface them Hith the broader scope of 23 the Corrective Action Program and have a consistent approach, 18 24 He for the Staff as Hell as you, the applicant for the 1
25 facility.
- 66 1 In going through the list I identified six'additiona) l _
2 items that quite clearly do interface with Corrective Action 3 Program activity and probably more than that. I-Just want to 4 point those out. They are the mild. environment and 5 environmental qualification, for which a GIR is to be issued-6 and also a PSR; mechanical equipment qualification; the final 7 protection and safe shutdown; the EQ update and status.
8 And if you want to, I can give you numbers the way I numbered 9 your items on your two lists. They are in numerical order 10 number -- mild environment is number 3; mechanical equipment 11 is number 10; fire protection, number 26; equipment, 12 qualification update and status is your item number 27; then 1 i 13 have seismic and dynamic qualification status, number 32; and 14 finally, main steam line break outside containment, which is L
15 number 34. I Just listed your table numerically.
16 We believe all those items do show clear interfaces 17 with the Corrective Action Program, and'I Just H. ant to note 18 that, and if you have any disagreement with that--
19 MR. WOODLAN: No. With your broader definition of L 20 interface, we agree with that.
j 21 MR. SCHIERLING: Finally, I would like to discuss 22 briefly the status of a number of priority items, priority 23 items as for as TU Electric is concerned. And, Mr. Woodlan, 24 those are the eight items that you recently identified to us.
I 25 However, I think at this time the item of highest priority is ,
67 1 the -- as far as you and the Staff are concerned -- is the 2 extension of the Unit 2 construction permit Hhich, as you 3 know, has an expiration date of August 1, 1987; however, you 4 requested an extension, I think it was in late April or early l
5 May, and, of course, in accordance with the regulation, that 6 license is now active until the Staff takes the proper action. i 7 I would like to mention that during our review, as 8 you know, He raised an issue regarding ground Hater withdrawa]
9 at the site, Which is a license condition, and He are 10 currently evaluating if that license condition needs any 11 change -- has to be changed or not. While the license 12 condition does read that the ground Hater -- that a ground l l
, 13 Water withdrawal rate of 40 GPM applies during the 14 construction period of the plant, that evaluation was based or.
l 15 a Staff evaluation for a construction permit expiration of 16 August 1, 1987. I think it was at that time five years. i 17 So we are currently, at this time, revisiting that 18 issue and determining if indeed that license condition has to 19 be changed or not. You provided us with additional 20 information Hhich He are at this time reviewing and 21 evaluating.
22 Regarding the eight items that you identified to us 23 as priority items, I would like to briefly give you our status 24 on those items, and on many of these the staff interaction 25 Hith you will take place in the near future on a smaller scalo
j a
- 68 l
1 in public meetings but probably not of this magnitude.
2 The first item is one that you brought up yesterday, 3 technical specifications. As you know, the Staff sent to you 4 in 1984 What Has then the final draft of the tech specs which 5 were Just about ready to be issued in anticipation of issuance 6 of a license. It is our understcoding that you are currently 7 revieHing those tech specs in light of changes to the plant, 8 both in physical as Hell as plant procedures are concerned.
9 and also taking into consideration more recently issue 10 technical specifications td other facilities.
11 As you know, the Staff is preparing What we refer to 12 as a desk copy of standard tech specs for Westinghouse plans,
~
i . 13 and that's based on Westinghouse Revision 5 standard tech le specs. We had expected to provide a Copy to you for some 15 weeks noH, but unfortunately, He are not quite there yet.
16 HoHever, He have initiated our review of the tech specs by --
17 as you are aHare, He asked you to provide a complete updated 18 set of FSAR's to our accountants Hho are assisting us in the 1
19 revieH of tech specs, and they have initiated that revieH.
20 I think the question before us now is, to what exteni !
21 can the draft tech specs of 1984 be updated by you and 22 reviewed by the Staff to reflect the current plant? Or to 23 Hhat extent should He use the standard tech specs that are 24 shortly coming out?
25 To fully address that issue and evaluate which optior t
t 7
j l
69 I i
1 l
1 is most feasible both to you and to us, He propose to meet l 2 Hith you next week in Washington to discuss the options that l 1
3 are open. So He are proposing to meet with you next week in I !
4 Washington to look at the two options that I can see right 5 now.
6 MR. WOODLAN: We accept your proposal.
7 MR. SCHIERLING: I do note, however, though, that I 8 think your schedule that you laid out yesterday indicated a l 9 final tech spec approval by, I think it Has, February 1988.
10 As I mentioned yesterday, the tech soecs Hill be issued Hith i 19 l 11 the license, and that Hill be the final approved set of tech j l
12 specs,
, 13 Prior to including them into the license, they Hill 14 be sent to you for verification so there is some iteration l
15 involved that recuires some time, and I imagine that all this l
l 16 activity you envision to be past February 1988; but 17 nevertheless, He are looking at a ver./ tight stiledule to 18 review the tech specs regardless of which option He Hould 19 take.
20 For occkground information, normally for a new plant 21 that comes in the Staff provides the applicants With a set of 27 tech specs and then various iterations do take place, and the 23 entire process normally takes something on the order of 50 24 Heeks, or Close to a year. We Hill make every effort to do il 25 faster, if necessary, but He Hant to make sure He do a
70' ]
l
-i 1 thorough lob and also arrive at a set of tech-specs that will
[. 2 nut require shortly after their issuance a number of l 3 amendments because something does not fit your needs and you 4 want to take this table out or take that table out.
5 Hopefully, all this Hill be done prior to issuance of the 6 technical specifications.
7 Do you have any comments on that?
8 MR. WOODLAN: We agree With what you're proposing.
9 It's worth mentioning that we are in the midst of the detailec 10 revie Really, every group within the nuclear organization 11 of TU Electric is evaluating the tech specs. We're anxious tc 12 see the new proposed draft, although He do expect that it wil]
. 13 be very similar to the more recent tech specs that have been l 14 issued for the operating plant, which we are using in our 15 evaluation.
16 MR. SCHIERLING: I hope so, too.
17 The second item is your item number 18, TDI diesel 18 generators. The Staff did issue about a year ago a generic 19 Safety Evaluation Report on Trans American diesel generators 20 to you, to which you responded in February of this year, The 1
21 Staff has not completed its review of your detailed responses, t
! ,22 but it is one of our priority items and we will follow up on I I
23 that and keep you abreast of our schedule. I i
29 The third item is arbitrary. pipe breaks, which has 25 been discussed in -- I forget which was the last SER-where we l
o 71 i 1 discussed it, but you recently -- the Staff recently issued a 2'. generic letter-on that issue,-generic' letter 8711, which 3 provides.some relaxation of the branch technical position.
4 The Staff also just prior to issuance of that letter, we were 5 very close to completingLour review of your responses on that 6 subject, and recently you submitted to us, I think it was 7 about -- it was about two weeks ago.-- you informed us that 8 you are invoking -- that you are applying the relief that was 9 granted in generic letter 8711 and therefore have suspended 10 your activities on that subject.
11 The Staff 1s currently revisiting that issue to see 12 if and to what extent generic letter 8711 can be applied to
~
i 13 Comanche Peak, and hopefully we will let you know within the.
14 next couple of weeks to what extent that is acceptable, and 15 then, if necessary, schedule a meeting with you to resolve the 16 issue.
17 Another item that was on your list yesterday was fire 18 protection, and we agree with you that indeed the Comanche 19 Peak branch technical position 9.5-1 does apply. We' also 20 agree with your description of the Staff audits that were done 21 in 1984 and the last documentation in SSER 12.
22 As you know, the Staff'recently was at the site to l
23 perform a scoping-type audit to determine exactly what.
1 i
24 additional work has to be done on this subject, what kind of.0 j i
25 follow-up inspection is necessary, And we are currently' l
I 1
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . - _ _ _ _ _ . - _ . - _ . _ _ - - -- - - - I
a -
72 1 forming a team to perform that inspection, and although not 2 firmly decided, we believe that we will perform that 3 inspection in the fall of'this year.
4 Again, we have had interaction on that subject.
- 5. The one thing that we-are looking at is to take into 6 consideration changes that have been made since SSER 12'was 7 issued, what items have been resolved, and also take into 8 consideration all changes you have made to-the FSAR and 9 amendments in the area of fire protection. All of that'will' 10 be factored into our reinspection effort,'and as I mentioned i
~
11 earlier, probably hopefully by the fall of this year we'will 12 perform that inspection,
~
i 13 Any comments?
14 MR. WOODLAN: No. We agree with your assessment.
15 MR. SCHIERLING: A more~ complicated matter is the i
16 matter of equipment qualification. As I pointed out to you, I 17 both on your list as well as our internal tracking list, there 18 are a number of specific licensing items that do refer to the 19 overall scope of equipment qualification. In your list there 20 are four items: the mild environment and the environmental 21 qualification, mechanical equipment qualification, equipment 22 qualification update, and main steamline break outside-l 23 containment.
( !
F 24 All of these do interface with the Corrective Action {
25 Program, and as a matter of fact, one of the Corrective Actior i
- h. .-
i 73 l
1 Program activities is equipment qualification. So this is onc 2 area where He clearly want to make sure that these specific 3 items -- and maybe there are others -- are appropriately 20 1 4 f actored into and addressed in your equipment qualification -- !
5 in your scope of the equipment qualification as defined under-6 the Corrective Action Program, which is, I think -- the object -
7 of which is to demonstrate compliance with your commitments 8 and NRC requirements and also to develop a mechanism to 9 maintain that compliance throughout the life of the plant.
l 10 So we want to make sure that all aspects that do 11 relate to equipment qualification are addressed in your ,
1 .l l 12 effort, and He have already initiated on effort to see hoH f
13 indeed that interface betHeen the specific licensing action .
i 14 and the Corrective Action Program, how that is taken care of, j 15 and that indeed these concerns are addressed.
16 The equipment qualification of mechanical equipment.
17 for example, the Staff has been reviewing that, and He are l
18 near conclusion, but now in light of the Corrective Action l 19 Program He Hill revisit that partiCular item.
! 20 Earlier this year, and I think that is as far as He 21 can see and Where He do OHe you a rather quick response, is a 22 response to submittal by you of March of this year regarding a 23 definition of harsh versus mild environment and how it can be 24 applied, because it is an input to your Corrective Action 25 Program activity on equipment qualification.
l I
74 1 to that is one of our'high priority items to support 2 your efforts. I also envision that as a result -- or once He 3 have determined what the scope of the entire equipment 4 qualification matter does involve, He Will get in touch, He 5 Hill coordinate'this effort with our group at the site becausE 6 they Hill be heavily involved in performing-the specific 7 inspections that are needed.
8 I can foresee that probably Within the next three.,
9 four Heeks He might have a meeting on equipment' qualification i l
10 for us to understand what is going on, for you to understand 11 What He require, and scope out that effort and then get-12 started on it.
,- 13 Any comments?
14 MR, WOODLAN: We feel that time frame Hould be 15 appropriate. ,
i 16 MR. SCHIERLING: I think I have two or three more l
17 items, l
l 18 The next item, separation of instrumentation and 19 control -- I&C cables and raceways. This also is a matter 20 that interfaces Hith Corrective Action Program and 1s a 21 specific -- I think is included in one of your activities. l I
i 22- The Staff recently'was at the site,.I think-about'a I
23 Heek or two ago, and again performed a scoping audit to see i
24 exactly Hhat has to be done. It.is a subject of one of the 25 ISAP's, ISAP 1.b.3, and we intend to perform a more detailed 1 - .i
'75 1 audit at Stone & Webster as part of the' Corrective Action 2 Program on this particular subject. As a matter of fact, I l
l I 3 think it has been scheduled for early August, first to look at 4 the criteria that you are applying and then the 5 implementation.
6 MR, WOODLAN: It should be clear that this item was 7 the criteria itself and our submittal of that criteria and 8 supporting test documents, and we understand and agree that l
l 9 that relates directly to the Corrective Action Program and i
10 that follow-up audits will occur, although this item itself 11 was meant to be the approval'of the criteria.
12 MR. SCHIERLING: Right. And these criteria are beinc
,,- 13 audited at -- I think you submitted them in one of your recen1 14 amendments. That is being factored in, so that will -- I 15 think we will audit those at the -- at our audit at Stone &
16 Webster and we will coordinate that with you.
17 MR. WOODLAN: Okay.
18 MR. SCHIERLING: Another item is the main steamline 19 isolation bypass valve. Again, you responded in, I think, 20 December of 1986. The Staff is reviewing your response. It's ;
-1 21 partially completed. It also relates to some degree to 22 equipment qualification, so we have to interface that aspect 23 when we look at equipment qualification. But we or you will l
24 respond to your December '86 submittal on that particular 4 i
.i 25 item.
76
, 1 MR. WOODLAN: Yes.
2 MR. SCHIERLING: Now, I would like to briefly mentior 3 how He have been doing our review on these specific items and 4 how He intend to continue to do that review. These are 1
5 specific licensing items, and I forget -- when Has SSER 12 6 issued? That was '85, I think. What He intend to do is 7 revieH the specific licensing items, hopefully reach a l
8 resolution in discussions with you and submittals by you, and i
9 then inform you by letter of our evaluation and include that l 10 evaluation, or include such an evaluation, in inspection I
l 11 reports as are appropriate. However, prior to issuance of a l 12 license, He intend to consolidate all .ese individual i 13 evaluations in a single document, a Supplemental Safety 14 Evaluation Report, that would reference all the specific 15 activities that have been going on, and that would be one of 16 the bases for issuance of the license when the time comes.
17 And the SER Hould clearly state the item is resolved or 18 further action is required and when that action has to be 19 completed, be it prior to license, be it prior to issuance of 20 the low power license or full poHer license or whatever time 4
21 frame we might impose. And they might even end up as license 22 conditions.
23 We intend to issue a number of SER's, at least one ori 24 the licensing item, and, of course, there Will be other Safets
' 1 25 Evaluation Reports on matters such as the CPRT and the
1 e s. ** )
Il 8'
1- Corrective Action Program.
~2 We also expect to issue at'least one, probably more, .
3 __SER's on allegations, and all these documents would form the j 4 basis for issuabce of a-license. ,
, 5 In your presentations, I-think primarily today,.you 6 made reference to your tracking of commitments, and we expect e
7 that He intend to audit that list and.indeed make sure that 8 all these commitments are being met, We also would like you-9 to keep track of all open. items, confirmatory items, and 10 commitments in any kind of correspondence with us or other 11 places to make sure that indeed all these issues are resolved.
12- And we might request -- He haven't decided it' yet -- to inforni i 13 us that indeed all this has been done and demonstrate to us 14 that it has been done by reference.
15 That's all I have to say at this time regarding 16 routine licensing issues. We intend to continue to discuss 17 these matters with you either by correspondence or in meeting:
18 as appropriate, but I think right noH He hav'e -- the items I 19 Just went through are indeed high priorty items, and the next 20 one that's coming up is the meeting next week; and I would 21 like CASE to know that we decided on that meeting, I.think it I i
22 was, yesterday, so He do not hnve the normal time'to get out I 23 on official meeting notice, but I will inform you that indeed i
24 it is a meeting open to the public next-Heek in Washington on i 25 tech specs, i
a
r n -
78 1 MS. ELLIS: When?
2 MR. SCHIERLING: Wednesday.
3 MS. ELLIS: Where?
4 MR. SCHIERLING: I haven't found a room yet, but it 5 probably will be in the East-West Building where we are 6 located.
7 Chris, that's all I have to say on licensing. Do yot 8 have anything to add?
9 MR. GRIMES: No.
10 MR. SCHIERLING: Anyone from the staff?
11 MS. BOLTZ: No.
12 MR. GRIMES: In that case, Mr. Counsil, I will now gc' i 13 on to our summary comments in the meeting unless you want to l 14 pretace that.
l l 15 MR. COUNSIL: I would very much like to --
16 MR. GRIMES: Please proceed.
i 17 MR. LOL'NSIL: I appreciate the opportunity to make (I l 18 closing statement on the last two days, specifically on agendcl 19 items-5.1 and 7-.4 concerning the design and construction i 4 20 validation processes, j l !
l 21 One, the safety-related portions of Comanche Peak j i
l 22 design will be validated with the following exceptions,-which j i 23 He have discussed: Nuclear steam supply system hardware, i 24 although we are reviewing the design interfaces; and equipmen1 l 25 supplier design. And once again, those design interfaces are !
l \
j
I, . -
79 I
)
l l
i being reviewed.
2 Two, the as-constructed safety-related portions of 3 Comanche " 'k will be validated to conform to the validated l l
4 design. That means all final quality acceptance attributes t
5 will be validated; that is, challenged for acceptability.
6< We will reinspect using engineering or QC personnel in all 7 cases except where during the formal challenge the disposition 8 of the Ottribute shows that it is acceptable.
9 This disposition Will be done by procedure using 10 qualified personnel.
11 This process is similar to how an NCR is i
12 dispositioned.
, 13 The procedures for this disposition process will be 14 available in about one month.
15 This commitment requires revising Proceditre ECE 16 9.04-05 mentioned yesterday extensively, i 17 The entire process will provide documentation and an 18 audit 1ble trail, j 19 Three, the adequacy of the validation processes is i
20 being assessed by the Engineering Functional Evaluation of i
21 Stone & Webster Engineering Corporation.
22 Four, the adequacy of the validation processes is 23 also being assessed oy the TV Electric Technical Audit Prograr:
24 including hardware validation.
i 25 Five, overviews of the adequacy of'the validation
80 I
1 processes is being conducted in selected areas by CYGNA and 2 TENERA Corporation.
3 Six, overviews of the engineering functional l 4
evaluation, TU Technical Audit Program and TENERA is being
- 5 conducted by the Senior Review Team.
I 6
In addition, our extensive validation effort Hill 7
assure that the safety-related design and construction of i 8 Comanche Peak has been rigorously evaluated.
9 This approach is far beyond the sampling approach in ,
10 assessing design and construction adequacy at other licensed 11 facilities.
12 In addition, our goals and the NRC goals are
,i 13 consistant. TU Electric is not interested in seeking a 14 license for Comanche Peak until He are satisfied that the 15 safety-related design satisfies licensing commitments and 16 safety-related hardware satisfies that validated design.
17 We, as I am sure you are, also are not interested in 18 performing any activities which are not Harranted.
19 We are confident the program described the past tHo 20 days provides the basis for us to proceed. !
{
21 Thanks for letting me summarize.
22 MR. GRIMES: You're welcome. !
23 Would CASE like to make a closing comment before or 24 after I do?
{
i 25 MS. GARDE: We'll put our comments in a letter.
m _-
, . j 81 l 1 MR. GRIMES: I Hould like now to try to condense the ;
2 Staff perspective of Hhat we've been able to accomplish or rot 3 accomplish over the past two days.
4 First, I'd like to note that from yesterday He left 5 open a question on the extent to which there are nonconforming 2
6 conditions not reflected in Hhat Here referred to as, quote, 7 the historic NCR, unquote. We're not going to pursue that 8 issue at this time because He feel that's a small part of a ,
9 bigger issue of being able to very clearly define what is the 10 nature of the nonconforming conditions that are being resolvec 11 by CPRT in the Corrective Action Programs.
12 We expect that during the course of our evaluation 01 i 13 the process that the answer to that question Hill become 14 clear.
15 I'd also like to note that I raised three questions 16 during my presentation of our perspective of the Corrective 17 Action Program. One was a question concerning a clarificatf or i 18 on the document floH betHeen the CPRT and the Corrective
- 19 Action Program, a question about the contents of the CPRT 1
20 Results Reports in a broad sense, and a question about the 21 relationship betHeen design validation and the Reinspection 4
22 Program.
23 The answers that He got to those questions, as He i
24 understand them, are we are going to take the figure that I 4
4 25 presented and try to clarify it Hith respect to document floH. I
- _ . , --- --- ~. -- ----
82 1 The results of the CPRT activity will be reflected ir 2 a different number of report, but more specifically the 3 question about what finding was made in~the design area will 4 be reflected in a collective Significance Evaluation Report.
5 The last question concerning the relationship betweer 1 6 the design validation and the Reinspection Program focused on .
I 7 your clarifying remarks, and in that respect I would like to 8 make the following comments.
9 First, that there is a consensus on the Staff that 10 there has never been a project that is as complex and !
11 complicated as Comanche Peak, bnth from the standpoint of the 12 historic evolution and confusion of issues. But also we i 13 believe that the situation has been exacerbated by attempts to '
14 try to package the problems in various different forms. Our 1
! 15 attempt in this meeting was to try to more simply explain whai 16 the current and future course of these efforts will be. We 17 were not terribly successful. But we have learned that the 18 lesson that we come away with is that we can't approach the 19 review of this process as we would another OL application. !
20 The Standard Review Plan and inspection modules are designed :
21 for a different circumstance. This circumstance is l 22 sufficiently unique that we're going to have to develop a 23 review plan that is more consistent with your overall 24 approach.
25 And in that regard we know that there has beEn a l
~_. _ _ - --
a I r 83.
1 considerable amount of work ongoing to improve procedures, to 2 perform inspections, to do redesign, We know about all the 3 individbJ1 parts of the process. You have been very patient 4 in trying to explain to us all those activities and how'they-
- 5 relate to each other, but quite frankly, at this point we 6 still can't see the whole. We're. going to continue.to try tc 7 do that, and we will do that in the context of evaluating the
! 8 plan. We will continue that evaluation until we have that 9 picture clear.
l 10 At that point we are going to put the explanation of 11 what constitutes the whole and what we will look for in our l 12 review to serve as the licensing basis'for Comanche Peak on 1
~
i 13 the docket so that all can understand what the end point will
! 14 be and what issues are going to be addressed and how they're 15 poing to be addressed.
16 In that regard, while we understand broad 17 programmatic explanations of activities, we need more detail 18 on how they're conducted, the scope and nature, and the 19 exclusions. The point that you made about excluding the NSSS 20 except for the interfacing is an examole of such an exclusion, 21 We would like to see t00se Clearly enumerated 30 that no one 22 misunderstands what the nature of our evaluation process is 23 going to be.
24 We will evaluate the results of the material that hat i
25 been presented during the last'two-days of meetings.. We're I
f l c_____ o__2__ oom mmm m_~_. mmm ommm
i 84 1 going to determine what additional explanation we require and 2 either 90 out and find it or we'll have another meeting with 3 more specific comments.
4 And we will continue to work towards an evaluation 5 that's going to clearly establish a licensing plan.
6 In that respect,.Ms. Garde noted that CASE will i l
7 submit written Comments. I'd like to again offer, Mr.
8 Counsil, that if you feel that any additional clarification of 9- what the whole of the activities look.like, you may submit 1
10 those for us to consider in our evaluation.
11 If there are any other comments from the Staff? .
12 Ms. Garde, do you want to now comment?
,- 13 MS. GARDE: I have a question that I'd like to 14 address to you to clarify one of your stateme:lts.
15 M'R. GRIMES: Certainly.
16 MS. GARDE: Is your comment.to Texas-Utilities about 17 seeking further information to be considered as a request to 1p Texas Utilities for the program plan, the intergrated program 19 plan, and all procedures? Is that what you have asked them l
l 20 tor?
21 MR. GRIMES: No, I have not asked that.
22 MS. GARDE: Then let me,. representing CASE, put to i 23 the NRC that we think at this point that-the NRC has a clear 24 obligation to ask for the program that's been presented to i
25 date in detail and to docket that program.
I
- O m __ _ - O ._ _. A _ AAO AAN M - ^- ^ ^^ ^^^^
8S I
1 I can't see any reason why a program that they have j
.- 3 )
2 written.that in some c0ses is near Completion in certain area 5 t
3 is not made available to the Staff and to the interveners'. I 4 don't see any reason why that would not1be considered by the ;
5 NRC as mandatory to going forward. You may have to consider 6 that, but I think that is one thing we feel'real strongly 7 about 8 MR. GRIMES: I understand your point. Let me Just 9 say that, as I mentioned before, I think that asking Texas 10 Utilities for an additional Program Plan or another plan to 11 out into the hopper is going to only add to the complexity anc!
12 the confusion.
, 13 MS. GARDE: It's the plan they've already got.
14 MR. GRIMES: And at this point we have a 15 presentation that we can evaluate. We know where the 16 procedures are, and we will go back and review this 17 information to determine what specific information we want to 18 have docketed so that that information-is clear.
19 I would eventually make a request for details of l 20 these activities, but I want to make sure that the request is 21 , clearly planned so that we don't get any more extraneous l
22 information before us.
23 But your point is taken, and we will Consider it 24 during the course of our evaluation of what more we need to do
,e 25 to define our evaluation approach.
l n _ _ , :_
c __ _ -c. --~ ~. .-- ----
v.
1 Mr. Counsil, do you want to add any other comments?
2 MR. COUNSIL: I have no further comments.
3 MR. GRIMES: Then the meeting is now closed. Thank 4 you all for coming.
5 6
(The meeting Hos closed at 2:30 p.m.)
7 8
9 I
10 11 12 i 13 14 l
15 16 Al l ;
i 18 1
19 20 21 )
l 22 J 23 1
)
24 I
25
! l Carmen Gooden, CSR, RPR, Metro 429-5532
_ __ _ _ -_- -_ A
. 6 87 l
1 2 STATE OF TEXAS )
)
3 COUNTY OF TARRANT )
4 I, Carmen Gooden, Certified Shorthand Reporter of the 5 State of Texas, certify that the foregoing hearing was 6 reported stenographically by me at the time and place 7 indicated and that the foregoing is a true record of the 8 hearing.
9 Given under my hand and seal of office on this the 1st das 10 of August, 1987.
11 i
12
[ g['
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, 13 [ tm _-
LM < -<
Carmen Gooden, Notary Public ancl 14 Certified Shorthar.: Reporter in !
and for the State'of Texas. {
l 15 1
16 Certificate No.: 2353 Expiration Date: 12-31-87 l 17 Notary Expires: 08-10-87 I 18 19 l
20 21 22 23 24 1
25 a--- _ - _ _ ~ --- --- - -- ----
DOCUMENTS HANDED OUT BY CASE MORNING 0F THilRSDAY, JULY 30, 1987; regarding other-than-Nonconformance Reports used to handle nonconforming conditions (and some information regarding welding):
CAT Report (Constructial Appraisal Inspection 50-445/83-18, 50-446/83-12, NRC Staff Exhibit 206, bound in at back of volume following Tr. 6286 (with charges markged) -- especially pages II-16, II-17, III-6 through III-9, IX-1 through IX-10 Attachments A, B, and C to Affidavit of CASE Witness Mark Wal;h, attached to CASE's 10/30/84 Motion for Additional Time and CASE's Second Partial Answer to Applicants' Statement of Material Facts as to Which There is No Genuine Issue Regarding Applicants' Quality Assurance Program for Design of Piping and Pioe Supports for Comanche Peak Steam Electric Station 1/8/85 letter from Darrell G. Eisenhut, Director, Division of Licensing, Office of Nuclear Regulatory Regulation, to M. D. Spence, President, TUGCO, under Subject.
! Comanche Peak Review, especially cover letter and pages 1, 2, 4, 5,. 7, 8, 17 through 20, and 25 1/9/85 8oard Notification No. 85-01, from Darrell G. Eisenh'ut, Director, Division of Licensing, Office of Nuclear Reactor Regulation to NRC Commissioners, especially pages 2, 4, 5, 17, 18, and 25.
SSER 11, NUREG-0797, Supplement No.11, Safety Evaluation Reoort related to the operation of Comanche Peak Steam Electric Station, Units 1 and 2 Docket Nos. 50-445 and 5f-446, May 1985, especially pages P-30 and P-31 Inspection Report 50-445/86-31, 50-446/86-25, from NRC Region IV to TUGC0's Mr.
W. G. Counsil, especially pages 28 through 34 i
_ _ - - _ _ _ _ - - _ - - - - - ~
I, .
't 10/30/84 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of i <
l TEXAS UTILITIES GENERATING l Docket Nos. 50-445-1 COMPANY, et al. i and 50-446-1 (Comanche Peak Steam Electric Station Station, Units 1 and 2) {
CASE'S MOTION FOR ADDITIONAL TIME AND CASE'S SECOND PARTIAL ANSWER TO APPLICANTS' !
STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS l N0 6ENUINE ISSUE REGARDING APPLICANTS' QUALITY ASSURANCE PROGRAM FOR -
DESIGN OF PIPING AND PIPE SUPPORTS FOR COMANCHE PEAK SYEAM ELECTRIC STATION We are attaching subject Motion and Second Partial Answer for the Board's consideration, in the form of the attached Affidavit of CASE Witness Mark W31sh.
However, as discussed by Mr. Walsh in his Affidavit (see especially .
pages 38 and 39), reviewing the two-foot tall stack of documents which Applicants have provided to CASE on discovery and attempting to determine what changes have been made in the procedures and instructions has been a mammoth job. As Mr.
Walsh stated, it was simply impossible for him to adequately review and discuss all of them at this time; consequently, he was unable to address all of the specific points in Applicants' Statement of Material Facts. We believe that the Board will be able to appreciate the magnitude of this job when they review the documents attached in conjunction with Mr. Walsh's Affidavit.
In addition, there are documents which Applicants have refused to provide to CASE which we believe are absolutely necessary for us to be able to adequately
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of i 1
TEXAS UTILITIES GENERATING ] Docket Nos. 50-445-1 COMPANY, et al . and '50-446-1 (Comanche Peak Steam Electric Station l Station, Units 1 and 2) l CASE'S SECOND PARTIAL ANSWER TO APPLICANTS' STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE RECARDING APPLICANTS' QUALITY ASSURANCE PROGRAM FOR DESIGN OF PIPING AND PIPE SUPPORTS FOR COMANCHE PEAK STEAM ELECTRIC STATION in the form of AFFIDAVIT OF CASE WITNESS MARK WALSH
- 1. Applicants state:
"Each of the responsible design organizations for piping and supports at Comanche Peak has established procedures to implement the provisions of 10 C.F.R. Part 50, Appendix B and ANSI N45.2.11 to their respective applicable functions in the piping and support design process.
(Affidavit Table IV.1)"
I disagree. Applicants state that each of the responsible design organizations) have established procedures to implement the provisions of 10 CFR Part 50, Appendix B and ANSI N45.2.11, but this statement cannot be so, based on the information already contained in the record of these proceedings. As vill be shown in answer 5, the Applicants do not have any design control procedures in the field except to document what is in the field. This is not sufficient to comply with the requirements or intent of 10 CFR Part 50, Appendix B and ANSI N45.2.11.
l 1
r Communications Mg i ATTACHMUT A Report 11111!!!!!Il!!111111111111111!
companr Texas L(tilities a Tew on n conference n pon
- J N' Comanche Peak Steam Electric Station 84042 Independer,t Assessment Program Phase 3 oste: -
5/10/84 sumect T'"*
_orrective C Action Systems 12:50 p.m.
Place:
"*"''*"'i l S. Bibo . N. Williams
CES i
l D. Wade, R. Tolson TUSI Recuired ttom Comments l Action By We asked to meet with D. Wade to clarify in our minds exactly what " vehicles" were used at CPSES to document design deficiencies. Dave asked that R. Tolson be brought into the discussion.
Tolson and Wade explained that in addition to such documents as Nonconformance Reports (NCR's), Deficiency Review Reports (DRR's) Corrective Action Requests (CAR's) Significant i
Deficiency Analysis Reports (SDAR's), etc., other documents could j be used to document design deficiencies. These documents are 4 Computer Modification Cards (CMC's), Design Change Authorizations (DCA's), and Inspection Reports (IR's).
Tolson explained that he didr.'t feel it was important relative to what you called the piece of paper, as long as the deficiency was documented.
l .
1
- l l
o,.innui,m h /rg Page } of M. Wi lliams, u. Wade, u. brace, s. B1bo, s. I reby, i>. t i li s, Pro.j ect t i le
}.
l Communications A[ l3 ATTACHMENT B Report tilllll!!!!!Ill!!!!!!!!!!!!!!!
- "" T * "
Texas Utilities Ck conference Repon Proiect Joe No.
Comanche Peak Steam Electric Station 84042 Date:
Independent Assessment Procram - Phase 3 5/3/84 -
Sub;ect. Time:
1:00 p.m.
Place:
Review of CMCs CPSES
Participants:
of Mike Strance TNE Shaid Ali TNE
- 0. Smediev Cvana Acousred item Comments Action 8v
- 1) Asked Mike how many CMCs and DCAs existed from day #1 until now, how they are numbered and how CES could easily determine which CMCs are design related?
His response was that:
i a.
Current # of CMCs to date is 97894 (CMC
- 18,400 through 30,000 were not used) so actual # of CMCs issued to date is 86,294.
- b. 20,300 DCAs and DC/DDAs have been issued to date.
- c. Approximately 36,000 CMCs issued are pipe support related and are not tracked by DCTG, and are not G&H design related.
- d. DCTG can identify which CMCs are pipe sup, port engineering related if CES requires i that information. 1 i signeo 01/) jf - -
p.g. o, V / i V 2'/l(((f.m
/ cam 1 1 D'*ta*"aa:
N._Wi l.11ams , Ma de , G._G race. _S. B i bo ._S._Iceby,_J, _E l l i s., _P_r.oj ect Fi l e
l E Communications g[Pj ;' fj ATTACH 4ENT C Report lilllllilllit!!!!!!m!!!!!!!!
conference Report Texas (Itilities g Tesec n Pro;ect. Job No -
Comanche Peak Steam Electric' Station 84042 Independent Assessment Program - Phase 3 p g f g4 Subiect. Time:
1nspection Reports 4:40 PM Place.
Partsc pants ~ of S. Ri bn ry nna Donna tewellen Tutt item Comments Ae o ey Donna called me per request of Tony Vega to supply me with requested information relative to the number of Inspection l
Reports (irs) issued at CPSES. Donna stated that between the "old" IR system and the "new" IR system there are in excess of 150,000 irs. She stated that the new system has a computerized log but that the old irs were manually logged. The old system l contains about 100,000 irs. Donna explained that the number of irs given is her "best estimate".
We also discussed procedure CP-QP-18.00. Donna inferined me that D. Lewell-this procedure was up to revision 17. I asked her to send me
! revisions 12 thru 17.
l l
1 Ylh l)/ At A' A /dhb 1 1 D'"*"*"'
N. Williams, D. Wade, G. Grace. D. Smedley, S. Bibo, S. Treby, J. Ellis, L______.___.______ _ . _ _ _ _ . _.
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