ML20248D066
| ML20248D066 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 09/21/1989 |
| From: | Ellis J Citizens Association for Sound Energy |
| To: | Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| NUDOCS 8910040116 | |
| Download: ML20248D066 (30) | |
Text
m .
" C A S E == - ?
g' 21b/pk6-9hh6 hts'~ u a
. (CITIZENS ASSN. FOR SOUND ENERGY) .__g na 1 September 21, 1989 g gjd 5"o -W t/yg .
Mr. William G. Counsil -'I Vice Chairman -
TU Electric
- h 2001 Bryan Tower, Suite 1900 Dallas, Texas 75201
},
i Dear Mr. Counsilt
Subject:
Notification of Dispute Pursuant to Paragrepas B.1 and B.2 of .the Joint Stipulation I Regarding Specified Activities 1:!volving the I&C Scaling Calculation Program This letter is to notify TU Electric of the position of Citiaens Association for Sound Energy (CASE) in regards to identified concerns and problems in the scaling calculation program at Comanche Peak. .
I As you know, for some time CASE has been reviewing and participating in an audit and technical review of scaling calculation concerns raised by an alleger to TU Electric. To date both CASE and TU have expended substantial resources on the audit and technical review of those concerns.
On September 12, 1989, CASE Monitor Owen Thero recommended to CASE that a "stop work" order should be issued by TU Electric's Ocality Assurance department against the scaling calculation program as a result of the findings of the audit process and technical review process of the scaling calculation program. CASE forwarded a copy of the memorandum.to you. The memorandum included the basis of the CASE position that the issuance of a stop work order was appropriate (Enclosure 1).
TU responded with its position that a stop work order was not needed, and also proposed the corrective action program for the identified deficiencies.
On September 19, 1989, CASE provided TU Electric with a copy of Owen Thero's ,
September 18, 1989, initial response to the proposed corrective actions (Enclosure 2).
In addition to the exchange of these letters, CASE personnel and TU Electric have engaged in a series of meetings and discussions about this issue, most recently on September 20, 1989.
It is clear that, at least at this point, we have reached the stage of a dispute over this issue. Therefore, CASE is formally notifying you pursuant to Paragraphs B.1 and B.2 of the Joint Stipulation that we are raising the l issue presented in the attached memoranda.
l 8910040116 890921 PDR ADDCK 05000445 00h NM dl(
A puu .
,p, , .
.cn
-. +
- e _.
k 7 ,(h I
1 .
h.
We understand that you will respond' to both the request for a stop work.
~
order and the comments on the proposed corrective action program. We expectJ j '
that you will' also provide to CASE the documentary information which supports your position on each aspect of the dispute.
- We look forward to your response. >
Sincerely, l:
I< CASE (Citizens Association for Sound .;
' Energy) ;[
s.) Juanita Ellis President
, Enclosure 1 September 12, 1989 Memorandum from CASE Monitor Owen Thero .
to B.' P. Carde, Attorney for CASE M Enclosure.2: September 18, 1989, Hhaorandum from CASE Honitor Owen Thero to B. P. Garde, Attorney for CASE cet . Mr. Christopher I. Grimes Comanche Peak Project Division Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D.C. 20555 1
i 1
1' 1
l li 2
[ .
C,L_'___________ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ._ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
m_ .-
n . .~:
./
ENCLOSURE 1
. TO: B. P. ' Garde
- TR0!i: - O. L. Thero DATE: Y September 12,;1989
- St!BJECT: CASE Position Regarding Need for a Stop Work on Specified
, Activities involving' the I&C Scaling Calculation Progras l
pit- ~)1 TU Procedure NEO 3.25, Rev. O, stop Work (attached)
- 2) :10 CFR Part 50, Appendix B, Quality Assurance Criteria f or Nuclear Power Plants and Tuel Reprocessing Plants On the basis of the ongoing and in-process IAP Audit (ATF-69-146S) findings and results of the technical reviews conducted by TU Electric / CECO over the past few months, and previously conducted audits and surveillance, it is'my belief that evidence exists. verifying a pregrammati. breakdown of the scaling calculation / document review progran,. This evidence establishes x
'that several of the criteria f or which stop work action is appropriate have been met (i.e. , NEO . 3.25, paragraphs 6.1.3, 6.1 4, 6.1.5, and 6.1.6).
However,'since only one condition is required in cetermintrr the need. to l- stop work (see KE0 3.25, paragraph 6.1), I shall address the oasis f or only 1
one-of the criterion. 6.1.5, although cther criteria could also be tited.
Paragraph 6.1.5 contained in the referenced crocedure states that a stop work order condition exists if:
- . "A division, department, section, unit or individual, by rept.titive f ailure to comply with ad=inistrative or technical controls, l- contributes to' a condition that is a significant GA program design and/or construction deficiency."
Y t .-
\
O _ 2. _ _ ____ _ __..________. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ___ _ ___ _ _ _ {
w fr s," ', a Ty ;77 ~ ,
SW" , , /3,M i n s
d...g _
' t .x o - 1 v ,e ;- 4g$:
+
apn $ 3 - 4 ,, -
L' .
', l k.
li ^
'~
i '
{'. ff _. 'L:Q: ON _ 3: 'h.
y N.}~qh
.aq
%p rj , W:]e*f
.C; f'3.' Tr' g,
)~
'+"
f Op ' gfy o , I'L
'. , f:h r -:-l , 4 .
-] c ., ,
'r
.. y x ~
\
f p* >y s ~ s f.b 'J
, a >
.-[l. --
- c. , ,
n g: w 'n - >-d, pji ;- , s ~. '3.
-y r,;f %. s +(()(, .. /:{ - ' . . .,
l- ,
'- I/ ).,s ,s,
')i.l 1 @ .-g '-
'J ' ( ' .
yyl ;
' h.
1 "
' 4,This concition is established. by noting the. f ollowing inf ormspon -
.n s - ( n.
'3: .
1 3;A
,# , ;(i .,. '. avai,lable' to CASE monitors through the additing process, technical / revieu ~ ,,
r;,r g/. +f.
3 i-i g ;-
.6 ,
.g ,
.y d, medings,. Und 'f rom the' historical review of ' th( problematic conditions as W W[ b [j s !known '4' tolCASE: y a
.)
iK kn' ,y ': E,',.
< ?
- p.
,p - O, 1)hdTN Electric Letter NE-19097,. dated 5/10/BS' (attached), f rom 0. W. Love k w .,
- g #y , >
> 7^ ' to ge t . Stamm (SWEO),' verif:led G. W. ' Eodif ord's technical ( concetNs
.j;, 10, '?' .j-QI>
reported '.to SATE!EAM . on f riday', November 20, 1957. :In addi: ion to 4J 7gE,
, q'
,. j',)a
, Y1 w; . t .
'.,vq agree p t:. .:ne Salidity . and significant of those ' conecrns, 0. . V.- Lown
< 47,e .f l outlined)a multi-f aceted program f or the' 5WEC scaling calcyla: ion y9 ' -
i g.
. <l proj et: ~ to . fellow in ccrrecting deficient conditions identified by Mr. .
? q <
,' j o .
1,elif e rd . 1:r the =ost cart, the cerrective reasures cory:itted.to it.
%, ') ' :ne ces: ntre n:: been Acoler; ente.. This has sect. verifief sy TU t
\>:
(
. a, ' Ele::ric, 'roth through tne in-process TAP aud:: findinge &nd :ne y ,
- technical interchange meetings with TU =anagecent and C00 personnel.
- i n 1:. add::i::.. :ne ccficien: pregra==::2: and te:nnic 1 cend::: ens re:cgnize: :n :ne hay 10, 198E , ne=o nave neer. 'allowe: to cent:nue
. g i, g' ' t ' I h :nrou:ncu:. One cast ' veri, even:tnouct severa; rreviour !AT. T0. an:
bf ET.0 aud::s and surveillance nave been concu::ed.
4
-m 10 Cn Part 50. AttendiT 3. Criteria AODarentiv Ti:lEted:
, h 'L .
1:
n:f.
dj, . II. Qualt:y Assurance Progra
". . 1T)he applicant shall regularly review the status and adequacy of the quality assurance program. Management of other organizations participating in the quality assurance program shall regularly review the status and adecuacy of that part of the cuality assurance program which they are executing."
2 y
m ., ,_ _
,f ;
\ . %
y g '4 )
)t
_y
(
< \
w .,
3> ,
j
,n>, (.
( , s 3- , .
t u. h, x ,
6
,g
,( ...
j ~
.1
\
l' W , VII. Control of hrchased Material, Eculpme:nt,. and Services u ;
p >[ ( i
Messures' shall be established to assure that purchased . . .
services, .c. . conf orm to tne procurement occuments. These s
4< . censures sna. . ine uce provisions, as appropriate f or . .
g E l- obje ctive evidence of ouality furnished by the contractor . . . .
The ef festiveness of tne centrol. of ouality by con':ractors and succor.:ractors snal; be assessed by the applicant or designee. . ."
7.s <
?
r, llti c XVI. Corrective Action
! " Measures shall be established to assure that conditions adverse
/ to cunlity , . . . are tron:ti:iuentified and cerrected."
< [ '
y'iTII.Qualiry As surance katords i
"Suf fi cient records shall be ::ittained to furnish evidence of i activities aff ecting cuality."
s.
- .-~. . . v. . . p.,., a. 4. . . ,.,
"A =cr:renentive myster c: rinnned and certed:: audits snal', ce carried ou: tc ve:if'; ect:llance v::: a;; aspects of :ne cuality assurance pregram and to cetermine :ne ef te:tiveness cf :ne rrecr as. .. . I:llow up c tier., in: iud:::; re-audi ef asf :icn creas snr.1: ce t ake r vners .nd: st c;..
- .
- nt aI : :. cf int r i V 5 U. , 7. ! 12 C 'c : 121:* : n ".* : nt s:0:V ~ :*M i
OOru:!CC:,:i:I Eup?:r!1r: ~, n t re:lin" :Di:J42* 0! rr:~ran 1 in:E : CrOi n ;;E CL *nt peln: Of Etn; ::s*uncti ni. ar.:: l'.n r t h : . L i t. . ~ T.1 9 is evidenced Enrough 10t enistente Cf :
a) ' exter. rive unin ::: rated I;A ' E '; ; . t . , li'-u s; some Ii7 s nave fune:icna*. ::rcui: nanges nnnd ann tated en :ne drawing cut no:
- incorport.ned onto tne drawing or approved by the responsible orgar.ization; b) the 1. set of control of Westinghouse 5555 specificatient; ant, 3
w_______ _ _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ . _ _ .- - . - - -
y , : yrg du m c
@;g ):t;_
9 9 m, , ;G
+
- l}
/
i
,{ 7[% ^% - 4 ! ' 1.-
') 4 -' [ 'Il[ c i
. j ., . ,,
h " M g.g.g .' ,
O )
,1 ,
%, _y.g 7 . ,
.7 c . . ,
c-e V,,C c ,
j.g.
K 4
"{.,
,p-
^ ,
1 a .
a- c) Lthel lack of. control of We'stinghouse baseline documents (i.e., WCAP
, v m , .
9696 and supplements).
i
- s- .'
's- ,
f .
1
-10 CFR Pagt 50, AnDendix B, Crittric Aeoarentiv Violatedt i ,
s j '. _
IIIi Desigb Control'
?'
[> * ') ..
'E "Messures shall be established to assure that. applicable fd", f ' s' regulatory requirements and the , design basis, . . .'7. 'are correctly .
, l translated into specifications, drawings, procedures. . l. ."
9 /
l l
.V. ~ Inr>tructions, Procedures,' and Drawings
", 1 - " Activities 'affecting quality Shall' be prescribed by documented t_ '
instructions, . procedures, or drawings, . . . and shall be accomplished in acco'rdance with these instructions . . . .
Instructions . . . shall include appropriate quantitive or
- qualitdrive acceptance criteria . . . . ."
i VI. . Document Concrol, ,
" Measures shall be established to control the' issuance of.
documents , . . . , including changes thereto, . . . . . These reasures shall assure that decuments, including changes, are 4
'" reviewed for adequacy and approved f or release . . . ."
,j ,
VII. Control of Purchased Meterial, Equipment, and Services
" Measures shall be established to assure that purchased . . .
services, . . . conf orm to the procurement documents. These measures shall include provisions, as appropriate for . . . ,
' objective evidence 'of cuality furnished by the contractor . . . .
The' eff ectiveness of the control of quality by contractors and subcontractors shall be assessed by the applicant or designee . .
l;
. .n XVI. Corrective Action t
s i ,-
" Measures shall be established to assure that conditions adverse
. to quality , . . . are promptly identified and corrected."
4 i
( , (Q
..L.___ ____:__..._._._____.________. _ _ _ _ _ _ . _ _ _ _ _ _ , _ _ _ _ _ _ _ _ _ _ _ _ _ __ ___ _
.;,+
,=e.
XVII.Ouality Assurance Records
" Sufficient records shall be maintained to furnish evidence of activities ' af f ecting quality."
be 3) The existence of a deficient and unreliable Design Basis Document (DBD-W1 - -
c , EE-032'which, according to the FSAR, is supposed to control the Analog
-and Scaling' Calculation technical ef fort).
~
In a technical meeting on 8/26/89 between CASE and TU Electric /
' CECO personnel, TU Electric / CECO concurred that DBD-EE-032 was F'
= deficient _and did not convey the information required to support the a' i h
" ' scaling calculation program. IT Electric / CECO stated to CASE that DB&-
' EE-032' would be deleted in its entirety and the relevant data.would be o
4; 1
incorporated into the scaling manual (SC-SB00) and/or various DED's as
. deemed necessary.
~
y'
- ~
10 CFR Part 50, ADDendix 3. Criteria Antarentiv Violated:
III. Design Control
" Measures shall be established to assure that applicable
, regulatory requirements and the design basis, . . . are correctly 1o translated into specifications, . '.. ."
?O ,
-V. Instructions, Precedures., and Drawings
}
V-
~'~
" Activities cifecting quality shall be prescribed by documented l?
instructions, . . . and shall be accomplished in accordance with L these instructions . . . . Instructions . '. . Shall include
[ J' -4 appropriate quantitative or qualitative acceptance criteria for determining that important activities have been artisf actorily
.N' '
accomplished."
l l
[.
L' Lv .,
- f. ~
Emim=_ __ __ l
c, o; VI. Document Control .
"Heasures shall be established to control the issuance of .-
' documents', such as _ instructions, . . . including changes'thereto, which prescribe all . activities affecting quality. . These measures shall assure that documents, including changes, are reviewed for
- adequacy and approved for release by authorized personnel . . . . ."
-4) - Scaling Calculation Manual ~(SC-8800 and . Appendices)'contains
[ -
deficient / outdated technical data and does not provide a technical
~
overview f or the ' scaling calculation program.
a)' Appendices "F" & "C" do not appear to have formal Westinghouse concurrence;-
b)- Appendix' "1," while being a controlled document, does not interf ace between the FE's (Field Engineering sketdhes verifying instrumentation elevations) and TVM-069; c) Appendix "H" does not provide technical explanations and.is a summary document only , i . e . , the data listed for the NAL cards is misleading and.could inpact setpoint methodology as well as the scaling calculations; d) . Appendices "J", "K", and "L" are still referenced (DBD-EE-032) but the Appendices themselves have been celeted; e) the information in DSD-EE-032 is not correctly addressed or presented; and f) the scaling calculation manual does not provide comprehensive technical guidance.
6 wm
_ . _ _ _ . _ _ . _ _-_m_ . _ _ . - - _ _ - _ _ _ - - . _ _ _ . - _ . . . . _ __ _ .- -. _ _ . - . _ .
V' +-
' . , 1 k
- j. N' L
{
(' . 10 CFR Part 50, Appendix B, Criteria ApDarentiv Violated:
I L III. Design Control f,
" Measures shall be established to assure that applicable regulatory requirements and the design basis, . . . are correctly translated into specifications, drawings, procedures and instructions. .These. measures shall include provisions to assure that appropriate _ quality standards are specified and included in
~
design documents and that deviations f rom such standards are controlled.. . . . [T]he design control measures shall provide for verifying or checking the adequacy of design . . . . The verifying or checking process shall.be by individuals or groups other than those who performed the original design, but who may be from the same organization."
V. Instructions, Procedures, and Drawings
" Activities affecting quality shall be prescribed by documented instructions, . . . and shall be accomplished in accordance with these instructions, . . . . Instructions, . . . shall include approp;)e e ' quantitative or qualitative acceptance criteria for deteren.,ng that important activities have been satisf actorily accomplished."
VI. Document Control
'" Measures shall be established to control the issuance of documenis, . . . , including changes thereto, which prescribe all activities af fecting quality. Inese measures shall assure that documents, including changes, are reviewed for adecuacy and approved for release .. . ."
X. Inspe ction "A program for inspection of activities af f ecting quality shall be established and executed by or for the organization perf orming the activity to verify confor=ance with the documented instructions, procedures, and drawings f or accomplishing the activity."
XVII.Ouality Assurance Records
" Sufficient records shall be maintained to furnish evidence of activities affecting quslity. The records shall include . . . the results of reviews, inspections . . . . Inspection . . . records 7
h- m_____._m4___.____ _ . __..___ _ _ _ _ _ _ __ . _ . _ _ . _ _ _
I 71 fe:
c.
R 'shall, as a minimum, identify the inspector or data recorder, the type of observation;, the results, the acceptability . . ."
- 5) The scaling calculation program issued calculations based on an I inadequate engineering definition program in place (and without its
- being maintained current, see I through 4) and without a technical
[
training program for the scaling calculation staff.- This produced indeterminate products. . For example:
a) CECO responsible technical personnel were unable to explain the basic functional usage of the hTL card as applied to the Auxiliary Peedwater system and DCA 88869, Rev. 0., and therefore were unable to adequately explain or analyze the implication of deficiencies.
b) Tne engineering definition for the NPL card requires a specific TROM (programmable read only memory) chip to be uniquely " burned in" and placed in a specific NFL card
.circui: configuration, and in a specific orientation position (can be installed backwards). Neither the scaling calculations nor the WD drawings identify the " burn in" -
program to be utilized or reference the required PROM library.
c) There are f our (4) types of timer modules PROM configurations available for use in the L' westinghouse 7300 printed circuit cards. The scaling calculations do not identify the PROM configurations that must be utilized to support each unique application.
8
.m . .___. -______.____m_
a-k
,e y
d) The PROM chips themselves' are not procedurally controlled,
' including installation, or uniquely identified to prevent their inadvertent use.
10 CFR Part 50, Annendix 3, Criteria Annarentiv Violated:
11.- Quality. Assurance Program
'". . . . (T}he program shall take into account the need for special controls, . . ., and skills to attain the required quality, . . .
. The program shall provide for indoctrination and training of personnel performing activities af f ecting quality as necessary to assure that suitable proficiency is achieved and maintained. The applicant shall regularly review the status and adequacy of the quality assurance program. Management of other organizations participating in the quality assurance program shall regularly review the status and adequacy of that part of the quality assurance program which they are executing."
111. Design Control
" Measures shall be established to assure that applicable regulatory requirements and the design basis, . . . are correctly translated into specifications, drawings, procedures and l' ins tructions. These neasures shall include provisions to assure that appropriate cuality standards are specified and included in design documents and that deviations from such standards are controlled. . . . IT]he design control measures shall provide f or verifying or enecking the adequacy of design . .. ."
V. -Instructions, Procedures , and Drawings
" Activities af fecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, .. .. Instructions, . . . shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisf actorily accomplished."
9 d
- $ W I dPg -
__ m___ .____.______ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
x
'4.
I P. VI. Document Control
" Measures shall be established to control the issuance of
. documents, such as instructions, procedures, and drawings, including changes thereto, which prescribe all activities affecting quality. These measures shall assure that documents, including changes, are reviewed for adequacy and approved for b
release by authorized personnel. . . . Changes to documents shall be reviewed and approved . . . ."
VII. Control of Purchased Material, Equipment,'and Services "Heasures shall be established to assure that purchased . . .
services, . . . conf orm to the procurement documents. These measures shall include . . . , objective evidence of quality furnished by the contractor . . . .
!T]his documentary evidence shall be retained . . . and shall be sufficient to identify the specific requirements, such as codes, standards, or specifications
.. . . The effectiveness of the control of quality by contractors
. . . shall be assessed by the applicant or designee. . ."
VIII. Identification and . Control of Materials, Parts, and Components.
" Measures shall be established f or the identification and control of materials, parts, and components, including partially f abricated assemblies. These measures shall assure that identification is maintained by . . . . , part number, serial number, or other appropriate means, . . . . These identification and control measures snall be designed to prevent the use of incorrect . . . parts and components."
XVI. Corrective Action
'Hessures shall be established to assure that conditions adverse to quality, . . . are promptly identified and corrected."
XVIII. Audits "A comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program and to determine the eff ectiveness of the program. . . . Tollow up action, including re-audit of deficient areas, shall be taken where indicated."
10 0
_m-_m.-_m..-.._ -
41'{
6). There is inadequate. correlation and explanation of setpoints, setpoint sources, and serpoint source revision levels (Scaling Calculation
~
. Manual 8800 'and the scaling calculations). -
1 ..
1 ;'
10 CFR Part 50, Accendix B, Criteria Apparentiv Violated:
L '111. Design Control o " Measures shall be established to assure that applicable regulatory requirements and the design basis, . . . are correctly -
translated into specifications, drawings, procedures and instructions. ' These measures shall include. provisions to assure that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled. '. . . IT)he design control sensures shall provide for l' verifying or checking the adequacy of design . . . . ' The verifying or checking process shall be ,by individuals or groups other than those who performed the eriginal design, but who =ay be f rom the. sane organization."
V. Instructions, Procedures, and Drawings
" Activities af f ecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be acco:plished in accordance with these instructions, .. . . Instructions, . . . shall include appropriate quantitative or qualitative acceptance criteria f or deter =ining that important activities have been satisf actorily acceeplisned."
I; .XVI. Corrective Action
" Measures shall be established to assure that conditions adverse to quality , . . . are promptly identified and corrected."
XVIII. Audits l
"A comprehensive system of planned and periodic audits shall be i carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program. . . . Follow up action, including re-audit of deficient areas, shall be taken where indicated."
11 l
4 i
y J
~
l l
_m____________________________... _ _ _ _ _ _ _
j
" ~ ~
- ..; 4
- 7) ltens are incorrectly referenced or not referenced at all to the
~
engineering source (i.e., card specifications)~ in all scaling
' calculations.
10 CFR Part' 50, Annendix B, Criteria Accarentiv Violated:
lilk Design Control'
'" Measures sh' a ll be established to . assure that applicable regulatory - requirements and the design basis, . . . are correctly translated into r.necifications, drawings, procedures and instructions. Tnese measures shall include provisions -to assure that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled.~ . . '. [T)he design control measures shall provide for verifying or checking the adequacy of design . . . . The-verifying or checking process shall be by individuals or groups -
other than those who _ perf ormed the o'riginal design, but who may be f rom the same organization."
V. Instructions, Procedures, and Drawings
" Activities aff ecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the' circumstances and shall be accomplished in accordance with these instructions, .. .. Instructions, . . . shall include appropriate,, quantitative or qualitative acceptance criteria f or determining that important activities have been satisf actorily
-"* ac co=plished."
XV1. Corrective Action
" Measures shall be established to assure that conditions adverse to quality , . . . are pro =ptly identified and corrected."
XVIII. Audits a
^
"A comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program and to determine the eff ectiveness of the program. . .. . Follow up action, including re-audit of deficient areas, shall be taken where indicated."
12
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ . _ . _ _ _ _ _ _ _ _ . _ _ .__. _ . _ _ . _ . _ _ . _ _ _ _ . _ _ _ _ _ _ ___o
.:g
[t ?;_4 :
c w., ,
- 8) LThe'use of " Confirmation Required" to' expedite issuance of incomplete
' and/orTinaccurate scaling calculations. (all), rather than selected i
items, appears to have been utilized to meet schedule commitments. In
- addition,- the' " Confirmation Required" was applied unevenly to calculations that perform identical functions. To date, this type of situation has not been-corrected on the calculations.
'10' CFR Part 50. Apnendix B, Criteria Annarentiv Violated:
'1. . Organization-
".'. . [T)he applicant may delegate to others, such as contractors, . . . the work of establishing and executing the
- quality assurance _ program, or any part thereof, but shall retain responsibility therefore. .. . IT}he~ quality assurance functions are those of (a') assuring tnat an apptcpriate quality assurance program is established and ef f ectively executed and (b) verif ying, such as by checking, auditing, and inspection, that activities affecting the saf ety-related functions have been correctly perfo rmed. The persons and organizations performing quality
. assurance functions shall have sufficient authority . . . to identify quality problems; to initiate, recommend, or provide solutions; . . . , li)ncluding sufficient independence from cost and senedule wnen opposed to saf ety considerations, are provided."
11.- Quality Assurance Program
". . . IT}he program shall provide for indoctrination and training of personnel performing activities aff ecting quality as necessary tc assure that suitable proficiency is achieved and maintained."
III. Design Control
". . 1T}hese measures shall include provisions to assure that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled. . . . [T]he design control measures shall" provide for verifying or checking the adequacy of design . ...
13 e
. . _ . _ --_i__..____._____.-____ _
. . .o .
. l o'
' ' . s 4 , ;t3 .. . ,
- N V. : Instructions, Procedures, and Drawings
> " Instructions. . . . .' . shall include approptNe quantitative or -
,3 qualitative acceptance criteria for determining that important i activities have been satisfactorily accomplished."
3
- 9) Processes exist that are indicative of progran problems; for example, the review and verification process of scaling calculations is
. .. % r ,s ,,
,9
. . . ,a, , ,, ,
performed to draf t handwritten calculations and notes prior to the
. documents being signed by anyone. Review of handwritten notes and calculations before formalization does not provide the assurance that
- 3. .
' items or facts will not be altered prior to signoff. The intent of the
- .y b
.c~; a -
L
- a .- . signoff is to confirm that information contained. in the document was in fact reviewed.. If a documment requires further review af ter formal '
processing (i.e., typing), why review draf t work? It appears little, if any, further review takes place, as evidenced by the signature
. dates.
10 CTR Part 50, Appendix B, Criteria Apparentiv Violated:
III. Design Control
" Measures shall be established to assure that applicable regulatory requirements and the design basis, . . . are correctly translated into .. . . instructions."
VI. Document Control
" Measures shall be established to control the issuance of documents, . . . . which prescribe all activities af f eeting quality."
14 4
9 n O
u > q*
,Q~' ,
,X ; ,
' .U
- h. 4 i e [ d, } *- ( '
n;. .: my. :
, s ._. .m
, 1Y110mality Assurance Records E UN" '
b
" Sufficient records shall be-maintained to furnish evidence of i activities affecting~ quality."' j
~ 10) .It is' evident, on the basis of the audit (ATP-89-1465) that SWEC 4
concentrated on scaling calculations only.- It is my understanding that s a detailed review of other supporting documents was requested and
, ,~ : .n -,.v. -n a n g.<
required by TU Electric (Brian Haynes)'in a' TU Electric /SWEC meeting (with Bill Smith) on or about December,1986. TU Electric (G. .i Creamer /B. Haynes) instructed SWEC to address the scaling calculations and all- supporting documents with emphasis on the interaction between 7 _ _
May , qi;;F ,
the calculations and the referenced supporting documentation (basis), i i
and to clean up the problems associated with the drawings .(also see item 1). . There has been no evidence presented to CASE that this has been done as of September 9,1989.
l 10 CFR Part 50. Apoendix B, Criteria Accarentiv Violated:
- 1. Organization
". . . IT]he applicant inay delegate to others, such as contractors, . . . the work of establishing and executing the quality assurance program, or any part thereof, but shall retain responsibility therefore. . .. . [T]he quality assurance functions are those of (a) assuring that an appropriate quality assurance program is established and ef fectively executed and (b) verifying, such as by checking, auditing, and inspection, that activities affecting the safety-related functions have been correctly performed. The persons and organizations performing quality
' assurance functions shall have sufficient authority . . . to identify quality problems; to initiate, recommend, or provide
" solutions; . . . , li]ncluding sufficient independence from cost and schedule when opposed to safety considerations, are provided."
1.
n 15 t
o
s,c
- 7h c
W '" .c I r . .,
'=t;
, gth (;jy. ;e
' t S4 ,
yX .
- 11. -Quality Assurance Prograa '
'". .c. [T]he applicant shall regularly review the status and 3
. . adequacy of the quality assurance progras. Management of.other
[(fJ. organizations participating in the quality assurance program shall regularly review;the status and, adequacy. of that part of. the
.[ quality assurance program which they are executing."
III. Design Control ,
p, , m,4 . . < - .
- p. ,
ie "Heasures shall be established to assure' that. applicable regulatory requirements and the design basis.. .. .. ..are correctly translated.into specifications,' drawings, procedures and instructions.- These measures shall include provisions to assure that' appropriate quality: standards are specified and included in design documents and that ' deviations' from such standards are controlled. . .- .- [T]he. design control measures- shall provide'for E
" _ verifying or checking the adequacy of design... ..... TheQing ..
verifying or, checking process shall be by individuals or groups" .
other than those who performed the origin.s1 design, but who.say be
'f rom the same organization."
V. . instructions, Procedures, and Drawings
" Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions. . . . . Instructions, . . shall include
_ appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisf actorily accomplished."
VI. Document Control
" Measures shall be established to control the issuance of documents, such as instructions, procedures, and drawings, including changes thereto, which prescribe all activities affecting quality. These measures shall assure that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel. . . . Changes to documents shall E
be reviewed and approved . . . ."
VII. Control of Purchased Material, Equipment, and Services
" Measures shall be established to assure that purchased . . .
. services, . . . conform to the procurement documents. These l
16 (
i i
i .i k
- I
! ., f ' .
(*~ ,j O
measures shall include provisions, as appropriate for . . .,
objective evidence of quality furnished by the contractor . . . . . 1 The effectiveness of the control of quality by contractors and I subcontractors shall be assessed by the applicant or designee. . ." '
l XVI. Corrective Action "Hemsures shall be established to assure that conditions adverse to quality, . . . are promptly identified and corrected."
XVII.Ouality Assurance Records L
" Sufficient records shall be maintained to furnish evidence of activities affecting quality."
XVIII. Audits /
"A comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the.
program. . . . Follow up action, including re-audit of deficient areas, shall be taken where indicated."
Diary Review During review of Mr. Bodif ord's personal diary, it was noted that on May 30, 1987, he made the following comment: "The documentation is incorrect and no one is willing to spend time or money to fix this problem (in a comprehensive manner - not piece meal)." Audit ATP-89-146S and technical reviews to date indicate that this problem still exists almost two-and-one-half years later. Also, on May 27, 1987, and again on June 2,1987, Mr.
-Bodiford reported incorrect wide range RDF/RTD serial numbers and subsequent scaling problems with the actual hardware received and the WCAP 9696 (Sect.
- 11) scaling calculation manual. Audit ATP-89-146S verified that this issue still remains today.
17
_._______..____m._____.___:..___._____-_.____._.___.-_.____m_ ..__. -
,. 4 -
.] 1
+ . + x 4 !
y,r ,.-
[
b ,. .
Aa, entry made on June 5,1987, indicated that the drawings were still l
incorrect and that no_ one!" Fisher, Reynolds, Nevins, St. John, Smith, Shah ~'
aNLlor akk (TUE). Haynes . (TUE)" was lwilling to make the drawinge _ correct. To.the best of my knowledge, there has been no corrective action as of September 9, 1989.
10 CFR Part 50, Appendix 11. Criteria' Apparentiv Violatedt 1 h '
I.- .
-Organization
". . . .L IT]he' applicant may delegate to others, such as contractors, . . . the work of establishing and executing the quality assurance program,- or any part thereof, but shall retain responsibility _ therefore. . . . IT]he quality assurancer functions.
L are those of (a) assuring that an appropriate quality assurance I
program is established and: ef fectively executed and (b)' verifying, z such 'as by checking, auditing, and inspection, that activities affecting the safety-related functions have been correctly perf ormed. .The persons and organizations performing quality assurance functions shall have sufficient authority . . . _ to identify quality problems; to initiate, recommend, or, provide solutions; . . . _ , li]ncluding sufficient independence from cost and' schedule when opposed to saf ety considerations, are provided."
XVI. Corrective Action
" Measures shall .be established to assure that conditions- adverse
' to quality . . . . are promptly identified and corrected."
XVII.Ouality Assuraw Records
'" Sufficient records shall be maintained to furnish evidence of activities af f ecting quality."
XVIII. Audits . I "A comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program. . . . Follow up action, including re-audit of deficient areas, shall be taken where indicated."
18
_ _ wa m et .t.-m e.m_mw:n .nr _ _me m .*s.c e _________.__________._______.______..._______._.-_________
- ?g l,
Engineers, performing in a strictly engineering function (design /
development).. of ten find themselvea in a position to justify, from a technical compliance standpoint, what has been previously implemented. It 4 is my understanding that the TAP organization is primarily made up of design engineers, performing technical audits from a technical viewpoint (i.e., is the activity practical and does it exhibit accepta'ble engineering l principles?). Although they do have a general understanding of the OA program and that quality . records must be available to prove the engineering position,10 CFR'Part 50, Appendix B, is not, in my opinion, the criteria which forma the basia of their QA compliance audits. This premise therefore forms the basic difference of opinion between CASE and TU Electric reFarding the subject matter.
It should be noted that the TU Electric OA Audit Plan for TAP Audit ATP-89-1465 references 10 CFR Part ' 50, Appendix B, as one of the applicable Reference Codes and Standards ( ANSI N45.2.11-1973 was the other) to form the basis of the criteria governing the audit.
The following matrix, therefore, has been compiled to show that, in my opinion, a widespread breakdown in 10 CFR 50, Appendix B, implementation has occurred, and indeed continues today, in the scaling calculation program.
This matrix directly correlates to the items indicated below and discussed on pages 2 through 18 preceeding.
19
, u, .n n ; ' ' a;( .
_,-.- 1 f
- I ITEM i APPENDIX B C112XRION AFFECTED - ,
r.
I II III- V '
VI 'VII'IVIII X l XVI IXVII' XVIII I) X X X X X (overall) 2) X X X X' X~ X 2-a) (X) (X) (X)
'2-b) (X) (X) (I) ~(X) -
2-c) -
(X) (X)- -(I)- (X)
I- 3)' X X X f(overall) 4) X X X X X 4-a) -(X) (X) i .
b) (X) (X) (X) 4-c) (X) (X) (X)
'4-d) (X)
'4-e) (X) (X) (X) 4-f)' (X) (X) (X) l
- 5) X X X X X X 1 X X r 5-a) (X) (X) (X) (X) (X) 5-b) (X) (X) (X) (X) (X) (X) (X) 5-c) (X) (X) (X) (X) (X) (X) 5-d) (X) (X)
- 6) X X X X
- 7) X X X X
- 8) X X X X
- 9) X X X
- 10) X X X X X X X X X (Diary Review) X X X X 20 :
I
(. . Le - l C ' ' 9/ \
" xe j
3 l
TU Electric, as the licensee, has the ultimate responsibility to ascertain that the construction, testing, inspection, and operation of j i
)
Comanche Peak Steam Electric. Station complies with the requirements as set .{
- forth in 10 CFR Part 50, Appendix B, which procedurally (NEO 3.25) includes the-issuance of a Stop Work Order when appropriate. As is allowed by Appendix B, and is customary in the industry, the sharing of this OA.
responsibility may be delegated to others.. At CPSES, it has been delegated to CECO, SWEC, and previously Gibbs & 11111, and etners. It is my professional opinion- that the present organizations have failed to recognize q f
the symptoms (criteria) that constitute a programmatic breakdown which warrants an immedia'te Stop Kork Order in order to assess. the overall problem, icplecent corrective action, and sucsecuently gain control of tne activity. ' It is most disconcerting that TU Electric and other responsible organizations appear to be lacking in a full understanding of the requirements of 10 CFR Part 50, Appendix B, especially with the anticipated
' fuel load date of October 1989, and in view of tne past histery of this particular scaling calculation program.
General Concludine Comments
- 1) The audits and surveillance ref erenced in response to item 1 of this report are contained in SWEC letter SWTU-9733, dated August 1, 1958.
These reviews were of a narrow focus which did not encompass the aggregate issues previously identified by Mr. Bodif ord, as evidenced by the results of the current TAP audit ( ATP-89-146S) and technical resolution meeting commitments. From my preliminary review of the SWEC 21
' *) g _
.F
- 4 u*
1 ,
- response = letter, the. response 1 appears to be incorrect in certain areas, incomplete in' others 'and contains com=itments that have not been resolved- to date. CASE's overlying questions here are:
a) If all' the.. audits, etc., referenced in SWTU-9733 and previous TAP
- Audit'- ATP-88-105, conducted f rom July. 20 through September 7, 1988, were 'in f act complete, accurate , and thorough reviews, how
-is'it that the programmatic and technical problems identified in the current audit- ( ATP-89-14 6 5) , with the NFL card configuration and the scaling calculation, were not previously addressed in the years following 1987?
b) DBD-EE-032,. the . Scaling Manual SC-8600 and Appendices "H" and "I"
are deficient. Additionally. Westinghouse MSSS documentation (i.e. , specification sheets, WCAP 9696) have not been updated.
How can auditors perf orm an accurate and thorough audit with deficient or out-of-date governirg documents?
m.
?
c) If. the scaling program were adecuate, why have the deficiencies in ATP-BE-90 (03, OB) identified en March 16, 1988, not been corrected?
- 2) The only spe:ific technical question presented by CASE to TU Electric could not be answered by the responsible engineers (see item Sa). The technical solution presented oy TU Electric did not work. The question
' asked by CASE was, "How does this card work?" The engineer responded, "We called the field and they said they could make it work." A safety-
- related 'DCA was approved and signed of f without technical justification E
l but. based on the assurance that the I&C technician could make it work.
22 1.
I m___ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ . _ .___ _ _ . _
g_ .. - , _
- 3. . ; _
- $ n; jo ,
i
.j
<*; a ,
.This is a l serious deficient condition. . The scaling calculation
,provides. the engineering implementation- of the. design basis, which is
.. then reviewed and-verified -- not lef t open to interpretation. A subsequent. review, of the current scaling calculation showed 'no m
configuration' control in this area.
- 3) ( According to Mr. ~ Bodif ord, during the time , of his employment at CPSES, .
a general intimidating atmosphere existed in his department. No actions have been taken to resolve the existence or implications of this atmosphere or even to determine:if it existed as he claims. CASE
- is ' concerned that a similar condition still may, exist. today, as evidenced : by a comment recently of f ered by 'an employee who stated ne was " directed to sign of f a' document under curess by t his) supervisor."
.This , intimidating condition, in conjunction with a ceficient scaling i- calculation / documentation review program, does not provide CASE.With the assurance that the programmatic problems identified to date will not adversely affett the cperation of the saf ety-related systems.
~
s 23
= = __ ______ _-____- - --_ _ - - - _ _ ._ -.
'or G
p %:
m.~ .,
l 4 I
4 CONCLUSION g -
'In summary, it is clear to me, ~on the basis of all- the documentation i.
reviewed to date-(i.e., the Bodiford personal log, Project correspondence, SAFETEAM transcript and file, -etc.), that the individual and aggregate p
. issues were clearly- identified to TU Electric and SWEC, at least by'1987.
It is also clear that these same issues have not been resolved. as of b ,
- September 9,1989.
[ This is particularly serious because the same problems with. the piccram r ..
. purportedly were being addressed by Gibbs & 11111 prior to the assumption of the work by SWEC.
Audit ATP-89-146S and CASE's evaluation ~ of Mr. Bodif ord's issues have (verified the repeated f ailure of the scaling calculation / documentation review program to perform adequately and fulfill its intended purpose.
Audit ATP-89-1465 and CASE's assessment have further verified that many of the previously identified and validated programmatic deficiencies were not even addressed as had ceen indicated in TU Electric letter NE-1909' cated 5/10/BS, much less corrected. In addition, it is disturbing to CASE that n' Electric, at this late date, still exhibits an unwillingness and s or
' inability to recognize and deal with the f ailure of this program.
The inability of TU Electric to cognizantly recognize this programmatic breakdown, and their f ailure to track and implement previous corrective action commitments, clearly indicates the critical necessity f or a stop work order to be issued immediately. It is crucial that TU Electric management assess this issue for encompassing corrective action and generic Y implications f or other program areas.
24 e L_L_..___.L_ . - . . - - - - _ _ _ _ - . _ . . - - . .
-~ "
y t'ft _CO. f , 3' c ' 2 s
3
[$ ghb N p.. NT e( -
1
-lv . .
- 4 m se "
. ENCLOSURE'2 8 : p TO:' Bi Pi Garde 5 'FROM: ;0.;L. Thero y :m DATE:: 9/18/89
'SbBJECT._ReviewandCommentstothe,T Electric Draft Action Plan
.(undated and unsigned)'
The subject plan appears -to be a compilation of the verbal commitments 4 . presented lto CASE .(G. Bodiford/0. Thero) during a tecnnical meeting v held.on 8/25/89. 1The; plan. basically addresses the questions documented to Susan Palmer on August 6,1989, regarding DBD-EE-032 and other t'echnical' issues. .Our report responds ' to each item number on the draf t:
~
plan, withithe subsets (dashes) identified as a),.b), c), etc.
- 1) The: Scaling Calculation Manual referred to should be identified as the TU Electric Manual SC-8800. -" Specific revisions will:" should be
. changed to". . . " Specific revisions will include, but- not be limited to:"
a) ~ Generally,'we disagree.with the stated intent to " Clarify-the role 1
of Westinghouse NSSS specification." TU committed to do more than " clarify". 'As.we recall, they agreed to perform an engineering review of the specifications and to control them m
. Ithrough the Dccument Control System.
b) -We Lalso disagree with the stated intent to: " Clarify the role of WCAP-9696". The document should be stated as: " Scaling Calculation Manual VCAP-9696, and Supplements." Also, more than a 1
i mA.2-_.----.%,s.n_-.- - . _ _ - - . -,. .- m-
~
0 1~
G l
~ >
i I
. a
}
the manual is accomplished, appropriate data can be extracted from the DBD and incorporated 17 the manual.
- 2) Totally agree with this item.
l l 3) This item directly interfaces with item 1.c above. The training should I
include the application of the documents (by type) and how the drawings work.
- 4) This item f alls short of committing TU Electric to implementing a total programmatic and technical corrective action progran pric: to reviewinr, all safety-related scaling calculations. Also, there is the disturbing ca cat (as necessary) added to the committed action to have all saf ety-i related scaling calculations revised prior to fuel load. If the "as necessary" comment only applies to the revision of the deficient scaling calculations, and not to the fact all safety-related calculations must be reviewed, then we have no problem with the caveat.
It must be made clear, however, that tne propratmatic corrective actions nust be in place, and ef f ect.ive , prior to reviewing anc revising the safety-related calculations.
- 5) The same issues for non-safety related scaling calculations apply as indicated in item 4 above. In our opinion, the existing first scntence i should be changed as f ollows: . .. It] hey are technically correct and meet the upgraded program procedural requirements resulting f rom the corrective cetion measures taken."
- 6) This item coes not describe where the NCH and NCB card issues "will be addressed". Our position is these issues could be addressed in the Set Point Calculations and possibly included in Appendix H.
3
o.
p
. - r, O.
/
7 )'. This item is, limited to WPT lettera only. The' type of a review
, proposed in this item should-include all other miscellaneous-
- correspondence and documents that' transf er :inf ormation. Shop Orders
?, 320, 325, 395, etc., should also be reviewed to verify that all i.
sections are still appropriate. This would require that the entire P1P.
be reviewed by shop order for drawing applicability and when i
applicable, control those documents through the DCA/DCC System. When p 3 the documents are not. applicable, they should at a minieuc, be annotated a "Information Only".
'B) Items Ba, b, e, f are restatements of items 4 and 5. This item (8) must be performed prior to items 4 and 5 being accomplished. Item c) should be more than just makin;; sure that the DCA' program is "in compliance with Project procedures." The DCA procedure appears to be deficient in that consideration is not given to timeliness (3-6 months) prior to document update. Additionally, DCA's involving multiple documents, issues and pages should be assessed individually f or incorporation.
e) This item should also address confirmation / validation to Appendix "I".
f) " Instrumentation data sheets" should be changed to
" Instrumentation specification data sheets."
- 9) No comment, except that so f ar, the OA TAP organization has l
demonstrated a reluctance to aggressively implement their project procedures. Also, if past perf ormance is any indication, reported deficiencies could be open for at least several months, or years.
1 4
i
-m _ _ . _ _ _ _ . _ _ _ . _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.y _-
' .. a- - ,-
- j -l/l -
Li!.
' . g .-_
-s ,
-(
I 5 'Iqk I
The closir.; para,traph is not acceptable. It states in part: "1.1.'
action itemr, cefined above vill ne completed trior to f ue; ioad except for Item 5 an rossibly Item 5." 1; is mancatory tna iter. o be resolved prior to f uel load. The ocficiencies identified to date ceal witn casically trograccati: issues tna form the framework for an
.cffe::1ve ar.c con:r:11c; s r n m cal:uit.u tn cro:rce.
cc: Juanita Ellis Gary bodiferd s Ecna 0: tnt:.
l\
5
--m- _____mm_____ _ _ _ . . _ _ _ . _ _ _ _ _ _ _ _ _ _