View source for TXX-1008, Forwards Response to Case Documented Request for Action: Unit 1 1982 RCS Primary Cold Hydrostatic Test. Util Requests That NRC Deny Requested Relief in Accordance W/ Joint Stipulation

{{Adams
| number = ML20246H680
| issue date = 05/09/1989
| title = Forwards Response to Case Documented Request for Action: Unit 1 1982 RCS Primary Cold Hydrostatic Test. Util Requests That NRC Deny Requested Relief in Accordance W/ Joint Stipulation
| author name = Counsil W
| author affiliation = TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
| addressee name = Grimes C
| addressee affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| docket = 05000445
| license number = 
| contact person = 
| document report number = TXX-10086, NUDOCS 8905160165
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 26
}}

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       .g-M """"                                                   1 EE Lo    # TXX-89179 Fi e # 10086
                                                                          =          =.                                           q lilELECTRIC                                                  1 I
May 9, 1989 William G.Counell Vke Chairman .
U. S. Nuclear Regulatory Commission Attn:' Christopher I. Grimes, Director Comanche Peak Project Division Office of Nuclear Reactor Regulation Washington, D.C.          20555

==SUBJECT:==
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES).
DOCKET N0. 50-445                                                                      )
DOCUMENTED REQUEST-FOR ACTION' UNIT 1 1982 REACTOR COOLANT SYSTEM PRIMARY COLD HYDR 0 STATIC TEST FILED BY CITIZENS ASSOCIATION FOR SOUND ENERGY (CASE)

==Dear Mr. Grimes:==

Pursuant to Section B.4 of the June 30, 1988, Joint Stipulation among CASE, TV Electric and the NRC Staff, TV Electric hereby submits its response to CASE's " Documented Request for Action: Unit 1 1982 Reactor Coolant System Primary Cold Hydrostatic Test" (Request for Action).
As you know, TV Electric has performed an extensive assessment of the 1982 RCS. Cold Hydrostatic Test and has provided comprehensive information'regarding its acceptability
                          -Standards (TDLS)y             to the NRC.and in ER-ME-01                 to the Texas and TXX-88575,           and atDepartment a number ofof. Labor and public        ,
meetings. In addition, in TXX-89007, TV Electric agreed to incorporate                                   )
additional requirements into the hot functional test that is currently being conducted.          On the basis of all of this information and their own thorough reviews, the 1982 RCS Cold Hydrostatic Test was accepted by the NRC in their {{letter dated|date=December 5, 1988|text=letter dated December 5,1988}} and by the TDLS in their {{letter dated|date=February 14, 1989|text=letter dated February 14, 1989}}.
While these reviews by the NRC and the TDLS were taking place, TV Electric was
      .,g                  also responding .to numerous questions raised by CASE in its Inquiry 88-0001 eo                  (provided to TV Electric in November 1988). CASE's inquiry and j$@                    TV Electric's response (January 12,1989) were available to the NRC and TDLS
    .go                    as they were reaching their conclusions.
o~ln Mo                    Although the responsive process between TV Electric and CASE resulted in the Lg                    resolution of almost all of CASE's original inquiry items, its Request for o                   Action identifies three residual issues. While the Request for Action j@ .                   contains some new information developed by CASE's consultants, the questions
_g                     it ' raises are very similar to those previously responded to by TV Electric.
oce                   In our view the Regt.est for Action does not raise any matters of substance not
    .@@g                   previously addressed by TV Electric and considered by the NRC and TDLS, within their own jurisdictional interest. Nevertheless, we have prepared the enclosed detailed responses to CASE's three issues in order to assure thet the record on these matters is clear.
2001 Bryan Tower Dallas. Texas 75201

e n.
o                                                                                                i TXX-89179 May 9, 1989                                                                                 I Page 2 of 3                                                                                 I CASE's basic claim is that it has uncovered substantial evidence to establish "that the 1982 Reactor Coolant System Primary Cold Hydrostatic Test did not fully _ satisfy ASME Section 111 and other procedural and regulatory requirements." (LetterfromCASEtoNRC'datedMarch 13, 1989, p. 3.) To the contrary, as shown in ER-ME-01 and TXX-88575, TV Electric's. thorough technical assessment in 1988 confirmed the adequacy of the RCS Cold Hydrostatic Test and l~                       its satisfaction of ASME Code and NRC substantive requirements. CASE's review
;                       has focused not on substantive technical requirements, but on a number of questions concerning aspects of the test documentation ~that were not a i                       necessary part of the TV Electric's technical assessment. As shown in the l                       enclosed detailed responses and prior TV Electric submittals, the RCS Cold Hydrostatic Test satisfied ASME Code and NRC documentation requirements, with minor exceptions that do not affect the acceptability of the test. Thus,.
neither of CASE's requested actions is warranted; there is no substantive reason to reperform the 1982 test and there is no ASME Code violation for which a code case exception should be sought from the ASME board.
TV Electric is pleased to note that in Phase 1 of the report filed by CASE Consultant, Jack Doyle, " Technical Evaluation of CPSES 1982 Hydrostatic. Test and ASME Section XI VT-2 Test," (Doyle Report), he concluded that he could
                        " find no _ problems of a technical nature from [his] perspective which would invalidate the July 1982 hydro test of the RCS..."1/ Mr. Doyle's favorable Phase 1 conclusion as to the acceptability of the 1982 results is subject to his understanding that any spool pieces subsequently changed on the primary side have been hydroed to the prevailing codes and procedures. (Doyle Report,
: p. 10.) This understanding is correct.
In Phase 2 of his report, Mr. Doyle also favorably concludes that the ASME Section XI hydrostatic test "will provide a high level of confidence in the acceptability for the Reactor Coolant System...," as long as appropriate procedures are established for the test and are properly implemented. (Doyle Report, p. 17.) The procedures for the ASME Section XI hydrostatic test were provided to the NRC, TDLS and Mr. Doyle for their review, and their comments were taken into account prior to performance of the test. In addition, the NRC, TDLS and Mr. Doyle had the opportunity to observe the performance of the ASME Section XI hydrostatic test. TV Electric is confident that both of Mr. Doyle's provisos have been satisfied.
CASE also submitted a report by its other consultants, Quality Technology Company (QTC), entitled " Evaluation of the Texas Utilities Comanche Peak Steam Electric Station Reactor Coolant System Primary Cold Hydrostatic Test" (QTC Report). TV Electric has reviewed the QTC Report and established that none of the QTC items affects the validity of the 1982 RCS Cold Hydrostatic Test. To the extent that CASE relies upon the QTC Report to support its request for NRC 1/ Although Mr. Doyle made no attempt to determine the quality of the documentation associated with the test, as shown by TV Electric the ~
documentation deviations do not affect the validity of the test.
i
                                                                                      -__--.-_-.__-____-a

l 1.
l-                                     s-TXX-89179 May 9, 1989                                                                      l Page 3 of 3 actions, TV Electric addresses those portions of the QTC Report in the         i attached response to CASE's Issue 2. In addition, TV Electric, in accordance with its standard procedures, has addressed the documentation discrepancies cited in the Request for Action. 2/
Since the attached responses demonstrate that CASE's Request for Action provides no substantive new information and raises no significant unanswered questions, TV Electric requests that you deny the requested relief in accordance with the Joint Stipulation.
Very truly yours,   ,
d    ??(//
William G. Counsil DAR/grp Attachment c - Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3) 2/   TV Electric has also addressed other documentation concerns specifically identified in the QTC Report. Regarding other items discussed in the QTC Report which were not cited in the Request for Action, CASE advised the NRC in its {{letter dated|date=March 17, 1989|text=March 17, 1989, letter}} forwarding the QTC Report that CASE will be discussing further with TV Electric those issues CASE considers to be indeterminate. Many such items have already been responded to by TV Electric in presentations to the NRC, TDLS, or CASE. TV Electric will disposition any item which CASE informs TV Electric is still open and for which CASE provides a documented concern.

    .- Attachment to TXX-89179
  . May 9, 1989 3    Page 1 of 23 TV ELECTRIC'S RESPONSE TO RCS COLD HYDR 0 ISSUE I Stated Issue
       " Texas Utilities (TV) cannot provide objective evidence that all welded joints, welded connections, base metal repairs involving welding, and all regions of high stress (such as elbows, tees, reducers, flanges, fittings,                                                        ,
etc.) were inspected to ASME Section III and associated standards, and that                                                       I these locations and components will withstand normal and postulated accident stresses when the plant becomes operational." (Request, p. 1) in support of Issue I, CASE cites a number of regulations, codes, standards and procedures (Request, pp. 2-3); provides several specific arguments (Request, pp. 3-4); identifies some supportive information (Request, pp. 4-5);
and states its conclusion (Request, p. 5).
TV Electric provides below its response to each of the foregoing portions of Issue 1.                                                                                                                          >
A. Cited Regulations, Codes, Standards and Procedures 1
The regulations, codes, standards and procedures cited by CASE (Request, pp. 2-3) were reviewed. The following clarifications are necessary:
: 1. The quotation attributed to ASME Section III, NX-6224 does not appear                                                   4 there. The cited paragraph reads: "...all joints, connections, and regions of high stress ...shall be 4 xamined for leakage..." (1980 Edition through Summer 81 Addendum). CASE's quotation is apparently taken from CP-QAP-12.2, Revision 3.
: 2. Requirements for inspection planning and inspection results documentation are identified as being quoted from ANSI N45.2.6, Section 2.1 and Section 2.3, respectively. Instead, it appears that the quotations are taken from ANSI N45.2.8. However, N45.2.8. is not                                                    i applicable. As stated in CPSES FSAR Tables 1A(N) and 1A(B), USNRC                                                       l Regulatory Guide 1.116, which endorses the use of ANSI N45.2.8., is not applicable to CPSES during the Design and Construction phase of the project. Furthermore, ANSI N45.2.8-1975 itself states, in part, in Section 1.2 (Applicability), "...this standard does not apply to activities covered by Section III Division 1 and 2 and Section XI of the [ASME] Code for those activities covered by the Code."
: 3. The section of ANSI N45.2.9 (Draft 11, Revision 3)-1973 Appendix A which specifies lifetime retention of Hydrostatic Pressure Test Procedures and Results is A.S. Section A.3 discusses retention of Manufacturing Records, including Pressure Test Procedures and
,                Results, and is not applicable to this issue. Section A.6.1 discusses Operation, Maintenance, and Testing Records and is not i                applicable to this issue.
1 1

H      #       Attachment-to TXX-89179 May 9, 1989
    */         Page_2 of 23 B.- Specific CASE Arguments On pages 3-4 of the' Request, CASE first restates Issue I ("TV Electric cannot provide, objective evidence . . ."), then presents what appear to be.
three basic arguments:
                    " [1. ] -  Although TV Electric's applicable governing. documents. correctly stipulated that no leakage was allowed from the' required areas and items of inspections, no additional proceduralized instruction criteria was provided to any of the Quality Control (QC) Inspectors by way of on-the-job training, inspection check lists, walkdown inspection sheets, or other specified documentation.       (See Pressure Data Sheet Attachments, and TV's response to CI-88-0001, Items.26 and '33.) No inspection data is available that ascertains how the requirements of ASME, Section III, associated standards, and other regulatory requirements were actually met.
[2.]      ' Additionally, no individual QC Inspector's signature attests to his/her own areas of inspection. Instead, the Pressure Data Sheet Attachments (11) were signed by a QC Lead or Alternate Inspector or another QC Inspector, on behalf of all the team members.       The typed names of the QC Inspectors appearing on the-Pressure Data Sheet Attachments are not necessarily those of the
                              -inspectors that were involved with the test. Therefore, the signatures on the Pressure Data Sheets mean virtually nothing at this stage.
[3.].      Finally, given the nature of the task, the test conditions and parameters, together with the lack of objective evidence, CASE believes it is impossible to verify compliance to 1982 Codes, standards, and regulatory requirements based on the historical memory as presented by TV Electric officials and engineers'in 1988."
TV Electric's response to each argument follows.
Argument 1 Although it is unclear what CASE means by referring to an alleged lack of
                   " additional proceduralized instruction criteria," as TV Electric understands CASE's first argument, it appears to criticize the conduct of the 1982 RCS Cold Hydrostatic Test for: lack of sufficient direction to QC Inspectors (" inspection check lists, walkdown inspection sheets, or other specified documentation"); lack of "on-the-job training" for QC Inspectors; and lack of resulting " inspection data."
As summarized in ER-ME-01 and TXX-88575, TV Electric concluded that the RCS Cold Hydrostatic Test was completed utilizing procedures which complied with the requirements of ASME Section III and therefore were adequate to control the activity. These hydrostatic test procedures l
required that the specific test boundary be examined by appropriately                    '
qualified and certified Quality Control Inspectors for the absence of
_    _   - - _- -_ A

Attachment to TXX-89179                                                                 l''
                                   .May.9, 1989 Page 3 of 23' leakage of the test medium at welded connections, base metal repairs involving welding and regions of high stress. The acceptance of this hydrostatic test was. documented on the applicable flow diagrams, Pressure Test Data Sheet and Quality Checklist as required by CP-CPM-6.91 and CP.-QAP-12.2.. These procedures provide the necessary acceptance criteria and test acceptance guidelines as required by the ASME Code.
Gi'ven that the RCS Hydrostatic Test boundary was extensive, it was divided into a series of smaller areas for inspection purposes. The Pressure Data Sheet; Attachment was.used to facilitate test completion by allowing an inspector assigned to a given area to document the results of his/her-team inspection for.that area on a separate document. These documents, along-with other documents, then provided a basis for final test acceptance E                                                 signoff as procedurally required on the Pressure Test Data Sheet. The Pressure Data Sheet Attachment was not required by procedure and was not necessary to fulfill an ASME Code requirement because final acceptance of the test was to be, and in fact was, appropriately documented on the Pressure Test Data Sheet and Quality Checklist. However, use of the Pressure Data Sheet Attachment in this case, where the test boundary was extensive, documented in a more complete and auditable fashion the manner in which the associated inspections were conducted. The ASME Code does-not require additional direction to QC Inspectors (i.e., additional inspection or instruction criteria and inspection checklists) than what was developed and used at CPSES to inspect and subsequently to accept the RCS Cold Hydrostatic Test.
With respect to training of the QC Inspectors it should be emphasized that the QC Inspectors assigned to participate in the RCS Cold Hydrostatic Test inspection were certified Level 11 MIFI inspectors. The Mechanical Fabrication Inspection (MIFI) certification encompasses the inspection of pipe'and hanger fabrication, welding process control, pipe and hanger installation, post weld heat treatment, pressure testing and other related special processes. During the certification process,.among the specific qualification areas addressed for pressure testing are the purpose of pressure testing; methods used; general and specific requirements regarding test media, pre-test requirements, press';; e gauges, and system inspection for pressure, leakage, and weeping or leaking at valve packing; and documentation. To be certified as a Level 11, an individual must meet the required education and experience level, complete specific training requirements (including formal training, on-the-job training, and procedure requirements training), and successfully complete a comprehensive examination which assesses an individual's general, specific,'and practical knowledge of the inspection area to the satisfaction of a Mechanical Le el Ill inspector. Upon completion of the qualification requirements, the individual's credentials are presented to a Level III inspector for documented certification.        Subsequent to this certification, the individual maintains proficiency of knowledge through training in procedure revisions. Satisfactory performance is required for decertification.
_ _ _ _ _ ___.___ _ _ _                                                                                   )

   ' ' ,               Attachment to TXX-89179 May 9, 1989 Page 4 of 23 Satisfaction of the foregoing requirements for a Level II inspector was, in itself, sufficient to assure that the inspectors were properly trained for the 1982 RCS Cold Hydrostatic Test.       However, extensive preparations were made for the conduct of the test, including dry runs to familiarize inspectors with their assigned inspection areas. An initial dry run of the RCS Cold Hydrostatic Test inspection was held on June 14, 1982.
Thereafter, dry runs were continued weekly up to implementation of the
                           ' test.
Finally, TV Electric disagrees with CASE's assertion that there is "no inspection data" that " ascertains" how the applicable requirements are met. As discussed above, documentation is contained on the Pressure Test Data Sheet, Quality Checklist, and the corresponding Pressure Data Sheet Attachments and respective Test Isometrics. As summarized in ER-ME-01 and TXX-88575, this documentation demonstrates that the requirements of ASME Section 111 are satisfied.
Argument 2 As TV Electric understands CASE's second argument, CASE believes that the signatures on the Pressure Data Sheet Attachments are meaningless because no individual QC 'nspector's signature attests to his/her own areas of                                        '
inspection but instead each Attachment was signed by a QC Inspector on behalf of the team, and because the typed names on each Attachment do not necessarily identify the QC Inspectors involved in the test. 1/
TV Electric disagrees that each QC Inspector had to be identified on each Attachment and that each QC Inspector should have signed some documentation attesting to his/her area of inspection.                                 There was no such requirement in applicable codes and standards.
The Brown and Root Quality Assurance Program, Section 11.0, Control of Inspections (Rev. 13,9-17-81), through its implementing procedure Ql-QAP-2.1-5, required the assignment of appropriately certified personnel for this inspection activity. All of the personnel who were either identified on the pre-planned lists or who were annotated on the documentation as having participated in the test held the correct l                           certification (MIFI Level II), and were capable of performing their required functions. Therefore, there is reasonable assurance that only appropriately certified personnel participated in inspection activities.
As discussed in ER-ME-01, TXX-88575 and the response to Argument 1, the specific inspection task during the 1982 RCS Cold Hydrostatic Test was divided into eleven areas, each of which was inspected by a team of certified Level II inspectors. The inspection effort was designed to provide a flow of information from many individuals to one individual responsible for and authorized to report the results in the required 1/     CASE's argument relating to the pre-listed names of QC inspectors on the Attachments is discussed below under the second " supportive fact."

   ,e   Attachment.to TXX-89179
: f.
* May 9, 1989 l       Page 5 of 23 format. The completion of inspection activities by each team was attested i
to by one or more QC Inspectors who signed and dated the Pressure Data l            Sheet Attachment. This information was then used by the individual who l            signed the documentation required under CP-QAP-12.2 (i.e., the Quality Checklist and the Pressure Test Data Sheet) which verified that the inspection requirements had been satisfied. The requirements of 10CFR50, Appendix B Criterion XVII, which state, in part, that " inspection and test records shall, as a minimum, identify the inspector or data recorder,
             ...the results, [and] the acceptability...", were satisfied by completing I            and signing the Quality Checklist and by signing B&R QC Acceptance on the Pressure Test Data Sheet. 2/
Moreover, even apart from any interpretation of Criterion XVII, the signatures on the pressure Data Sheet Attachments are meaningful and support the validity of the RCS Cold Hydrostatic Test. The inspection areas assigned to each of the 11 teams were clearly defined, and the availability of certified QC Inspectors to perform such inspections during the test is confirmed by time records. Thus, the signatures on each Pressure Data Sheet Attachment provide meaningful supporting evidence that the inspections of the 11 areas were properly performed. This conclusion is also supported by other factors, such as the relatively small area covered by each inspection team, the close proximity in which all inspections were performed, and the signatures of the Authorized Inspection Agency representative on each Pressure Data Sheet Attachment.
As TV Electric informed the NRC on July 15, 1988, although none of the issues that had been raised impacted the acceptability of the RCS Cold Hydrostatic Test, actions were being taken to enhance the controls for code pressure testing. (See TXX-88575, Attachment, pg. 4.) As part of the enhancements adopted by TV Electric, procedure AQP 12.1 has been revised to include the signatures on each test isometric of each QC Inspector involved with the inspection of piping reflected on that isometric, in addition to the signature on the Pressure Test Data Sheet of the inspector who signs for the successful completion of the test for the                                ;
entire test boundary.                                                                                    !
Argument 3 CASE argues that a lack of objective evidence makes it impossible to verify compliance with 1982 Codes, standards and regulatory requirements based on historical memory as presented by TV Electric officials and engineers in 1988.
The process used by TV Electric in 1988 to assess the technical validity of the 1982 RCS Cold Hydrostatic Test and the bases for the conclusions reached by TV Electric are described in ER-ME-01. Basically, TV Electric developed a method of assessment to ensure the following objectives were met, which in turn would be used to assess the integrity of the piping system:
2/     See also the discussion of the letter from the ASME Boiler and Pressure Vessel Committee at page 9.

  ,,     Attachment to TxX-89179 May 9, 1989                                                                                                                                                                        i Page 6 of 23
: 1. Identify the applicable ASME Code and regulatory requirements.
: 2. Develop a matrix correlating ASME Code hydrostatic test requirements to CPSES hydrostatic procedure requirements.
: 3. Independently review RCS Cold Hydrostatic Test related documentation identifying where inspections should have been performed, as required by ASME Code, and compare these identified inspection points to the existing RCS Cold Hydrostatic Test documentation. The documentation reviewed included:
o            flow Diagrams o            Piping Isometrics o            Fabrication Spool Sketches o            All Applicable Spool Weld Documentation                                                                                                        l l
o            Hanger Drawings o            RCS Cold Hydrostatic Documentation o            Component and N-5 Code Data Reports
: 4. Evaluate the technical adequacy of the RCS Cold Hydrostatic Test related procedures with respect to Code and regulatory requirements.
: 5. Generate appropriate corrective action documentation for potentially discrepant conditions in accordance with existing procedures.
: 6. Review the qualifications of the applicable inspection personnel relative to applicable requirements.
_ _ _ -- - _ _ ___                                                                                                                                                                1

        , , .             Attachment to TXX-89179 May 9, 1989 Page 7 of 23 The following results, as provided by TV Electric in ER-ME-01, were identified upon completion of the preceding methods to satisfy the RCS Cold Hydrostatic Test assessment objectives:
o      The RCS Cold Hydrostatic Test boundary was pressurized to ASME Code requirements.
o     The test was acceptable to the requirements of ASME Section III by the NA Certificate Holder and Authorized Inspection Agency upon completion of the test bounda'ry inspections.
o      The applicable procedures which controlled the RCS Cold Hydrostatic Test provided the appropriate inspection criteria and were adequately                       .
implemented.                                                                                 l l
o      The Quality Control Inspectors involved with the test had the appropriate qualifications and certifications.
o      None of the discrepant conditions identified as a result of the assessment and subsequently by external sources impacted the validity of the test.
As discussed in more detail in Section D of the response to Issue 11, TV Electric did not rely on " historical memory" as part of the bases for determining the technical validity of the RCS Cold Hydrostatic Test in the foregoing assessment. CASE's reference to " historical memory" apparently relates to memoranda which were attached to ER-ME-01 only for the sake of completeness and to document that personnel involved in the performance of the Cold Hydrostatic Test were contacted as part of the assessment.
TV Electric did not take credit for the content of these memoranda in reaching its conclusions. (See Response to CASE Inquiry No. 88-0001.09.)
C. CASE's Supportive Information At pages 4-5 of the Request, CASE identifies the following five " elements of the test conditions and nature of the task that CASE finds particularly persuasive in support of its position":
                               "1. According to information provided verbally by TV Electric, an estimated 1,800 welds and a large, but undefined, number of other                           ,
attributes required inspection during the RCS Primary Cold                                  !
Hydrostatic Test.
l
: 2. According to the official test record and subsequent engineering                           ;
reports there is a conflict in the number of inspectors who actually                        '
l                                    participated in the July, 1982, test. Although the official TV Electric position has changed to claim that thirty-four inspectors may have participated during the inspection aspect of the test, the objective evidence can only establish that seventeen inspectors participated in inspection activities.
________________-----_-_.________________j

q
              ' Attachment'to TXX-89179-
    ''
* May 9,.1989                                                                                      i Page.B of 23
: 3.     'According to information provided verbally by TV. Electric, each'                    ,
                            . inspector (or team of inspectors). carried the specific drawings for                '
their area. of . inspection responsibility into the field as the source document to determine the specific attributes necessary for their.
inspection; no other checklists or criterion were provided.
: 4.      During the test. the reactor coolant test boundary was- leaking'large-amounts of water.from valve bonnets and seals, which, in CASE's view,      .
contributed to an inspection area making identification of leaks more difficult. .The existence of leakage from these areas was identified on NRC Inspection' Report Docket: 50-445/82e16, dated August.17,                     ,
1982, and' verbally confirmed by TV Electric as occurring and not                    l unusual, particularly from valves that have been installed for some                  f
                           'three years or more.
: 5.      According to data contained in the 1CP-PT-55-01, Test Log, page 36, the actual inspection time frame available-for inspection.of ASME
:Section III attributes was within a 32-50 minute period.                 The required inspection pressure was reached at 0557 hours ("RCS at 2500 psig"), and ended at 0629 hours (" Reducing RCS pressure to 2235 will place seal injection instruments back in service"). Even under the o                            most liberal considerations, the time at allowable inspection L                            pressure could not have exceeded 50 minutes."
Til Electric addresses each of these items below.
It is true that an estimated 1800 welds plus a large number of attributes required inspection during the 1982 RCS Cold Hydrostatic Test.                  However, the scope of the task did not detract either from TV Electric's ability to perform it in 1982 or from TV Electric's ability in 1988 to assess the adequacy of the performance of the test. As explained below, the inspection points were identified'in the test documentation and eleven teams were well able to perform the inspections.
As to the number of OC Inspectors.who actually participated in the test, TV Electric had originally asked the CPRT to review the certification status and qualifications of thirty-one individuals who had been identified by B&R as having been potentially involved in the 1982. test.
More recently, TV Electric reviewed the records to identify each individual whose name was typed in as a lead or alternate on the pre-prepared Pressure Data Sheet Attachments, who signed such Attachments or who made an inspection notation on the associated documentation. These activities identified a total of 34 individuals.        All were qualified as Level 11 inspectors. A review of the time records then determined that 30 r
of those individuals were present during the early morning hours that the test was conducted. (The four who were not present had been pre-listed as aleadoralternate.) Accordingly, there is reasonable assurance that the QC Inspectors who performed the inspections have now been identified.                   But
                   ' their precise identification is not required for QA record purposes, since, as discussed above, reliance is properly placed on the signature of the individual (s) who signed on behalf of the inspection team.
l i

c   . Attachment toiTXX-89179
                                    .May 9, 1989
                            . f.
                             ,        Page 9 of 23 With' respect to inspector checklists or criteria.as discussed in ER-ME-01
                              ,             and TXX-88575, the QC Inspectors had ample information identifying the specific attributes to be inspected and the criteria to be satisfied. As' confirmed by TV Electric's 1988 technical assessment and subsequent reviews to respond to questions from external sources (i.e., NRC, TDLS and CASE) the 1982 test package consistently identified all the areas (i.e.,
vendor welds, field welds, base metal repairs involving welding, integral welded attachments) within the test boundary that were required by ASME Section III to be inspected. Moreover, the appropriate inspection criteria of ASME Section III were contained in the' inspection procedure.
TV Electric disagrees with CASE's apparent position that each QC Inspector had to have a checklist identifying each item to be inspected or had to
                                           . document his/her inspection of each item.
TU Electric's position regarding the QC Inspector's documentation is-buttressed by the ASME Board's answers to two questions requesting an
                                          . interpretation of NA-5220. Although NA-5220 is applicable to the '
Inspector (AIA), TV Electric believes that this interpretation is pertinent-to the overall discussion. The questions with corresponding replies are provided below (reference {{letter dated|date=February 1, 1988|text=February 1, 1988 letter}} from Kevin Ennis, Assistant Secretary, Boiler and Pressure Vessel Committee to R. J. Vurpillat) .
Question 1: Is it a requirement of the Code that each weld, base metal. repair, component and high stress point of piping system examined for leakage during the hydrostatic test be individually documented as having successfully passed the required pressure test?
Reply 1: No.
Question 2: May the signature of the Certificate Holder's representative and the Authorized Nuclear Inspector, and-date, on a hydrostatic test report in accordance with the Certificate Holder's Quality Assurance Program be considered as sufficient evidence that the required pressure test has been successfully completed?
Reply 2: Yes, provided the hydrostatic test report identifies the item tested.
As r.oted above, the 1982 test package did identify the items to be tested              i and such information was incorporated in the hydrostatic test report.
Thus, for the reasons described above and in the response to Argument 2 (pages 4-5), TV Electric concludes that each QC Inspector did not have to document his/her inspection of each item and that each QC Inspector had sufficient information to perform the inspection function.

r         Attachment'to TXX-89179                                                                  )
     *~
           .May 9, 1989                                                                             i Page 10 of 23 l
CASE's fourth " supportive" fact alleges that leakage from valve bonnets            I and seals made identification of. leaks more difficult. ASME Section III, NB-6215 and CP-QAP-12.2 specifically permit leakage from valve packing,             I seals, and mechanical joints. TV Electric agrees that leakage from valve bonnets and seals may make identification of leaks more difficult.
However, recognizing this, as discussed earlier in the response to this issue, QC Inspectors were trained in the appropriate inspection methods for the conduct of hydrostatic tests, including the potential for weeping i
or leakage of. test medium at a mechanical joint. TV Electric knows of no leakage concerns that were identified in.1982. As noted by the NRC in its Inspection ~ Report 50-445/82-16,'"The test results indicate the. test met-the acceptance criteria- of the test procedure. The only leakage identified was from valve packing and bonnets. A total of 14 g)m was               !
attributed to this source. There was no other identifiable lea < age."
Finally, CASE suggests that performing the inspection properly was difficult because only a "32-50 minute period" was available. Since the ASME Code requires that a pressure exceeding design rating by 25% be maintained for 10 minutes before inspection could begin, the 1982 inspections'could not have begun before 0506 (ten minutes after such pressure was attained at 0456). 3/ Since the lead ANI stated that the RCS Cold Hydrostatic Test inspection was completed (all of the documentation was available) at 0615, the actual inspection period could not have exceeded 69 minutes. However, the precise amount of time taken for the inspections is not significant. There was no arbitrary cut-off to the test; it was declared at an end when the inspections were completed and documentation was available. Eleven teams performed separate portions of the inspection. The initial dry run conducted on June 14, 1982 indicated-that no more than 40 minutes were required for each area. There is no indication that the period of time was not adequate for performance of the test.
D. Conclusion CASE concludes (Request, p. 5) that there is no objective evidence that the signatures of QC Inspectors on the eleven Pressure Data Sheet Attachments verify that all ASME Section III attributes were actually inspected and therefore the of ficial record does not provide CASE with verifiable evidence that the ASME Section III requirements were met.
3/    Although commencing the QC inspection prior to reaching the lowered examination pressure (i.e., design pressure) deviated from CP-QAP-12.2 and from paragraph 3.7 of NX-6224, such deviation does          I not affect the validity of the RCS Cold Hydrostatic Test. The intent of these provisions relates to personnel safety, not to proper              ,
inspection performance. This discrepancy has been addressed in             !
Deficiency Report C-89-00412.
___ ___-- ----__ _ _ _ _ u

        '     ''         Attachment to TXX-89179' May 9, 1989 Page 11 of 23 As summarized in ER-ME-01 and TXX-88575,- TU Electric's 1988 technical assessment has confirmed that the 1982 RCS Cold Hydrostatic Test was implemented, inspected and documented in accordance with the requirements of the ASME Code, NRC requirements and governing CPSES procedures, with minor deviations that dic not affect the acceptability of the 1982 test.
It has been found to be acceptable by both the NRC and TDLS. CASE's conclusion is not-based on any evidence as to technical inadequacy of the RCS Cold Hydrostatic Test, but rather on its concerns as to the adequacy of the relevant documentation. These concerns have been satisfactorily addressed above.
Accordingly, Issue I does not provide any basis to require further NRC action.
I
_____ ___ _ __ ___ _ _ _ a

      , Attachment to TXX-89179
  . May 9, 1989
    ,   Page 12 of 23 TV ELECTRIC'S RESPONSE TO RCS COLD HYDRO ISSUE II Stated Issue "TV Electric cannot establish through complete, accurate, and verifiable documentation that the 1982 Cold Hydrostatic Test of the reactor coolant pressure boundary was conducted in accordance with industry codes, standards and regulatory requirements." (Request, p. 6)
In support of Issue II, CASE cites several regulations and standards (Request,
: p. 6); argues that it identified a number of documentation deficiencies (Request, pp. 6-8), including deficiencies "noted in" 1CP-PT-55-01 (Request, pp. 8-9); claims that TV Electric relied on " historical memory" (Request,
: p. 9); and states its conclusion (Request, p. 9). TV Electric provides below its response to each of the foregoing portions of Issue II.
A. Regulations and Standards As discussed under Issue I, ANSI N45.2.8 is not applicable to CPSES for the Design and Construction phase of the project, nor is that standard applicable to ASME Code activities for Section III or Section XI.
Additionally as discussed in TV Electric's response to Issue I, the relevant section of Appendix A to ANSI N45.2.9 is A.5, not A.3 and A.6.1.
As such, the statement that TV Electric is " absolutely committed" to these standards is inaccurate.
B. Documentation Deficiencies On pages 6-8 of the Request, CASE discusses a number of document deficiencies "in the form of missing, incomplete, inaccurate, non-retrievable or lost documentation." CASE states that a summary of some of these deficiencies are included in the Request because it demonstrates "the significant weakness" in the test record relied upon by the NRC. These deficiencies are characterized by CASE as " broad areas of concern."
The documentation deficiencies noted by CASE predominantly relate to aspects of the test documentation that were not reviewed in TU Electric's 1988 technical assessment because they were not a necessary part of the determination of the technical adequacy of the test. Although little information concerning these alleged documentation deficiencies has been provided by CASE either in the Request or the subsequently submitted report by Quality Technology Company (QTC) entitled " Evaluation of the
,            Texas Utilities Comanche Peak Steam Electric Station Reactor Coolant System Primary Cold Hydrostatic Test" (QTC Report),
1                                                                                               - _ _ _ _ _ _ _ _ _

Attachment'to TXX-89179 May 9, 1989 Page 13 of 23 TV Electric has reviewed the items cited in the Request to determine whether they could affect TV Electric's conclusions regarding the technical adequacy of the RCS Cold Hydrostatic Test. As described below, TU Electric has determined that no items have such affect. 4/
The first category of items involves differences between verified drawing revision numbers of documents used for the 1982 test, including the Test Procedure, and the Startup Test Record. (Request, pp. 6-7; QTC Report, pp. 26). Flow diagrams were used in preparation for the RCS Cold Hydrostatic Test to delineate the RCS Cold Hydrostatic Test boundary as required by Startup procedures. TV Electric verified the adequacy of the test boundary during performance of its 1988 technical assessment by the use of the ICP-PT-55-01 valve lineup sheets and the test isometrics.
Since the flow diagrams were not used for the performance of inspections, identification of inspection attributes or inspection acceptance, 5/
reference to various revision levels of the flow diagrams did not affect the completion or adequacy.of the test. TU Electric does concede that the various revision levels noted by CASE in the Request constitute a potential deficiency, even though there was no impact on the technical adequacy of the test. This potential deficiency has been addressed in Deficiency Report C-89-00450.
The second category consists of " examples of problems associated with incorrect drawings being used . . ." (Request, p. 7; QTC Report, pp. 26-28). These are miscellaneous and generally unrelated problems.
10 Electric is unable specifically to address CASE's first concern (CMCs) because the CMC number or drawing number in question is not-provided.
But, as shown in the response to Argument 3 under Issue I, TV Electric performed a technical assessment to assure that all required inspection areas were consistently identified. In that assessment no concerns were identified with CMCs with respect to the test boundary, and it was determined that the inspection areas were consistently defined.
(See ER-ME-01).
4/    Even though TV Electric has determined that items specifically identified in the Request do not affect the adequacy of the RCS Cold Hydrostatic Test, in Deficiency Report C-89-00450 it reviewed such items in detail to determine whether any deficiency exists requiring corrective action for any other reason (i.e., clarification or supplementation of documentation). In addition, Deficiency Report C-89-00450 also dispositioned other documentation concerns specifically identified in the QTC Report even if such concerns were not relied upon in the Request.
5/   Use of flow diagrams by B&R, as described in ER-ME-01, was to define the original test boundary. B&R delineated the required inspection areas and boundaries on the test isometrics, as discussed in ER-ME-01 and TxX-88575.
         ,_                          _  _        _- - _ _ _ - - _ - _ _ _ - _ - _ _ - - _ - _ _ . -~
l

                           ,,, LAttachmenttoTXX-89179'
                 <              May 9, 1989 g           Page 14 of 23 The second set of concerns noted by CASE within this category identify potential minor discrepancies in flow diagrams, but do not affect the
    .                               . adequacy of the Cold Hydrostatic Test. As previously discussed, flow diagrams' were not used in the inspection or subsequent acceptance of the i                      test boundary. The facts that some revision dates are not legible or are torn off is attributed to the reproduction quality and the number of. times that these drawings have been reviewed since 1982. Neither of these concerns constitute deficiencies or have any impact on the adequacy of the test. The revision date of BRP<.RC-1-RB-020, Revision 7 is 5/25/82 not 5/23/83 or 5/25/83. Therefore there is no anomaly or concern.
The last two concerns listed in this category refer to test isometrics BRP-MS-1-RB-005 and BRP-MS-1-RB-011. Neither of these isometrics identify piping which was within the RCS Cold Hydrostatic Test boundary. 6/
CASE's final category consists of " additional examples of the types of significant documentation discrepancies which have been noted..."
(Request, pp. 7-8; QTC Report, pp. 26-28). Again, these are miscellaneous
                                   .and generally unrelated problems. The first item listed in this category-deals with NPP-1 Code Data Reports for piping subassemblies. As noted by CASE, these documents stated " Field Hydrostatic Test required," yet the documents were not completed to verify this requirement was met. As discussed by TV Electric in response to CASE Inquiry 88-0001.20, NX-2122(a) of ASME III permits the Installer to perform the hydrostatic test of the piping in lieu of the Manufacturer. Verification of completion of the hydrostatic test is required by ASME III to be documented on N-5 Code Data Reports not the NPP-1. The completion of the CPSES RCS Cold Hydrostatic Test is appropriately noted on the Unit 1 N-5 Code Data Reports.
Several items within this category discuss discrepancies with heat lot numbers, weight / grade, missing checklist, missing initials on corrections and additions and an incomplete form. The heat numbers and weight / grade discrepancies do not affect the RCS Cold Hydrostatic Test boundary, inspection criteria or those areas requiring inspection. The detailed information developed in the assessment completed by TV Electric, and summarized earlier in the response, make it clear that the discrepancies concerning missing initials on corrections and additions and the two items concerning the missing Structural Checklist and the incomplete Hanger Inspection Report have no effect on the technical adequacy of the test.
Furthermore, some of the items listed by CASE in this category, such as BRP-MS-1-SB-003 and BRP-FW-1-RB-004, contain no piping which is within the RCS Cold Hydrostatic Test boundary.
Therefore, TV Electric concludes that these items have no effect on the adequacy of the test.
6/    As discussed in TU Electric's response to CASE Inquiry Cl-88.0001.08 and .34, any necessary testing of welds added after the RCS Cold Hydrostatic Test was performed under the rules of the ASME Code.

Attachment to TXX-89179 May 9, 1989 Page 15 of 23 C. Deficiencies "Noted In" 1-CP-PT-55-01 At pages 8-9, CASE states that "the following examples of documentation deficiencies were noted in 1-CP-PT-55-01":
              "1. The test documentation was fragmented and disjointed, various parts were located at different CPSES locations. (Itwasdifficult,and impossible in some instances, to determine which was the official test record. It appears it is intermixed.) This is contrary to 10CFR50, Appendix B, Criterion XVII.
: 2. The official test record is void of any entries noting water level change although water level monitors had been installed. It is unclear what type of record of the level monitoring was required by the procedural change which required the monitors.
: 3. Revision 5 of the Pressure Test Data Sheet, CP-CPM-6.91, was the latest revision at the time of the test; however, an obsolete form was used for the test.
: 4. ICP-PT-55-01, TPD#29 reported changes to a change.                                         The procedural steps were not documented as being approved by the shift supervisor, and the steps that were changed were not uniquely identified.
: 5. The eleven Pressure Data Sheet Attachments do not contain accurate data. The eleven Pressure Data Sheets indicate changes that were made incorrectly, e.g., no initial /date. It is impossible to define which inspector inspected what. This is contrary to 10CFR50, Appendix B, Criterion XVII, and ANSI N45.2.8."
TV Electric's review of examples 1 through 5 above, including related discussion in the QTC Report (at pp. 6, 10, 29, 19, and 50 through 51 respectively), has determined that CASE's criticisms of the documentation are mistaken (with minor exceptions that do not involve substance), and that none of its " examples" affect the technical validity of the 1982 test.
In order to evaluate CASE's allegation that the test documentation was fragmented and disjointed, it is necessary to take into account relevant background information. The performance of the RCS Cold Hydrostatic Test is a requirement of the ASME Code. The completion and acceptance of the test is required prior to N-5 Code certification of the Code Class piping systems. As summarized by TV Electric in ER-ME-01, Brown & Root (B&R) as the ASME Section III HA Certificate Holder (i.e., Installer), was responsible for installation, testing, inspection, and certification of the CPSES Code Class piping systems. The TV Electric Startup Department
,             (S/U) was responsible for establishing the test boundary and test parameters, and for achieving the required test pressures for the B&R inspection. The records which provide the basis of Code acceptance and compliance are by definition those documenting the activities performed by the Installer. Therefore, these records would be the " official record" l
i            for the Installer's responsibilities. The records which were generated as l            a result of TV Electric Startup performing its responsibilities could be

,T lc          .. - .        .   ..
l
'    '#*   Attachment to'TXX-89179 May.9, 1989:
L          Page 16 of 23.
defined as the " official test record" with respect to the.Startup-responsibilities. 10CFR50, A)pendix B, Criterion XVII does not address the question of location of t w " official test record." Criterion XVII states that records shall be maintained to furnish evidence of activities affecting quality. This is exactly what occurred for the 1982 test, with records being maintained by both B&R and Startup. TV Electric does not find the RCS Cold Hydrostatic Test related records to be fragmented, disjointed, or contrary to the requirements of Criterion XVII.                                                The records.are W. intermixed except for those instances where separate organizational procedures duplicated an activity.
As to the Steam Generator water level monitors, they were not used as part of the RCS Cold Hydrostatic Test to obtain information needed to determine the adequacy of that test. Although these monitors may have been used as a tool during examinations of the Steam Generators, they were not used as-a basis for accepting the Steam Generators or the adequacy of the test itself. Therefore, no record was required to be maintained concerning the monitors.
With respect to CASE's. third example, TV-Electric compared the Pressure Test Data Sheet form attached to CP-CPM-6.91, Revision 5, CP-QAP-12.2, Revision 3 and the Pressure Test Data Sheet that was completed and signed off by B&R and the AIA. The form attached to CP-CPM-6.9I is the same as the completed form. .However, the form attached to CP-QAP-12.2 has one line that is not shown on the completed form:
                   " Originator:                    Approved TUGCo Test Engineer                                                     "
This discrepancy has been addressed in Deficiency Report P-89-00413.
TV Electric has reviewed the additional information that was required by-                                           i CP-QAP-12.2, Revision 3, Attachment 1 and has concluded that the absence                                            l of this information on the form had no impact on the adequacy of the test.
Furthermore, this additional information is identified and completed on the cover sheet of ICP-PT-55-01 and in the text.
TV Electric has reviewed 1CP-PT-55-01, TPD#29 and finds it to be acceptable. The Shift Supervisor approved the TPD in the required space, and a procedure page mark-up, clearly denoting the specific changes, was appended to the TPD. The fact that TPD#29 reported " changes to a change" is both acceptable and irrelevant to its acceptability.
CASE's final example alleges that the eleven Pressure Data Sheet Attachments contain inaccurate data resulting from changes made in violation of 10CFR50, Appendix B, Criterion XVII and ANSI N45.2.8. ANSI N45.2.9 addresses the issue of changes to records, not Criterion XVII or ANSI N45.2.8 (which is not applicable to CPSES auring the Design and Construction phase, as discussed above). The ANSI N45.2.9 standard states, in part, that quality assurance records "may be corrected or supplemented in accordance with procedures . . ." and shall include "the                                            3 date and identification of the person . . . ." There were correction and                                            i I
supplemental. entries on four (4) of the Pressure Data Sheet Attachments                                            l that did nut include initials /date. Nevertheless, ANSI N45.2.9 states that records become valid when they are signed or otherwise initialled and dated. The substantive portion of these records was the attestation of acceptability, not the listing of IS0s or inspector names.                                                          ,

r
  '.. ''   Attachment to TXX-89179 May 9, 1989 Page 17 of 23 In each case, the attachment was signed by one or more Level II MIFI inspectors and an ANI. While the uninitialled/ undated addition of an 150-number is not the appropriate methoc' to make a change, the added 150 was included in the record package.. Similarly, the addition or deletion of inspector names, while not done by the appropriate method, is not a substantive issue. (See TV Electric's response to Argument 2 under Issue I for additional details.)
D. Use of " Historical Memory" CASE alleges that TV Electric used " historical memory" in lieu of required quality assurance records to " complete the record" and to address the questions regarding RCS Cold Hydrostatic Test activities. (Request,p.9)
The process used by TV Electric to assess the technical validity of the 1982 RCS Cold Hydrostatic Test and the bases for the conclusions reached                                 !
by TV Electric are described in ER-ME-01 and TXX-88575. TU Electric did not attempt to assess the adequacy of the test, as previously summarized in its responses, based upon the memory of personnel present at the time of the test. TU Electric has obtained inf , tation concerning certain activities during the reviews by TV Elect . and external sources of the 1982 RCS Cold Hydrostatic Test that depended upon the historical memory of personnel involved in the test.       However, this information was used only to achieve a better understanding of the 1982 RCS Cold Hydrostatic Test                                  <
and to develop road maps to expedite TV Electric's understanding of the test. TU Electric did not rely or depend on this information to determine the technical adequacy or compliance of the test with respect to the ASME Code requirements. (See ER-ME-01, TV Electric response to CASE Inquiry                                    1 88-0001 and TXX-88575.)
In responding to questions raised by CASE, often at CASE's suggestion, TV Electric has obtained information based on the memory of participants.
For example, as discussed in the response to Issue III, in interviews with                                ,
twenty-one individuals (including eighteen OC Inspectors associated with the 1982' test who were still at the site), TV Electric has confirmed that the QC inspectors were not subject to undue pressure from any source.
However, TV Electric does not consider information of this type to be essential to assessing the technical validity of the 1982 test, but to be information obtained solely to respond to an inquiry.
E. Conclusion CASE concludes that the performance of the test cannot be verified and that the NRC must require TV Electric to repeat the test and create a                                      !
reliable record. (Request, p. 9.) TV Electric disagrees.                                                  I The responses above have demonstrated that many of CASE's criticisms are                                  j mistaken and that none affect the technical validity of the 1982 RCS Cold                                  l Hydrostatic Test. TV Electric has shown that the conduct and                                              !
documentation of the test were in conformance with ASME Code requirements                                 1 and, with minor exceptions that do not affect the technical acceptability                                 ;
of the test, with NRC documentation requirements.
l
__ ______-                   D

            ,   ,.                    ' Attachment to TXX-89179 May 9, 1989 Page 18 of 23 Accordingly, Issue II does not provide any basis to require further NRC action.

                                          ..- Attachment to TXX-89179                                                                              .
                        . , .                 May 9, 1989
                             .                Page 19 of 23 TV ELECTRIC'S RESPONSE TO                                                                            ;
RCS COLD HYOR0 ISSUE III                                                                            l Stated Issue "The failure of TV Electric to be able to actually demonstrate which inspectors and supervisors actually participated in the inspection of welds, regions of high stress, etc., is compounded by the fact that several of the allegedly involved inspectors and supervisors have a personal history of actions which previously negatively impact project quality or violated quality commitments." (Request, p. 9)
In support of Issue 111, CASE cites several NRC regulations (Request, pp. 9-10); basically repeats its argument that TV Electric cannot verify the scope of the individual inspection performed by each QC Inspector (Request,
: p. 10); and argues that such alleged failure is compounded by allegedly
                                              " undisputed" factual matters in regard to Inspector "A" and Supervisors "B" and  "C".
TV Electric provides below its response to each of the foregoing portions of Issue Ill.
A. NRC Regulations TV Electric does not have any comments on CASE's excerpts from NRC regulations (Request, pp. 9-10), but notes that they have little relevance to the matters addressed in Issue Ill.
B. Verification of Scope of Individual Inspections CASE's argument that TV Electric cannot verify the scope of the individual inspection performed by each QC Inspector (Request, p. 10),
has already been addressed by TV Electric (see the response to Argument 2                                                   ,
under issue I, above) and need not be repeated,                                                                             l However, two additional points should be made. First, CASE argues that in accepting the adequacy of available documentation " reliance is largely on the assumption that individual inspectors performed the inspection."
(Emphasis added). To the contrary, no " assumption" is involved. As explained above, use of a team of inspectors is an acceptable mechanism for performing an inspection. The signature of the team member responsible for documentation provides objective evidence that the inspection was performed, not just the basis for an " assumption."
Second, without elaboration CASE argues that TV Electric has not "been able to demonstrate that the QC supervisors exercised prudent judgment in regard to their supervisory responsibilities..." TV Electric is at a loss to understand what it allegedly failed to demonstrate. CASE has not identified any specific " judgment" that the supervisors had to exercise nor how such " judgment" should have been documented (whether or not exercised properly) . In the absence of identification of a specific problem by CASE, its allegation cannot be pursued.

     '- Attachment to TXX-89179
  '[    May 9, 1989 Page 20 of 23                                                                                                                           ,
C. Alleged " Undisputed" Factual Matters At pages 10-12, CASE discusses Inspector "A" and Supervisors "B" and "C",
              "whose competence and/or judgment was called into question through the litigation of the Harassment and Intimidation issues before the Atomic
~
Safety and Licensing Board (ASLB)." Although CASE alleges that the factual matters it discusses regarding these individuals " remain undisputed," that statement is largely inaccurate. Moreover,' CASE fails to acknowledge the limited relevance of the hearing record concerning these three individuals to the performance of the 1982 RCS Cold Hydrostatic Test. TV Electric places the record concerning Inspector "A" and Supervisor "B" in a proper context in the discussion below.
When questions were recently raised by CASE, TV Electric had, at first, believed that Supervisor "C" was involved in the actual performance of the Cold Hydrostatic Test, and had so informed CASE. However, TV Electric's subsequent review of the time records for July 31, 1982, determined that Supervisor "C" was not present at CPSES on the date of the RCS Cold Hydrostatic Test. Accordingly, TV Electric believes that the portion of the Request'that addresses Supervisor "C" is irrelevant, and is not responding to it.
Inspector "A" Inspector "A" was qualified as a Level II MIFI Inspector and was decertified on July 22, 1982, based on " demonstrated technical competence." CASE properly states that Inspector "A" was employed at CPSES from May 1979 to the fall of 1982, when he was dismissed for cause.
However, CASE is mistaken in implying that his termination was based on a general lack of competence.
Pursuant to the ASLB's Order of November 1,1984, the records relating to the termination of Inspector "A" were provided to the ASLB and the parties. See enclosures to letter from Watkins to Roisman dated November 7, 1984. CASE's description of the reason for Inspector "A"'s terminatico is ap>arently based on the fact that, on his termination interview form, tie pre-printed box stating "Not capable of performing assigned work" had been checked off. However, the more detailed narrative description of the work performance problems filled out by his supervisor on the same day (also provided to the ASLB and the parties),
shows that Inspector "A" was terminated because he was having difficulties in properly documenting the results of his inspection of hangers. Subsequently, during the course of the hearina, a witness who was questioned concerning Inspector "A"'s performance, testified that it
             " reflects adversely on his ability to fill out documentation properly, which is what he was ultimately terminated for, as I understand it."
Tr. 20893. Thus, it is apparent that Inspector "A" was terminated for documentation difficulties, not for technical incompetence.

Attachment to TXX-89I79
  .                           May 9, 1989
;    .                        Page 21 of 23
                                   .The witness also testified that he had recommended that a sample of Inspector "A"'s work be reexamined, to assess his competence. Tr. 20894.
Although this explicit recommendation was not implemented, Inspector "A" was one of the QC Inspectors whose work was reviewed by CPRT when it performed its sampling investigation of the quality of hardware at CPSES under ISAP VII.c. Inspector "A"'s work was part of 66 out of 247 packages reviewed by the CPRT in the categories of large bore pipe supports; non-rigid, large bore pipe supports; rigid, small bore pipe supports; pipe whip restraints, and fuel pool liner. There were no CPRT findings of hardware errors of judgment by Inspector "A". Thus, both his                                                  !
demonstrated technical competence in his decertification examinations in 1982 and the lack of any finding of significant deficiencies in his work by CPRT further support that his termination resulted from documentation difficulties rather than technical incompetence. Accordingly, there is no reason to believe that Inspector "A" was not qualified to perform his limited functions during the RCS Cold Hydrostatic Test, which imposed no documentation responsibilities upon him.
The fact that the inspections were performed in the brief period of about an hour (rather than a task that required days or weeks), as part of a team of carefully trained inspectors working in close proximity, with an ANI associated with each team countersigning with respect to the team's inspection, make it very unlikely that any QC Inspector was delinquent in                                                 >
performing his/her duties. CASE has provided no evidence indicating that Inspector "A" did not properly perform his duties during the RCS Cold Hydrostatic Test.
Supervisor "B" CASE's allegation concerning Supervisor "B" relates to the litigation at the CPSES hearings of an accusation that he had harassed a QC Inspector with regard to fuel pool liner documentation (Request, p. 11).                                                    CASE states that both 01 and the NRC 5taff concluded that Supervisor                                                   "B" had pressured a QC Inspector in an improper manner to sign acceptance on welds, which the inspector had not witnessed, on the basis of allegedly inadequate records.
i

Attachment to TXX-89179 i
[              May 9, 1989 Page 22 of 23 L
There are a number of relevant additional facts. First, limited evidence l
accusing Supervisor "B" was presented at the hearing, and both the i
occurrence of the incident in 1984 and Supervisor "B"'s involvement were strongly disputed by TV Electric. Second, although both 01 and the NRC staff reached negative conclusions concernir.g a QC supervisor involved in the incident, 7/ the NRC did not require that any action be taken with I                                   respect to that supervisor's past or future work. 8/ With the NRC's i                                  knowledge, Supervisor "B" has remained in an active supervisory QC role at CPSES from the alleged occurrence of the incident (1984) to the present.
7/ Neither the 01 Report nor any subsequent document issued by the NRC Staff is specific as to whether its conclusions address Supervisor "B" or another QC supervisor who actually directed the complaining QC Inspector's work.
8/ On May 2, 1986, the NRC Staff issued a notice of violation and proposed civil penalty relating to the incident at the same time that it issued several other proposed penalties for alleged instances of intimidation and harassment. On June 2, 1986, TV Electric requested that the NRC Staff reconsidet the findings in this violation and that the civil penalty not be assessed, discussing, among other things, numerous generic actions it had taken. On August 25, 1987, the NRC Staff adhered to its conclusions, but expressed its belief that further deliberations on the specific circumstances would not further the purpose of the Commission's Enforcement Policy and, t.herefore, withdrew the proposed penalty. The NRC did not require that TV Electric take any action concerning the alleged offender.
l i

h
* Attachment to TXX-89179 7 >,                                                                                    ,
May 9, 1989 Page 23 of 23 In any event, Supervisor "B"'s alleged actions in a single incident in 1984 can provide no basis for questioning the validity of the RCS Cold Hydrostatic Test. Supervisor "B"'s role in the test was peripheral, in that he apparently provided the QC Inspectors for the test, without direct involvement in supervision of the work. Moreover, in view of the activities taking place on a team basis, the presence of individuals from numerous other groups (e.g., Startup, AIA) and the preparations that had been made to conduct the inspections promptly and efficiently, it is unlikely that harassing or intimidating actions could have occurred and gone unreported. Finally, as CASE acknowledges, TV Electric's Director of QA recently interviewed 21 test participants (including 18 QC Inspectors who were still at the site) and reported that no undue pressure had been imposed on the inspectors during the RCS Cold Hydrostatic Test.
In the absence of any evidence that intimidation or harassment took place, there is no basis for any concern regarding Supervisor "B"'s relation to the RCS Cold Hydrostatic Test.
C. Conclusion In addition to repeating the conclusion it reached under Issue I, CASE concludes "that the ' historical memory' of individual inspectors with a history of poor judgment or incompetence is an inadequate basis for regulatory compliance..." Request, p. 12. As previously explained, TU Electric did not rely on historical memory to reach its conclusions on the validity of the RCS Cold Hydrostatic Test. In particular,              ;
TV Electric has not relied on the historical memory of Inspector "A" or Supervisors "B" and "C".
In the statement of Issue III,. CASE claims that the competence and judgment of these individuals are additional factors that the NRC should censider in evaluating, once more, the validity of the RCS Cold Hydrostatic Test. However, CASE has presented no evidence substantiating that its stated concerns with respect to these individuals impacted the proper performance or validity of the test. There is no justification for further NRC action based on Issue III.
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