ML20214P701

Discovery Rept 9,App G,Requesting Description of Circumstances Under Which Senior Review Team Directed That Written Description of QA Measures Controlling third-party Activities Be Developed.Related Correspondence

ML20214P701
Person / Time
Site:	Comanche Peak
Issue date:	09/18/1986
From:	Garde B Citizens Association for Sound Energy, TRIAL LAWYERS FOR PUBLIC JUSTICE, P.C.
To:
Shared Package
ML20214P697	List: ML20214P694 ML20214P701 ML20214P710 ML20214P728 ML20214P764 ML20214P773 ML20214P784 ML20214P803 ML20214P824 ML20214P848 ML20214P866 ML20214P886 ML20214P896 ML20214P904 ML20214P924 ML20214P930
References
OL, NUDOCS 8609240029
Download: ML20214P701 (15)

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t Lh1LO CONItEE 00CHETED edFOds THg USNRC UNITdD STATdd NUCLEAa RnUULATORY COMMISSION 1

SD)22 f! 5 8 decore the Atomic Safety and Licensing soard UFK: "a ~,_ '

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In tne Matter or )

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TEXAS UTILITIES GdNdRATING COMPANY, ) Dx t. Nos. 30-445-OL et al. ) 50-446-OL

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(Comanene Peak Steam diectric )

Station, Units 1 ano 2) J CPRT DISCOVdRY - 9 Appendix G

1. Descrioe in precise detail the circumstances unoer wnica tne Senior aeview Team tsxT) directed tnat "a written oescription or quality assurance measures controlling CPRT tnird-party activities ce oevelopeo" (Appendix 6, p. 1).

Incluae in your answer the followings

a. Ioentity the individuals f rom the SRT who gave the airection to estaolian the identified quality assurance measures.

o. Ioentity all tne documents that provide the direction.

c. Loentity tne time and cate that tnese directions were 91ven.

4. Descrion in precise cetail now it was cecided which criteria ano principles trom 10 CPR Part 30, Appendix B, were relevant to tne CPRT ettort.

8609240029 860918 DR ADOCK 050004 5

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1 3.

Describe in precise detail how the CPRT quality assurance program aescrio~ ed in Appendix G of Revision 3 meets the goals of the program as aescribed in the statement made by W. G.

Counsil in niw Aug. 10, 19o3, letter to Vincent Noonan, in which ne states (p. J):

it is our view that these steps ano the Oyt, taxen together with the carefully structured taira party nature or the CPRT program plan itself, provide a vigorous and open process which meet the requirements of 10 CFR 60, Appenaix 8, ano essentially guarantees its integrity ano tnat or the final product and Conclusions.

Incluoe in your answer a description, in precise detail, or what Mr. Counsil cellevea woula De acced to tne CPRT generally ana/or appena1x u in particular enat woula provide a basis for this statement ana that has not been added to the CPRT generally ana/or Appenaix G in particular.

4.

Describe in precise detail what Mr. Counsil meant in his August 16, 1965, letter to Mr. Noonan when he stated that the CPRT efrort will " meet the requirements or 10 CFR 50, Appendix 8." For instance, was this intenced to indicate that the requirements or the program, if met, would provice compliance with all the aetailed criteria or 10 CPR Part 60, Appendix at 3.

Describe in precise aetail what is meant by the statement in tne summary at page J of Appendix G tnat "perrormance to tne re3uirements or the wu ality Assurance Program will ensure high quality stanaaras in accordance with the SRTs ana 'rucco management's expectations ano coannitments to quality."

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For instance, was tnis intenaea to indicate tnat the requirements or tne program, it met, woulo proviue compliance with all tne deca 11eu criteria or lu CFR Parr 30, Appena1x et o.

Identity all TRT ISAPs tnat were ongoing as or July 43, 1900 in tne civil, Structural, Mecnanical, Electrical, Testing, and silscellaneous groups.

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Or tne ISAes icentitieo aoove, provice tne completion aate ot tne actual document review or inspection process.

Explandtlon:

wnen aio the 9atnering of raw cata stop ano tne preparation or tne Resultu Report begint

o. Expidin in precise cetdil tne rollowing statement f rom tne July 23, Ivoo, letter trom Counsil to Noonan:

Tnese as well as otner CPRT audit activities are aesigned to De in process activities; tnererore, unless speciric audit findings indicate a neea to audit completed TRT ISAP activities, audits will not ce conducted of tne implementation ot a TRT ISAP arter its Results Report nas Deen suomitted to tne SRT ror review ano approvea.

v. laentary all tne " measures previously instituted of the dRT" reterreo to in tne last sentence on page 1 of tne July 4J, 1300 letter.

Au.

wnat was tne casts or tne SdT's cetermination tnat tne "CPRT program principles, implementation requirements, ana po11cles anc guiuelines, in conjunction witn tne aetailed guidance proV10ed in eacn TMT 18AP are sutricient to ensure tne qu ali ty eerrormance ot Thf ISAP activities and results"t i

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in proviainy the answer, ioentify all documents or oral aovice trrom whom) upon which the SRT relieo.

11. Explain in precise detail what quality assurance measures were in place for each of the completeo ISAPs not covereo of Appenoix b and identify what documents existed that descrioed those measures and/or were used to govern or carry out tnose measures, including procedures and training manuais.

12. For each ISAP identified above, explain the basis upon wnica tne CPRT intenas to rely to estaoiish the quality of the worn performeo.

1J. Provice tne casis ror tne oecision made by the SRT that aooitional quality measures "would oe appropriate to ensure the quality" or tne WOC program.

Ioentity all documents, memoranda, or any meetings at which this issue and decision were discusse6..

14. To wnat extent, it any, did the SRT review the NRC inspection record of the exC program at the Braidwood facility?

It tue NRC inspection record was considereo, identiff the person or persons wno performed the review and ioentify air documents tnat were revieweo.

13. Iuentary tne status or all w0C activities at the time tne Sat required the QOC Review Team to implement a quality assurance program ror its activities (p. 3).

A

lo. loentity the process of wnich the Senior Review Team will review all audits ano corrective actions ,taken in response to aucith. Incluue in the response to this question the iuentitication or all proceoures used to accomplish tne review 19 Jf.

it. Explain tne oasis or the statement that "CPRT activities associateo witn implementing these idAPs were perrormeo of a smaiA numoer of persons in accordance with the principles ot the CPhT Program Plan" (p. 4). Include in your answer now tne CPkt nas any assurance that the work was pectormed in accoraance with tne plan since there was no QA program tor the plan.

10.

loentity each or the consultations oetween the 3df and tne various Review Team Leaders for the TRT ISAPs that led to the aetermination that "auoltional implementing procedures, providing aetails or management controls beyond that existing in the ISAPs anu CPRr Pro w ram uocuments, were not requireo" (p. 4).

13 loentity the oasis or tne RfL's decisions to issue or not to issue supplemental instructions for each tat ISAP. The answer snoulo De trom eacn indivioual RTL and should state what oocuments ne or sne reviewed or discussions he or sne had to reacn tnat determination.

40 For eacn ruf 1 SAP ioentarf now the quality assurance critetta requirements ot 10 CPR 50, Appendix d, are coalt with.

For example I

-g-For example:

ISAP I.A.4.

Applicaole/NA Incorporateo Criterion i Na Incepenaence not required because not the program of record.

Criterion 11 Criterion III Criterion IV

" y V1 Applicaole Checklist ana procedures,

" Sect. 4.2.0.

VII .

VIII IA A

x1 All x111 Alv AV AVI Avil AV111

21. ' Explain in precise aetail the basis for excluding eaca of the following Appendix B criteria from the CPRT:

Criterion III - Design Control Criterion IV - Procurement Document Control Criterion VII - Control of Purchased Materials, Squipment and Services Criterion VIII - Ioentification and Control of Materials, Parts, and Components Criterion IA - Control or Special Process Criterion A1 - Test Control Criterion All - Control of Measuring and Test Equipmentt Criterion A111 - Hanoling, Storage, and Shipping Criterion A1V - Inspectin, Test, and Operating Status 1

22 Ioentity any other measures not aescrioed in Appendix G upon wnicn tne Applicants rely to uemonstrate that there is assurance of tne quality or TRT IsaP activities.

23.

Iaentity and proauce all audits and/or inspections conoucted into tne CPRT program plan or any of its elements since Octooer 1964. Tnis incluaes out is not limited to TOGCo audits, INPO audits, audits by the NRC inspectors, MAC, Brown & Root, Stone = Weoster, Comoustion Engineering, E8ASCO, TERA.

44.

In rewaro to tne Overview guality_ Team (OyT), identify tne criteria upon whicn tne SRT will conclude that "the level of CPRT activities no longer justities the need for the OQT" (p. 2 or tne OwT program, Rev. 2, July 2J, 19o6).

es. Luentity tne criteria oy which the OQT will evaluate tne implementation or the CPRT WA program " relative to 1

acnlevement" or tne oojectives listea on page 2, of the OyT.

26. I Identity the "other measures" -- and identify all ,

oocuments that descrioe these measures and/or are used in  :

I implementing these measures, including procedures ano training manuals -- tnat assure the quality or the following activities:

a. SRT activities;

o. Tecnnical Review of Results Reports;

c. Assessment ot tne CPRT Program Auequacy.

i 2 /. Iaentity ano explain the oasis on which the OUT will mane tne determination as to wnether personnel "are acequately .

qua11tica ano traineo to pertorm tneir assignea tasks" (p. J).

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zo. Iaentity ano explain tne casts on wnich the OyT, will make tne aetermination as to whether personnel "can perform their aSalynea tasks oojectivelf ana Witnodt incluence from prior organizational artiliations" (p. a ).

49.

Explain in precise detail tne rollowing about the OyT's Procecure Review, Section J.4 of tne OQT (p. 4):

a. How are tne procedures to ue reviewed by the OQT selectedt

o. Icentity tne criteria upon which tne owT makes its aetermination on whetner the proceaure, if properly implementea, "w111 acnieve tne oojectives ot tne QA program."

c. Is tne wA program reterreo to in tais section the CPRT wA program as aescrioea in Appendix G, or the site wA program?

a. Explain in precise detail now tne OQT processes, comments on, or questions the procedural implementation, e.g., on what torm are comments or questions recordea?

JU. in re9 ara to Section J.J, "Auait Plans and Record Review," identify tne written torm or procedure upon wnich the Uwt will 109 any aesireo additions or changes with the OAP and w0C 19 4 ).

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Icentify tne written torms or proceuures upon which any areas ot disagreement will oe reterreo to tne SRT tor resolution

\p. 4),

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_9 J2. Iaentity tne criteria the OQT will use to determine if selected audit plans are "aaequate" in regard to audit frequency, timeliness, ano thorougnness (p. 4).

JJ. Icentity the process which records and evaluates the OwT's concerns in tne event that the records review reterred to in Section J.3 generates a question f rom the OyT with respect to wnetner or not aucit oojectives were achievec (p. 4).

J4. Explain in precise detail the reason that tne OQT's acoltional aualtors or inspectors " work under the direction of -

the DAP and yOC program aucit team leaders," instead of under the OwT ty. 4).

J 3. Icentity tnose aucits conoucted by the QA organization ot tne DAP ana WOC program review teams wnich tne Ogf members will participate in as observers (p. 4). How is this selection maae and what criteria are used to make it?

J o. Icentify those overview inspection activities for which the OwT will pertorm direct observations (p. S).

J 7. Identity tne written forms or documents on which the Out will recora its observations from reviewing the activities aescrioco in Section J.d ana 3.0 of the OwT.

Jo. Identify all written forms or cocuments upon whicn the OwT will loentity any prooleins or issues it oelieves need e .

resolution.

49. Identity tne criteria the OQT will use to determine if the work prooucts or QA activities are conducted in accordance witn applicaoie industry standards ano practices (p. 5).

40. Identity ano provide all OQT open items tracking sheets oiscusseo in 23.11 tnat have oeen completed to date (p. 6).

41. laentify and provide all periodic progress and status repor ts of the OwT ef rort (p. o).

42. Identity the individual (s) who are assignea to the positions listed on Figure 4.1 uA/QC Review Team Organization.

43. In regara to Figure J.4 or the CPRT wA/yC Review Team guality Assurance Matrix, identity each lu CFR Part 50, Appendix d, criterion that is not aeemed applicable to the QA/QC Review Team Activities ano explain the oasis for its exclusion.

44. On page 26 of the MP plan, Rev. 4, under the Procurement Document Control, Section 4.0, it states that "iciertain procurements for services were accomplished prior to tne establisnment or this MP Plan." For each or these p rocu r e sken ts, identity it and provide the documents reviewed and tne criteria oy which ERC determinea that there was proper l Inclusion of quality assurance requirements.

i 43 i

Explain in precise detail what is meant oy the term

( "non-contorming haroware and accumentation" as usea in the MP Plan on page JJ.

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40 Icentity wnat part ot the CPRT reinspection of hardware ano cocumentation is not done of the wA/yC Review Team according to tne MP Plan.

47. Explain in precise detail now a non-conforming condition is luentified.

4o. Tne MP Program states tthat the DRs "are used only tor WA/wC Review Team dvaluation purposes." Identify all persons who perrorm tne evaluations ot the DRs.

49 loentify all tne procedures useo to ao the evaluations or tne uns.

a u. Explain in precise detail wnat tracking or trending of tne dericiency reports are cone.

31. Is each nonconforming condition, whether or not it is determinea to De a deviation, documented on a deviation report?

On any report / It so, which one or ones?

34 Explain in precise aetail the process by which oeticiencies "uncergo an evaluation to verify validity." Include in your answer an identification of all the procedures used for i veritying tne valiaity.

DJ. Explain in precise aetail wnat is the aisposition or tne oeviations tnat are aeemeo invalla accoraing to tne criteria explainea in response to question 32.

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se. dxplain in precise detail, including identifying, the process that nas been established to ensure that rework or repair is not cone until atter the safety significance evaluations is completed,

33. Iaentity tne criteria used by the SSEG to determine if a aeviation, if uncorrected, woula result in the loss of capability "to perrorm its intenaea safety function" (MP, p. , 3 4 ).

So. Identity, by example if necessary or helpful, in what cases tne wA/wC Review Team Leaaer "may designate other Review Teams responsible for conducting evaluations for safety signiricance in lieu of the SSEG" (MP, p. 34).

6 /. dave any cases arisen to cate in which other RTLs conouctea tne safety signiricant evaluation instead of the SSEG?

If so, specify.

so. Descrioe in precise detail the requirements and proceaures for conoucting root cause and generic implication analyses of sarety signiticant ceticiencies.

5v. Descrine in precise cetail the requirements and

{ proceoures tor tne review and evaluotion of deficiency reports j " tor the purpose or iaentitying adverse trends" (MP Plan, p. 34).

00 Describe ano explain in precise detail the difference I

Detween a "proolem," a "ceviation," and a "cericiency," relating l

l to TuuCo's wA Program, as aiscussea on p. JS of the MP Plan.

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01. Descrioe ano explain in precise detail the difference between a " problem," a "aeviation," and a " deficiency," relating to cne Comanene Peak Station hardware.

62. Explain in precise aetail the circumstances unaer which proolems, aeviations, or deficiencies would not be identified or processed on a deficiency report (DR), but would appear either in a Results Report or in a collective evaluation report (p. 35).

Treat each separately.

oJ. DescriDe ano explain in precise detail the process by which recommendations for corrective action are provided to TUuCo.

64. Identity the person (s) who make up the Procedures and Project Assurance Group.

os. sxplain in precise detail the process by which the Procedures and Project Assurance Group ensures that identified proolems are correctea.

co. Provide each corrective action request written on the Comanche Peak project since ERC began work under these procedures (p. 30).

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o /. Provice eacn stop work order written on the Comanche Peak project since BRC began work under these procedures (p. 36).

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Descrioe ano explain tne basis upon which, after a stop worn oraer is in ef fect, tne QA/wC RTL ano the Manager of QA would agree tnat work may be resumeo (p. Jo),

09. Identity waat records are kept in the B&ESO files aescrioea on v. J / of tne MP Plan.

/U. Does tne ERC auait program descrioed on p. 38 of the MP Plan meet the requirements of 10 CPR Part 50, Appendix B?

a. It not, explain wnat portions of the program ao not meet criteria requirements ana sny.

o. It so, inaicate which portion of the ERC program meets whicn criteria. It tne compliance is not self-eviaent, please explain now tne program acnieves the claimea compliance.

71. Identity ano produce all auaits conducted oy the BRC Division Manager or wuality Assurance of any of the QA/QC Review Team activities as " defined in the CPRT program plan and appenaices ... anc wis" (p. 30).

/2. Iaentity tne circumstances under which the Manager of quality Assurance woulo conduct or would be required to conduct auaits ot BRC suocontractors ano other third-party inspection agencies utilized by tne CPRT Review Teams.

/J. dave any dualts oeen conducted pursuant to tne circumstances cescrioco in question /z aoove? It so, procuce the aualts.

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74. Produce for inspection and copying all documents iaentitiea in the answers to these questions and all documents reliea upon and/or examined in preparing the answers to these questions.

Respectfully submitted, y

alLLIE P. GAto)E f /

Trial Lawyers for Public Justice 3424 North Marcos Lane Appleton, WI 54911 (414) 730-8534

, Counsel for CASE Dated: Septemoer 18, 19o6 4

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