ML20206S263

Response Team Discovery 3 Rept Re Program Principles & Objectives.Certificate of Svc Encl.Related Correspondence

ML20206S263
Person / Time
Site:	Comanche Peak
Issue date:	09/15/1986
From:	Garde B TRIAL LAWYERS FOR PUBLIC JUSTICE, P.C.
To:
Shared Package
ML20206S259	List: ML20206S255 ML20206S263
References
OL, NUDOCS 8609220148
Download: ML20206S263 (20)

Text

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00LKETED USNRC 16 EP 18 21:16; F '

UNITED STATES OF AMERICA 11 NOCLsAR REGULATORY COMMISSION BRANCH I '

[0C Before the Atomic Sa'fety and Licensing Board In the natter ot J

}

TBXAS UTILITIES GdN8 RATING )

COMPANY, et al. ) Docket Nos. 50-445 /

(Comanche Peak Steam diectric

)

)

50-440 [L Station, Units 1 & 2 )

CPRT OISCOVERY - 3 PROGRAM PRINCIPL8$ AND 08JECTIVBS

1. Identity oy name, title, and organization the individuals who participated in the decision to develop the Comanche Peak Response Team (CPkT). (Revision 3,3P . 1)1 or the section on Program Principles and Oojectives).

4. Iaentity all meetings, oetween July 1,1984 ana October, lyse at wnich the response to the September 16, 1984 letter trom tne Tecnnical Review Team (TRT) was discussed. (pg.1)

(af For each meeting identitlea list all participants, wnetner or not they are employees or other owners, TubC, Brown = Root, otner site contractors, suocontractors or consuAtants.

1 All page rererences are to the section on Program Principles and Gojectives ot Revision 3 unless otherwise noteo.

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to) For each meeting iaentified produce all aocuments, (see instructions) in the possession of any of the participants.

3. Produce all drafts of Rev. O of the program plan.

4. Describe in detail the process (each step in the development, research, writing, editing and finalizing) used to develop the CPdT program approach (objectives, scope, creath, metnocology, details, etc.) taken in Rev. O.

5. Was any consideration given to tne appropriateness of using then current site QA/QC personnel (e.g., Tony Vega, Ron Tolson) in the CPRT development process or the CPRT Plan itself?

(a) It yes, what constoeration was given and by whom.

(b) It no, why not?

b. The CPRT, Rev. 3, states that TUEC has made a number of changes to the CPRT Program as a result of three listed factors.

For each factor answer the following questions:

(a) "Adaitional Meetings" - Identify all meetings with l

tne NRC, CASE, Cygna and allegers which provided any impetus for change in the CPRT.

(D) For each meeting icentify the time, place, participants, and topics alscussed.

(c) For each meeting provice all documents in tne possession or any of tne attendees (or tnelr representatives or colleagues) who participateo in the meeting at the request of TU8C, other owners, Brown & Root, or any or the contractors, soucontractors or consultants.

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(d) "Acaitional NRC Requests For Information" -

identity all requests for intormation received from the NRC whicn provided any impetus for changing the CPRT.

(e) For each " request tot information" identify in what way it influenced a change to the original CPRT.

(f) Identify each enange wnich was generated by auditional request for information from the NRC.

(g) In regards to TUEC's determination tnat the CPRT should engage in a self-initiated evaluation

completely explain the tull basis of that determination.

(h) Identify all meetings at whicn the self-initiated evaluation was discussed. ,

(i) For each meeting identified list all the participants in each meeting, and identify each participant's title and organization.

(j) For each meeting identified produce the documents used at that meeting or generated in preparation for, at or as a result of the meeting which are in the possession or any of the participants, or in the possession ot TUSC, the other owners or any of tnelr contractors, subcontractors or consultants.

7. The CPRT states that the scope of the charter was expanded to "incude quality of construction and construction J QA/QC issues" raised by additional sources. For each source i

listed identify the issues for review which were included beyond the original scope of the CPRT from the sources listed below:

(Revision 3, pg. 1)

(a) NRC ASLB OL proceeding (which portion of which Order):

(b) NRC Staff SSER's (which one and which portions):

(c) NRC CAT inspection (which one and which portions):

(d) NRC SIT inspection (which one and which portions):

(e) NRC Region IV Inspection Reports (which one and which portions):

(f) Cygna Independent Assessment Program (which findings or communications). '

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(g) For each of the issues identified in a-f characterize the issue as either a " quality of construction concern" or a " construction QA/QC concern."

8. For each source listed in 7(a-f) identify the issues for review which were included beyond the original scope of the CPRT.

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9. The CPRT states tnat "the charter was expandea to include a mandate of assuring TUEC management of the satety of the plant regardies a of tne extent to which issues might have oeen raisea by external sources."

ta) In regards to that statement descrioe what individuals or Group in "TOSC Management" must have tne assurance of the plant's safety.

(b) For each person identitied in response to question (a) include that individual's own description of wnat is considered proof that the plant is safe.

(c) For each person identified in response to (a) above identify any meetings or presentations in which the CPRT program plan, was explained to them or any way in which the individual nad input into the CPRT program plan.

10. Identify all CPSES project personnel involved in the CPRT, by category of work responsibility, and when that responsibility started, ended, ano or was enanged, removed or replaced:

Example:

Reason Person CPRT From To for .

xesponsioliity Change i

Ron toison Paint Coatings 10/ofd4 - 3/3/85 Resigned RTL rhis question incluces site uC inspectors and QA personnel.

11. Identify tne reason or reasons which the CPRT program changed trom "a project effort" to a "primarily third par ty ef for t."

12. Identity when tne CPRT program changed from "a pro]ect effort" to a "primarily third party effort."

(a) Identify what work was completed or partially completed when the CPRT was primarily a CPSBS pro]ect.

(b) For work partially completed identify the percentage completed. ,

13. For all the work done while the CPRT was a " project ef for t" identify to wnat extent any third party overview was done or the original work. ,

Bxample: The majority of the I.a.4. Inspection work was done on Decemoer 29, tnrough January 3, 1984 while the CPRT electrical work was under the airection and supervision of project personnel.

To what extent was any CPRT work conductea under the direction and supervision or project personnel reviewed or will it be reviewed oy third party experts? 8xplain in detail what constitutes a third party expert in your answer and the process of the review.

14. Identify at wnat point and in what manner the CPRT will aavise TOSC management as to wnetner or not there is

" reasonable assurance tnat CPSES has oeen designed, constructed, ano tested sucn tnat it is capaole ot being operatec without undue risk to tne puolic"? (Pg. 2 1

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13. Iaentity which TU8C management officials will receive the CPRT evaluation and trom whom, or in what form the report will be received.

16. Explain, by example and definition, when or under wnat circumstances it woulo not ce possiole to " investigate and aetermine" tne root cause of found safety-significant deficiencies.

17. To what extent is it an objective of the CPRT to resolve tailures to adhere to project QA/QC committments or procedures? wnat process will be useo to accomplish this purpose.

ld. Tnrough what process will the discovery of a root cause assist the CPRT identifying potential generic implications.

13. In any investigation into the probable cause of a deficiency, how will the possible " contributing causes" be recorded or preserved? (Page 2, footnote)

20. The first paragraph on page 3 descrioes a complementary process of program expansion. Identify where in l

the CPRT the implementation details of the process are explained, or explain how the process works. (Page 3) l 21. Since the expansion provisions were added after the initial program plan (Revision 0) explain how the work already done was covereo of the process aescribed aoove.

22. Identify what External Source Issues were recognizec as naving potential generic implications? (Page JJ

24. For eacn of the issues identitied in response to question 22 cescribe tne process tnrougn which that decision was l

made, tnis includes out is not limited to the following:

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ta) Icentify all persons or the person responsible for identifying each of the external source issues with

" potential generic implications."

(b) Identify all discussions or meetings, at wnich the topic of tne potential generic implications were discussed, who they were between, when they occurred, and the individuals present.

(c) Produce all documents developed for or at the discussions identified in response to Item 23(b) above.

24. The SIE does not include in its objective the need for supporting bases for conclusive statements about adequacy of the QA/QC program or its implementation. Why is this lef t out of the SIB?

25. Ioentify the person or persons within the CPRT who

" recognized" the need for additional investigative efforts to support conclusive statements regarding the CPSES quality of construction and design. (Page 3)

26. Identity the basis of tne SRT determination that "the testing area did not require a self-initiated etfort." (Page 3) ta) Identify the person or persons on the SRT wno reached the decision not to include testing in the SIS.

(b) Identify all documents (see instructions) which were generated in the decision-making process l

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regarding leaving the testing area out of tne SIE.

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27. To what extent is the SIE determining that the investigative ef forts of the CPRT program are of sufficient depth and breadth to permit the conclusions for the components of the external source investigations to be extended to:

(a) the balance of the installed hardware at the plant, (b) the adequacy of the QA/QC program as implemented during the construction of the plant.

28. Identify what portions of the plant are considered "s af e ty-rela ted " in tne statement on page 3.

29. Explain, by example and definition, when or under what circumstances it would not be possible to " investigate and determine" the root cause of found safety-significant defi-ciencies or adverse level of non-safety significant deviations or design observations. (Page 4)

30. To what extent is accomplishment of these ob]ectives (referred to in the previous question) dependent upon compliance witn specific program procedures and commitments as opposed to compliance with the program's general principles.

31. Have any situations arisen which made it appro-priate to revise the conduct of the CPRT, as identified on page 47 (a) If the answer to the above question is yes, identify all the situations which have arisen and what changes resulted in the CPRT.

(b) If the answer is yes, identify all documents which describe or explain each situation and/or which were generated or used in making the decision.

32. Have any situations arisen where it has become appropriate to revise the scope of the CPRT's activities?

(a) If the answer to the above question is yes, identify all the situations which have arisen and what changes resulted in the CPRT.

(b) If the answer to the above question is yes, identify all documents which describe or explain each of the situations above and/or which were generated or used in making the decision.

33. Identify the person or persons who decided to include " experienced third-party personnel" in the CPRT organization and when the decision was made. (pg.4 ).

34. For each person identified in response to the preceding, question include their explanation of why the CPRT organization was changed to ensure "a fresh and objective" perspective. (pg.4)

35. In what cases or types of cases will the CPRT identify possible implications of its findings that should be considered by TUEC for impact on design, construction, testing and maintenance af ter the unit is in operation? (Page 6)

36. Identify the process through which the Quality of Construction Review Team will consider closed External Source issues for information regarding potential root cause and generic implications. Include in the definition any forms or procedures l

l used to do the review.

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37. Explain, by oescription and example what the type of information the wuality of construccion Review Team would consider in a closeo external source issue as relevant to potential root cause and generic implications. (pg.6) 3d. Explain, by description and example, what type of intormation the QA/QC Adequacy Review Team would consider in a closed external source issue as relevant to potential root cause and generic implications. (pg.6)

39. Explain, by description and example, what type of information the Design Adequacy Review Team will consider in a closed external source issue report as relevant to potential root cause and generic implications. (99 6)

40. For each of the CPRT program principles identified on page 6, and explained on pages 7-13 explain in precise terms, j using examples trom completed results reports, how the principle objective is acnteved. Include in the response to each, principle answers to each ot the following questions. If tne question is not appropriate explain wny it is not.

(a) Iaentify wnat individual or group of the CPRT is responsiole for conducting the activity.

Example: John Doe, CYGNA Quality Engineer, is responsiole for the " thorough review" for 1 SAP x.A.7.

(o) Identify wnat proceaures govern the work done to acnieve eacn principle.

Example: CYGNA Records Review Procedure 36.1,

" Review of Records for ISAP X.A.7." is used to accomplish the review.

(c) Identify the individual and/or organization responsible for the insuring that the implementation of the activity to achieve the program principle was properly implemented.

Example: Jane Smith, CYGNA QA, or another member of the document review team reviews the X.A.7.

records.

(d) Identify the procedures used to insure that the implementation of the activity to achieve each specific program principle was properly implemented.

Example: CYGNA QA procedure 3.42 was used to conduct the quality review of the activity.

41. For each member of the CPRT Senior Review Team (SRT) include an explanation of why each " insisted" on the development and inclusion of the principles in the Program Plan.

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42. The plan commits to a " thorough review of each issue". Describe the process of review used for items which are not classified as either deficiencies or deviations.

43. How does the CPRT determine if a loss of capability of a system, structure, or component would, as opposed to could result in the inability of the system to perform its intended l safety function. (Page 7) l

44. Identify all documents, working or completed, which were used to classify each system, structure, or component.

45. To what extent is the " safety-significant" clarification determined by the original classification of the affected system, structure, or component.

Example: Paint coatings / fuel pool liners were classified as safety-related at the time of failures to meet commitments but are not classified as safety-related now. How would similar failures to meet past commitments be classified under the current definition?

46. The program plan states that root causes will be investigated and determined where possible. (pg. 8) Explain when it would not be possible to complete a root cause determination.

47. Describe or identify the implementing procedures which will be used to govern the tasks which will " investigate and determine the root causes of identified deficiencies." (Pg. 8)

48. To what extent, if any, are root cause determination investigations parsued for f ailures to meet original commitments where the previous f ailures to meet a commitment are not now classified as deficiencies.

49. Identify forms or documents or types of documents on which " initial root cause hypotheses" are recorded.

50. What individual or group of individuals are responsible for making the initial root cause hypotheses on each ISAP?

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51. To what extent, if any, will root cause determinations be reached for specific deviations which do not become an adverse trend.

52. Identify the person or persons responsible for performing each evaluation of potential generic implication as a result of a root cause determination.

53. Identify the CPRT procedures which are used to perform the evaluation of each potential generic implication.

54. To what extent will there be any collective significance evaluation of identified deviations or design observations?

! 55. Identify the person or persons responsible for performing each collective significance evaluation.

56. Identify the procedures to be used to perform each evaluation or evaluations of collective significance.

57. Identify in what manner the collective significance ,

evaluation will receive for consideration the " multiple, apparently isolated and relatively minor discrepancies" in order to perform a determination.

58. Identify the procedures used to perform and record the collective significance evaluation, and at what stage of the CPRT it will be performed.

59. Identify the person or persons (s) responsible for l

i identifying " lessons learned" through the collective significance evaluation.

60. Identify the procedures or forms upon which the

" lessons learned" f rom the collective significance evaluation will be recorded.

61. Explain, in precise terms, how the collective significance evaluations including the lessons learned, will apply to already completed - as opposed to future - activities at CPSES, Units 1 and 2.

62. Explain what is meant by the statement " appropriate corrective actions ... will be defined to resolve all specific and programmatic deviations and deficiencies identified by the CPRT..."

63. Identify the person or persons who will decide what is the duration of each third party overview of corrective actions.

64. Provide the definition of " third party personnel" as used on pg.9 Sec.H.

65. Identify the person or persons responsible for deciding what provisions of the CPRT program plan are deemed essential to the execution of the work in each group (pg.9)

66. Identify when it would not be applicable to provide training to action plan or existing QA program procedures.

67. Explain in precise terms what the phrase "auditable record of the CPRT program" means.

68. Identify the person or persons who decide when it is necessary f or members of the CPRT to have access to documentation and plant areas (p.12)

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-lb-b9. Descrioe in precise terms the mechanism oy whicn the SRT',s exercise tnett " review ano approval"over the _ RTL's in establisning the scope and content of ISAPs and DSAPs (p.12)

70. What is the purpose of the requirement on p912, Item d, that analyses and calculations will De performed either by an organization "not previously responsiole" for the technical suo]ect area ror tne CPSES project or the alternative of the thira party overview? (pg.12)

71. Identity what process or procedure is undertaken to insure tne organization's indepenaence discussed in tne previous question.

72. Does tne CPRT require that individuals working for tne indepenaent organizations be different trom those who had perrormed the previous analyses or calculations? Why or why not?

73. Identify the process through which it is determined wnetner CPSES inspectors were not personally involved witn the inspection activities tney are working on for the CPRT (p.12)

74. Wnat is the basis used by the RTL and the RTL for tne wA/wC Review Team to decide on selection or personnel.

72. Identity the person or persons who decide wnother recoros reviews and evaluations will oe performeo either by enird party personnel or oy CPS 8S Project personnel? (p.13) lo. Identity the person or persons who decide whether recorus reviews and evaluations will oe perrormed either oy 3ra party personnel or oy CPS 6S Project personnel? (Pg. 13)

77. Describe in detail the differences, if any, between the application and scope of the CPRT to Unit 1 and Unit 2.

78. Produce for inspection and copying all documents identified in these answers, examined and/or relied upon in providing the answers.

Respectfully submitted,

/

a ,e BILLIE P. GARDE ' '\

TRIAL LAWYERS FOR PUBLIC JUSTICE 2000 P Street, N.W., Suite bli, WASHINGTON, D.C. 20036 l

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UNITED STATES OF AMERICA DOCKETED NUCLEAR REGULATORY COMMISSION USNRC BEFORE THE ATOMIC SAFETY AND LICENSING BOABD ao SP 18 N1:16 In the Matter of ) 0FFICE OF SEdr TARY

) 00CHETihG & SEHVICf.

TEXAS UTILITIES GENERATING ) BRANCH COMPANY, et al. ) Docket Nos. 50-445-OL

) and 50-446-OL (Comanche Peak Steam Electric )

Station, Units 1 and 2) )

CERTIFICATE OF SERVICE ay my signature below, I hereby certify that true and correct copies of CASE's CPRT DISCOVERY - 3 have been sent 1

to the persons listed oelow this 15th day of September 1986 by:

Express mail where indicated by *; Hand-delivery where indicated by **; and First Class Mail unless otherwise indicated.

Administrative Judge Peter B. Bloch U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Kenneth A. McCollom 1107 West Knapp Stillwater, Oklahoma 74075 Dr. Walter H. Jordan sul W. Outer Drive Oak Ridge, Tennessee 37830 Elizaoeth B. Johnson Oak Ridge National Laboratory P.O. Box X, Building 3500 Oak Rioge, TN 37830 Bilen Ginsberg, Esq.

U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Robert A. Wooldridge, Esquire Worsham, Forsythe, Sampels i Wooldridge 2001 Bryan Tower, Suite 32u0 Dallas, Texas 75201 Nicholas Reynolds, Esquire Bishop, Liberman, Cook, Purcell & Reynolds 1200 17th Street, N.h.

Wasnington, D.C. 20036 Geary S. Mizuno, Esquire Office of Executive Legal Director d.S. Nuclear Regulatory Commission Washington, D.C. 20555 Docketing & Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20S55 Renea Hicks, Esquire Assistant Attorney General Environmental Protection Division Supreme Court Building Austin, Texas 78711 Mrs. Juanita Ellis President, CASE 1426 S. Polk Dallas, Texas 75224 Mr. W.G. Counsil Executive Vice President Texas Utilities Generating Co.

l Skyway Tower, 25th Floor l 400 N. Olive Street l Dallas, Texas 75201

, Mr. Roy P. Lessy, Jr.

l Morgan, Lewis & Bockius 1800 M Street, N.W.

Washington, D.C. 20036 i

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Mr. Tnomas G. Dignan, Jr.

Ropes & Gray 225 Franklin Street Boston, Massacnusetts 02110 M  %

ANTHONY .

OpMAN  %

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