ML20214P694

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Discovery Rept 8 Re Transcripts of 851003 & 860206 Meetings. Related Correspondence
ML20214P694
Person / Time
Site: Comanche Peak  Luminant icon.png
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:
References
CON-#386-802 OL, NUDOCS 8609240025
Download: ML20214P694 (13)


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c 00CKETED USNRC 88FOut Tdt utJITED STATED - -

NUCLEAR REGULATOur COMMISSION 4 97 22 P1 :08 _

Berore tne Atomic Sarety and Licensing Boara g g;re n: t, gec-[ Tyj j A _. J-m- ., ,

in the Matter or )

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TEXAS UTILITIES GENERATING COMPANY, 1 Okt. Nos. 50-445-OL et al. ) 50-440-OL

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(Comancne Peak Steam Blectric )

Station, Units 1 ano 2) )

CPRT DISCOVERY -

6 FeDruary o, 1930, Meeting Transcript ana Octooer 3, 1983, Meeting Transcript FeDruary e t 19do, Meeting

1. Was tne proolem witn tne Unit i neating, ventilating and air conditioning caole tray supports iaentitied under the CPRT program (Transcript, p. 5)?
a. It yes, identity tne (portion) or the CPRT in wnich the proolem was alscovered, tne procedures under wnicn it was aiscoverea, and tne circumstances surrounding tne decision to issue a 50.5s te) report.
c. To wnat extent, it any, will tne HVAC proolem be evaluatea Oy tne CPRT program ror root cause or generic imp 11 cations ana/or considerea in tne collective evaluations
c. Is tne " sampling program" reterred to by Mr. '

I, Couns11 on page / or tne Transcript a CPRT program? II not, wnat ,

sampling program is ne reterring tot

c. Who is Mr. Couns11 reterring to in his statement 8609240025 860918 i' PDR ADOCK 05000445 h G PDR t a

"we pnysical Ay reinspected 60 packages ourselves." ( Tr.Ln.16-17 ;

e. nno and wnat is Mr. Couns11 referring to in nis statement on Line 20-21, tnat "we De11 eve at tnis point tne calance or tne program on unit 2 is satisractory in tnele proceeolngs."
2. Are the EdASCo. guality Control teams reterreo to on Tr. page 9 CPRT inspection teams governed oy tne CPRT program, or CPSES project personnel under the supervision of TUGCo VA management (Tr. pp. d-10)?
a. II tne answer to tne aDove question is that the EBASCo errort is Deing done unoer the CPRT, ident1ry tne proceaures usea ror training each ot tne teams, the procedures the inspectors were trained to, and wnicn Boasco personnel (incAuoing consultants and job snopers; are involveo wno worgea at tne Comancne Peak plant site at any time prior to May 1985.
3. Iaentity all documents useo oy ana prepared during tne "experiencea engineers walgaown" that was conductec in j

Novemoer 1:#05.

a. loentity all persons wno participated in tne l wa1Koown (p. 11).

I

o. To wnom is Mr. Klause reterrin3 o n T r. p.11, line 12-14, wnen he stateo tnat "we are reviewing those ooservations to ce ter.itine wnat action is requireo of tne project and TuGCot" C. Wds the " engineers wa1Koown" Conductec unoer the l

CPRT program?

I

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a. It not, will tne rinalngs or tne waixcown ce considered of tne CPRT in any way?
e. It tne rinoings or tne walkoown are conslaerea of tne CPRT, identity in wnat phase and unoer wnat procedures the tinalngs will oe consicerea.
4. Iaentity all instances where procedures were requirea to be moditled to give tne engineers more specific instructions in tne reanalysis effort (Tr. p. 11, Ln 15-19).
5. Explain, in precise details, what the " major generic tecnnical issues tentatively resolveo" are (Tr. p. 12, Ln 6-10).

Detine the steps tnat must ce completed and the criteria and/or procedures used for " tentatively resolved" issues to oecome finally resolveo.

o. Iaentify tne person or persons who were included in the process of determining that it was necessary to replace Monty wise in oraer to yet a " completely f resh look" at the testing area, as aescricea on page 12.
7. cxplain in precise terms what Mr. Becx aneant oy his statement on page 12, in 3-8 that:

"As that particular aiscipline was explored over tne past year, SRT determined tnat we sianply aia not nave a strong enough Third-Party tlavor. The cleanest way to ao that was to nave a new set or eyes ano a new inina to evaluate all tne areas associated with

testing, ...

Incluae in your explanation why a stronger " Third-Party flavor" was needeo and in wnat way the existing sysytem didi not meet this neeo.

o. Descrioe, in precise aetail, the changes made to the Safety Significance Evaluation group around the time period of tne Feb. o, 19o6, meeting.
9. Explain the reason tnat it was necessary to add a senior level manager to tne SSEG group.
10. Wnat comments did Mr. Hansel receive from NRC staff (eitner TRT or Region) about tne effectiveness and adequacy or tne Sded ettort? -
11. Identify all conversations between NRC staff members and Mr. Hansel, Mr. Beck, Mr. Counsil, or any other management personnel in which the SSEG was discussed,
a. For*each conversation identify the date, place, participants.
o. For eacn conversation identified above identify all documents prepared curing or atter the meeting reflecting the comments or tne NRC regaroing tne SSEG.

.I

12. Identity and produce the " log" referenced on page 15 for logging tne.cnanges to tne ISAPs.
13. Descrioe the criteria used by Mr. Terry Tyler to l

l

aetermine whetner a change to an ISAP is minor or substantive, ano identify all procedures or written cocuments that describe or govern tnis aetermination.

14.

Iaentity the person or persons who are responsible for the determination of whether an ISAP change is substantive or minor, ano ioentify all procedures or written documents that describe or govern this determination,

15. Explain, in precise detail, the revision added to ISAP VII.A.2 for reviewing the technical acequacy of NCR dispositions (Tr. p. 23).
a. Icentity the procedures aeveloped to implement the revision.
o. Identity and explain the oasis for the revision of the ISAP.

. 10. Identify the internal concerns referred to by Mr.

Beck on Tr. p. 28.

a. For eacn concern identifiea above provide the details of how the concern was brought to the attention of Mr.

Becx, and wnat specific portions of the CPRT program were i

involved.

l '/ . Proouce all oocuments developed curing the course of the investigation and/or audit of the QOC program, including but not limited to all notes of interviews ot any persons Interviewea ano all analysis of those interviews ano any otner information gleanea during the investigation or audit. (This

answer should include all information, in precise detail, aeveloped or aiscovereo curing the investigation or audit about the quality instructions, including listing the proceaure and the revision numoer or- tne procedure.)

Iaentify tne incividuals who participated in the lo.

retraining or " hand-in-hand exercise walkoown of VI's" referrea to on Tr. 99 29.

1

19. 6xplain in aetall wnat is meant oy tne pnrase

" accuracy ano completeness" as usea on p. J0, Lines 12-15.

20. In reference to the stop work order, identify which ISAP's or portions ot ISAP work was actually stopped, wnen work was actually stoppea, ana wnen it oegan for each ISAP.
a. Produce the stop work order instructions or other documents directing personnel at all levels to stop work.

D. Produce the documents directing personnel at all levels to restart work.

c. Proauce all documents in which the decisions to stop and/or restart worn were discussed and/or maae.

r

21. Icentity all casen in wnica "cackfit" of tne implementea CPat work would oe requirea as reterencea oy Mr.

Tyler on Tr. p. 31, Line 7.

a. For eacn case in whicn cacKrit was anticipated if Rev. J was approvea as written, identity tne 1 SAP, the oojective, and/or tne specific portion or tne CPRT wnicn was anticipated to r

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__ , . _ _ _ . . _ _ _ . . - , . -___ . . . . . . _ _ _ _ , , . . _ - __ _ _ _ _ . _ , , _ _ . . ~ . - . . _ _ . _ . _ . - . _ .

require backfit as of February 6, 19o6.

b. Explain, in precise aetails, Mr. Tyler's statement tnat tne oackfit would oe "mainly in the area of how you categorize finaings that come out of the program..."
c. Explain, in precise detail, Mr. Tyler's statement tnat tne backtit wi11 impact "how you go through and do evaluation for root cause generic implica tion s..."
a. Explain, in precise aetail, how the backtit would affect tne method for overview of corrective actions by the CPRT.
e. Describe in detail the actual implementation of these backfits and identify all oocuments directing the backfit, all accuments retlecting the changes caused by the backfit, including procedures and training manuals, and all documents reflecting the changes in implementation or the CPRT as a result of the backfit.
22. explain why "the additional steps to the Action Plan" reterrea to by Mr. Tyler don't impact the status ot the
CPRT.

2J. For eacn situation identified in response to I

question 21 aoove identity whether Revision 3, if approved as written in Feoruary 19ab woulo require expansion of work already finisned or doing the CPRT, or any part of it, over again.

( 24. Ioentity and produce tne aucit described by Mr.

r tiansel on p9 32, line 10-11.

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23. Iuentity ano produce the "proposea Actio1 Plan" l

tnat Mr. Hansel referrea to on Tr. p. 32, line 12-13.

20. loentify all documents prepared in the review of tne satety significant evaluations aescribed oy Mr. Hansel on Tr. p. 3e.

2 /. Iaentity tne person or persons who participated in tne review of the quality instructions.

2d. Iaentity tne proceaures and descrioe in precise aetail the process used to do the review of the instructions.

43. Identity the nine inspectors conducting the "over inspections" referred to on Tr. 99 33, line 21-24.
30. Identity the CPRT procedure or procedures usea oy the inspectors to do the over inspections.

J1. Icentify which ISAPs or portions of ISAP/OSAPs or the selt-initiated inspection is coverea by over inspections.

J2. Identity all documents created oy the overinspectors (or anyone else in the process) wnicn was used to

" evaluate eacn inspector" (eg.34, line 2-3).

JJ. Icentity all accuanents createa of the over inspection (or ar4y otner process) wnica was used to give " good insignt as to tne accuracy of inspections" (p. J4).

J4. Identity the supervisor to tne over inspectors reterred to on page 34, line 17-19.

3

J5. Identify tne be inspections which were referrea to oy Mr. Hansel as complete on page 34, line 19-22.

30. Identify all documents which were created in the review of the oo inspections referrea to on page 34 line 19-20. ,

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i October at 1985, Meeting J7. Wnat is meant oy the phrase " adequacy of the construction" as useo on p. 64, in 12-20 (Transcript, Octooer 3, 19o5, meeting)?

Explain in precise detail, including identitying what is considered " adequate," anc who makes that determination.

36 What is meant ny the phrase " adequacy of the wA/QC programt" Explain in precise detail, including identifying what is constoerea "acequate" and wno makes that determination.

39. Identify all oocuments developed in or for the work oescrioea on Tr. p. 06, in 24, to p. 6u, in 20. Ttnis list should incluce out not be limited to:
a. tne list or questions or cnecKpoints used to determine if an activity was "reasonaoly homogenous' (in 1-4);
b. tne list of "all drawings, specifications, ano the construction procedures," etc. (in 5-8) for each category;
c. all analyses or review sheets for each category (In 14-17);
o. all lists ot questions used to " draw a finer tune ano put into groupings the worn processes (Tr. p. 67, on 22-24).

Su.

Explain in precise detail wnat was meant oy tne statement on p. o 's , in 10-20, tnat "we didn't want to t1uster tsic) into tne same population tne work done oy two groups or two companies, or two utiferent inspection groups."

i 41.

Ioentity all documents oevelopeo in or tor tne second i

j

phase of the analyses described on pp. 68-69.

42. On page ~/2, Mr. Hansel identified an "early verification" process in lines 4-6, which apparently provided the inrormation to permit the grouping of difterent attributes. In regato to this early verification process, answer the following questions:
a. Icentify the date or dates, or time period, that the early verification process covered, b.

Icentify all the persons who participated in the early verification process by name, position, and employer.

c. Identity tne procedures and/or criteria by which tne early verification process was conducted.

d.

Identity all project individuals (i.e., TTUEC, 8&R, Gibb & Hill, etc.) who participated in the early verification process.

e. Identify in precise detail what was being verified '

or reviewed.

f.

Provice the contract (s) that commissioned the work described above.

9 Ioentity tne documents tnat are the result of the early veritication process and their location.

4J. In reterence to the oiscussion in the Oct. 3 transcript regarding the establishment of the Homogenous Work Attributes utWAs), provice all preliminary assumptions used in developing unAs ano all cases you have for accepting these assumptions.

exampie 1: There in an assumption tnat if the electrical

crart are traineo tot tne most complex activities tney "should oe aDie to" nanale lesser activities (see p. 79, dOJ.

Example 2: There is an assumption tnat the TOGCo turnover anu cneckout proceoute was very eftective (p. 104).

44. Provioe the criteria used to decide whether there is suf ticient commonality to oetermine tnat conclusions can be drawn 3 from a single strata sample for:
a. processes
o. people
c. proceoures
d. specifications.
43. 8xplain in precise detail the oasis for selection or each homogenous work activity and how it was accomplished (Tr.

pp. 79-61, 100-109, 114-120).

example: On p. 84 of tne transcript, lines 21-24, Mr.

Hansel states that "twj e nave lookea at this suf ficiently to answer in our own minos that tne work processes are the same; no need to go back tnrougn all the other common attributes and ,

commonality procedures and specs." explain what the actual basis of determining the uWA was tor eacn HWA in tne electrical area, i

as well as for each otner specific HWA.

40 Considering tne explanation of tne casis for each HWA provided in response to wuestion 45, icentity now tne homogeneity j was based on the people wno did the work, not the attrioutes or proceaures tor eacn uWA.

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47. Produco for inspection ano copying all documents iaentified in the answers to these questions ano all documents re11ea upon or examinea in tne preparation of the answers to tnese questions.

Res eecttully suomitted,

.h k x_

BILLIt; P. GARDS q Trial Lawyers for Public Justice 3424 North Marcos Lane Appleton, WI 54911 (414) 730-8534 ,

Counsel for CASE Dated: Septemoer 18, 1986 t