ML20238C392
| ML20238C392 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/09/1987 |
| From: | NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| Shared Package | |
| ML20238C385 | List: |
| References | |
| NUDOCS 8712300248 | |
| Download: ML20238C392 (62) | |
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U:Nutu STATES NUCLEAR REGULATORY COMMISSION
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OFFICE OF SPECIAL PROJECTS In the Matter oft )
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STATUS OF CORRECTIVE ACTION ) Docket Nos: 50-445 PROGRAMS AT COMANCHE PEAK STEAM ) 50-446 ELECTRIC STATION, )
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(UNITS 1 AND 2) )
MEETING Pages: 1 through 60 Date: December 9, 1987 Place: Dallas, Texas ,
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Heritage Reporting Corporation Official Reporters 1220 L 5:rvet. N.W.
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1 UNITED STATES NUCLEAR REGULATORY COMMISSION Sec50T&I 2 OFFICE OF SPECIAL PROJECTS 3
In the Matter oft )
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MEETING: )
5 )
STATUS OF CORRECTIVO ACTION ) Docket Nos: 50-445 6 PROGRAMS AT COMANCHE PEAK STEAM.. ). 50-446 ELECTRIC STATION, )
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(UNITS 1 AND 2) ,)
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Plaza-C Ballroom 10 Plaza of the Americas -
250 North Pearl 11 Dallas, Texas 12 Wednesday, December 9, 1987 13 .
14 The above-entitled matter came on for hearing, 15 pursuant to notice, at 1:00 p.m.
16 APPEARANCES:
i 17 On behalf of the Nuclear Regulatory Commission:
l 18 CHRISTOPHER GRIMES 19 STUART EBNETER ANNETTE VIETTI-COOK 20 JANICE MOORE U.S. Nuclear Regulatory Commission 21 Mail Stop EWW302 Washington, D.C. 20555 22 23 24 25
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1 APPEARANCES: (Continued) 2 On behalf of the Texas Utilities' Electric Co.:
3 AUSTIN SCO$T LARRY NACE 4 WILLIAM COUNSIL JOHN BECK 5 WARREN NYER' JOHN STREETER 6 Texas Utilities Electric Co.
Skyway Tower 7 400 N. Olive Street
- Dallas, TX 75201 8
On Behalf of'the Citizens Association for 9- Sound Energy:
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JUANITA ELLIS JERRY ELLIS 11 Concerned Association'for Sound Energy 1426 South Polk 12 Dallas, TX 75224 13
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3 1 PROCEEDINGS j 2 MR. GRIMES: Good afternoon, ladies and gentlemen. '
3 My name is Chris Grimes. I am director of the Comanche Peak ,
1 4 Project Division, in the Office of Special Projects. I would 5 like to welcome you to a meeting to discuss the status of the 6 Comanche Peak Project.
7 By way of opening remarks, I would first like to note 8 that we have an agenda to identify the major items that.we'd 9 like to discuss today. But before we begin, I'd first, for the 10 court reporter's benefit, like to go around the table and if 11 you'd please identify yourself, your title and your affiliation 12 for the record, then I'll go into formal discussion.
13 Mr. Scott, would you begin, please?
v 14 MR. SCOTT: I'm A. B. Scott. I'm the Vice President 15 for Nuclear Operations, Texas Utilities Electric Company.
16 MR. NkCE: Larry Nace, Vice President, Engineering 17 Construction, TU Electric.
18 MR. COUNSIL: Bill Counsil, Executive Vice President 19 of Nuclear Engineering, TU Electric.
20 MR. BECK: John Beck, Vice President, Nuclear 21 Engineering, TU Electric.
22 MR. NYER: Warren Nyer, member of the SRT.
23 MR. EBNETER: Stuart Ebneter, Director, Office of 24 Special Projects, NRC.
25 MS. VIETTI-COOK: Annette ViettiiCook, Project
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1 Manager, NRC.
2 MS. MOORE: Janice Moore, Office of General Counsel, 3 NRC.
4 MS. ELLISt Juanita Ellis, President of CASE, 5 Citizens Association for Sound Energy, Intervenor.
6 MR. ELLIS: Jerry Ellis, CASE.
7 MR. GRIMES: Thank you very much.
8 The agenda identifies those elements of the Texas 9 Utilities' corrective action efforts that have been discussed 10 in previous public meetings. The purpose of this meeting is to 11 discuss the status of those efforts, both the third party 1 12 Comanche Peak response team review and Texas Utilities' 13 corrective action programs. This is a culmination of the
- 14 staff's review of a number of submittals that Texas Utilities 15 has made to the staff describing these programs which will lead 16 to our formal evaluation of the programs which we hope to issue 17 by the end of the year.
18 The submittals that we have reviewed thus far include 19 the June 25th responses to the Staff's May 12th questions on i 20 program activities, the June 25th Revision 4 to the CPRT 21 Program Plan, the August 20, 1987 description of the CPRT and 22 corrective action program interrelationships, the August 28, 23 1987 corrective action program descriptions for the 11 scopes !
24 of work, the September 8, 1987 description and decision process 25 for the post-construction hardware validation program, the i
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1 September 8, 1987 description and procedures for the technical 2 audit program and engineering functional evaluation, the 3 September 23, 1987 hardware validation program attribute I l
4 matrices, and the November 25, 1987 corrective action program )
i 5 clarification.
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6 We have reviewed these documents and we are preparing i l
7 an evaluation to identify what additional requirements may be 8 required in order to ensure that the programs will provide an 9 adequate basis to resolve design and construction adequacy so )
10 that the staff has reasonable assurance that the plant can 11 operate safely.
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12 We are documenting that evaluation now, and we are l 13 holding this meeting in order to obtain certain clarifications s- 14 and get matters discussed in a public forum. We will note 15 those questions and clarifications during the course of the 16 mceting, and you'll note on the agenda that after the 17 presentations the staff intends to caucus, and then we'll make 18 any closing reraarks with regard to where we go f rom here. j 19 I'd like to note that in a memorandum from Jim Kepler 20 to Victor Steller dated November 6, the staff presented a 21 preliminary finding that we found these programs acceptable 22 with relatively minor conditions. And that finding received 23 some media attention, because we distributed the memorandum to 24 Board and parties after discovering that we had inadvertently 25 sent it to the General Counsel.
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6 1 That finding was in no way intended to preclude the 2 staff's final decision, nor to preempt an opportunity for 3 Intervenor to present their comments and concerns. The 4 memorandum noted specifically that we intended to solicit 5 Intervenor comments before finalizing our positions. And in 6 that regard, I sent a letter to Mrs. Ellis dated November 13th, 7 asking her to present any specific comments and concerns that 8 CASE had so that we could discuss them in this meeting.
9 We haven't yet received any, comments, but we will 10 ' continue to accept any comments either during the course of 11 this meeting or in writing while we're completing our 12 evaluation. We will also offer Texas Utilities to review the 13 transcripts of this and the previous public meetings to
-- 14 determine whether or not they want to make any clarifications 15 before we finalize our evaluation.
16 We have been monitoring implementation of-both the 17 CPRT and corrective action programs as has been reflected in 18 periodic inspection reports that have been issued by our site 19 staff, and also there have been audit summaries distributed 20 based on inspections and audits being conducted as part of the 21 design validation process, 22 With that, Mr. Counsil, I'd like -- excuse me -- with 23 that, I'd like to offer Mrs. Ellis an opportunity to make any 24 opening remarks if you would like. Otherwise, we have reserved 25 time on the agenda for you to make comments later in the i
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1 meeting.
2 MS. ELLIS: I'll just wait until later. Thank you. j 3 MR. GRIMES: Thank you.
l 4 With that, Mr. Counsil, would you like to make any 5 opening remarks and otherwise proceed with the agenda items?
6 MR. COUNSIL: Oh, I would like to proceed with the j i
7 agenda items, but I would once again like to welcome the NRC 8 staff to Dallas and, in particular, Mr. Stuart Ebneter, our new 9 Director of the Office of Special Projects.
10 If I may then proceed, I'll turn it over to John Beck 11 for introduction of the No. 2 agenda item.
12 MR. GRIMES: Thank you. I would like to remind all 13 the speakers that if you don't get too.close to a microphone,
%- 14 please speak very loudly so that the transcript from this 15 meeting is accurate.
16 MR. BECK: Thank you, Bill.
17 I'd like to introduce a member of the SRT, who is 18 going to handle the report of CPRT activities today, Warren 19 Nyer, who was introduced earlier, will take that chore.
20 Warren.
i 21 MR. NYER: I might begin reporting on the CPRT 22 activities by talking briefly about the Revision 4 of the 23 program plan. I would like to note first what was not going to l 24 Revision 4 from Revision 3.
25 First of all, the CPRT mission is still the same.
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l 8 l 1 Although the wording has been changed very slightly, it was 2 merely to bring it in conformance with the language in the NRC l
3 regulations. j i
4 Secondly, the issues specific action plans, the 5 ISAPs, have the same objectives and the execution was the same. ,
1 6 They were essentially unchanged. j 7 The primary change was in the discipline specific 8 action plans, and that came about because of the 100 percent 9 validation in the corrective action programs that was 10 undertaken. ;
11 There were also some changes in the details of the l 12 implementation. There were some modifications in the CPRT 13 approach to the old review in quality of construction and QAQC, 14 and some of the DCPs were updated. These changes are outlined j i
15 in detail in the Revision 4 forward, and in the Appendix A to 16 the Revision 4. In summary, other than the changes noted, the i 17 ICPs and the DCPs were relatively untouched.
18 Now, let me mention where we are at the present time, 19 and the starting point for saying what we have done is the 20 Progress Report No. 8 that was filed October 30, 1997, which !
21 brought things up to date as of that time. In that report, it 22 said that six results reports were under active consideration 23 by the SRT. Now, actually all 10 remaining results reports are 24 under active consideration by the SRT. All are very nearly in 25 the final stages, or will be very soon.
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1 We expect to essentially have all of them approved by 2 the SRT by the end of the year. In fact, since the issue of 3 the October 30th Report No. 8, three more results reports have 4 been noticed to the ASLB. There was Report 1-C, 1-D-1, and 5 5-B, and I can give you the titles of those. They are, 6 respectively, Conduit Supports, QC Inspector Qualification and 7 Shortening of Anchor Bolts. There are reveral more in the mill 8 to the Board at the moment.
9 The 14 questions that-accompany the results reports 10 are all underway being actively worked on. Some are only a few 11 days away from completion; others are just beginning. So it 12 might be some time before some of these will be completed.
l l 13 The collective evaluation is expected to be completed
'- 14 on December 18th, and the collective significance report will 15 be issund shortly after the publication of the last project 16 status report.
17 I might mention one thing that is now occupying a 18 major portion of what the SRT does that actually started a long )
19 time ago, and that is the overview function. In fact, this has 20 been going on to some degree for months, if not years. But the 21 activity has been strengthened as time has gone on, and it was, 22 in particular, formally strengthened as a part of the 23 organization changes in Revision 4, with specific assignments 24 to the program director and his staff.
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1 audit program, the engineering functional evaluation, the post-2 construction hardware validation program and, as I said, the 3 program director and his staff. We get regular: briefings for 4 the SRT by these organization and reports from them.
5 .And I_just might mention parenthetically almost that 6 the technical audit program. audits.have all come to us. We 7 have reviewed all of them, not in formal meeting, but informal 8 discussions among ourselves about these, and those audits-9 number very close to 100 by now.
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10 And I think that brings you up to date on what we 11 have done in the last six weeks since the report was issued.
12 MR. GRIMES: Thank you.
13 Could you tell me do you -- how do you envision the
14 SRTs developing a conclusion from their overview function?
15 Have you given any thought to where that will lxs presented, or 16 if that would be presented?
17 MR. NYER: We're in the process of devoting some 18 attention to that right now, and are unable to give you a final 19 answer.
20 MR. GRIMES: All right. I gather from the close 21 proximity of the completion date for the collective evaluation 22 report that you have essentially concluded on what needs to be 23 done to reconcile construction, QAQC and testing?
24 MR. NYER: Yes, I think so.
25 MR. GRIMES: And those are now recommendations that
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have been forwarded to Texas Utilities to carry out as part of 2 the corrective action programs, or are they on a separate 3 track? Either your or Mr. Counsil or Mr. Nace.
4 MR. C,0UNSIL: All of the recommendations that have 5 come out of the ICPs, plus recommendations coming out of, in 6 particular, the 7-C program have come to the TU project staff.
7 All recommendations and how they will be implemented have been 8 concurred with by either the review team leaders, and 9
recommendations as well as the results report will be shortly 10 published by the SRT.
11 MR. GRIMES: All right, thank you.
12 MR. EBNETER: Could you enlighten us a little bit on 13 the overview function where you say you have reviewed over 100 14 audit reports?
15 MR. NYER: Yes. What I might say about that is that 16 we receive all the audit reports and individually we read them.
17 If there is a problem that any of us perceives in them, we 18 usually have a special meeting with the audit people.
19 MR. EBNETER: How many problems have you seen with 20 the audits?
21 MR. NYER: I can't give you a number.
22 MR. EBNETER: Have you seen any trends in the audits? !
23 MR. NYER: No, I can't give you an answer to that at '
24 the moment.
25 MR. EBHETER: How many more audits do you expect to Heritage Reporting Corporation (202) 628-4888 i
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2 MR. BECK: Mr. Ebneter, M'r. Streeter is going to l 3 cover in detail the audit program --
4 MR. EBNETER: Fine, we'll wait for Mr. Streeter then.
5 MR. BECK: -- findings and so forth. (
l 6 MR. GRIMES: Thank you, Mr. Nyer.
7 And, Mr. Counsil, who is going to discuss the f 8 corrective action program activities?
I 9 MR. COUNSIL: Larry Nace, Vice President, Engineering 10 Construction, who heads up the corrective action programs, will l 11 discuss the results to date of each of the phases.
12 MR. NACE: Rather than three separate presentations ,
13 as laid out in the agenda, one on design validation, one on
14 hardware validation, one on reconciliation, what I'm going to 15 give you this morning is an overview of the status of the 16 design validation activities, followed by an overview of the 17 total hardware validation activities and status, and then look 18 specifically at each of the 11 different scopes of work and 19 give you status information where the design validation and 20 where the hardware validation activities stand in that 21 particular scope of work. And then I will follow talking 22 briefly about the reconciliation program.
23 (Slide) 24 With respect to design validation activities, since 25 the July publication, we have issued the first five of the
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, 13 1 project status reports as shown in this slide.
2 The remaining six project status reports, like 3 validation activities, is nearing completion. -We expect thct 4 completion to be by the end of this year.in each case. Based 5 upon limitations of logistics, such as the final report 6 preparation, creating the final reports-and getting the reports 7 into distribution, it may be early, say the first half of 8 January until the remaining reports are in fact issued to all 9 parties. The big picture-wise, by mid-January we do expect'all 10 those reports to be in the hands of all the parties.
11 (Slide) ,
12 With respect to hardware validation, this slide shows 13 the overall scope of the program with respect to all 11 .
~- 14 individual scopes of work within the corrective action program.
15 The post-construction hardware validation program is driven by )
l 16 a set of 50 field replication method procedures. They are 17 shown on the left of the side as the 650 FPMs abbreviated, 18 relating to the program.
19 This slide also shows that 39 -- I'm sorry -- 45 of 20 those procedures have been initiated, and in fact 16 of them
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21 have been completed already. I 22 What we.are going to do now is look at each of the 11 23 different scopes of work and show you how they --'what the 24 status of those scopes of work is relative to the design 25 validation and hardware validation activities.
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r o 14 1 MR. GRIMES: Excuse me, Mr. Nace.
2 MR. NACE: Yes.
3 MR. GRIMES: Do you have a handout for the staff?
4 MR. NACE: Yes, it is coming.
5 MR. GRIMES: Okay.
6 (Slide) 7 MR. NACE: This slide shows the schedule and status 8 of the hardware activities relating to the 50 field 9 verification method procedures that we looked at. It shows 10 that all of the procedures will be in progress by the end of 11 this month, and it shows that all procedures will be completed 12 by the end of July, 1988.
13 If I could pause for a minute, I think my handouts
-- 14 have arrived.
15 (Pause.)
16 Could we go to the next slide, please?
17 (Slide) 18 This slide shows the status of design and hardware 19 validation activities relating to large bore piping and pipe 20 support scope of work. That particular scope of work we have 21 broken down into 384 design validation packages that are 22 abbreviated here as DVP. And in this case, those bVPs relate 23 to the individual stress packages associated with Unit 1 and 24 common piping systems, Classes 1, 2 and 3.
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1 packages have been completed from the design validation 2 standpoint. What remains is the.' hardware validation-3 activities.
4 Three of the field verification method' procedures in- 1
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5 fact relate to this particular scope of work, and all of those 6 are in progress. Since in the piping area it is-relatively 7 easy to qualify a particular commodity _that relates to that-8 scope of work, you can see from the bottom two figures in the.
i 9 Unit 1 and common areas of the plant there are a total of i I
10 12,023 pipe supports, of which 3,579 have been completed 11 through the design and validation processes. ,
12 (Slide) i 13 With respect to the small bore piping and pipe'
-- 14 supports, that is broken down into 457 design. validation-15 packages, all of which have been completed from the design 16 validation standpoint. Three of the field verification method 17 procedures relate to this particular scope of work; all three 18 of those are in fact in progress.
19 In this particular case, the small bore piping, or 20 small bore pipe support population in Unit 1 common pipe areas 21 is 6636 small bore pipe supports; of which 570 have been.
22 completed to date.
23 (Slide) 24 This slide describes the. cable tray hangers scope of' 25 work. This scope of work is broken down into 2441 design Heritage Reporting Corporation (202,) 628-4888
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1 validation packages. Again, all of those have been completed 2 from the design validation standpoint.
3 In the post-construction' hardware validationLmanual',
4 there are design-specific fuel verification method pr redures 5 that relate to this scope of work, although I wou1S'.c,aution you?.
6 'one of those is being -- two;of those are'being combined. So 7 in the current index there- are eight; historically,i here'were t ; g 8 nine. There has been no change in. content other than conisining 9 them'for administrative simplicity, o 10 All nine of those have be'en started. In fact, five n
11 of those have been completed already. The total population of ,,
12 cable tray hangers in Unit 1 common areas could be 549; of
. 13 which 514 have been completed to date.
%- 14 MR. GRIMES: Excuse me, Mr. Nace.
15 MR. NACE: Yes.
16 MR. GRIMES: On the figures that you're using for '
i 17 measuring your commodities, are these affected hangers, or is 18 A
that the total number of hangers in the, plant?
19 MR. NACE: Total number of hangers of the Unit 1 g 3
20 common portion of the plant.
21 MR. GRIMES: So as I understand it then, of those 22 5549, maybe not all of them require some' action?
23 MR. NACE: All of them require some action in'the.
24 standpoint of hardware validations.' That might'just be 25 strictly some reinspection. All of them require some action
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17 I to process within accordance with our existing procedures.
2 MR. GRIMES: I understand. Thank you.
3 (Slide) 4 MR. NACE: This slide describes the status of the 5 conduit support trains A, B and C, , greater than 2 inches. In 6 the layman's sense, this is the large safety-related conduit 7 and conduit supports in the plant.
8 Again, when I say in the plant, I'm referring to Unit 9 i in common areas of the plant.
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10 From a design standpoint, this particular commodity -
l 11 was designed to have one design validation package. As you can 12 see, that has been completed from a design validation i 13 standpoint. Five of the field verification methods procedures 14 relate to this particular scope of work. All of those have 15 been started. In fact, two have been completed.
16 The total population of conduit supports within this 17 particular scope of work is of the order of magnitude of 18 37,000. Ninety-five hundred of those have been completed !
l 19 through our last inspection program.
1 20 I might say while I'm giving you our status j 21 information, this is really end of November status.
22 (Slide) 1 23 The next scope of work would be conduit supports 24 train C, less than 2 inches. In the layman's sense, this is l 25 the small nonsafery-related conduit and conduit supports in the !
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18 I safety-related portions of the plant.
2 That has been broken down into two design validation 3 packages. Both of them have been completed from a design 4 validation standpoint. One of the field verification methods 5 procedures relates to this scope of work. It in-fact has been 6 in progress.
i 7 The total number of conduit supports in the Unit 1 8 and common areas of the plant within thic scope of work is 9 105,000. As you can see from the side, 96,318 of those have been comp-leted.
10 11 (Slide) I 12 The next scope of work deals with equipment l 13 qualification. That program is broken down into three design i
s- 14 validation packages. As of the end of November, one of those (
15 have been completed. I might hasten to add that the other two 16 are expected to be completed by the end of this month.
17 Four of the field verification methods procedures 18 relate to this scope of work. All four of those have been 19 started some time in the past. Two of them have been 20 completed.
21 The best way to describe a commodity, if you will, '
22 for the equipment qua).ification scope of work deals with J
23 specific qualification packages. For the Unit I common areas 24 of the plant, we tallied approximately 785 qualification ;
l 25 packages. Of those, 530 have been completed to date from a Heritage Reporting Corporation
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- 1 qualification bases. The reason that I state from a 2 qualification bases standpoint, that means that the design has 3 been validated, the documentation has been scoped. There may 4 be one, two or three remaining open administrative volumes 5 associated with each package and are punch listed such as 6 collection of additional documentation that are still needed 7 for the files.
8 MS. VIETTI-COOK: Larry.
9 MR. NACE: Yes.
10 MS. VIETTI-COOK: I know that the technical audit 11 program had some concerns with qualification packages. Have 12 you resolved those concerns?
13 MR. NACE: Yes, we have.
- 14 MS. VIETTI-COOK: Okay.
15 MR. NACE: The next scope of work is heating, 16 ventilation and air conditions, or in the trade sense it's HVC 17 package. For the remaining scopes of work, these are more 18 broad disciplined scope of work and is extremely difficult in !
19 the sense of a meeting such as this to quantity the scope in 20 terms of commodities such as you can do in pipe supports.
21 So for these scopes of work I can only provide here 22 the broad status with respect to the status of validation 23 design activities and the status of the hardware validation 24 activities.
25 The heating, ventilation and air conditioning scope
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\- 1 of work is broken down into two design validation packages.
2 Both of these have been completed from a design standpoint.
3 Three of the field verification methods procedures relate to 4 this scope of work. All three of them are in progress.
5 (Slide) 6 The next chart describes the status of the mechanical 7 scope of work. The mechanical scope of work consists of very 8 broad mechanical subjects in the plant such as equipment, .
9 pumps, valves, heat exchanges and so forth. It also includes 10 two very spec'ial subsets of programs.- One being fire 11 protection and the second being system interaction.
12 This chart shows the number of design validation 13 packages for the mechanical discipline to be 29, in addition to
%- 14 the six validation, design validation packages in fire 15 protection, and design validation packages in system 16 interaction.
17 From a completion standpoint, four of the six fire 18 protection design validation packages have been completed for 19 design. The remainder of the fire protection and the bulk of 20 the mechanical and the system interaction are scheduled for the 21 end of this month.
22 From the field validation standpoint, the field 23 verification methods standpoint, six of the procedures apply to 24 the mechanical discipline. Eight of the procedures apply tc 25 fire protection. Nine of the procedures apply to system Heritage Repor+.ing Corporation (202) b28-4888
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21 1 . interaction. So you can see from the bottom statistics, four 2 of the mechanical procedures have been started, of which one 3 has been completed to date. Five of the fire protection 4 procedures have been started, and which four of those have been 5 completed to date. All nine of the syr. tem interaction -
6 procedures have been started. One of those has been completed 7 to date.
8 The electrical scope of work has been broken down 9 into 12 design validation packages. None of those have yet 10 been completed from a' design validation standpoint. Going back 11 to my earlier statement on the expected issue of PSRs, we do 12 expect all 12 of those to be completed by the end of this 13 month.
%- 14 Seven of the field verification methods procedures 15 relate to the electrical scope of work. Five of those have
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16 already been started; one has been completed. ;
17 In the instrumentation and control scope of work, t
18 that has been broken down into seven design validation '
19 packages. None completed to date. Again, we expect all of 20 those to be completed from a design validation standpoint this 21 month, l
22 Five of the field ver'ification methods relate to this 23 particular scope of work. Three of those have been started.
24 The final scope of work relates to the civil 25 structural area. That has been broken down into 19 design Heritage Reporting Corporation (202) 628-4888
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validation packages.
1 Again, none completed as of the status 2 date for this report. Again, we expect them all to be 3 completed this month.
4 Five of the field verification methods apply to this 5 scope of work. Three of those have been started to date.
6 (Slide) 7 Now the next slide I have here is just to make sure 8 that you understand if someone added up all of the FVMs I gave 9 you in the 11 different scopes of work, you're going to get a 10 lar'ger number than what I gave you in the second slide. There 11 are 50 procedures., Some of those procedures apply to more than
. 12 one scope of work.
l 13 An example being a field verification procedure that
-- 14 deals with the checking of physical separation between pipe and 15 conduit. That field verification procedure would be included 16 in both the conduit and the piping scopes of work. So if you 17 add up the number of FVMs in the earlier slides, we get 61.
18 That's not the right answer. There are 50 FVMs. They have 19 multiple impact upon different scopes of work.
20 (Slide) ,
21 The final area of discussion have dealt with the 22 question on reconciliation process. This particular slide l 23 that's on the screen right now is not in your handout. It is a 24 handout from the August 20th submittal on the Comanche Peak 25 programs, and just identifies the area of design r. conciliation Heritage Reporting Corporation (2.02) 628-4888 I
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4 a 2? l s- I which John pointed out on the slide.
2 Now to discuss the procedural controls in that block, 3 I'll really use the next slide.
4 (Slide) 5 The intent of the reconciliation block in the 6 Comanche Peak programs was to describe the normal criterion 15 7 process of taking the design and validating it against the 8 hardware. You have a validated design, you make your 9 observations on the hardware, and you resolve the differences 10 in accordance with your criterion ~1.5 program noncompliance 11 reports. Eight of them supported by all of your design and 12 control procedures.
13 And that's really to the answer,to the. question of
- s. 14 procedural controls are our nonconformance report procedures as 15 supported by all design and control procedures.
16 MR. GRIMES: Mr. Nace, another way to say that is 17 that any discrepancy found in the validated design when you do 18 the field verification method inspections will show up as a 19 nonconformance report?
20 MR. NACE: All inspection discrepancies are 21 applicable as a nonconformance report, yes.
22 MR. GRIMES: Thank you.
23 MR. NACE: That completes my presentation. I'll 24 answer questions.
25 MR. GRIMES: One last question, Mr. Nace. In terms .
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'- 1- of the reconciliation process, do you have any' figures on what-
-2 findings you've- had so :f ar from FVMs that' have been instituted?
3 Maybe a better-way to put that would be,-how many-4 NCRs.have you issued in the last two months?
5 MR. NACE: I could get.you those numbers. I don't 6 have them here. Perhaps -- I wouldn't want.to speculate.
7 101. GRIMES: All.right, thank you.
8 MR. NACE: But those numbers are available on site.
9 (Pause.) .
10 MR. COUNSIL:- Mr. Grimes, do you have any additional 11 questions, or move on to agenda item 47 12 MR. GRIMES: Let's move on to agenda item 4.
. 13 1MR . COUNSIL: All right. To discuss the technical' s- 14 audit program and the engineering functional' evaluation,' John 15 Streeter, Director of Quality Assurance of TU Electric, who is
.16 now passing out his handouts, by the way -- he gets a lot.of 17 support; you can see-that -- will discuss both programs.
18 MR. STREETER: 'If you'll bear with me'just a moment, 19 I'll give a little bit of background information leading up to 20 the information I'm going to be presenting.
21 The technical audit program was initiated in January 22 1987. The reason for the initiation was, twofold.
23 The primary purpose was t'o give an added level of 24 assurance of the effective execution of the corrective action 25 program by TU and its contractors using a dedicated staff of
't Heritage Reporting Corporation (202) 628-4888
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1 personnel within the quality assurance department, staffed by a 2 number of highly qualified and experienced design engineers. ,
J 3 The secondary purpose was to verify that the project 4 organization had effectively executed or implemented the l l
5 commitments and recommendations made by the project -- made to j 6 the project by the CPRT.
7 The numbers that have been discussed previously, one 1 l
8 was mentioned a figure of 100. And I would like to address 9 that just for a moment. 1 10 The technical audit program has these two divisions. -
11 One dedicated to the design validation effort and one dedicated d 12 to the verification of the implementation of the CPRT 13 recommendations. .
l v 14 These are separate staffs within the technical audit 15 program group. The staff that is dedicated to the ISP 16 commitment verification numbers about 20. They have issued to 17 date about 26 audit reports. They have covered somewhere 18 around that number of ISPs, and they have, based on the number 19 we have to issue, about that many more to go.
20 The remainder of -- the other side of the house, as 21 you will see here shortly, we have issued about slightly more 22 than 50 audit reports. That totals about 75. That's where the l 23 number estimate of 100 comes from.
24 The remainder of my remarks today will be limited to 25 the aspect of the technical audit program dedicated to assuring '
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26 s- 1 effective execution of corrective action policy. If anyone has 2 any questions relating to other aspects, I'll be willing to 3 address them, but that's the primary purpose.
4 (Slide) 5 To date, as I have just discussed, we have completed 6 about 54'-- 54 audits of the design validation activities. We 7 have issued 54. For convenience, we have broken these down 8 into the different disciplines, or as Larry called it, scopes 9 of work within the corrective action program.
I 10 The only reason we have broken it down this was is '
11 one of the objectives we had in the technical audit program to 12 begin with was that we wanted to be sure that we audited each ,
l 13 one of the scopes of work within the corrective action program, I s_ 14 and we also wanted to audit each one of the organizations along 15 with those scopes of work at every location that performed j 16 significant activities. i 1
17 For example, in the case of SWEC, Stone & Webster I 4
18 Engineering Corporation, they conducted activities within the l 19 corrective action program in Houston, Cherry Bell, New Jersey, 20 Boston, and We went as far as auditing some activities that 21 were conducted at the location of the Stone & Webster facility 22 in Toronto, Canada. That gives you an idea of the ex'Jant that 23 we went to to assure that we covered all of these activities.
24 So we conducted 54 to date. We have one principally 25 in progress. We have one more scheduled for the remainder of Heritage Reporting Corporation (202) 628-4888
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-- 1 1987.
2 To give you a feel for 1988, we have on our schedule 3 right now about 15 audits presently scheduled. So that clearly.
4 shows, at least to me, the intensity of the effort hare that'we-5 have in the technical audit program, and,we expect that to 6 continue for at least another quarter. l 7 (Slide) 8 Just some more background information on the next 9 slide to give you an idea of the kinds of folks that we have
.10 involved in the technical audit l program. We have about 20 11 experienced, and only two exception,.they are degreed engineers 12 in design and' design experience.
13 We-take these engineers in. turn. When we develop an-s, is audit scope, we tailor their qualifications for what they're 15 going to do. It makes sense and we do that.
16 As I mentioned before that.one of our objective was 17 to cover each one of.the scopes of work within the corrective 18 action program, we have done that as demonstrated by the'first t
19 slide, and we're going to continue to do that. Some areas 20 where we have derived a higher level of confidence, such'as the 21 PSE area, we'll probably secure fewer audits.than we will 22 perhaps in the qualifications.
23 I mentioned before each location where~significant 24 activities were audited, the -- in our post-audit program we 25 have emphasized timely responses. And what' chat means is Heritage Reporting Corporation (202) 628-4888-
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- 1 normally -- normally in an audit program you will see times 2 such as issuance of an audit report wi' thin 30 days of 3 completion of audit activities, require an audited organization 4 to respond within another 30 days, and then about the same s 5 amount of time to evaluate that response by the auditing 6 organization to get back to the audit table and accept all the 7 response. We chopped that in half.
8 Now we have not always made that, but we have 9 administrative 1y tried to control it, because the fast pace of 10 the corrective action program to kee'p up'with it, we've got the 11 issues addressed as the program progressed and reflected the 12 ongoing work, we cut that to 15 days with auditors to get their 13 report out after they completed their work, 15 days for the s, 14 auditor organization to respond, and then our time for 15 evaluation and assessment of that. And that evaluation and 16 assessment normally, at least on significant issues, involve 17 senior management, it involves the auditors organization and 18 the technical audit program staff sitting down. In many case 19 involving working out the detail on acceptable corrective 20 action.
21 The next item that's on the slide is prompt 22 management involvement. In all cases where there was an 23 assessment of an unsatisfactory result from a technical audit 24 program staff, my staff informed me of that, and we elevated l 25 that issue to the appropriate level of management. My Heritage Reporting Corporation (202) 628-4888
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-- 1 involvement and the management involved organization.
2 We, as Warren.had mentioned before, because the CPRT 3 is using the technical audit program as one of its -- on way of 4 deriving confidence in conduct of the corrective action!
5 program, we keep them apprised of the activities in two ways, j 6 As Warren mentioned, we distribute audit reports'to 7 all members.of the SRT and their own control. distribution to. i 8 that. ]q l
9 Secondly, on approximately a monthly basis, the
{
10 technical audit program, as we will d.iscuss.a little later', the 11 engineering functional-evaluation program staff conduct joint 12 briefings of the SRT. Likewise, at about thefsame time, we .
13 conduct the same briefing with Larry.Nace,-the Vice President
_ 14 of Engineering Construction.
15 Lastly on the slide, at Mr. Counsil's request.at the 16 inception of the technical audit program, we provide Mr.
17 Counsil'on a monthly basis an execu'tive summary'with some 18 details on the audited activities on a monthly basisEto keep )
19 him up to speed as to what the technical audit program-staff is j 20 identifying, and what we're doing with those issues, so that l 21 he's apprised of the conduct.
22 MR. EBNETER: Mr. Streeter, could I ask you one or i 23 two questions?
24 MR. STREETER: 'Yes, sir.
25 MR. EBNETER:- You mentioned the prompt management Heritage Reporting Corporation
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- 30 1 involvement'and the resolution of significant issues, and you 2 said that you have escalated.these to
- higher management.
~3- How often has that occurred?
4 MR.- STREETER: Too frequently. The number of'the 5 occasions were probably, just.off-the top of my head,.perhaps 6 out:of_these 54, perhaps somewhere in the order of half a-7 dozen.
8 MR. EBNETER: Half >a dozen.
9 Were the escalations: effective-in resolving the ;
W 10 issues?
11 MR. STREETER: Yes, in all' cases.
12 MR. EBNETER: About how high'a level of management i i
13 did you have to go? j 14 MR. STREETER: Generally at the project manager level--
15 of the contractors. For one specific occasion, our minimum 16 corporate qualification,'it was at the vice president level of i
17 the regional office for that contractor as well as the H 18 ' corporate director of quality assurance'and:.the regional 19 director of quality assurance. I 20 MR. EBNETER: Okay, I think both you and Mr. Nyer J
21 both mentioned that the SRT reviews these audits.
22 What have you gotten back from the SRT?. '
23 Can I ask you the next question if you want to skip i
24 that one?
25 MR. STREETER: The interaction we have with the SRTc
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- 1 is two ways, and Warren didn't mention one. It's very 2 important that this be brought up.
3 The SRT has designated, as they have in other areas, 4 a lead person to keep their fingers on what's going on, to sit-5 in on some entrance interviews,during the audits, some exit, 6 some watching actually part of the audit team to observe the 7 conduct of audit.
8 In the case of this particular effort, that was Jack 9 Butt. So Jack -- remember the SRT, he's dedicated as the eyes 10 of the SRT to watch what's going on with the technical audit 11 program.
12 Now the thing is that during these monthly briefings, 13 we exchange views on the findings that we bave, our technical
. , , 14 audit program assessment of them, and we receive inquiries from 15 the SRT as to what our plans are, how did we resolve them, so 16 that they have satisfaction that we're handling them correct.
17 MR. EBNETER: Does the SRT think you are handling it 18 effectively.
19 MR. STREETER: Yes.
20 MR. EBNETER: They have not given you any guidance at l 21 all on the resolution of issues?
22 MR. STREETER:- Not on resolution of specific issues, 23 no.
24 MR. EBNETER: Okay, I guess I have one more question, j 25 and maybe Mr. Counsil wants to address it.
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32 s- 1 What does the executive vice president do with these 2 reports and what feedback have you had, Mr. Streeter, from Mr.
3 Counsil?
4 MR. STREETER: Could I say something before, because 5 I don't want --
6 (La97her.)
7 MR. STREETER: Let me offer up this to give you an 8 indicaticn of my perception. The evidence that I got from Mr.
9 Counsil was not only seeing these reports, but he was doing 10 something with them. He has caught in one of the monthly 11 reports a couple of items where they were indicating that we 12 were having some difficulty or some discussion from the fall of
, 13 the year design basis documents.
s, 14 At that point he designated Mr. John Krefty(ph), who 15 is a director on Mr. Counsil's staff, to get directly involved 16 to assure that the contractors are addressing the technical 17 audit program findings, and they are resolved. That was 18 accomplished and effective. So that's one thing that I can 19 offer directly.
20 MR. COUNSIL: The direct answer, what John perhaps 21 didn't mention, although the SRT is obviously on the j 22 distribution, so am I, for all audit reports as well as all 23 audit report deficiencies.
24 I do read the audit reports as does Larry Nace, as {
25 does John Krefty, as he indicated, who is my director of I Heritage Reporting Corporation 1 i
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m 1 organizational interface. j 2 In many instances, I do not wait for that monthly 1
3 report to come. I take direct action as.I read the report. I J
J 4 was asked a question once something about the equipment i I
5 qualification audits that had to do with both the Impel 6 Corporation and with Westinghouse Electric. I had taken action- l l
7 the day I got the report, and I then got a summary some three 8 weeks later about that, but the action had already been taken 9 and the issues had already been resolved by Mr. Nace with help l i
10 from Mr. Krefty. So we do try to sit on top of it, and we i 11 don't work off of just summaries.
12 MR. EBNETER: Okay, thank you.
13 MR. STREETER: As a demonstration of the depth of 14 these audits that I told you were numerous, 50 - 55 over'a 12-
.15 month period, I might mention that they are conducted typically 16 one week in duration; involve anywhere from three to six design 17 engineers or analysts on each audit. So the people have 18 performed these activities that they are now auditing, they 19 know what they're looking for, and they spend a week in an 20 auditing capacity looking at design basis documents, l
21 calculations, specifications, the foundation of computer 22 programs and the less contiguous, verification of the 23 implementation of generic technical issues, and looking at the 1
24 technical adequacy of design changes that come out of the 25 design validation program. That's just a demonstration of the
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34 s- 1 program.
2 I would like to now turn to something -- some' summary 3 of the results that we found that we have had, and summary 4 conclusions that we can say, and I want to emphasize that we're 5 not finished yet until this conclusion on the bottom of the 6 page says, results to date with -- assuming the corrective 7 action which we have not confirmed in all cases, if that's 8 completed, we have developed confidence so far that the 9 technical audit program will be effectively executed, but we're 10 not finished. That's the final conclusion. ;
11 We have identified problems. For those significant 12 issues that have come up, more than a mathematical error in- i I
13 calculation or something like-that, we have not hesitated to 1 i
m_ 14 involve the corporate level of management. This is not a
{
l 15 normal audit program.
16 And normal audit programs that I have been involved 17 with do not do this. We exercise a great deal of initiative in i
i 18 assuring that when we see problems, we get it to the right 19 level immediately. That we have the -- the right level has 20 involved senior management. On two occasions I met with Barker i 21 One where both counsel has taken the initiative to assure that 22 some action were corrected. t 1 23 i On another occasion I recall John Beck, my boss, 1 24 writing a letter to each one of the engineering contractors 25 emphasizing to them the importance of getting a quick l Heritage Reporting Corporation i
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35 s_ 1 turnaround on these audits so that corrective action can be 2 taken and implemented for the ongoing work. So we haven't 3 suffered from lack of support in that regard at all.
4 We have followed up on our corrective actions that 5 have been taken as a result of our findings, and we've had 6 positive results and leading us to that bottom line conclusion.
7 Preliminary, we're not finished yet as I indicated before. But 8 so far, although we've gotten problems, we have had them 9 corrected as far as we know, and we're going to verify that, 10 complete or audited stuff and then we will come to a bottom 11 line.
12 MR. EBNETER: Could I ask you about the issues that 13 you've identified?
l s. 14 MR. STREETER: Yes.
15 MR. EBNETER: Could you name me two?
16 MR. STREETER: I'll give you two.
17 j The first issue is one that Annette mentioned before 18 where we had several findings on the --
19 MR. EBNETER: That one doesn't count.
20 MR. STREETER: -- qualification.
21 Well, we had one on the environmental qualification 22 area. We have recently had one on the seismic qualification 23 area, different organization. The one Annette was referring 24 to involved our organization. The latest one we had involved 25 Westinghouse. So one was seismic -- well, both were seismic Heritage Reporting Corporation (202) 628-4888 l
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36 s- 1 issues. 1 2 Another issue that we identifled was the development 3 of the design basis documents. They, in our view, did not.
4 stand alone as a complete basis for the design, and that was an 5 important matter to us. We have achieved resolution of that.
6 We haven't verified the implementation'of that corrective 7 action, but we're satisfied that it is taking a corrected l 8 issue.
9 MR. EBNETER: Do you do any follow-up audit on all of 10 these, or just samples?
11 MR. STREETER: Every one of the items that we 12 identify, we will confirm that they are dealt with and properly i 13 resolved.
s_ 14 MR. EBNETER: I guess I'm still concerned about the 15 SRT interaction.
16 MR. BECK: Mr. Ebneter, can I -- excuse me.
17 MR. EBNETER: I can't seem to -- go ahead.
18 MR. BECK: Let me speak to that. The intent of the 19 SRT as used in the technical audit program is not in any way to 20 interfere in a traditional line management role. The SRT is a 21 third party observer. It's of particular important to the SRT 22 how this technical audit program functions for two reasons.
23 One, from a straight forward functioning capability 24 of the TU Electric quality assurance organization under these l 25 somewhat unusual circumstances where there is a massive s-Heritage Reporting Corporation (202) 628-4888
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-- 1 corrective action program underway, where there is a clear and 2 distinct responsibility for the TU Electric QA organization to 3 do its job under those unusual circumstances. The SRT wants to 4 see how that works.
5 It has the added advantage of a very wide and broad 6 and detailed window into the functioning of the corrective 7 action participants, the doers, not the QA overseers.
8 So it's a double-barreled opportunity for the third 9 party observer to check the functioning not only of the QA 10 program, but also of the executive of the corrective actions.
11 So it's used in that way, and the SRT interaction is one of an 12 information exchange rather than giving direction or 13 necessarily in a direct sense criticizing the functioning of
- s. 14 the technical audit program itself, or of the corrective action 15 people on a real time basis.
16 We intend to use that information in junction with 17 output from the engineering functional evaluation. This 'eing b
18 performed by Stone & Webster Engineering Corporation, as well 19 as any additional looks into the corrective action 20 implementation to satisfy the SRT, that body of independent 21 outside observers, that corrective actions have been 22 effectively implemented. And I hope that flavor is helpful to 23 you.
24 MR. EBNETER: Well, it doesn't persuade me, but I l
25 guess I was looking for something that the SRT had took credit
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.i 38 s- -1 for, you know, of your writeups as being a significant feature, 2 but I don't see, or I haven't.been'able to elicit from anyone l 3 that it has done anything other than receive 100. audit reports.
4 'MR. STREETER: I, Stuart, gave you the wrong 1
5 impression, and'let me try again.
- 6. In these monthly meetings that we have, my remarks
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7- probably portrayed the SRT as passive, and it isn't. The 8 evidence is the continued involvement of Jack Butts aside from !
9 these monthly meetings where he is involved in.seeing how the 10 process is going.,
- 11 At the outlet, me say that the SRT was based on the j 12 developmental programs. In other words, things satisfied.and 13 we got. comments at that time. .The specifics I don't recall on s- 14 the technical audit program before it was issued.
l 15 Now that we have implemented it, how I see it is when 16 we present these findings to the SRT, w<e're telling them the 17 problem is identified. They ask, questions. They just don't 18 sit there and be passive. Importantly, the ask.us what we're 19 doing to resolve them to assure that they are satisfied with 20 that.
21 But, thirdly, the assure themselves that we have the 22 support necessary to resolve them. That's a very important 23 point.
I 24 Now my perception of that, if they were satisfied 25 with the program, they're knowledgeable of the results, how Heritage Reporting Corporation (202),628-4888
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L 39 s- = 1 they're being handled, and that we have the' support. My. l i
l 2 perception is that there is no reason for them to offer any. I 3 kind of technical direction, or direction on the specifics.- !
1 l 4 I have no doubt, if they had reservations about any }
l 5 item, that they would so offer that advice and direction.
l l 6 MR. GRIMES: Just to insert'for Mr. Ebneter's 7 benefit, we have been struggling since last April trying to be l
8 able to capture a definition of the role of the senior review 9 team and how it, either in an advisory. capacity or in its -
10 ability to articulate.their views'on' the process. And we're 11 .somewhat frustrated by wanting'to'see the collective 12 significance report in advance of these activities ~so that we .1 j
13 have a better understanding of how their inv;olvement leads to !
l 1
s- 14 an overall view of how well you're conducting those programs. I 15 MR. EBNETER: Thank.you, that's the staff's defense 16 for my question. We still haven't' solved it, but I think'we 17 need to answer sometime in the future.. It reminds me of the 18 old safety evaluation groups who look good-on paper, but. don't !
19 contribute much. I guess I'd like to see at our next~ meeting i 20 something a little more substantive of.what the SRT is doing, 21 and I would also like to hear a little more probably at the j 22 next meeting about what your technical audit programs are l
' 23 seeing in ways of trending and generic issues as opposed to s
24 just broad statements.
25 MR. COUNSIL: If I may comment at this point. .i l
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'- As far as the' trending comment, we do trend the 1
2 technical audit program. We do trend all of our other audits, 3 and there is a comprehensive management review of that trending 4 program as well as a review by the SRT.
5 There is a monthly meeting chaired by the vice 6 president reporting to me, and for the other four vice q j
7 presidents in attendance. I'm there, it's reporting to me, and' l 8 I attend all of those meetings. All of the senior management 9 reporting to the vice presidents attend those meetings, )
10 including all management of quality assurance.
11 And I can tell you we are not bashful about bringing 12 up the problems or seeing on the trend reports that's only one
. 13 agenda item. SRT does attend that meeting in the person of s- 14 Jack Butt, and isEues are in fact resolved at those meetings.
15 And they are of a more programmatic type nature.
16 And as a matter of fact, if I can remember correctly, 17 for the last three meetings there has been a NRC representative l l
18 in attendance at those meetings. I 19 MR. EBNETER: That was my next question.
20 MR. COUNSIL: Cliff Hale has attended two of the l l 21 meetings, Mr. Grimes walked into one of them.
22 MR. GRIMES: I'm invited.
l 23 MR. EBNETER: Bob Warnick has attended one of those?
l 24 MR. COUNSIL: Pardon?
l 25 MR. EBNETER: Bob Warnick has attended one.
l l
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- s. 1 MR. COUNSIL: Yes, that's correct. The last meeting 2 late last month, Bob Warnick was at the first four we've been 3 at.
4 MR. EBNETER: Okay, we'll check with the staff on it.
5 I may want to attend one of your meetings.
6 MR. COUNSIL: You're welcome. We have a complete 7 list in your hand of all meetings that go on, and including 8 that, any special meetings that come up during the week, Mr.
9 Warnick is invited.
10 MR. EBNETER: Okay, thank you.
11 MR. STREETER: Next Tuesday at 8:30, Engineering 12 Building.
13 MR. EBNETER: Won't be there next week, John.
,, 14 MR. STREETER: In cummary, to give you an idea of 15 where we're headed, as I mentioned before our conclusion was 16 preliminary. We're not finished with our activities. We had 17 at the outset established a planned scope of work, and we're 18 perhaps two-thirds of the way there, but we have activities to 19 be completed.
20 We have to resolve all of the open audit findings.
21 We're going to audit the post-construction validation program. ;
22 If you recall that block when Larry made his presentation 23 awhile ago, I had trouble finding, we're going-to audit that 24 too, design reconciliation process. Those are some other 25 elements, but that's the principal findings. )
)
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42 s, 1 That's the technical audit program.
2 MS. VIETTI-COOK: Have you done any of the audits of 3 FVM? What do you call them, field --
4 MR. STREETER: FVMs?
5 MS. VIETTI-COOK Yes.
6 MR. STREETER: Yes, but not directly -- not as the 7 technical audit program staff. We have done extensive audits 8 and are continuing to do surveillance by the internal audit, 9 also under my organization, but not by the technical audit 10 program staff directly.
11 If we could, we would like to move over into the 12 status of engineering functional evaluation. This is another 13 program that was initiated by TU Electric to give an added 14 level of assurance in the conduct of the corrective action 15 program. Also, it does some additional things besides design 16 validation activities.
17 The engineering functional evaluation started in May 18 of this year. They are at a poknt now where -- the first 19 slide, Bob, if you will. ;
20 (Slide,)
21 There is some information about what the engineering 22 functional evaluation's intended to do. That it is divided up 23 into four scopes of work, four modules as we call them. One is 24 the design completion activities, and that's one more closely 25 aligned to really look at the effectiveness of the adequacy of Heritage Reporting Corporation (202) 628-4888
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43 ss 1 the conduct of.the corrective action program.
2 .There are two other modules that relate to once you 3 validate the design, how does the testing and organization use 4 that information, and likewise, how does the maintenance and 5 operations organization us that information, how they 6 incorporate it into the procedures, how they train their 7 people.
8 The last module work that the engineering functional 9 valuation role encompasses, the operated plant design control.
10 That's supposed to answer the question, all right, you're 11 designed okay. How are you going to keep it all right 12 .throughout operation. This is a programmatic assessment to 13 assure that we have the controls in place to maintain it once s, 14 we've got it.
15 Relative to the design completion activities, there l 16 will be a report coming out on that. Bob, if you want to show 17 the next, please.
ir (Slide) 19 The emphasis to date, because the principal activity 20 has been corrective action program and design valuation l 21 activities, likewise, the emphasis here are_the engineering 22 functional evaluation, I-think, have been keyed to that ongoing 23 effort. So the emphasis in place. The engineering functional 1
24 evaluation staff has completed most of its document reviews.
25 It has some remaining. But the principal area now of leading s-Heritage Reporting Corporation (202.) 628-4888 i 1 1 _ _ _ _ _ - - _ - . - - - - - _ - - _ _ _ d
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- s. 1- to the completion of this module is.the resolution of open 2- findings that.they have identified with the engineering 3 organizations. So that's going to be the principal area of 4 effort in the near future.
5 It's expected that the' design on this -- a report on 6 this part of the program will be issued the first quarter of 7 1988, hopefully in the early months. It's-too early-to tell 1
8 exactly when in the quarter that's going to occur. Originally, 9 it was intended to be one report for'the whole engineering 10 functional evaluation effort. We decided to split this'out and 11 have a report on this one for now.
12 To give you an idea of where the engineering.
13 functional evaluation is going, as I said,'they have to s, 14 complete their scope of work and the design documents. A lot 15 of effort dedicated to the resolution of items that they have 16 already identified. They are going to issue that report the 17 first quarter, as I've indicated. They will continue on l 18 completing the remainder of the three' modules, and with a final 19 report expected to be issued some time next summer of this l
20 year.
l 21 I might add that we have between the technical audit 22 program staff and the engineering functional evaluation staff, 23 we have a lot of communication to find out where each of the 24 programs is, what each is finding, and to see if we need to 25 made adjustments in either of our programs. Those adjustments l
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- s. I haven't occurred yet, and we have one area that we're 2 evaluating now where our results didn't quite match up with 3 engineering functional evaluations,-and we're looking at that.
4 We may want to change the emphasis or make other adjustments in:
5 the program.
6 We do that always on a monthly basis, and it.just 7 precedes the joint breaking of these two efforts by the vice 8 president of engineering construction and the senior review 9 team, and they have been beneficial.
10 . That's the end of my remarks on the two programs.
11 Any questions?
12 MR. GRIMES: I have one question. And that is, there
~
13 was no defined time frame established for TAP and EFE that we s, 14 could tell in the description of the' program. Do you intend on 15 continuing TAP and.EFE through not only the Unit I completion, 16 but on into Unit 2 activities?
17 MR. STREETER: We will -- our plans for these, the 18 technical audit program was a special dedicated staff set up to 19 assess the effective execution of the corrective action 20 program. That staff will not -- it will go away so to speak 21 when we derive that level of confidence and we have drawn a 22 conclusion.
23 At that point in time we sti_1 intend to continue 24 technical audits for a much lower level than we have now. We 25 have 40 - 45 folks in there. You won't find another place in
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- s. I the country who have that many people doing technical audits so 2 to speak in their organization. It's clearly, in my view, an 3 unprecedented effort in this effort and its intensity.
4 So we will come down and the level of technical audit 5 activities, those activities will be, as you see, are absorbed 6 within our internal audit program.
7 MR. GRIMES: Do you have any particular way of 8 letting us know when you accomplished that absorption?
9 MR. STREETER: Yes. Well, the way, I don't know. I 10 believe'-- we have made a commitment to the staff in our letter 11 describing the two func,tions that if there is any significant 12 changes in these efforts, the staff will be notified. And so 13 that's how you're notified. When it's ,done, you will know.
s, 14 MR. GRIMES: Thank you.
15 MR. COUNSIL: If I may, the answer to the 16 engineering, that was a technical audit side. The engineering 17 function evaluation should slide between normal engineering l
i 18 assurance functions and Stone & Webster Engineering 19 Corporation, which is a normally staffed program anyway. And 20 when we move into that mode again, we will tell you.
21 MR. GRIMES: Thank you.
22 We have the alternative of either breaking now, then 23 coming back for CASE's comments and then breaking again for a 24 caucus, or CASE can present their comments now, and then we can 25 break and caucus at the same time.
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-- 1 Mr. Counsil, do you have a preference?
2 MR. COUNSIL: Oh, I defer to Mrs. Ellis, what her 3 preference is.
4 MR. GRIMES: Mrs. Ellis?
5 MS. ELLIS: Could we take a break now?
6 MR. GRIMES: All right,' fine. We'll take a 15-minute 7 break. Reconvene at 2:30.
8 (Whereupon, a recess was taken.)
9 MR. GRIMES: We would like to reconvene the meeting.
10 All right, at this point on the agenda we have set 11 aside time for Mrs. Ellis, as President of Citizens Association 12 for Sound Energy, to present any comments or concerns 13 concerning the corrective action efforts for Gomanche Peak, s, 14 Mrs. Ellis, would you like to tell us your views.
15 MS. ELLIS: Our remarks today will be rather brief.
16 As you are aware, we're having a meeting next week 17 between the Applicants and one of our witnesses, Jack Doyle, 18 who has been involved in the design issues. And we expect to 19 have more questions then, more specific questions at that time.
20 So our remarks will also be rather general.
21 I guess the first thing I need to do is to welcome 22 Mr. Ebneter to the " tar baby plant". I do that a little 23 hesitantly --
24 MR. EBNETER: Excuse me. The TVA plants are referred 25 to that, too, so I am sort of used to it now.
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48 s, 1 MS. ELLIS: The last gentleman in your position that 2 I welcomed, I hope that my welcoming had nothing to do with 3 this, but he didn't come back. We hope we'll see you again.
4 MR. EBNETER: I'll be back.
5 MS. ELLIS: Another thing that I guess we were a 6 little concerned with the letter from Mr. Kepler to Mr.
7 Steller, because that seemed to indicate that things were all 8 over but the shouting; that the NRC staff had made up it's 9 mind, and, oh, yes, incidentally, we're going to give the 10 Intervenor the opportunity to say a few words.
11 It's now my understanding from having spoken with Mr.
12 Grimes and from what he said earlier that that's not the case, 13 and we hope that we will have sufficient time to do what we've 14 got to do.
15 You need to understand that we are in a little bit l 16 different position from the NRC staff. The staff can routinely 17 go down to the plant and also you attended some of the monthly 18 meetings, some of the people have. So you are a little bit 1
19 ahead of us on some of the things that we have to find out.
20 We're trying to do that, and I think the meeting next 21 week will be very helpful along that line.
22 One of our concerns I think is that -- well, I guess 23 really this will be a question sort' of to the'NRC staff -- is l 24 what you perceive this meeting to mean, and what you intend to 25 use this meeting for. If you plan to use this meeting to try Heritage Reporting Corporation (202) 628-4888
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,, 1 to come to a decision at this point in time, I think that would 2 be a grave mistaken, and I'd urge you to reconsider if that's 3 what you have in mind.
4 If you are in the same position, so to speak as we 5 are, and you're trying to get information from this meeting, 6 which will then be fed into your overall conclusions, then 7 that's a different matter.
8 And I think what we have here is the real ptasibility 9 for haste on the part of the NRC staff which could conceivably 10 create a lot of waste in the long run. And I want to urge you l 11 to go slowly, give us time to do what we have to do to get the 1
12 information we need to do so that we won't all be in litigation 13 on this plant for the rest of our lives,. Certainly that's not 14 our desire and I hope it isn't yours.
15 There could be very well many things that we will not 16 need to litigate if we're given adequate time and information 17 to be able to conclude on our own that, yes, this part of it is 18 okay, this part is okay, this part is okay. Well, on this one 19 we want to challenge what you're doing on this particular 20 thing. We have to have enough information to be able to do 21 that.
l 22 So I guess part of our problem and part of our 23 concern is that this meeting, if it is to come to a conclusion 24 by the NRC staff, is premature for sure. If it is to gather 25 information, I think there have been some helpful comments made
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'50 s_ 1 today. There have been -- certainly they have been helpful-to 2 me, and hopefully there will be more next week.
3 Another thing that I do want to mention for possible 1 4
4 inclusion next week is that we have been somewhat disappointed 4
5 in the lack of detail in the project status reports. For 6 instance, I'm thinking back to the time when we had the last 7 CYGNA hearings where the CYGNA reports had details'of the 8 specific problems that were found. -They had various levels, 9 including observations, and told what the problem was, what the 10 resolution was and so forth. It also had things like details 11 about the specific problems that had been encountered, and even 12 drawing of some of the things.
. 13 This is the kind of detail we had been hoping we s, 14 would find in these project status reports, and that type of 15 detail just isn't there. So we're going to have to dig for it 16 which will slow things down I think considerably.
17 One of the things that I think is unusual about these 18 proceedings at this point in time is that we have a real 19 opportunity for the NRC' staff and the Applicants and CASE to 20 try to work together to narrow the issues before we actually 21 have to get into the litigation stage. And I think that we are 22 all willing to do this. i 23 And I guess that's about all of our comments for !
24 today other than to say we just are not going to be rushed into 25 something, into a fast judgment about things until we are sure Heritage Reporting Corporation (202) 628-4888
51 s, I we understand what's going on and can make intelligent, 2 informed comments and decisions on it. i 3 Thank you.
4 MR. GRIMES: Thank you, Mrs. Ellis.
5 I would like to clarify a point that I had made to 6 you before, and that is, Mr. Kepler's memo reflected the 7 results of internal staff meetings to discuss our review of all 8 the documents.
9 The purpose of the meeting today was to gather 10 additional information and to share what we have concluded 11 based on those efforts, not only with the utility but with you, ;
12 to let you all know what our views are at this. point in time.
13 We are going to offer you an opportunity at the end of this s, 14 meeting to submit additional specific comments for us to 15 consider before we finalize that position. We will also offer 16 Texas Utilities an opportunity to offer any additional comments 17 that they want considered before we document the results of i I 18 that review.
19 But even thereafter, in the course of reviewing the 20 project status reports and in concluding on the adequacy of the 21 resolution of all the issues, here will be ample opportunities 22 to provide additional comments and to follow the course of the 23 activities. We don't want to go any further without making 24 some statement about the overall adequacy of these efforts, and 25 that's what we hope to achieve after this meeting.
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s_- 1 MS. ELLIS: Yes, I appreciate that,'and I appreciate 2 your sharing this with us, and we'll look forward to your 3 comments as well.
4 MR. GRIMES: Thank you.
5 Mr. Council, do you have any comments that you want 6 to make before the staff breaks to caucus?
7 MR. COUNSIL: We have no additional comments.
8 MR. GRIMES: All right. In that case,.the staff is 9 going to break to caucus to review the results of the 10 presentations and our notes, and'then we'will reconvene at five 11 minutes to 3:00. Thank you.
12 (Whereupon, a recess was taken.)
13 MR. GRIMES: I would like to reconvene. There was 14 not a whole that we could do in fifteen minutes other than to 15 check our list to make sure that we still had everything here.
. 16 But I would like not to go to those-specific requirements that l 17 the staff feels need to be added to these programs in order to 18 ensure that that they provide everything that-we need to 19 complete our finding of reasonable assurance, and to conclude ,
i 20 on construction and design adequacy. '
21 The first item concerns the major change in the CPRT 22 program plan, and that was to drop the root cause and generic 23 implications evaluation for design by virtue of going to a 24 complete design validation program.
25 While that is understandable from the standpoint of
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53-s, I having a new architect-engineer involved, it leaves a question 2 in our minds in terms of how you evaluate the basis for judging 3 corrective actions that have resulted from the findings of the 4 design activities up to this point.
5 So we will require that you evaluate the nature of 6 the design deficiencies and provide us with a basis for judging 7 the acceptability of the corrective and preventive actions. We 8 will try to articulate that position clearly in our safety 9 evaluation.
10 The second item is that we noted that in he previous 11 meeting on July 29th and 30th that the logic of the nardware 12 validation program is one that relies on findings before to 13 determine what needs to be reinspected, but it does not provide
,, 14 for a means to articulate why the things that are not going to 15 be reinspected do not need to be.
16 So we will require that you group those attributes 17 that will not be reinspected and explain why they do not need 18 to be, just to make the description of the hardware validation 19 complete.
20 The third item concerns providing guidance in the way 21 of where things are changing or have been changed, or where the 22 answers to certain questions are. These are questions about 23 documentation of results. And there are three parts to it.
24 The first part is that the staff has sent you two 25 previous letters concerning code ch'anges. And they involve s-Heritage Reporting Corporation (202) 628-4888
54 s, 1 also FASR changes. We recently received Amendment 65 to the 2 FASR that has picked up a number of issues that have evolved 3 over the course of the last year in CPRT.and CAP activities.
4 In order to make sure-that we clearly understand 5 where the changes are and what is coming down the pike as we 6 are reviewing the corrective action programs, we want you to 7 establish a procedure for identifying potential FASR amendments 8 early and providing the staff with early notification when you 9 feel you need to change the licensing basis for the plant for 10 any particular commitment that currently exists in the FASR.
11 That may be a small effort now because of Amendment 12 65, and I understand Amendment 66 is in the works. But given 13 the nature of the activities that we are going to have during s, 14 the course the review, I would like to have such a system in 15 place from now on.
16 The second part of that is that we have identified 17 certain AISC and ACI code changes in letters that I have 18 written to Mr. Counsil where it.is not clear that we know what 19 are all of the optional requirements that are being imposed 20 where the code allows to either meet a specific requirement or 21 to establish an alternative basis for acceptance.
22 And so we want you toldevelop a catalogue that keeps 23 track of all of the code exceptions or alternative approaches, 24 so that we can be able to look for those during the course of 25 our reviews, s- Heritage Reporting Corporation (202) 628-4888 l
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- s. 1 Along the same lines, we have noted that the issues 2 that the staff previously raised in safety evaluation reports 7 3 through 11 have a number of specific requirements and issues I 4 that you were to address. Some of them have been dealt with by 5 the CPRT and some of them are being tracked through the 6 corrective action programs.
7 In order to make sure that we find all of the answers 8 to those questions, we want you to develop a matrix that 9 identifies the specific issues that the staff previously raised 10 in the technical review team inspections and where the 11 resolution of that particular issue resides, whether it be in a 12 CPRT results report or a corrective action program project 13 status report. , )
,, 14 We would also like to note that a number of 1
15 presentations by Mr. Scott concerning your intentions for 16 pre-operational testing. While we have reviewed the intent of j 17 your approach, that effort is still evolving. And.so that 18 there is not any question in the future when you get that 19 program defined, it will be the staff's position that we expect 20 you to complete a repeat of the pre-operational tests except 21 where you specifically justify that repeating the test is not 22 warranted, or otherwise an alternative can be justified.
23 We want to make that point clear now so that you are 24 not misled in the future in terms of what we expect for 25 pre-operational testing.
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,. 1 There are some administrative points in terms of 2 clarifying your position on what you have done. The staff 3 wants Texas Utilities to confirm that corrective. actions that i 4 have evolved as a result of NRC inspections of CPRT activities 5 have been applied to the initial CPRT activities. The staff 6 began inspections in July of 1985. As a result of those 7 inspections, checklists were changed and procedures were 8 amended, and some of the inspections were repeated.
9 However, the CPRT activities h'ad begun in November of.
10 1984. In order to ensure that all of the CPRT activities are 11 up to date, we want Texas Utilities to go back and confirm that 12 all of the things that you have done as a result.of the 1
13 subsequent staff inspections have been applied to that initial 14 work, and we want a written confirmation of'that finding. (
! 15 During the course of your presentations, you have 16 i
noted that the thrust of the corrective action. program is ]
17 always a line towards Unit 1. The commodities are measured'for 18 Unit 1, and the specific actions.are designed for Unit 1. The 19 application of those corrective actions to Unit 2 is left to ;
l l 20 some kind of managerial control of the status of Unit 2.
21 Before we get much further down in the review of the 1
22 corrective action program, we want you to develop an 23 explanation of the applicability of the corrective action 24 programs to Unit 2, what actions are applied directly and which 25 ones are picked up as part of the formal construction
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'- 1 management process given the status of the construction of Unit 2 2 at this time.
3 And the last item is just a comment for 4 implementation. We previously noted that we are looking into 5 the basis for corrective and preventive actions with respect to 6 design. In terms of our review of the implementation and the 7 adequacy of corrective and preventive action for all of the 8 corrective action programs' scopes of work, we are going to 9 monitor, audit, and inspect the administrative and procedural 10 controls to ensure that those preventive actions and corrective 11 actions are properly implemented.
12 I bring this point up particularly with respect to 13 training activities for new organizations that will be picking s- 14 up responsibility for design from the AEs, or testing from 15 vendors, or like activities. And we would just note that we 16 consider that a very important part of implementation in this 17 substantial corrective action program. And we want to 18 sensitize you to the importance of those managerial and 19 procedural controls.
20 Those are all of our comments at this time. Those 21 also represent the thoughts, and conditions, and requirements 22 that we drafting into our evaluation, which as.I mentioned 23 before, we are going to be finalizing and circulating for staff i
24 review and comment. We hope that process will take 25 approximately two weeks.
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<- 1 So if CASE or Texas Utilities would like to submit 2 information for us to consider, particularly if' Texas Utilities 3 can give us a response to the issues that.I have just raised, 4 we will consider those comments, and commitments, and concerns 5 specifically in our evaluation. You. realize, of course, that 6 means that I am going to be working hard between Christmas and 7 New Years.
8 And with that, Mr. Counsil, are there any closing 9 remarks that you would.like to make?
10 MR. COUNSIL: I have no comments as.taa.the timing 11 between Christmas and New Years.- We will take under advisement 12 the seven items that you have passed to us and the 13 multi-part item, number three, obviously, and attempt to.
s, 14 respond to you prior to Christmas as to what action we will 15 take.
16 MR. GRIMES: I'think that it would also:be prudent 17 for you to tell us what schedule you think that you can l
l 18 accomplish them by.
19 MR. COUNSIL: We will attempt to do so. Some of 20 these items, as I am sure you are well-aware, would be a part 21 of the living document as the p,rogram proceeds. And if so, we 22 will so indicate.
23 MR. GRIMES: All right. Thank you.
24 Ms. Ellis, would you like to make any closing 25 comments on behalf of CASE?
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a 5 59 s, 1 MS. ELLIS: I think that we are all going to be busy 2 through Christmas and New Years. We will do our best to do 3 what we can. As I said, we will continue to give you 4 information when and as we have it available. .And thank you 5 very much.
6 MR. GRIMES: Thank you. Mr. Ebneter.
7 MR. EBNETER: Well, I enjoyed coming to see Comanche 8 Peak and meeting my staff for the first time down here and also 9 the new staff. You heard Chris' comments on these concerns 10 that the staff has, and we expect'a two week response. We 11 would expect CASE to respond within two weeks to the extent 12 possible.
13 If we grant to you any extension of time for these l , 14 comments, we will pass the same extension to Ms. Ellis, so that 15 you will have the same opportunity. We do not expect at this 16 point to grant any extension to our request of two weeks.
17 You did note Ms. Ellis' comments in the meeting. And 18 I want to reassure you that these information gathering 19 meetings to help us make decisions. And we encourage you to 20 get your comments into us, so that we can integrate those into 21 the procedure.
22 With regard to haste, the project will move on in 23 accordance with the schedules that you have established to the 24 extent that the work can be done. We will move within the 25 regulatory framework and times established by the Judge for the s- Heritage Reporting Corporation (202) 628-4888
~ 3 60 1 hearing. So you can be rest assured that we will do whatever 2 we need to do given that time frame.
3 One final comment to PU and Chris* comment on the i
4 Unit 1 ar.d Unit 2. The hearing will be on a two unit site.
5 And you should not lose sight of that factor, because I am sure 6 -that the Judge will not lose sight of it. And we should not !;
7 have significant differences between 1 and 2 that cannot be j 8 explained in the hearing.
9 Other than that, that is all that I have. I 10 appreciate the attendance and the comments by everyone, and of 11 course by my staff. Chris has done a fine job for us, and 12 Janice and Annette. So thank you.
13 MR. GRIMES: The meeting is adjourned. Thank you
%- 14 all.
15 (Whereupon, at 3:10 p.m., the meeting was adjourned.)
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l' CERTIFICATE' 2
v.
3 This'is to' certify that the-attached proceedings;be' fore the 4 United States Nuclear Regulatory Commission in the' matter'of: 1 5 Name: Meeting: Status of Corrective Action Programs at ,
6 Comanche Peak Steam Electric Station' Units l' and 2 ]
7 Docket-Number: 50-445/446 8 Place: Dallas, Texas 9 Date: December.9, 1987 10 were held as herein appears,.and that this is the original 11 transcript thereof for the file of the United States ~ Nuclear 12 Regulatory Commission taken1 stenographically by me and,.
13 thereafter reduced to Typewriting.by me or under the direction-14 of the court reporting company, and that the transcript.is a' 15 true and accurate record of the foregoing proceedings.
16 /S/ 6L4 17 (Signature typed): Barbara Wall '
18 Official Reporter 19 Heritage Reporting Corporation 20 21 ,
1 22 l 23 24 25 Heritage Reporting Corporation
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