ML20195J080
| ML20195J080 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/20/1988 |
| From: | Arros J, Levin H TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20195J075 | List: |
| References | |
| OL, NUDOCS 8801210156 | |
| Download: ML20195J080 (11) | |
Text
O 00LMETED Filed: January 20, SYkk UNITED STATES OF AMERICA 18 JW 20 P133 NUCLEAR REGULATORY COMMISSION OFFICE CF 5ECy14+ v 00 M b C before the ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
)
Docket Nos. 50-445-OL
)
50-446-OL TEXAS UTILITIES GENERATING
)
COMPANY et al.
)
)
(Application for an (Comanche Peak Sceam Electric
)
Operating License)
Station, Units 1 and 2)
)
)
ANSWERS TO BOARD'S 14 QUESTIONS (Memo; Proposed Memo of April 14, 1986)
Recardina Action Plan Results Renort V.b In accordance with the Board's Memorandumt Procosed Memq-randum and Order of April 14, 1986, the Applicants submit the answers of the Comanche Peak Responso Team ("CPRT") to the 14 questions posed by the Board, with respect to the Results Report published by the CPRT in respect of CPRT Action Plan V.b, l
"Shortening of Anchor Bolts."
openina Recuest:
Produce copies of any CPRT-generated checklists that were 1
i used during the conduct of the action plan.
Resoonse:
No checklists were generated or used by the CPRT during the i
conduct of the action plan.
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8G01210156 880120 PDR ADOCK 05000445 l
0 PDR l
Question No. 1:
1.
Describe the problem areas addressed in the report.
Prior to undertaking to address those areaa through sampling, what did Applicants do to define the problem areas further?
How did it believe the problems arose?
What did it dis-cover about the QA/QC documentation for those areas?
How extensive did it believe the problems were?
Respon13:
ISAP V.b addressed improper shortening of bolts at the Steam ' Generator Upper Lateral Restraint (SGUL) connections and the consequent inadequate thread engagement of these bolts.
It also addressed problem areas involving improper installation of tl ?. SGULs and the consequent damage to the threads in the embedment holes, inadequate QC insta31ation inspection records, inadequate design of the SGUL connects.ons and the lack of sup-porting calculations, and discrepancies in the loads specified in the steam generator compartment analyses.
In order to define the problem further and to assist in determining the root cause and generic implications of the improper bolt shortening and observed thread damage in the SGUL l
connections, a number of tasks were performed as part of this l
ICAP, described as follows:
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(1) The fabrication and installation of the SGULs were reviewed to identify the aspects of the fabrication and instal-lation process that might have directly or indirectly contribu-i l
ted to the thread engagement and thread damage on the SGUL connecti;as.
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l (2) The process by which thread engagement requirements for bolting were specified in the design and ir. the inspection requirements were reviewed.
(3) Two populations of threaded connections, Richmond incerts and structural connections with a drilled and tapped blind hole, were inspected on a sampling basis for thread engagement adequacy.
(4) The precess for installing the fifteen different types of bolted connections that constitute the total population of drill and tap blind connections was evaluated to address the possibility of generic applicability of the thread damage problem discovered in the SGUL connections.
The initial concern about improper shortening of the SGUL bolts resulted from an allegation by a former Brown & Root employee.
Section 5.8 of the Results Report contains a detailed discussion of how and why tne problem arose.
No documentation could be located to confirm QC inspection of the SGUL conections at the time of installation.
Other related QC documentation was available, such as Receiving Inspection Records for the SGUL components and Inspection Records of placement of the SGUL embedments before the concrete pour.
The problem with the SGUL connections was resolved by revising the design, fabricating new bolts and shims, and reassembling the connections in accordance with the revised l
design.
No discrepancies were identified in measurenents of i
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I thread engagement of the sample of bolts in the drill and tap blind connections.
Richmond insert inspections and inspection results are dircussed in Appendix 33 of the ISAP VII.c Results Report.
Question No. 2:
2.
Provide any procedures or other internal documents that are necessary to understand how the checklists should be inter-preted or applied.
Response
No checklists were generated or used by the CPRT during implementation of this Action Plan.
Question No. 3:
3.
Explain any deviation of checklists from the inspection report documents initially used in inspecting the same attributes.
Response
This question is not applicable by reason of the response to question 2.
Question No. 4:
4.
Explain the extent to which the checklists contain fewer attributes than are required for conformance to codes to l
which Applicants are committed to conform.
Response
This question is not applicable by reason of the response to question 2.
Question No. 5:
5.
(Answer Question 5 only if the answer to Question 4 is that l
the checklists do contain fewer attributes.)
Explain the engineering basis, if any, for believing that the safety margin for components (and the plant) has not been degraded by using checklists that contain fewer attributes than are i
required for conformance to codes.
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Response
This question is not applicable by reason of the response to question 4.
Question No. 6:
6.
Set forth any changes in checklists while they were in use, including the dates of the changes.
Response
This question is not applicable by reason of the response to question 2.
Question No. 7:
7.
Set forth the duration of training in the use of checklists and a summary of the content of that training, including field training or other practical training.
If the train-ing has changed or retraining occurred, explain the reason for the changes or retraining and set forth changes in duration or content.
Response
This question is not applicable by reason of the response to question 2.
Question No. 8:
8.
Provide any information in Applicants' possession concern-ing the accuracy of use of the checklists (or the inter-observer reliability in using the checklists).
Were there any time periods in which checklists were used with questionable training or QA/QC supervision?
If applicable, are problems of inter-observer reliability addressed i
statistically?
Response
This question is not applicable by reason of the response to question 2.
Question No. 9:
9.
Summarize all audits or supervisory reviews (including reviews by employees or consultants) of training or of use O
of the checklists.
Provide the factual basis for believing that the audit and review activity was adequate and that each concern of the audit and review teams has been resolved in a way that is consistent with the validity of conclusions.
Responta:
No checklists were used, and therefore no audits of train-ing or of the use of checklists were appropriate.
No audits were performed on the overall implementation of this action plan.
Question No. 10:
10.
Report any instances in which draft reports were modified in an important substantive way as the result of management action.
Be sure to explain any change that was objected to (including by an employee, supervisor, or consultant) in writing or in a meeting in which at least one supervisory or management official or NRC employee was present.
Explain what the earlier drafts said and why they were modified.
Explain how dissentirq views were resolved.
Response
No substan*.ive modifications were made to the Results Report as a result of management action.
Question No. 11:
11.
Set forth any unexpected difficulties that were encountered in completing the work of each task force and that would be helpful to the Board in understanding the process by which conclusions were reached.
How were each of these un-expected difficulties resolved?
Re6eonse:
In the course of the investigation of the ISAp, problems l
were determined to exist with design of the SGUL connections, as well as with installation and bolt thread engagement.
To correct the design problem, Westinghouse redesigned the connections based on more conservative loads established in a
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t
revised compartment analysis prepared by G&H and on its own inspection and evaluation of the embedments.
The redesign involved using bolts with a minimum 2-1/8 inches thread engage-ment and with suffici9nt pretensioning to assure a friction connection, ouestion No. 12:
12.
Explain any ambiguities or open items in the Results Report.
Response
To the best of our knowledge, no ambiguities or open items are left in the Results Report.
Ongoing activities are identi-fled in Section 7.0 of the Results Report.
Question No. 13:
13.
Explain the extent to which there are actual or apparent conflicts of interest, including whether a worker or super-visor was reviewing or evaluating his own work or supervis-ing any aspect of the review or evaluation of his own work or the work of those he previously supervised.
Resconse:
No actual or apparent conflicts of interest existed.
Investigatory activities not performed by third-party personnel were closely monitored by third-party personnel.
Question No. 14:
14.
Examine the report to see that it adequately discloses the thinking and analysis used.
If the language is ambiguous or the discussion gives rise to obvious questions, resolve the ambiguities and anticipate and resolve the questions.
Response
The Issue Coordinator and others who aided in the prepara-tion and approval of the Results Report have reviewed and O
checked the Results Report for clarity and believe that no ambi-guitieo exist.
Respectfully submitted, IM J/ K. Arros Action Plan V.b Issue Co rdinator f
)
~w.
H.IA. Levin
\\' NG Review Team Leader The CPRT Senior Review Team has reviewed the foregoing responses and concurs in them.
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OOCKETED 4
UNITED STATES OF AMERICA USNRC NUCLEAR REGULATORY COMMISSION 18 JM 20 P153 before the ATOMIC SAFETY AND LICENSING BOARD f0 E G
V BRANCH
)
In the Matter of
)
Docket Nos. 50-445-OL
)
50-446-OL TEXAS UTILITIES GENERATING
)
COMPANY et al.
)
)
(Application for an (Comanche Peak Steam Electric
)
Operating License)
Station, Units 1 and 2)
)
)
CERTIFICATE OF SERVICE I,
Thomas A. Schmutz, hereby certify that the foregoing Answers To Board's 14 Questions was served this 20th day of January 1988, by mailing copies thereof (unless otherwise indicated),
first class mail, postage prepaid to:
- Peter B.
Bloch, Esquire
- B.
Paul Cotter, Jr.,
Esq.
Chairman Chairman Atomic Safety and Licensing Atomic Safety and Licensing Board Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D C.
20555
- Alan S.
Rosenthal, Esq.
Assistant Director for Chairman Inspection Programs Atomic Safety and Licensing Comanche Peak Project Division Appeal Panel U.S. Nucleav Regulatory i
U.S. Nuclear Regulatory Commission Commission P.O.
Box 1029 Washington, D.C.
20555 Granbury, TX 76048 i
- /
Asterisk indicates service by hand or overnight courier.
2-
- Juanita Ellis Robert D. Martin President, Case Regional Administrator, 1426 South Polk Street
' Region IV Dallas, TX 75224 U.S. Nuclear Regulatory Commission William R. Burchette, Esquire 611 Ryan Plaza Drive Heron, Burchette, Ruckert, Suite 1000
& Rothwell Arlington, Texas 76011 Suite 700 1025 Thomas Jefferson St., N.W.
- Dr. Kenneth A. McCollom Washington, D.C.
20007 Administrative Judge 1107 West Knapp
- William L. Clements Stillwater, Oklahoma 74075 Docketing & Service Branch U.S.
Nuclear Regulatory Joseph Gallo, Esquire Commission Isham, Lincoln & Beale Washington, D.C.
20555 1150 Connecticut Ave.,
N.W.
1 Suite 1100
- Billie Pirner Garde Washington, D.C.
20036 Government Accountability Project
- Janice E. Moone, Esquire Midwest Office Office of the General Counsel 104 E. Wisconsin Avenue - B U.S. Nuclear Regulatory Appleton, WI 54911-4897 Commission Washington, D.C.
20555 Renea Hicks, Esquire Assistant Attorney General
- Anthony Roisman, Esquire Environmental Protection 1401 New York Avenue, N.W.
Division Suite 600 Capitol Station Washington, D.C.
20005 P.O.
Box 12548 Austin, Texas 78701 Lanny A.
Sinkin Christic Institute Robert A.
Jablon, Esquire 1324 North Capitol Street Spiegel & McDiarmid Washington, D.C.
20002 1350 New York Avenue, N.W.
Washington, D.C.
20005-4798 Nancy Williams CYGNA Energy Services, Inc.
- Elizabeth B. Johnson 2121 N. California Blvd.
Oak Ridge National Laboratory Suite 390 P.O.
Box X Building 3500 Walnut Creek, CA 94596 Oak Ridge, Tennessee 37830 David R.
Pigott
- Dr. Walter H. Jordan Orrick, Herrington & Sutcliffe c/o Carib Terrace Motel 600 Montgomery Street 522 N. Ocean Boulevard San Francisco, CA 94111 Pompano Beach, Florida 33062
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- Robert A..Wooldridge, Esquire Worsham, Forsythe, Sampels-
& Wooldridge 2001 Bryan Tower, Suite 3200 Dallas, Texas 75201
- W.
G.
Counsil Executive Vice President Texas Utilities Electric -
General Division 400 N. Olive, L.B.
81 y
Dallas, Texas 75201
{f Thomas A. Schmutz Dated:
January 20, 1988 4
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