ML20198T102
| ML20198T102 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/05/1986 |
| From: | Mallanda J, Pearson J NRC, NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM) |
| To: | |
| References | |
| CON-#286-500 OL, NUDOCS 8606110314 | |
| Download: ML20198T102 (25) | |
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June 5, 1986 x
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UNITED STATES OF AMERICA 7N
'l NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARL 5
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In the Matter of
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Docket Nos. 50-445-OL TEXAS UTILITIES ELECTRIC
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50-446-OL COMPANY et al.
)
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(Application for an (Comanche Peak Steam' Electric
)
Operating License)
Station, Units 1 and 2)
)
)
ANSWERS TO BOARD'S 14 QUESTIONS (Memo; Proposed Memo of April 14, 1986)
Regarding Action Plan Results Report I.a.4 In accordance with the Board's Memorandum; Proposed Memerandum and Order of April 14, 1986, the r
Applicants submit the answers of the Comanche Peak i
Response 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 I.a.4.
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Que stior. :
1.
Describe the problem areas addressed in the report.
Prior to undertaking to address those areas through sampling, what did Applicants do to define the problem areas further?
How did it believe the problems arose?
What did it discover about the QA/QC documentation for those areas?
How extensive did it believe the problems were?
Answer:
This Action Plan was prepared and published to respond to a specific technical concern raised by the NRC Staff's TRT.
The TRT, investigating allegations to the effect that construction craft was mislanding conductors (i.e.,
connecting the conductors to improper terminals) and that QA was " buying off" on the mislanded conductors, investigated the state of the installed conductors.
Proof of the allegation would lie, if it were true, in the existence of mislanded conductors.
The TRT inspected some 1600 terminations and found six (and only six) that appeared to be mislanded.
At that point, however, the TRT stopped its investigation and posed the requirement to TUGCO that the matter be investigated further.
The first thing done by the CPRT Electrical Review Team was to analyze the six TRT-found terminations.
Our analysis, which is set forth in the
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ActionJian Re,sultesRepor.t,,
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the six terminations was (.n.fac9 mislanded so"as to N \\ s pr
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- Indeed, had the TRO investigation been structured so as'.
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to permit the TRI$o onduct a similar analysis and to
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j pursue.Mhe~ n.atter further than' TRT did pursue it, we
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doubt that'the TRT would bave;, included this item in itty
- list of'raatteri to be furtheriinves~tigsttsi.
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- p We did not!" define the problem" further, except that, as a means of invest,igating the hypothesis that
'tby allegations were truo we propoced and the Staff s
L concurred in a random sample re-inspection (at the 95/1 4
level) on a selected population of theJmost safety-siefpificant. y rminations.
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4We did liot review QA/QC documentatien6 Such a
,,s' review might have ' deen.,tequired in order to assess the 1
cause of a deviatir.e; terminat,i~on., had the re-
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inspectiotis found any de'.yiattop.s'.
No deviations were found.
As is discussed,insthe'Results Report, we
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craft maifeasance coupled with QA malfeasance or nonfeasance) did not in fact occur.
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Questiqn:
2.
Provide any procedures or other internal documents that are necessary to understand how the checklists should be interpreted or applied.
Answer:
Attached are copies cf the four revisions of the CPRT inspection procedures prepared for implementation of the termination re-inspections for this Action Plan.
(The re-inspections were performed for the Electrical Review Team by the QA/QC Review Team, under the direction of Mr. John Hansel of Evaluation Research Corporation.)
Please note that all inspections were performed under the last of these revisions (Rev. 3).
The only matter that occurs to us that might warrant explanation is that the checklist included an inspection attribute that was beyond the scope of the acceptance criteria as set forth in the Action Plan, namely proper tagging of the conductor.
The reason for including this attribute was to insure proper identification by the inspector of the conductor he was to inspect; it was included as a check on the inspector, not the termination.
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Questian:
3.
[ Original acceptance checklists.
See Transcript of the Pre-Hearing Conference of April 22, 1986, at 24,353-57, attached.]
Answer:
We are forwarding under separate' cover the revisions of QI-QP-11.3-28 in effect at three points in time:
when the TRT investigation was done (September, 1984); when the re-inspections for this Action Plan were done (January, 1985); and the present.
The inspection checklist is a part of the procedure.
There are a total of 30 revisions of this procedure, and any of them is available upon request.
Question:
4.
Explain the extent to which the checklists contain fewer attributes than are required for conformance to codes to which Applicants are committed to conform.
Answer:
Within the scope of the Action Plan, none.
By this we mean to point out that the Action Plan was itself limited to a single attribute of terminations, namely location.
This attribute is precisely the same as the cognate attribute that would have been inspected for in the original acceptance inspections.
On the _ _ _ _ _
other hand, of course, the original acceptance inspections also inspected for a number of additional attributes bearing on the quality of the termination, such as proper lug, proper tools, quality of crimp and the like.
These other attributes were not within the scope of this Action Plan.
Question:
5.
(Answer question 5 only if the answer to question 4 is that 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 required for conformance to codes.
Answer:
N.A.
Question:
6.
Set forth any changes in checklists while they were in use, including the dates of the changes.
Answer:
Rev. 0 - 12/13/84; Rev. 1 - 12/17/84; Rev.
2-12/20/84; and Rev. 3 - 12/28/84.
Rev. 3 - 12/28/84.
Please note that all inspections were in fact performed under Rev. 3.
Question:
7.
Set forth the duratien 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 training has changed or retraining occurred, explain the reason for the changes or retraining and set forth changes in duration or content.
Answer:
The training consisted of familiarization with the inspection procedure and checklist and familiarization with the Action Plan.
Given the limited scope of the inspections and the non-subjective nature of the inspection attributes, this training was appropriate.
All inspectors had been qualified as Level II inspectors in the electrical area.
No change in the training or retraining was deemed necessary or in fact performed.
Question:
8.
Provide any information in Applicants' possession concerning 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 statistically?
Answer:
We have no specific data regarding inspector reliability apart from the fact that nothing in the Inspection Reports or our analysis thereof has given us any reason to doubt the ability of the inspectors to implement the inspection procedure.
The nature of the "unsats" returned by the inspectors satisfies us that the inspectors were in fact doing their job as they were supposed to.
Question:
9.
Summarize all audits or supervisory reviews (including reviews by employees or consultants) of training or of use 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.
Answer:
No audits or supervisory reviews were performed by the Electrical Review Team or by the QA/QC Review l
Team.
Question:
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.
a.Dy 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 dissenting views were resolved.
Answer:
Neither the Review Team Leader (Mr. Mallanda) nor the Issue Coordinator for this Action Plan (Mr.
Pearson) can think of anything that amounts to a substantive change (much less an "important substantive change") that occurred during the Results Report review-editing-revision process.
As a consequence, our answer to this question is:
None.
Question.
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 unexpected difficulties resolved?
Answer:
While not a difficulty respecting terminations per se, the implementation of this Action Plan revealed some difficulties with respect to the implementation of the random sample selection process outlined in Program Plan Appendix D.
That process, which is based on a
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publish,ed list of random digits, required a substantial amount of tedious hand-calculation both to generate the random numbers and to " map" the resulting selections to the list of members of the population under evaluation.
In the ordinary course of verifying work and preparing a results report, a validation of the random sampling process employed during this Action Plan was performed by the Issue Coordinator, a portion of which validation consisted of the following steps:
Manually " key in" the random digits (from A Million Random Digits by the Rand Corporation) to a personal computer.
Instruct the computer to determine the list of population members for the same in accordance with Appendix D to the CPRT Program Plan.
Compare this list with that used during the reinspection process.
Sort this list by population member and compare for " duplicates" (population members selected more than once).
4 While the first three steps above did not reveal any errors, twelve (12) pairs of duplicates were _ _ _ -
4 identi(led by the fourth step, while only ten (10) had been identified by the original process.
An i
investigation into the reason for this difference revealed the following about the original process:
The list of pcpulation members for the sample had been " mapped" to the i
corresponding cable and conductor for inspection using a typewritten list of cables, which had the number of conductors in each cable identified in parentheses
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after each cable number.
" Selected" conductors were then grouped by their corresponding drawing to facilitate the inspection process.
It would be at this step that duplicates would be first noticed, and indeed there were only 10 duplicate pairs.
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j For the two (2) duplicate pairs that were not found originally, it was determined that one of each pair had been incorrectly mapped (i.e.,
the wrong conductor was chosen), and thus the two additional duplicate pairs could not have been detected.
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result of this discovery, a 100% check of the mapping 4
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process was performed and thirteen additional errors were found.
All errors have been corrected and the proper reinspections performed.
The results of these 4
re-inspections will be discussed in a pending revision to the results report.
The root cause of this specific problem was clearly the manner in which the population was listed.
i The Issue Coordinator found this method of listing caused the sample mapping to be a tedious and error-prone process.
Furthermore, while no errors had been found in the calculation of the sample numbers, the Issue Coordinator considered that process to be error-prone and extremely tedious.
CPRT has subsequently acquired personal computer " diskettes" with all of the digits from the Rand Corporation book transcribed thereon.
CPRT has written computer programs that access this data and perform all calculations and duplicate identification automatically.
These programs are being used by CPRT on an ongoing basis to both generate new samples, and to validate samples that were generated
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We wish to emphasize that these errors did not and could not have affected the validity of the Action Plan implementation.
In the first place, this was so because of the validation of the process.
- However, even if undetected, these errors would not have diminished the quality of any reinspection; rather they 4
would have affected the random sample selection i
process.
The effect, however, would have been to alter but not impair randomness:
while the aggregate sample selected would not have been precisely the one called for by the Rand Corporation digits, it would nonetheless have been selected free of conscious human input or bias.
Question:
12.
Explain any ambiguities or open items left in the results report.
Answer:
Please see the answer to Question 14.
Question:
13.
Explain the extent to which there are actual or apparent conflicts of interest, including whether a worker or supervisor was reviewing or evaluating his own work or supervising any aspect of the review or evaluation of his own work or the work of those he previously supervised.
4 _ __ _._
Answer 4, None.
Question:
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.
Answer:
Based on the re-examination that the Board has requested, and on some comments that we are aware of from outside sources, there are four matters that we will expand upon.
.l.
The population and random sample of condttetors whose termination was inspected included spare conductors in " safe shutdown" cables.
As previously discussed in a response to NRR, the basis for including spares was as follows:
Spare conductors could potentially be
' involved with functional deficiencies (e.g.,
a spare conductor reversed with a functional conductor, a spare conductor connected to an active circuit, etc.),
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thus information concerning spares should i
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not be bypassed.
1 Often conductors that were once functional 7
are spared by design change, and it was considered to be important to check these conductors for adequacy of the design change implementation process.
The TRT had checked and addressed spares.
In fact one of the' Cindings involved spare conductor = t c had once been functional and (after being spared by design change) were not lifted from their respective terminal points.
Subsequent to the publication of the Results Report, however, we have received a comment to the effect that spares should not have been included in the population, and that by including spares we effectively 4,
reduced the sample of non-spare conductors to something less than the 300 samples necessary to achieve the stated screen of 95/1.
For the reasons set forth above, we did not believe that criticism to be valid, 4
nor, given the results of the Action Plan, did we believe that the results would be different if only
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unspargd conductors had been considered valid samples.
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However, to satisfy any concerns, a new sample was j
selected to_ increase the number of active (i.e.,
non-4
. spare) conductors to at least 300.
This sample has been inspected and no "unsats" were noted.
The details 4
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of this additional activity will be included in a pending revision to the Results Report.
2.
Results Report, paragraph 5.5, discusses
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related CPRT activities, specifically ISAPs I.a.2 and l
VII.c.
It should be noted that neither of these ISAPs I
j have been completed, and the information presented for I.a.4 was intended only to show that terminations were being examined in other areas than just I.a.4.
Further, the finding regarding conductor reversal discovered during implementation of ISAP I.a.2 was
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presented due to its similarity to the original TRT l
j finding.
The details and resolution of all findings discovered during implementation of ISAP I.a.2 will be presented in either the Results Report or the working files for that ISAP.
3.
Section 5.2.1 employs the term " valid a
samples," which was not clearly defined in the Results 1
Report or working files.
The intent of this term was 1
_. _.. _ _ _ _ _ _. _. _. -. _, _ ~. _ _ _ _ _ _ _ _ _
to distinguish correctly-mapped conductors that were subsequently found to be accessible for ERC inspection.
A pending revision to the Results Report for this ISAP will provide a definition of this term, and will make some minor corrections in the exact count of conductors fitting this category.
4.
In the process of carrying out their inspections, ERC made several notations on inspection reports, which were subsequently addressed by TUGCO.
The TUGCO responses were all reviewed by third party personnel and found to be acceptable.
All of these activities are clearly documented in the ISAP working files, however, only those findings that uncovered potentially discrepant conditions were explicitly discussed in the Results Report.
We have reviewed the items discussed in the Results Report, and still JUN 9 '66 19: 48 C:-T-GLEN RO PAGE.22 consider that we have included all findings that are relevant to the issue of this ISAP.
Respectfully sumitted, I
hn J.J9tllanda PRT elm trical Review Team Leader N
. R.'Pearson Action Plan I.a.4. Issue Coordinator The foregoing responses have been reviewed and are concurred in by the CPRT Senior Review Team.
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- TOTAL PAGE.02 **
t 24353 1
minutes.
2 When this order was received, two questions were
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3 put to the SRT.
First question is, could the SRT respond 4
to each of these fourteen questions insofar as they were 5
applicable, of course, for each one of the CPRT results 6
reports that would be forthcoming, and do so comfortably; 7
and the second question was could you do so at all?
8 I won't tell you what they said about 9
comfortably, but the answer was yes, they could do it for 10 each of them.
It is not feasible to change the format of 11 results reports for results reports that will come out in 12 the future, so there will be a piece of paper entitled 13 something like "C?RT Answers to Board Interrogatories With
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14 Respect to Results Report No.
1."
15 And it will be out such that the thirty days 16 remains within the existing schedule that we have propraed 17 as modified by the Staff.
18 Having said that, I feel obliged to point out to 19 Your Honors that one of the questions, and we're not 20 objecting to the question, but one of questions presupposes 21 a fact that, for the most part, is not so.
t 22 Question No. 3 presupposes that what CPRT did 23 when they used an inspection checklist was to take an 24 extant checklist, a so-called original acceptance
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25 checklist, review it, mark it up with a blue pencil and TATE REPORTING SERVICE, (713) 222-7177
24354 1
then proceed ahead.
And the Question No. 3 says, in 2
essence, "Tell us each place that you wielded the blue
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3 pencil."
4 That is not how CPRT functioned.
Where it did an 5
inspection, it created its checklists from scratch in order 6
to comply with the requiremqnts of the ISAP and such a 7
comparison does not exist.
Apart from that, they said --
8 JUDGE BLOCH:
I didn't make that presupposition, 9
but does that mean that you can create that comparison?
10 MR. GAD:
The answer, of course, is he could be 11 made.
I cannot tell Your Honors that it could be done in a 12 reasonable time.
That's a lot of work.
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13 JUDGE BLOCH:
Okay.
Can you answer 4 without 1
14 answering 37 15 MR. GAD:
Yes.
16 JUDGE BLOCH:
Okay.
Is there any objection to 17 deleting Question 3 in that event, if 4 will be answered?
19 MS. GARDE:
I think if all the documents were 19 produced and the development of the checklist that we can 20 answe'r No. 3 ourselves and I think that since each of the I
21 ISAPS is very different, I looked at what.was produced 22 yesterday in response to the results r2 ports that are I
23 issued, and some of them don' t even have checklists, j
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24 per se.
25 I think because' of that, it is important to TATE REPORTING SERVICE, (713) 222-7177 i
24355 1
include the original inspection report or procedure 2
documents that were used so that
',e could explain the 3
deviations.
If that was done, I think that that was 4
acceptable.
5 JUDGE BLOCH:
Could you then produce the 6
inspection reports that were used originally and not make 7
the comparison?
8 MR. GAD:
Absolutely.
I suspect they were 9
already produced at one point in time.
10 JUDGE BLOCH:
For the Board's purposes, we'll 11 accept just the most recent checklist so that we can look 12 briefly at how it compares.
For discovery purposes, they
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13 probably want all of them and I'm not going to study all of 14 them right now.
15 MR. GAD:
Whichever.
The answer is yes, they can 16 be produced.
17 JUDGE BLOCH:
Okay.
So we will modify Question 3 18 by only asking that the most recent inspection reports 19 checklists relevant to that subject matter be attached.
20 MS. GARDE:
You mean inspection procedures?
You 21 want the original site inspection procedures used not all 22 the inspection documents.
23 JUDGE BLOCH:
It's the actual inspection
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24 checklists what we'rt talking about.
25 MR.. GAD:
What Your Honor wants is the checklist TATE REPORTING SERVICE, (713) 222-7177
1 24356
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I that was used for the yaying or naying an attribute --
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MS. GARDE:
Yes.
3 MR. GAD:
I understand that.
Sometimes it's in 4
the inspection report, sometimes it's in something else.
5 JUDGE BLOCH:
I tell you what, I'm trying to 6
remember, but I think at some point we asked that -- well, 7
under 2, we would get the procedures or other documents 8
necessary to understand the checklists.
Actually one 9
already asks for the checklists, doesn't it?
10 MR. GAD:
Those are the CPRT checklists.
11 JUDGE BLCOH:
Okay.
12 MR. GAD:
No. 3 refers to --
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13 JUDGE BLOCH:
I would only ask that if the' 14 checklists that you produce for some reason is ambiguous 15 without the attached procedure, just make a fair faith 16 judgement about that and then we would like to see the
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I 17 procedure.
If it seems to be fairly clear on it's face, 18 just give us the checklist.
19 MR. GAD:
Will do.
If in fact you're talking 20 about CPRT, both are in the files.
21 JUDGE BLOCH:
Okay.
Now we're talking in 3, the 22 inspection reports on the plant.
23 MR. GAD:
The original ---
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24 JUDGE BLOCH:
The attribute chestlist.
25 MR.. GAD:
If the checklist is obscure, we'll come TATE REPORTING SERVICE, (713) 222-7177
24357 3
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1 up with a document that explains -
2 JUDGE BLOCH:
Nothing could be so bad as to be
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3 obsctrre, but --
4 MS. GARDE:
5 think there needs to be a little 5
more clarification on that.
Are you requesting, and are 6
Applicants committing to provide the pre-CPRT inspection 7
checklists or the one that is currently in use on the site?
8 JUDGE BLOCH:
Pre-CPRT checklist.
Is there still 9
inspection work being done on the site other than by the
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10 CPRT7 11 MS. GARDE:
Yes.
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12 MR. GAD:
Absolutely.
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13 JUDGE BLOCH: 'So there is -- in some cases, just 14 based on my review, a significant difference between
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15 inspection procedures that may have'been used before the l
16 CPRT started its work and after the CPRT.
17 JUDGE BLOCH:
We'll count on C.A.S.E.
to clarify
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i 18 that for us.
We're just asking for the CPRT -- for the
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19 checklist that was used prior to CPRT.
20 MR. GAD:
With that, Your Honor, I'll contribute
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23 MR. CHANDLER:
We're going to make a major
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24 contribution that that effort, Mr. Chairman, because we 25 have no comments on this matter.
TATE REPORTING SERVICE, (713) 222-7177
r CERTIFICATE OF SERVICE l
I, Robert K. Gad III one of the attorneys for the Applicants herein, hereby certify that on June 5, 1986, I made service of the within " Answers to Board's 14 Questions (Memo; Proposed Meme of April 14, 1986) Regarding Action Plan Results Report I.a.4" by mailing copies thereof, postage prepaid, to:
Peter B.
Bloch, Esquire Mr. James E.
Cummins Chairman Resident Inspector Administrative Judge Comanche Peak S.E.S.
Atomic Safety and Licensing c/o U.S. Nuclear Regulatory Board Commission U.S. Nuclear Regulatory P.O.
Box 38 Commission Glen Rose, Texas 76043 Washington, D.C.
20555 Dr. Walter H. Jordan Mr. William L. Clements Administrative Judge Docketing & Services Branch 881 W.
Outer Drive U.S. Nuclear Regulatory Commission Oak Ridge, Tennessee 37830 Washington, D.C.
20555 Chairman Chairman Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Board Panel U.S. Nuclear Regulatory.
U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Stuart A. Treby, Esquire Mrs. Juanita Ellis Office of the Executive President, CASE Legal Director 1426 S.
Polk Street U.S. Nuclear Regulatory Dallas, Texas 75224 Commission Washington, D.C.
20555
T Renea Hicks, Esquire Ellen Ginsberg, Esquire Assistant Attorney General Atomic Safety and Licensing Environmental Protection Division Board Panel P.O.
Box 12548, Capitol Station U.S. Nuclear Regulatory Commission Austin, Texas 78711 Washington, D.C.
20555 Anthony Roisman, Esquire Joseph Gallo, Esquire Executive Director Isham, Lincoln & Beale Trial Lawyers for Public Justice 1120 Connecticut Avenue, N.W.
2000 P Street, N.W.,
Suite 611 Suite 840 Washington, D.C.
20036 Washington, D.C.
20036 Dr. Kenneth A. McCollom Mr. Lanny A.
Sinkin Administrative Judge Christic Institute 1107 West Knapp 1324 North Capitol Street Stillwater, Oklahoma 74075 Washington, D.C.
20002 Ms. Billie Pirner Garde Mr. Robert D. Martin Citizens Clinic Director Regional Administrator, Government Accountability Project Region IV 1901 Que Street, N.W.
U.S.
Nuclear Regulatory Commission Washington, D.C.
20009 Suite 1000 611 Ryan Plaza Drive Arlington, Texas 76011 Elizabeth B._ Johnson Geary S. Mizuno, Esquire Administrative Judge Office of the Executive Oak Ridge National Laboratory Legal Director P.O.
Box X, Building 3500 U.S. Nuclear Regulatory Commission Oak Ridge, Tennessee 37830 Washington, D.C.
20555 Nancy Williams Cygna Energy Services, Inc.
101 California Street Suite 1000 San Francisco, California 94111
).
iM r
Robert K. GdJII
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