ML20203N939

Answers to 14 ASLB Questions Re Action Plan Results Rept VII.a.5,per 860414 Proposed Memorandum & Order.Certificate of Svc Encl

ML20203N939
Person / Time
Site:	Comanche Peak
Issue date:	10/10/1986
From:	Gelzer J, Hansel J NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
To:
References
CON-#486-1091 OL, NUDOCS 8610200125
Download: ML20203N939 (11)

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, j/f)ff / Filed: Octobor'10, 1986 6

00CHETED USNPC 36 m:T 15 P1:12 UNITED STATES OF AMERICA hffh;k.[

gg _ f ; 6, L ?.i; NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of ) <

) Docket Nos. 50-445-OL

. TEXAS UTILITIES ELECTRIC- ) 50-446-OL COMPANY et al. )

) (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 VII.a.5 In-accordance with the Board's Memorandum; Proposed Memorandum and Order of April 14, 1986, the Applicants submit the answers of the Comanche Peak 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 Plen VII.a.5.

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r Opening Recuest:

Produce copies of any CPRT-generated checklists that were used during the conduct of the action plan.

Answer:

The checklist is attached.

Question:

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 ISAP was developed in response to the finding identified by the TRT and confirmed in Region IV Inspection Report 50-445/8432 that TUEC Management did-not regularly review the status and adequacy of their QA Program. The Region IV Report also stated that procedures had not been established to perform this activity. These findings were identified as violations of the FSAR commitment to 10 CFR 50, Appendix B.

The SRT decided that this ISAP (VII.a.5) would not address the historical aspects of this subject but would concentrate on ensuring that the current TUGCO program would provide for an adequate and effective periodic review of the QA Program for the remainder of l

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, construction and for the operating phase. The quality of hardware and any potential safety implications which may have resulted from an-inadequate review of the QA Program will be assessed through other hardware and programmatic ISAPs. Further discussion on why this approach was deemed appropriate is contained in Section 3.0 of the VII.a.5 Results Report.

Question:

2. Provide any procedures or other internal documents that are necessary to understand how the checklists should be interpreted or applied.

Answer:

The only checklist utilized was developed from the criteria contained in Sections 5.1.1 through 5.1.4 of the VII.a.5 Results Report. The criteria was developed by the Issue Coordinator; the checklist was then prepared and Implemented by the Issue Coordinator.

Therefore, no additional documentation was required.

Question:

3. Explain any deviation of checklists from the inspe,ction report documents initially used in inspecting the same. attributes.

Answer:

There were no TUGCO checklists generated to perform the activities that this Action Plan performed, i.e., review and evaluation of the TUGCO program for r-l Periodic Review of QA Program. Therefore, a comparison cannot be made.

-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:

The checklist was developed from criteria which are'actually expansions of the NRC acceptance criteria for this activity. These are based on the requirements of Criterion II of 10 CFR 50 Appendix B and ANSI N45.2.

There are no additional codes on which to base attributes. The checklist used thus conforms with codes and standards to which CPSES is committed.

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:

, In light of the answer to question 4 above, this question is not applicable to this ISAP.

! Question:

6. Set forth any changes in checklists while they were in.use, including the dates of the changes.

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Answer:

No substantive changes were made to the checklist during implementation of the ISAP.

Question:

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 training has changed or retraining occurred, explain the reason for the changes or retraining and set forth changes in duration or content.

Answer:

Because the checklist was prepared and implemented by the Issue Coordinator, no training was required.

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:

The checklist was used by the Issue Coordinator during the document review; therefore, it is unlikely that any error in the use of the checklist exists'.

Question:

9. Summarize all audits or supervisory. reviews (including reviews by employeer or consultants) of training or of use of the checklists. Provide the factual basis for believing that the audit

r 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 conducted.

Question:

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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

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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 dissenting views were resolved.

Answer:

No important or substantive changes were made to the Results Report.

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:

No unexpected difficulties were encountered in completing the work for this report.

Question:

12. Explain any ambiguities or open items left in the Results Report.

r Answer:

There are no'open items remaining in the Results Report. After review of the' report, we believe that no ambiguities are contained in the report.

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.

Answer:

The CPRT has instituted a procedure that requires personnel involved in CPRT activities to carefully examine possible areas of conflict and signify that conflicts of interest does or does not exist. This process, coupled with the initial screening process performed prior to bringing third-party consultants on-site for the CPRT, reduces the likelihood of a conflict of interest to an acceptably low level.

Question:

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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:

Mr. J. Gelzer, the Issue Coordinator, has

~ reexamined the Results Report and does not see any i

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c.mbiguitice or obvioua quantions. Admittedly, hio

. close association with the contents of tha repe:rt renders it difficult for him to discern questions or ambiguities.

However, we believed that the extensive review process has eliminated any ambiguities.

Respectfully submitted, Jp R. Gelzer/ J Action Plan VII.a. Issue Coordinator hn L. Hansel \

PRT QA/QC Review Team Leader The foregoing responses have been reviewed and are concurred in by the CPRT Senior Review Team.

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PERIOD 3C REVIEW DF DA PROGR

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Evaluate(Program)

Program the TUGCO written program f or the Periodic Review of QA in accordance with this checklist.

The criteria used to develop this checklist are the criteria developed during the implementation of f ound in Sections 5.1.1 through 5.1.4 ofISAP the VII.a.5, and may be Results Report for this ISAP.

The numbers checklist Results correspond Report. to the appropriate section ofin parenthes the VII.a.5 1.

Does status,the Programand adequacy, require compliancethe regular of assessment of the scope ,

Appendix B? (5.1.1) the OA program to 10CFR50, 2.

Does the Program define the management positions responsible for the Periodic Review of OA Program? (5.1.2) 3.

Are the management positions specified above or organization outsi de the forOA .

activities af fandecting the quality?

line managers directly responsible (5.1.2) 4.

Does the Program provide for frequent contact, by personnel reports, meetings, and/or audits?program responsible for the reviews, with (5.1.3) status through 5.

Does the Program provide f or the performance of preplanned and documented (5.1.3) assessments .to be perf ormed at least annually?

6.

Does the Program describe the methodology for reporting tracking, of and follow-up DA Program? (5.1.4) of the results of the periodic Review Concurrence _ dh _ld_

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.. 09.Wrre u.wc CERTIFICATE OF SERVICE 16 TT 5 PI 33 0

I, Robert K. Gad III, one of the attorneys f0t [lCE O snv. v ,,#k{

herein, hereby certify that on October 10, 1986, I made service of the within " Answers to Board's 14 Questions (Memo; Proposed Memo of April 14, 1986) Regarding Action Plan Results Report VII.a.5" by mailing copies thereof, postage prepaid, to:

Peter B. Bloch, Esquire Mr. Thomas F. Westerman Chairman Comanche Peak S.E.S.

Administrative Judge c/o U.S. Nuclear Regulatory Atomic Safety and Licensing Commission Board P.O. Box 38 U.S. Nuclear Regulatory Glen Rose, Texas 76043 Commission 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

/~ l Renea Hicks, Esquire Ellen Ginsberg, Esquire Assistant Attorney General Atomic Safety and-Licensing' 1 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 Mr. Lanny A. Sinkin Executive Director Christic Institute Trial Lawyers for Public Justice 1324 North Capitol Street 2000 P Street, N.W., Suite 611 Washington, D.C. 20002 Washington, D.C. 20036 Dr. Kenneth A. McCollom Mr. Robert D. Martin Administrative Judge Regional Administrator 1107 West Knapp Region IV Stillwater, Oklahoma 74075 U.S. Nuclear Regulatory Commission Suite 1000 611 Ryan Plaza Drive Arlington, Texas 76011 Ms. Billie Pirner Garde Geary S. Mizuno, Esq.

Midwest Office Office of the Executive 3424 N. Marcos Lane Legal Director Appleton, WI 54911 U.S. Nuclear Regulatory Commission Maryland National Bank Bldg.

Room 10105 7735 Old Georgetown Road Bethesda, Maryland 20814 Elizabeth B. Johnson Administrative Judge Oak Ridge National Laboratory P.O. Box X, Building 3500 Oak Ridge, Tennessee 37830 Nancy Williams Cygna Energy Services, Inc.

101 California Street Suite 1000 San Francisco, California 94111

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Robert K. Gad II

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