ML20205F530

Answers to ASLB 860414 Memorandum & Proposed Memorandum & Order on Comanche Peak Response Team (Cprt) Results Rept Re Cprt Action Plan I.a.3.W/Certificate of Svc.Related Correspondence

ML20205F530
Person / Time
Site:	Comanche Peak
Issue date:	08/14/1986
From:	Mallanda J, Pearson J TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
References
CON-#386-360 OL, NUDOCS 8608190234
Download: ML20205F530 (11)

Text

7 e m CORCESf'G**U L Filed: August /Y, 1986 DOCKETED USNRC j6 AUG 18 A1053 CFFIC: 0r EEi.. T -

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UNITED STATES OF AMERICA '.

NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD

)

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 I.a.3 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 Plan I.a.3.

8608190234 860814 PDR ADOCK 05000445 G PDR 1503

t Opening R'eauest:

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

Response

No checklist was used during the conduct of this ISAP. The task consisted of a review of the qualification document and procedures. This did not requita a checklist.

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 prbblem areas further? How did it believe the pr'oblems arose? What did it diccover about the QA/Q9 documentation for those areas?

How extensive did it believe the problems were?

Answer:

This Action Plan was prepared to respond to specific concerns raised by the NP.C's TBT. The concerns a, rose from conditions it;. posed on the use of butt-splices ifa control panelsi conditions were imposed by the NRC after reviewing TURC's justific.atiun for using butt-splices in control panels. (They were also imposed after the butt oplic.ea nns been <

installed.) Up6n inspection of the butt-splices in safety-related control pahels and review of the

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installation procedures, the TRT concluded that the procedural requirements set forth by TUGC0 did not include the three conditions for acceptability imposed by the NRC. These conditions are:

a) Qualifications - The butt splices must be qualified for their expected service conditions at CPSES. CPRT was to investigate whether such qualification existed, and, if not, recommend replacing the butt-splices with qualified hardware.

b) Operability - Circuit continuity must be verified for all spliced circuits. Though we considered that adequate electrical testing will ultimately be performed on all (spliced and non-spliced) circuits, a specific step that required continuity checks to be performed at the time of butt-splice installation was to be.added

i. to the appropriate construction and inspection procedures.

c) Staggering - Butt-splices in wire bundles must be staggered so that they are not adj acent to and pressing upon one another.

Procedural revisions to insure that future installations are staggered was a task of this action plan. Inspection of existing installations were to be covered as part of the inspection effort being performed under Action Plan I.a.2, " Inspection Reports on Butt Splices."

Question:

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

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Answer:

There is no CPRT checklist associated with this ISAP. The only reviews performed were to review the qualification data for AMP PIES splices to assure that they are qualified for the expected service conditions at CPSES, and to assure that procedures were updated to include continuity checks and staggering.

Question:

3. [ Original acceptance checklists. See Transcript of the Pre-Hearing Conference of April 22, 1986, at 24,353-57.]

Answer:

While there are TUGCO checklists associated with installation of butt-splices, they are not pertinent to this action plan. (See answer to question #2.) ISAP I.a.2 deals with the actual hardware inspection of butt-splices, and the comparison of TUGCO checklists with CPRT checklists will be meaningful within the context of that ISAP. That is not the case here' because ISAP I.8.3 does not use checklists and I.a.3 is not involved with the inspection of hardware.

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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:

None; no checklist was used in this ISAP. (See the responses to 2 and 3.)

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: 2.,

Not applicable due to the answer to question 4 being none.

Question:

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

Answer:

Since there were no checklists, there were no changes.

Question:

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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 l

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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:

Not applicable since there was no checklist.

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:

Not applicable since there was no checklist.

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:

Not applicable; there was no checklist, therefore training was not required.

Question:

10. Report any instances in which draft reports were modified in an important substantive way as the l

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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 dissenting views vero resolved.

Answer:

Neither the Review Team Leader (Mr. Mallanda) nor .

the Issue Coordinator (Mr. Pearson) can think of anything that amounts to a 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:

No unexpected difficulties were encountered. The progress of work on the action plan proceeded in a straight-forward fashion.

Question:

12. Explain any ambiguities or open items left in the results report.

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4 AUG 13 '86 16:55 CPRT-GLEN RO PAGE.03 AUG B 'WW 11139 NUrts uneetr sau suss siivws =

I Apswer No open items exist. No ambiguities are discernible to the authors or reviewers.

Question:

13. Explain the extant to which there are actual or apparent conflicte 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:

No conflicts of interest are known to the Review Team Leader or Issue Coordinator.

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.

! AnswgI The Review Team Leader and Iseue Coordinator have j

re-examined the Results Report, and are unable to perceive, any ambiguities or unanswered questions.

Respectfully submitted, M1.)MAda p hn Jff. Ma11anda CPRT m ectrical Review Team Leader i

AUG 13 '96 16:55 CFPT-GLEN RO PAGE.04 NUf3 9 'Ub 11139.. NUPhh GTU Bil*3JWOJWJ1 PROE.tJJ l #

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J. R. Pearson '

Action Plan I,a.3 Issue coordinator The foregoing responses have been reviewed and are concurred in by the CPRT Senior Review Team.

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CERTIFICATE OF SERVICE I, Robert K. Gad III, one of the attorneys for the Applicants herein, hereby certify that on August 14, 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 I.a.3" 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.G. Nuclear Regulatory U.S. Nuclear Regulatory Commission Cammission 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 I

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l 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 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.

Citizens Clinic Director Office of the Executive Government Accountability Project Legal Director 1901 Que Street, N.W. U.S. Nuclear Regulatory Commission Washington, D.C. 20009 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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i Robert K. Ga pII

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