ML20206P792
| ML20206P792 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/26/1986 |
| From: | Bloch P Atomic Safety and Licensing Board Panel |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#386-798 79-430-06-OL, 79-430-6-OL, OL, NUDOCS 8607020242 | |
| Download: ML20206P792 (6) | |
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3, UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before Administrative Judges:
0%EfED Peter B. Bloch, Chairman Dr. Kenneth A. McCollom
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In the Matter of
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Docket Nos. 50-443-0L TEXAS UTILITIES ELECTRIC COMPANY, et al.)
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ASLBP No. 79-430-06 OL (Comanche Peak Steam Electric Station,
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Units 1 and 2)
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June 26, 1986 MEMORANDUM (Board Concerns)
As the Board has deliberated about the first results reports, the Comanche Peak Response Team (CPRT) program plan, and the SSER No. 13, it has become increasingly apparent that the remedial program is a complex fabric that will not be completed until its makers weave the last section and remove it from the loom.
Concerns we now have could be resolved in the future, depending on how conscientiously later tasks are completed and how findings of later tasks reflect on the findings of earlier tasks. Nevertheless, aware as we are of the partial nature of our current knowledge, our studies leave us with continuing concerns that we have expressed earlier.1 We also 1
1 For example, we have expressed concerns that the level of assurance of safety not be permitted to degrade below what would have (Footnote Continued) t 8607020242 860626 PDR ADOCK 05000445 G
PDR 3soa
1 Board Concerns:
2 have developed some additional concerns that are somewhat related to the prior concerns and, to some extent, to each other.
We have decided to surface our concerns because of the enormous ongoing investment in the CPRT and the possibility that current knowl-edge of our concerns wou,1d permit Applicants to consider mid-course corrections.
As the views expressed by the Board are merely prelimi-nary, there is no need for a party to comment at this time.
Should comments be filed, we anticipate reading them but may not issue any further comments. Our failure to comment will not, as it has not in the past, indicate acceptance of the comments filed with us.
I.
Findings in One Area May Affect Study Design in Another Area There are clear guidelines in the CPRT plan about when it is appropriate to enlarge a sample when discrepancies are discovered within the sample. However, the plan is far less clear about how decisions will be made about expanding sample sizes in one area when partial or com-plete breakdowns of QA/QC are discovered elsewhere.
For example, there l
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(Footnote Continued) l occurred with full implementation of Appendix B for design and construction, with the proper interpretation of root cause, and with the appropriateness of samples in light of particular problems i
being addressed.
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Board Concerns:
3 appears to have been a breakdown of effective quality assurance with respect to the design of pipe supports.2 Obviously, such a breakdown requires a careful scrutiny of root cause.
Were the problems partially procedural?
Were they partly personnel selection?
Petsonnel training?
Supervision?
Management?
Then, once the root causes are determined, it is necessary to decide to what extent each of those causes may call into question other areas of design and design quality assurance.
Then, it will for the first time become feasible to examine the CPRT sampling methods that in many instances will already have been implemented and decide the extent to which they must be augmented in ordar to address properly issues arising from the root cause of the pipe support design breakdown. That is, in light of the perceived breakdown in quality assurance for design of pipe supports, it is not apparent that sampling of design in other parts of the plant according to the CPRT program's Appendix D is adequate.
In making this comment, we are aware that we are at this time not even certain that Applicants intend to make a thorough inquiry into the root cause of the pipe support design breakdown.3 Comments made to this 2
There appear to have been other breakdowns in design and construction quality assurance as well, but this particular example is the least controversial that we could pick.
It also is consistent with our prior decision, which continues to be the law of the case, concerning the inadequacy of quality assurance for the design of pipe supports.
3 See SSER No. 13 at Appendix C, p. 1.
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Board Concerns:
4 Board have suggested that some of the issues related to quality assur-ance for construction or design are consioered to be moot in light of the CPRT program. Applicants also have suggested at the same time that:
(1) they do not plan to inquire into whether there were errors made in filing before this Board, the technical materials that were part of Applicants first Plan, and (2) that they will respond to all external source issues, including the concerns of this Board.
So we are not at this time assured that Applicants will examine in the proper depth the design, design control and technical difficulties that have affected their plant and their conduct in these proceedings.4 We also are concerned about the potential importance of errors that Applicants have chosen not to trend. For example, their response to the Staff's findings that led to Results Report I.a.4 appears not to have dealt at all with the Staff's concern that QC inspectors may have improperly " bought off" construction that did not match design.
This oversight is difficult for us to understand or accept.
If there is a trend of improper QA/QC activity, it appears to us to be necessary to know the nature of that trend and ascertain and pursue the root cause of that trend until the plant is purged of the problem.
For example, the l
l six examples Staff found might relate to one inspector or one supervisor l
4 If quality assurance for design is not adequately addressed by the
- CPRT, then the Board's prior findings on this subject will stand as the law of this case and an inquiry may be made into the proper remedy for such a failure.
1 Board Concerns:
5 whose work may nnt be fully represented in the sample Applicants took.
Furthermore, that inspector may also have worked on other areas of QA/QC in addition to electrical construction and his suspect work may need to be redone.
We are generally concerned that root causes in one area may affect the appropriateness of the sampling utilized by the CPRT in another area.
II.
QA/QC For Design and Construction We are uncertain concerning how deeply Applicants will pursue the 5
question of breakdowns or failures with respect to QA/QC of Design and Construction.
The handling of Results Report I.a.4 was not reassuring to us because it seemed to treat a suspected QA/QC failure as of insuf-ficient importance to inquire further.
III.
Reliability of Observations When there are no data concerning the inter-observer reliability in making observations of quality items, there is a concern about whether observations are being classified with sufficient certainty to satisfy 5
There do not appear to be any DSAPs now planned for QA/QC for Design. This causes concern that some external source issues will not be covered by Results Reports.
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Board Concerns:
6 the assumptions for statistical snalysis.
It is possible that this uncertainty introduces additional variance that is not accounted for.
IV.
Staff Concerns We share many of the Staff concerns expressed in SSER No. 13, espe-cially the concern about there not being a loss of safety margin below what is required by codes and by Applicantr' commitments.
FOR THE ATOM SAFETY AND LICENSING BOARD
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Peter B. Bloch, Chairman ADMINISTRATIVE JUDGE Bethesda, Maryland i
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