ML20210S408

Answers to Board Questions Re Comanche Peak Response Team Action Plan Results Rept I.b.3,per ASLB 860414 Proposed Memorandum & Order

ML20210S408
Person / Time
Site:	Comanche Peak
Issue date:	09/30/1986
From:	Bizark R, Mallanda J TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
References
CON-#486-0994, CON-#486-994 OL, NUDOCS 8610080122
Download: ML20210S408 (8)

Text

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Filed: Saptsmber 30, 1986  ;

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UNITED STATES OF AMERICA 0FFigg,g;c.H 00 Lu 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

! COMPMOI et al. )

) (Application for an (Comanche Peak Steam Electric ) Operating License)

Station, Units 1 and 2) )

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ANSWERS TO BOARD'S 14 QUESTIONS (Memo; Proposed Memo of April 14, 1986)

{ Regarding Action Plan Results Report I.b.3 j

I 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.b.3.

8610080122 860930 PDR ADOCK 05000445 G PDR BJW

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First Request:

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

Response

An engineering review of an analysis was

. performed which did not lend itself to the use of checklists. Therefore no checklists were employed in this action plan.

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 Action Plan was prepared and published to respond to a specific technical concern raised by TRT as a result of a site visit / audit; the TRT noted that it could find no evidence that the NRC had reviewed an analysis justifying one inch separation criteria for conduit and cable tray. On page J-44 of NUREG 0797, Supplement No. 7, describing action required of TUGCO by.the NRC, the NRC expanded the request for the justification to include all separation between i

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T conduits and cable trays, which is the current focus of the results report.

As part of the CPRT activities, an independent review of the G&H analysis supporting the separation criteria was performed.

This issue did not specifically concern QA/QC, but instead focused on the thoroughness, accuracy, and judgment involved in the justification of the separation distance. Therefore, we did not review any QA/QC documentr. tion, i.e., design review / verification.

We believed the issue to be limited to cable tray-conduit separation, and it was perceived as a matter of course that the proper analysis would confirm or deny the separation criteria in a straightforward way.

Question:

2. Provide any procedures or other internal -

documents that are necessary to understand how the checklists should be interpreted or applied.

Answer:

No checklists were employed in this action plan.

Question:

3. [ Original acceptance checklists. See Transcript of the Pre-Hearing Conference of April 22, 1986,

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at 24,353-57.]

Answer:

No checklists were employed in this action plan.

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:

N/A because no checklists wer employed in 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 since the answer to question 4 is N/A.

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 employed in the execution of this ISAP, the answer to this question is N/A.

I 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:

Since there were no checklists, no training was necessary.

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:

As no checklists were used, this question is not applicable.

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.

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Answer:

As no checklists were used, this question is not applicable.

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 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:

After reviewing the drafts of the reports, neither Mr. Bizzak (the Issue Coordinator) nor Mr.

Mallanda (the Review Team Leader) could recall any substantive changes during the generation, review, and editing of the report resulting from management action.

Accordingly, 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?

'l Answer:

The Issue Coordinator judged the original Gibbs & Hill analysis to need more rigorous treatment in order to justify the criteria. Analyses were re-performed which, in the judgment of the IC and RTL, supports the separation criteria.

This activity required more time and effort than anticipated.

See section 5 of the Results Report for more details.

Question:

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

Answer:

To the best of our knowledge, none exist.

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:

To the best of our knowledge, no conflicts of I

interest exist.

l 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 l

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l SEP 26 '86 9:57 ROPES GR/617-350-5051 PAGE.02 ambiguities and anticipate and resolve the questions.

Answer:

This report is short and to the point. While the technical considerations used in the computer analysis are somewhat complicated, we think the logic of the report is not complex.

After consideration of the above, we do not believe any ambiguity or obvious questions exist with the Results Report as written.

Respoctfully submitted, fd1A0. Wh-d Robert K SizdSt i Action Plan I.b.3. Issue Coordinator l

l MJ.

John J.

WW allanda A .

CPRT E ctrical Review Team Leader The foregoing responses have been reviewed and are concurred in by the CPRT Senior Review Team.

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