ML20211A068
| ML20211A068 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/11/1987 |
| From: | Geizer J, Hansel J TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| References | |
| CON-#187-2515 OL, NUDOCS 8702190084 | |
| Download: ML20211A068 (13) | |
Text
1
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-Filed Fcbruery"11, 1987 2.5/5
-00CKETED.
US.NRC.
'87 FEB117 P5 :36 UNITED STATES OF AMERICA UFt :
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 1X) BOARD'S 14 QUESTIONS (Memo; Proposed Memo of April 14, 1986)
Regarding Action Plan Results Recort VII.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 VII.a.3, Document Control.
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Opening Request:
Produce copies of any CPRT-generated checklists that were used during the conduct of the action plan.
Response
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?
Response
TUGCO acknowledged that there were deficiencies in implementation of the drawing control program prior to mid-1984.
This ISAP was designed te provide assurance that the current plant hardware conforms to the design requirements, rather than to investigate specific drawing control program events which had previously occurred.
In addition, an assessment was made of the current drawing control program and its implementation.
Further discussion of the ISAP approach is contained in Section 4.0 of the VII.a.3 Results Report.,
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V Question:
2.
Provide any-procedures or.other internal documents that are necessary to understand how the checklists should be interpreted or applied.~
Response
The only checklist utilized was developed from the content of 10 CFR 50 Appendix B; 'the Standard-Review Plan, NUREG-0800; and_ ANSI N45.2-1971.
The L
checklist was prepared and implemented by the Issue Coordinator, therefore no additional documentation was required.
Question:
3.
Explain any deviation of checklists from the inspection report documents initially used in.
inspecting the same attributes.
Response
There were no TUGCO procedure checklists generated to perform the evaluation that_this ISAP performed.
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.
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Response
The checklist was derived-from a review of the aspects.of the ANSI Standards and 10 CFR 50 as they.
apply to the narrow focus of this Action Plan.
Therefore, we believe the checklist contains a sufficient number of attributes to ensure'conformance to the standards.
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.
Response
In light of the answer to Questien 4 above, this question is not applicable to this ISAP.
s Question:
6.
Set forth any changes in checklists while_they-were in use, including the dates of the changes.
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Response
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No change was made to the checklists 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 4_
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-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.
Resconse:
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 anyftime periods in which checklists were used with questionable training or QA/QC supervision?.Iffapplicable, are problems of inter-observer reliability addressed statistically?
Response
The checklist was used exclusively by the Issue Coordinator during the document review.
Consequently,
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inter-observer reliability is no an issue for this ISAP.
Question:
--.S.
Summarize all audits or supervisory reviews (including reviews by employees or consultants)
E of training or of use.of the checklists.
Provide e
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-q.'
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resolved in'a way that is consistent with'the
- validity of conclusions.
Response
.Two' audits of'the activities ofLthe Issue
- Coordinator were performed.during the implementation of the ISAP.
The first was-conducted prior to the
- development of the one checklist utilized for the ISAP, and therefore did not address the training'in, _or the use of, the checklist.
The-second audit, which included a review of-the checklist and data,.was conducted after implamentation of the ISAP was essentially complete.
There were no concerns identified during the audit that pertained.to this ISAP.
Question:
10.
Report any instances in which draft reports were modified in an importantfsubstantive way as the result of management action.
Be sure.tofexplain 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,
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Response
No substantive modification was made to Results Report drafts'as a result of management action.
Question.
11.
Set forth any unexpected difficulties thatLwere 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?'
Response
No unexpected difficulties were encountered in completing the wor.< for this report.
Question:
12.
Explain any ambiguities or open items left in the Results Report.
Response
While there are no open items, as such, identified in the ISAP VII.a.3 Results Report, the conclusions reached in the report are based, in part, on preliminary information from ISAP VII.c.
Although we believe it unlikely that the final data from ISAP VII.c will cause a change in the conclusions reached in VII.a.3, the potential does exist.
The final results of ISAP VII.c, as well as all other ISAPs, will be reviewed during the Collective Evaluations.
If the -
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,e-Collective Evaluation process determines that the conclusions reached in the ISAP VII.a.3 Results. Report are'no longer valid, a_ supplemental Results Report'will-be required.
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.
Response
To the best of our knowledge, no conflicts of~
interest exist.
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.
Response
Mr. J. Gelzer, the Issue Coordinator, has reexamined the Results Report and does not see any ambiguities or obvious questions.
We believe that the r
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extensive review process has eliminated any ambiguities.
Respectfully submitted, k
.1..e ion Plan VII.
3 Issue coordinator A.m,..a_
L. Hansel RT QA/9C Aeview Team Leader The foregoing responses have been reviewed and are sencurred in by the CPAT Senior Review Team.
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DOCUMENT CONTROL l
Program Checklist Review the apprWriate procedure to ascertain if the procedure provides the controls described in the numbered items below.
These items have been developed from 10CFR50, appendix B, Criterion VI; NUREG 0900, " Standard Review Plan," Section 17.13 and ANSI N45.2-1971, and pertain only to drawing and drawing change distribution and control and not all elements of the subject criteria.
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Concurrence !
t Procedure Reviewed:_________________________
1.
Does the procedure assure that documents are available at the location where the activity will be performed prior to commencing the work?
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2.
Does the procedure assure that obsolete or superceded documents are removed and replaced by applicable revisions in work areas in u timely manner?
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- 3. Does the document control of controlled documents?
system identify the current revisson
- 4. Have seasures been established and documented to control the issuance of drawings and changes thereto?
- 5. Does the procedure provide for the identification of individuals or organizatsons responsible for issuing drawings and revisions thereto?
- 6. Does the procedure provide for distribution li sts?
establishing current and updateo f
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CERTIFICATE OF SERVICE s
I, Robert K. Gad III, oneof'theattorneg[qqgppepggggicants herein, hereby: certify that on February 11,:1987, I made' service:of 0Fria..., c a, the within Answers to. Board's 14' Questions (NEEo#[hEkop55EbMemoof April 14,~1986) Regarding Action Plan Results Report VII'.a.3, 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 Rcse, Texas 76043 Washington D.C.
20555 Dr. Walter H. Jordan Nancy Williams Administrative Judge Cygna Energy Services, Inc.
881 W.
Outer Drive 101 CaliforniaLStreet, Suite 1000 Oak Ridge, Tennessee 37830 San Francisco, California 94111 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 7735 Old Georgetown Road Room 10117 Bethesda, Maryland 20314
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s Renea Hicks,' Esquire:
< Ellen GinskSerg,- Esquire'
~
' Assistant Attorney. General.
' Atomic Safety and Licensing-L Environmental-Protection Division
. Board Panel 1 l-
.P.O.. Box.12548, Capitol Station
.U.S. = Nuclear: Regulatory Commission,
)
D.C.
20555~
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-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. LannyEA. Sinkin Administrative Judge Christic Institute 1107 West Knapp 1 1324' North Capitol _ Street Stillwater, Oklahoma '74075
. Washington, D.C.
20002 Ms. Billie Pirner Garde Mr.. Robert D. Martin-Midwest Office Regional Administrator, 3424 N. Marcos Lane Region IV Appleton, WI 54911 U.S.
Nuclear Regulatory Commission.
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 Maryland National Bank Bldg.
Room 10105' 7735 Old Georgetown Road Bethesda,. Maryland 20814
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