ML20212K336
| ML20212K336 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/02/1987 |
| From: | Broad T, Rushwick J TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| References | |
| CON-#187-2704 OL, NUDOCS 8703090278 | |
| Download: ML20212K336 (11) | |
Text
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7-7djk Filed:
March 2, 1987 S9CKETED USNRC 51 MR -6 Ali:b3 CFFICE SF SECrii?Ff EOCKLTING 4 M " M I.
UNITED STATES OF AMERICA 8 RANM J
NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
)
)
Docket Nos. 50-445-OL HTEXAS 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 III.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 III.a.3; Technical Specification for Deferred Tests.
B703090278 B70302 PDR ADOCK 05000445 G
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g.e Opening Request:
Produce copies of any CPRT-generated checklists Ethat: were used during the conduct of the action plan.
Response
No checklists were generated.
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:
The NRC-TRT requested that TUGCO evaluate
+
Technical Specification requirements for plant conditions for the proposed deferred preoperational tests,'and obtain NRC approval where deviations were deemed necessary.
The NRC subsequently. modified their concern in CPSES Safety Evaluation Report, Supplement No.
7, to' state that the concern was no longer applicable, because TUGCO was now planning to conduct the tests prior to fuel load.
In order to ascertain whether TUGCO procedures require evaluation of Technical Specification,
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. requirements when, deferring.preoperational testing, the CPRT reviewed all appropriate station procedures.
The CPRT reviewed the actual documents used by
, station personnel, not.QA/QCEdocumentation.
Question:
2.
Provide any procedures or other internal.
. documents that are necessary to understand how the checklists should be interpreted or applied.
Response
.No checklists-were generated, therefore no procedures were generated.
Question:
3.
Explain any deviation of checklists from the inspection. report documents initially used in inspecting the same attributes.
Response
There were no checklists generated, so no
' comparison'can be made.
i 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
No checklists were generated for this ISAP.
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
The question is not applicable due to the answer to question 4.
Question:
6.
Set forth any changes in checklists while they were in use, including the dates of the changes.
Response
There were no checklists generated.
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..
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e.
Response
No checklists, and therefore no training, were generated for this ISAP.
Question:
8.
Provide any information in Applicants' possession concerning the accuracy of use of the checklists U
(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?
Response
No checkli'sts were generated for this ISAP.
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 validitp of conclusions.
Response
No checklists were generated for this ISAP.
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. _ ___
e-
' l r, Explain what the-earlier: drafts said and why they
'were modified.. Explain how dissenting: views were resolved.
' Response:
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No Results Reports were modified in an-important
- substantive way as the result of management action.
~ 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?
Response
There were.no difficulties encountered in performing the work.
Question:
4 12.
Explain any ambiguities or open items left in the Results Report.
- Response:
There are no open items, and the Review Team believes no ambiguities 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.
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-Response:
Mr. Rushwick has had a previous involvement with
'the TUGCO startup organization.
The involvement is discussed'in-the objectivity evaluation in the action-plan working-file and in the paragraph below.
Mr. Rushwick was-responsible for marketing startup program services to TUGCO in early 1975.
At that time, he was employed by EDS Nuclear Inc. in San Francisco.
From 1975 until 1978,-the nature of his
- involvement with the TUGCO startup group consisted of general contract administration, general employee related administration, and the assignment of personnel for the startup program.
Mr. Rushwick was responsible for R.
E. Camp's assignment as Lead Startup Engineer with TUGCO in 1975.
(Mr. Camp is currently under contract to TUGCO, but not in a startup capacity.)
At no time did Mr. Rushwick become involved in the startup program other than as stated above.
Mr. Rushwick is now self-employed and in no way obligated to the corporate entities involved prior to 1
1
'1978 in marketing the program to TUGCO.
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Mr. Broad has had a previous involvement with TUGCO.
This involvement is discussed in the action working file and in the paragraphs below.
As Division Manager for EDS Nuclear, Inc. in San Francisco from 1978 to 1980, Mr. Broad was responsible for general contract administration, general employee related administration, and assignment of personnel to the CPSES Operating Staff.
These personnel were involved in the preparation of program and procedures in the area of Maintenance, Engineering, Operation, Chemistry and Health Physics.
Mr. Broad is now employed by Management Analysis Company and in no way obligated to the corporate entities involved prior to 1980.
His knowledge is very useful as a third-party reviewer.
Accordingly, no conflict exists for either individual.
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.,,
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"'FEI i9 *if~14: 59 908E3 39 617-350-9CSA
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We have examined the report and believe there are i
no ambiguities or obvious questions.
Respectfully submitted,
[
Thomas Broad Action Plan III.a.3 Issue Coordinator
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,n J)mes E. Rushwick CPRT Testing Review Team Leader The foregoing res a have been reviewed and are concurred in by the CPRT Senior Review Team.
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4 DGLMETED USNRC
-CERTIFICATE OF SERVICE
'87 MAR -6 41 :03 I,
Kathryn A.
Selleck, one of the attorneys for the Applicants herein, hereby certify that on March 2, 1987, I hE h((kfthe MANCH within document 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 Rose, Texas 76043 Washington, D.C.
20555 Dr. Walter H. Jordan Ms. Billie Pirner Garde
_ Administrative Judge Midwest Office 881 W.
Outer Drive 3424 N. Marcos Lane Oak Ridge, Tennessee 37830 Appleton, WI 54911 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 Lawrence J. Chandler, 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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Renea Hicks, Esqu' ire 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 Elizabeth B.
Johnson Geary S. Mizuno, Esq.
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 Washington, D.C.
20555 Nancy Williams Cygna Energy Services, Inc.
101 California Street Suite 1000 San Francisco, California 94111 Kpthryn A.
Selleck
.