ML20212K543
| ML20212K543 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/21/1987 |
| From: | Hansel J, Ross G TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| References | |
| CON-#187-2308 OL, NUDOCS 8701290105 | |
| Download: ML20212K543 (12) | |
Text
13 3'6b Filads.
January 21, 1987 DCCHETED "mRC
'87 JAN 27 P1 :33 co.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the I
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 VII.a.7 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.7, Housekeeping and System Cleanliness.
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Opening Request:
Produce copies of any CPRT-generated checklists that were used during the conduct of the action plan.
Response
A Storage Surveillance Checklist was generated for use in observing the TUGCO performance of surveillances.
A copy of a typical filled-out list 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
The NRC Technical Review Team (TRT) identified two issues relating to housekeeping and system j
cleanliness.
The first pertains to the number of swipe tests required by a TUGCO flush plan to verify that the 1
l reactor vessel had been adequately cleaned.
The TRT l
concluded that the limited number of swipe tests l
specified (two) may not provide adequate assurance that i
the vessel had been properly cleaned.
The second pertained to an observation that not all pipe support -
A snubbers were protected from ongoing construction activity.-
This condition was immediately corrected when reported by the TRT.
A further TRT assessment of housekeeping and. equipment protection, as reported in i
SSER 11, found that the overall program for detection and correction of housekeeping deficiencies appeared to be satisfactory.
The NRC identified action to be taken by TUEC which consisted of evaluating the TRT findings, addressing the root cause and generic' implications of each finding, addressing the collective significance of the findings, and proposing an action plan which would ensure that such problems vould not occur in the future.
This Action Plan assessed the adequacy of the housekeeping and system cleanliness program through an evaluation of current housekeeping and surveillance procedures and their implementation; and through an evaluation of the adequacy of swipe testing of the reactor vessel and reactor coolant system.
The QA/QC documentation (Site Surveillance Reports, surveillance inspection reports and Surveillance Deficiency Reports) of current housekeeping / surveillance activi".les, i
)
reviewed during implementation of this Action Plan, was found to appropriately document the activity; no
-problems or concerns were noted.
The review of swipe testing documentation identified some inconsistencies.
These inconsistencies and the results of the overall assessment are presented in sections 5 and 6 of the Results Report.
Question:
2.
Provide any procedures or other. internal documents that are necessary to understand how the checklists should be interpreted or applied.
Response
The checklist generated for use in observing the TUGCO performance of surveillance activities is self-explanatory and was prepared by the individual who used it.
No procedure or instruction is necessary to understand its use.
Question:
3.
Explain any deviation of checklists from the inspection report documents initially used in inspecting the same attributes.
Response
Not applicable.
The checklist generated is for observation of TUGCO surveillance activities and
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contains equivalent or greater detail than the B&R and TUGCO checklists.
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
Not applicable.
The checklist contains attributes consistent with 10 CFR 50, Appendix B, ANSI N45.2.2 and ANSI N45.2.3.
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.
Response
Not applicable by reason of the answer to question four.
Question:
6.
Set forth any changes in checklists while they were in use, including the dates of the changes.
Response
Not applicable, since no change to the checklist was made.
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 ditration or content.
Response
The checklist generated for use in observing TUGCO surveillance activities is self-explanatory.
Therefore, no training in its use 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 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
The checklist used is self-explanatory; no training was required and no problems with its use were noted.
Interobserver reliability was not a concern and 1 I
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was not addressed.
Question:
9.
) Summarize all audits or supervisory reviews (including reviews by employees or consultants) l' 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.
Response
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- The checkl'ist used is self-explanatory.
No 1
audits or supervisory revievis of training or its use were performed.
Question:
10.'
Report any instances in which draft reports were I
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.
Response
No cubstantive changes have been made as a result of management action.
Question.
l 11.
Set forth any unexpected difficulties that were encountered in completing the work of each task l_
force and that would be. helpful to 'he Board in l
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understanding the process by which conclusions were reached.
How were each of these unexpected difficulties resolved?
Response
No unexpected difficulties were encountered which affected the process by which the conclusions were reached.
Question:
12.
Explain any ambiguities or open items left in the results report.
Response
The Results Report contains no known open items or ambiguities.
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 cwn 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 -
JAN 2187 15:54 ~ 'CPRT-GLEM'RO
~P A GE.' 0 2 JAN 21 '87 9:13 ROPES GR/617-350-5091 PAGE.10
Response
The Results Report clearly discloses the logic and analysis used without ambiguity.
Respectfully submitted, A.
K W. Ross Action Plan VII.a.8 Issue Coordinator C
/Jinhn L. Hansel GPRTQA/QCReviewTeamLeader The foregoing responses have been reviewed and are concurred in by the CPRT Senior Review Team.
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'87 JAN 27 P1 :33 CERTIFICATE OF SERVICE 6Ff: -
d *Vif a : Ar DOChUiTi l EEANOf I,
Robert K. Gad III, one of the attorneys for the Applicants herein, hereby certify that on January 21, 1987, I made service of the within Answers to Board's 14 Questions (Memo; Proposed Memo of April 14, 1986) Regarding Action Plan Results Report VII.a.7, 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 Nancy Williams Administrative Judge Cygna Energy Services, Inc.
c/o Carib Terrace 101 California Street, Suite 1000 552 North Ocean Blvd.
San Francisco, California 94111 Pompano Beach, Florida 33062 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 i
Legal Director 1426 S.
Polk Street U.S. Nuclear Regulatory Dallas, Texas 75224 Commission Washington, D.C.
20555
b 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 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 Maryland National Bank Bldg.
Room 10105 7735 Old Georgetown Road Bethesda, Maryland 20814 Ms. Billie P. Garde Midwest Office 3424 N. Marcos Lane Appleton, Wisconsin 54911 e
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