ML20212K570
| ML20212K570 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/21/1987 |
| From: | Hansel J, Ross G TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| References | |
| CON-#187-2307 OL, NUDOCS 8701290114 | |
| Download: ML20212K570 (11) | |
Text
Filcd:
January 21, 1987
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'87 JM 27 P1 :32 UNITED STATES OF AMERICA CFf:;
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t NUCLEAR REGULATORY COMMISSION
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before the ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of
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Docket Nos. 50-445-OL TEXAS UTILITIES ELECTRIC
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50-446-OL COMPANY et al.
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(Application for an (Comanche Peak Steam Electric
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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 VII.a.8 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.8, Fuel Pool Liner documentation.
8701290114 B70121
{DR ADOCK 05000445 PDR 3
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.o Opening Request:
Produce copies of any CPRT-generated checklists that were used during the conduct of the action plan.
Response
No checklists were generated for this ISAP.
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's Technical Review Team (TRT) identified an issue consisting of irregularities in the quality records for the fuel pool liner fabrication, installation, and inspection.
In a letter dated January 8, 1985 they said:
" Based on the TRT review of about 200 fuel pool travelers, TUEC was unable to maintain an effective and controlled QC program for fuel pool liner fabrication, installation, and inspection."
There followed eleven examples of documentation irregularities found in the TRT inspection. l
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 would not occur in the future.
The liner systems were site-fabricated and erected by Brown & Root.
Gibbs & Hill specification 2323-SS-18, Revision 4, April 5, 1985 identifies the stainless steel liner systems as Nuclear Safety-related, with the exception of the Unit 1 and 2 Reactor Building Refueling Cavities.
This specification also imposes 10CFR50 Appendix B QA Program requirements.
The CPRT determined that the problem area was confined to the fuel pool liner documentation since the fabrication, erection and inspection of this liner system was accomplished under a unique QC program with unique documentation.
Stated simplistically, the TRT concluded that the QA/QC aspects of fuel pool liner erection and fabrication were not properly documented, that.
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.o procedures had been violated, and that inadequate procedures-existed.
This Action Plan addressed fuel pool liner documentation problems.
The physi. cal reinspection of fuel pool liner welds was performed under ISAP VIII.c, " Construction Reinspection / Documentation Review Plan,"
population FPLR (Fuel Pool Liner).
The QA/QC documentation was the subject of this ISAP, and was extensively reviewed.
We have concluded that a substantial number of documentation problems exist in the fuel pool liner documentation packages, some of which raise concerns about the adequacy of the liner hardware.
This is covered in more detail 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
Not applicable.
No checklists were generated.
_4_
J Question:
3.
Explain any deviation of checklists from the inspection report documents initially used in inspecting-the same attributes.
Response
Not applicable.
No checklists were generated.
. 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.
Response
Not applicable.
No checklists were generated.
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.
No checklists were generated.
Question:
6.
Set forth any changes in checklists while they were in use, including the dates of the changes... -
Response
Not applicable.
No checklists were 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.
Response
Not applicable.
No checklists were generated; therefore 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 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
Not applicable.
No checklists were generated.
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 as -
ambiguities and anticipate and resolve the questions.
RGSP9A5ei The Results Report clearly discloses the logic and analysis used without ambiguity.
Respectfully submitted, e
C. W. Ross
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Action Plan VII.a.7 Issue Coordinator WM
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phn L. Hansel RT QA/QC Review Team Leader The foregoing responses have been reviewed and are concurred in by the CPRT Senior Review Team.
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validity of conclusions.
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Response
Checklists were not generated for this Action Plan; therefore, no audits or supervisory reviews of training or use of checklists were performed.
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 i
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 substantive changes have been made as a 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?
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Response
No unexpected difficulties were encountered which affected the process by which the conclusions were
. reached.
Question:
12.
Explain any ambiguitics or open items left in the Results Report.
Response
The Results Repcrt contains no known open items or ambiguities.
Question:
13.
Explain the extant to which there are actual or apparent conflii:ts 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 *:hinking 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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. :E CERTIFICATE OF SERVICE
'87 JAN 27 P1 :32 I, Robert K. Gad III, oneoftheattorneysforggg,e,ppp,lic,,angs BRAND 1 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.8, 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 Legal Director 1426 S.
Polk Street U.S. Nuclear Regulatory Dallas, Texas 75224 Commission Washington, D.C.
20555
__ _ _ _ _. =,,.
- 9 r
s 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
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.s Robert K.
Gad III y
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