ML20214T186

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Answers to Board 14 Questions (Memo;Proposed Memo of 860414) Re Action Plan Results Rept V.A.* Submits Applicants Answers to Board 14 Questions Re Comanche Peak Response Team Results Rept,Per Action Plan V.A.Certificate of Svc Encl
ML20214T186
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 05/05/1987
From: Levin H, Sanan R
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
References
CON-#287-3687 OL, NUDOCS 8706100155
Download: ML20214T186 (29)


Text

{{#Wiki_filter:(.. (( Filed: May 5,.1987 '~ 4 5IS' '87 JU1 -8 P4 :07-0FUu. i, 00CEIin,, . n ph~ UNITED STATES OF, AMERICA W NC" 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 TO BOARD'S-14 QUESTIONS (Memo; Proposed Memo of April 14, 1986) Regarding Action Plan Results Report V.a 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 V.a; Inspection of Certain Types of Skewed Welds. 8706100155 B70505 PDR ADOCK 05000445 G PDR r )9 a

10. l u Opening Request: Produce. copies.of any CPRT-generated checklists that were used during the conduct of the action plan.

Response

The attached ERC procedure QI-006 was developed for reinspection of Type-2 skewed welds. 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

This action plan was prepared to respond to NRC/TRT's expressed concern after it investigated Brown & Root inspection procedures for welds in pipe supports designed to ASME Boiler & Pressure Vessel Code, Section III, Subsection NF, and concluded that no fillet weld inspection criteria existed for certain types of skewed welds,.specifically those designated as Type-2. The TRT reviewedcweld inspection procedures and weld. data cards, and visually inspected several Type-2 skewed welds in randomly sampled NF supports where pipe stanchions were used. Although the small sample of )

welds' inspected by the TRT were acceptable, due to deficiencies in inspection records and the apparent lack of' inspection criteria, the TRT was not certain g whether other Type-2 skewed welds were inspected properly. Prior to implementing a sampling program, a chronology identifying measulament techniques and documentation methods used for the inspection of Type-2 skewed welds was prepared. Inspection procedures QI-QAP-11.1-26, QI-QAP-11.1-28 and CP-QAP-12.1 were reviewed to determine if the method of inspection included for Type-2 skewed weld inspections was adequate to address the unique aspects of skewed. weld dimensional configurations. The reviews indicated a need to assess the documentation methods and to verify on a random sampling basis that Type-2 skewed welds meet the design requirements. QA/QC documentation of the original inspections for a sample of 60 Brown & Root supports was reviewed to determine which procedures were used to inspect Type-2 skewed welds, and if there were relationships which correlated with undersized welds observed in the reinspections performed under this action plan. All.. J

l the supports in the sample have inspection records corresponding to procedures QI-QAP-11.1-28 or CP-QAP-12.1. A review of the relationship between the undersize welds found in the reinspections and the Brown & Root inspectors who performed the original inspections indicated no correlation. The problems were not considered to be extensive in view of the following: 1. Although objective evidence that the welds were measured using proper' techniques is not available, the results of the action plan support the conclusion that the' proper techniques were probably used. 2. Analysis results in a 95% confidence estimate that the number of supports exceeding the ASME allowable stress limits is one or less, and 3. A revision of procedure QI-QAP-11.1-28 to include acceptance criteria and measurement techniques for the inspection of Type-2 skewed welds has been made and should preclude future occurrence of this problem. -4_ J

Question: ~ 2 '. Provide.any procedures or other internal documents that are necessary to understand how the checklists.should be-interpreted or' applied.

Response

ERC procedure QI-006 (attached) delineates the technique and methods used in.the reinspection of Type-2 welds. Question: 3. Explain any deviation of checklists from the-inspection report documents initially used in inspecting the same. attributes.

Response

The original inspections could have been performed using either of tw'o techniques-scribe line or profile. The scribe line technique could not be used for reinspection because the supports had been painted and the original scribe lines were no longer. visible.. The profile technique for the reinspection was sthe same as that used in the original inspection of the skewed weld attributes. 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. 9

Response

The acceptance criteria used for weld size were as specified in ASME Section III, Subsection ND-4427(W82), to which the applicant is now committed. 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

This question is not applicable, by reason of the answer to #4 above. Question: 6. Set forth any changes in checklists while they were in use, including the dates of the changes.

Response

No changes were made to the reinspection technique during the course of the activity; however a change in the selection of the sample to be reinspected was instituted in July 1985 to exclude vendor welds, because the main focus of the investigation was to review Brown & Root's inspections. J

_-= 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

Because reinspection of the Type-2 skewed weld was performed by Level II inspectors, no special training other than a classroom discussion of procedure QI-006 was-deemed necessary. The reinspections consisted of measuring the two legs of the skewed fillet welds at various points along the periphery of the weld. By pressing a contour gage against the weld to obtain an as-built profile, and transferring this profile to a worksheet, tangential lines were then drawn and the size of the legs were measured. This reinspection was performed by third party inspectors, who were both knowledgeable and experienced and did not require any further training in this type of inspection. Question: 8. Provide any information in Applicants' possession concerning the accuracy of use of the checklists (or the inter-observer reliability in using the 3 I, e j

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

Since no unique measurement technique was developed or used, no-attempt was made nor considered necessary to statistically establish the accuracy of the reinspection procedure or its use. There were no time periods in which the procedure was followed by other than qualified Third Party Inspectors. 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.

Response

No audit specific to training or use of the reinspection procedure was 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 employee, supervisor or consultant) in writing or in a meeting in which at least one supervisory or >

4 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 modifications were 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?

Response

Reinspections, reviews and analysis performed as a part of ISAP V.a implementation did not present any unexpected difficulties. Question: 12. Explain any ambiguities or open items left in the Results Report.

Response

As a part of the revision of the project procedure QI-QAP-11.1-28, an error in the application of the scribe line technique was identified and corrected by the Project. This error involved the omission of a factor that is necessary to _g. l .J

i' mathematically correct the measured leg size of a skewed weld. This error did not affect the reinspection performed under this action plan, because the. scribe ~line technique was not used for the reinspection of these welds and as such did not affect the conclusion drawn. Project has initiated a corrective action for this error by generating a TDDR #PS-86-1973. 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

There were no conflicts of interest. 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

The Issue Coordinator, and others who aided in the preparation and approval of the Results Report, J

e have reviewed and checked the report for clarity and believe that there are no ambiguities. Respectfully submitted, .wo Y k. R. K. Sanan Action P an V.a Iseue coordinator f- -,- / Ntpr E d K. Levi % ~ CPRT Civil Structural Review Team Leader The foregeing responees have been reviewed and are concurred in by the CFRT Senior Review Team. I !.. T., r :. _ : :, 3 E, 0 2 +.

t EVALUATION RESEARCH CORPORATION COMANCHE PEAK RESPONSE TEAM PROJECT PROCEDURE FOR SPECIFIC ACTION PLAN VII,c FORINFORMATION ONLY CHANGE NOTICE: 001 PROCEDURE NO: QI-006 REVISION NO: 2 EFFECTIVE DATE: 08/06/86 REINSPECTION OF TYPE 2 SKEWED WELDS Prepared by: Date: 9 86 'U '/ Approved by: oas er k. m e:/ /N Issue Coordinator // 7Y!7d Approved by: Date: On-Site QA Reptesentative / O 6!8k Approved by: 4 Date: QA/QCReviewTeamLeadeg // J

= Change Notice 001 01-006 ~ Rev. 2 Page 1 of-1 i 1. Change Attachment 6.5, #2 and #53 to read: 2. ~CC-1-202-001-S53A 53. CT-1-033-414-C92A 3 l I l L J

Pego 1 of 3 EVALUATION RESEARCH CORPORATION COMANCHE PEAK RESPONSE TEAM PROJECT PROCEDURE FOR SPECIFIC ACTION PLAN VII.c PROCEDURE NO: QI-006 REVISION NO: 2 EFFECTIVE DATE: 09/28/85 FORINFORMATION ONLY REINSPECTION OF TYPE 2 SKEWED WELDS l Prepared by: [!h 9 $"!8f / Date: /// Q ~ / Approved by: [ d5 6(6D Y-fg-73' 2 e: lasuie Coord p tor h. Date: 9.I 2* W Approved by: On-Site QA Representative .Y, 7, 87 Approved by: Date: QA,p. 1.. T._ <...r

QI-006 Rsv. 2 1.0 PURPOSE 1.1 This instruction delineates the inspection criteria to be used ~ for the reinspection of random samples of type 2 skewed welds on class 1, 2, and 3 component supports. Note: Type 2 skewed welds are defined as welds between two members with curved ' surfaces or curved cross sections, such as a pipe stanchion (a section of pipe used as a structural member) welded to another pipe stanchion or a curved pipe pad. 2.0 APPLICABILITY 2.1 This instruction is effective for reinspection and recording of data for class 1, 2, and 3 component supports with type 2 skewed welds in units 1 and 2.

3.0 REFERENCES

3.1 TRT Action Item V.a 4.0 GENERAL. 4.1 Responsibilities 4.1.1.The Project Mechanical Engineer is responsible for the identification of specific support welds requiring reinspection. The specific supports with skewed welds to be reinspected are identified on attachment 6.5. 4.1.2 Evaluation Research Corporation (ERC) is responsible for the implementation of this instruction. ERC l personnel shall perform the reinspections in accordance with this Quality Instruction and shall be trained and demonstrate proficiency to this instruction. All training shall be documented per ERC Procedure CQAP-1.2 (Personnel Indoctrination and Training) and meet the education and experience requirements of ANSI N45.2.6-78 for Level II inspectors. 5.0 INSTRUCTION 5.1 Component support velds at skewed joints shall be reinspected to the criteria provided on the applicable component support, i drawing. Only those welds noted by the project mechanical engineer on the support drawing need to be reinspected. 5.2 Stanchion to pipe pad / saddle veld size shall be determined as detailed in attachment 6.1 and/or 6.2 as applicable. 1 2 ( )

QI-006 Rsv. 2 5.0 INSTRUCTION (Cont'd) 5.3 Stanchion to stanchion welds in which the members are perpendicular shall be inspected in accordance with attachments 6.1 and/or 6.2 as applicable. 5.4 Tube steel to pipe or pipe pad / saddle shall be inspected in accordance with attachment 6.3. 5.5 Inspection of stanchion to stanchion welds in which the members are attached at a skewed angle will be inspected in accordance with specific instructions provided in the inspection package provided by project mechanical engineering. 5.6 Documenting reinspection results. 5.6.1 The component support skewed weld data sheet (attachment 6.4) and the skewed weld worksheet shall be used to document reinspection results. The completed reports will become part of the inspection package and then transmitted to the project mechanical engineer for review and evaluation. 6.0 ATTACHMENTS 6.1 Inspection of Skewed Welds with Scribe Marks 6.2 Inspection of Skewed Welds with Contour Gauge - 6. 3 Inspection of Skewed Welds on Tube Steel Stanchions 6.4 Component Support Skewed Weld Data Sheet 6.5 Specific Supports to be Inspected 6.6 Support Drawing 6.7 Pipe Sizes and Wall Thickness 6.8 Skewed Weld Worksheet 3 J n

I ..1 % b ----> ud-- QI-006 Rev. 2 m-0 Page 1 of 1 1 1. When scribe mark is visible measurement of A A skewed weld is as shown. i f Y To measure this we'ld leg size use normal weld 6 gauges. y 3" {c { Find scribe mark "A", 3 inches from intersection of parts at fitup attachment. Measure "B" dimension and subtract %M$ "B" from "A" to get "C" gl _ 8' (leg size). r, NOTE: Use attachment 6.7 for actual outside diameter of pipe and stanchion. NOTE: For both attachments 6.1 and 6.2... Where D2 2 Then measure or take datum points around the El I 3 full circumference of weld. Where D2 2 Then measure or take datum points as shown. D1 3 %a = = i &%q y Due to engineering evaluation of weld strength, only the weld between points A-B cad C-D need to be measured when D2 ratio is greater than 2/3. A 8 Points A, B, C and D will be located by taking 1/3 D1 from centerline. y D Me %D, D I SEC.T. A-a a

~ Attach cnt 6.2 1' QI-006 Rev. 2 .Page 1 of 2 The following steps shall be followed to verify stanchion weld sizes where scribe layout marks have not been established at the time of weld joint fitup. 1. Starting at a 90' location, mark off pipe as shown in Figure 1, at:approximately 2" on center. for stanchion larger than 8" in diameter, mark off 3" on center. Number marks clockwise on the pipe and worksheet and show the orientation of weld on the worksheet. (i.e., elevation view looking west a mark should be placed at any point where the weld is visually smaller than the rest of the weld and measured, j . NOTE 1: Where the hanger design / configuration makes it i impossible to take measurements at the planned datum points, the inspector shall take measurements as near as possible to the planned points and record the locations on the skewed weld work sheet. NOTE-2: If 100% of the weld (s) on a support to be inspected is not accessible because of interferences, but at least 50% of l the weld is accessible, the inspector shall.take measurements i.. starting at the first accessible datum points and note the inaccessible areas on the skewed weld worksheet. If more than 50% of the welding is inaccessible, the hanger package shall i be noted and returned to the Project Mechanical Engineer for selection of an alternate package, j 2.- Press the contour gage against the weld at the points marked 1 above. Place the contour gage as perpendicular to the face of the weld as possible. 3. Prepara a worksheet per Fig. I and 2. The hanger number must be on the worksheet. Assign a number to each weld on the i hanger drawings to be inspected and on the worksheet. (NOTE: L Initial and date assigned numbers as shown on Attachment 6.6), i 4. Transfer the weld configuration to the worksheet by outlining i the contour gauge and number each transfer with the corresponding number given in step 1 and 3. 5. Use a straight edge and establish tangent lines as shown in l Fig. 2 steps 2 and 3. .J

Attcchsant 6.2 QI-006 Rev. 2 Page 2 of 2 ~ Figures 1 and 2 I / NOTE: Heasure size of fillet at 8 2 90* with standard fillet veld gauges. 90* p g Datum point need only to be located at one 90*.' + r 5 Figure 1 1. Transfer outline of contour gauge. 2. Draw two tangent lines corresponding to slope of outline as shown. Measure angle of the tangent lines and enter on worksheet, i led Pts, 3. Draw two more tangent lines parallel to first two lines at intersection of y contour profile and first two tangent l lines. Take a measure between the two N p tangent lines to get size of weld. 3 5 Figure 2

Attechmnt 6.3 QI-006 Rev. 2 Page 1 of 1 1. For tube steel to pipe or pipe pad / saddle use criteria in.2. for measurement of skewed welds. 2. Take measurements at datum points A, B, C, D (center of curved corners on tube steel), y p also take measurements at 2" / or 3" increments according to size of tube steel per I- '.2. NOTE: Measurements need only to be taken between points A-B and C-D. u 3. If ratio D2 2, no c/ \\ B H>3 measurements need to be taken.

  • b Note this is on hanger package 2

and return to Project Mechanical Engineer. [ 4. Number datum points clockwise o and note orientation of sketch on worksheet. 0, t 1

,1 ~ > n 11 Attechnsnt 6.4 QI-006 Rev. 2 i Page 1 of 2 COMPONENT SUPPORT SKEWED ** ELD DATA SHEET SUPPORT # REV. A. Instructions Inspector shall assign numbers in numerical sequence to all skewed welds on the inspection copy of the construction drawing that are to be reinspected per engineering direction. (Note: Welds to be reinspected will be noted on drawing.) Previously assigned numbers remain the same. The weld numbers shall be encored on the ne t Support Skewed Weld Data Sheet (SWDS). The inspector shall initial and dat e SWDS a datum point inspected per weld. If more than o pectcr c ucts weld inspections on a support, the inspect 11 nitial and date only those welds actually inspecte Siz

1) = Stanchion Side Leg; Leg Size 2 (Leg 2) ide L B.

Weld Reinspection A WELD NO. DATUM PT3 INSP/DATE COMMENTS AN V c) W e__ a v s i G g 7-, r m -y. y- ,w- --.-,,p,-,. 7 ,y y,,,ni-,

Attachm2nt 6.4 QI-006 Rev. 2 Page 2 of 2 WELD NO. DATUM PT. SIZE INSP/DATE COMMENTS LEG 1 LEG 2 D. <s W \\M ^ v NO) A NS QNs~ h W <\\%h ~ _(e X)' x ' A_0 INSP. SIGN./DATE REMARKS 1- ~ ,ww-~ r -w,, -ee, m n-wa-m- -e-,m-ww-moawe- --w

Attcchment 6.5 QI-006 Rev. 2 Page 1 of 2 HANGER NUMBER HANGER NUMBER 1. SI-2-071-405-S32K 27. SI-2-038-409-S22A 2. CC-1-202-001-S35A 28. RH-2-016-401-S22K 3. CT-2-005-403-S22K 29. AF-1-002-033-Y33K 4. CC-X-022-001-F43A 30. SW-2-035-703-J03R 5. AF-2-101-431-S33A 31. CC-X-079-006-A43A 6. CC-2-158-408-A43K

32. MS-1-002-008-C72K 7.

CC-1-009-016-A43A 33. CT-1-053-404-C62A 8. RH-1-001-010-C41K 34. S1-1-037-005-S32A 9. RC-1-146-003-C81K

35. DD-1-012-033-Y33A 10.

CC-2-028-411-S33K

36. CS-1-597-006-C42A 11.

CT-1-049-415-C92A

37. VA-X-05-716-A73K
12. CC-2-116-006-F43A
38. AF-2-084-401-S33A
13. AF-2-006-412-S33A 39.

BRX-001-720-A53A 14. RH-2-064-406-S22R 40. CC-1-087-004-A33A

15. RC-1-135-004-C51K 41.

RC-1-135-008-C41K

16. CS-2-597-403-C42A 42.

CC-1-235-006-C53R

17. CT-1-013-421-C82R
43. AF-2-009-413-S33A l

l

18. MS-1-004-009-C62K 44.

CT-1-039-423-C42A i 19. BR-X-106-059-S43A 45. CT-1-054-431-C42A

20. AF-2-004-405-S33A 46.

CT-1-042-401-C82A

21. CT-2-039-404-C42A 47.

CT-2-127-403-C72A l

22. CC-1-035-018-A33A
48. CT-1-127-403-C72A
23. DO-1-038-003-S63K
49. MS-1-002-012-C72S
24. CT-2-038-404-CS2A
50. CC-1-065-003'-S33R
25. MS-1-003-005-C72K
51. DD-1-012-724-A33A
26. AF-1-006-013-S33A
52. MS-1-003-009-C72K l

l L _]

4.5 01-006 Rev. 2 Page 2 of 2 HANGER NUMBER I

53. CT-1-033-414-C92K 54.

CC-1-019-003-A33R

55. CC-2-028-414-S33R.
56. CC-1-109-005-A43A
57. CC-1-173-012-S53A
58. CC-2-068-405-S33R
59. MS-2-416-405-S43R -

60. CC-1-065-002-S33R O t I { l E ]

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Attachmant 6.8 QI-006 Rev. 2 Page 1 og g SKEWED WEZD WORKSHEET SUPPORT NO. Rev. \\ @b m i e ,y, -._..wy,-,_ ..__,._..-,,-,...,,,,,,,,,_,,,,,..,_.-m.,m,_ m._,,,, _. _ _.,,.,, -, _, _ -_, _.,,,,.,

DcFUE uwc '87 JLN -8 P4 :07 CERTIFICATE OF SERVICE I, Robert K. Gad III, herebycertifyth[khngJu'ne;5)fl987, I 6F a k. i made service of " Answers to Board's 14 Questions (Memo; Proposed Memo of April 14, 1986) Regarding Action Plan Results Report V.a" by mailing copies thereof, postage prepaid, to: Peter B. Bloch, Esquire Mr. James E. Cummins Chairman Retident 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 GAP-Midwest Office 881 W. Outer Drive 104 E. Wisconsin Ave. -B Oak Ridge, Tennessee 37830 Appleton, WI 54911-4897 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 J

-o 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 Suite 600 Christic Institute 1401 New York Avenue, N.W. 1324 North Capitol Street Washington, D.C. 20005 Washington, D.C. 20002 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 N .s s 's- ) AL Robert K. Gad III i - -. -}}