ML20236H349
| ML20236H349 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/29/1987 |
| From: | Rushwick J TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| References | |
| CON-#487-4742 OL, NUDOCS 8711040083 | |
| Download: ML20236H349 (15) | |
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Filed:
October 29, lEhCEO UNITED STATES OF AMERICA 17 NW ~2 P2 :51 NUCLEAR REGULATORY COMMISS.ON before the OfflCE OF SidOA6Y 00CKEllNG A SERVICf.
BRANCH ATOMIC SAFETY 'ND LICENSING BOARD
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In the Matter of
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Docket Nos. 50-445-OL
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50-Il6-OL TEXAS UTILITIES GENERATING
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COMPANY et al.
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(Application for an j
(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 III.c In accordance with the Board's Memoran.um Proposed Memo-randum 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.c,
" Prerequisite Testing."
Opening Request:
Produce copies of any CPRT-generated checklists that were used during the conduct of the action plan.
Response
Attached is a copy of a memorandum from the norking file with the two checklists used by the Startup organization during their review of prerequisite test instruction data sheets to 8711040083 871029 PDR ADOCK 05000445 5 6'D' Q
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determine (1) the extent of the administrative infraction and (2) their evaluation of subsequent impacts-on testing, question No. 1:
1.
Describe the problem areas addressed in the report.
Prior to undertaking to address those areas through sampling, 3
what did Applicants do to define the problem areas further?
liow did it believe the problems arose?
What did it dis-cover about the QA/QC documentation for those areas?
How i
extensive did it believe the problems were?
Response
The report addressed the impact on iaquired testing of an administrative infraction committed by the Startup organization.
(No licensing commitments were violated, nor were NRC regula-tions involved with this administrative infraction because it I
was self-imposed.)
In its Startup Administrative Procedures, the Startup organization established an administrative requirement, q
which it subsequently violated, that verification of initial conditions during prerequisite testing be conducted by the System Test Engineer.
The S+.artup organization performed no sampling during its review of all prerequisite test data sheets requiring documented verification of the initial conditions to determine the extent of the violation.
The Review Team Leader believed the problem arose because a Startup Interoffice Memorandum was issued with instructions that conflicted
.th the administrative procedures but also presented i
a good ides, and the Startup organization failed to note the co r 71. i c t until the NRC-TRT identified it.
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The RTL reviewed actual Startup test records rather than QA f
documentation and concluded that the infraction of administra-I tive procedures was an isolated case, because no other instances
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Question No. 2:
2.
Provide any procedures or other internal documents that are necessary to understand how the checklists should be inter-preted or applied.
Response
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Other than the attached working file memorandum, no inter-j i
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nal documents were generated that explained the checklist.
Question No. 3:
3.
Explain any deviation of checklists from the inspection report documents initially used in inspecting the same attributes.
Response.
prior to the review, no checklists of this type were used 1
by the Startup organization.
l Question No. 4:
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
No codes or standards are applicable to this sub, ject.
Question No. 5:
5.
(Answer Question 5 only if the answer to P.uestion 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.
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Re s po n 2. a :
This question is not applicable by reason of the response to question 4.
Question No. 6:
6.
Set forth any changes in checklists while they were in use, including the dates of the changes.
Response
No changes to the checklist were made, question No. 7:
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 train-ing 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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1 Response; y
The checklist was self-explanatory, so no training was
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required.
1 Question No. 8:
8.
Provide any information in Applicants' possession cancern-ing the accuracy of use of the checklists (or the inter-observer reliability in using the checklists).
Were there 4
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 prerequisite test instruction data sheet review check-list was used only under the direction of the Startup Quality Assurance Specialist; therefore, inter-observer reliability was not a concern.
The checklist used to evaluate impact on subse-quent testing was used by the former Startup Manager only and. - _ - - _ _ _ _ - _ _ - - _.. _ _ - _ - - _ _ _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ - _ _ _ _ _
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was subsequently reviewed by the Startup Special Pro.j e c t s Super-visor and the RTL; therefore, inter-observer reliability was not a concern.
Quest. ion No. 9:
9.
Summarize all audits or supervisory reviews (including reviews by employees or consultants) of training or of use j
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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No attdits were performed other than the Review Team Leader's review.
Question No. 10:
10.
Report any instances in which draft reports were modi: ad i
in an important substantive way as the result of management I
action.
Be sure to explain any change that was objected to l
(including by an employee, supervisor, or consultant) in j
writing or in a meering in which at least one supervisory j
or management official.or NRC employee was present.
Explain what the earlier draf ts said and why they were l
modified.
Expir.in how dissenting sieus were resolved.
Re_sponse:
No draft Results Reporta were modified in any substantive l
l manner.
Question No. 11:
11.
Set forth any unexpected difficulties t h e.t 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 un-expected difficulties resolved?
Response
No difficulties were encountered while the work was being performed..
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I Question No.
12:
12.
Explain any ambiguities or open items in the Results l
Report.
Response
No items remain open, and the Review Team Leader believes the Results Report contains no ambiguities.
Question No.
13:
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13.
Explain the extent to which there are actual or apparent conflicts of i n t e r e s t :, including whether a worker or super-visor was reviewing or evaluating his own work or supervis-ing any aspect of the review or evaluation of his own work j
or the work of those he previously supervised.
Response
Mr. Rushwick was previously involved with the TUGCO Startup i
organization.
This involvement is discussed in the objectivity
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evaluation in the action plan working file, as well as below:
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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 con-sisted of general contract adm i n i s'c ra t i on, general employee-i l
l related administration, and the assignment of personnel for the l
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startup program.
Mr. Rushwick was responsible for R. E.
Camp's assignment as Lead Startup Engineer with TUGCO in 1975.
At no time did Mr. Rushwick become involved.in the startup program i
other than as stated above.
Mr. Rushwick is now self-employed and in no way obligated to the corporate entities involved prior to 1978 in marketing the program to TUGCO. _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ __
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Question No.
14:
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l 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 Review Team Leader has examined the Results Report and t
believes it contains no ambiguities or obvious questions, j
1 Respectfully submitted, l
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Ja es E.
Rushwick l
A ion Plan III.c ssue Coordinator and
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Review Team Leader i
l The CPRT Senior Review Team has reviewed
,e foregoing responses and concurs in them.
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CPRT Memorandum Testing Programs Review Team TO:
File III.c.3A FROM:
J.
E. Rushwick d?,
t DATE:
August 3, 198
SUBJECT:
Procedures and Checklista
,we Attached are copies of the3 checklists developed by the Startup organization to identify the extent of the administrative infraction,and to evaluate the consequences of administratively improper validations of initial conditions for those prerequisite test instructions that had this type of violation.
The checklists are self explanatory.
The evaluation checklist was approved by the RTL prior to use, and each entry on the checklist was confirmed by the RTL.
This checklist was developed as described in SIM-85073.
The other checklist was used to identify the individuals and prerequisite test instructions involved.in the administrative noncompliance.
This checklist was developed as described in SIM-85047.
1 No other procedures were develop for use during the evaluation of I
this issue by either the Startup organization nor the RTL.
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G nscwrar a I 1
l LIT. c., 3 A
.SIM-85073 Page 6
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i ATTACHMENT V 1
l Evaluation Checklist 1
1.
Would inadequate initial conditions affect proper conduct of the test or test results?
l NO - Impropr validation of initial conditions for the prerequisite test would have no impact on the adequacy of subsequent testing INDETERMINATE - Evaluate per Item 2 below YES - Evaluate per Item 2 below 2.
Do the test initial conditions require special training of an individual outside of his specialty to enable him to properly-j validate the required initial conditions for the test?
1 NO - Improper validation of initial conditions for the prerequisite test would have no impact on the adequacy of subsequent testing INDETERMINATE - Evaluate per Item 3 below YES - E.aluate per Item 3 below 3.
Would unsatisfactory equipment operation be detected or be obvious l
during subsequent operation or test activities?
1 YES - Improper validation of initial conditions for the prerequisite test would have no 1:npact'on the adequacy of subsequent testing l
INDETERMINATE - Evaluate per Item 4 below NO - Evaluate per Item 4 below 1
1 4.
Is the. specific test procedure under evaluation satisfactorily l
repeate'd for all cases having improper validation of initial conditions?
YES - Idproper validation of initial conditions for the prerequisite test would have no impact on the adequacy of subsequent testing INDETERMINATE - Evaluate per Item 5 below NO - Evaluate test results for the specific equipment that was not satisfactorily repeated per Item 5 below l
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M.c 3b j
.SIM-85073 Page 7 g } 17, 5.
Was the affected equipment tested, such that the design function and satisfactory operation of the equipment was demonstrated, as part of l
a subsequent test?
YES - Improper validation of initial conditions for the prerequisite test wop 1d have no impact on the adequacy of subsequent testing i
INDETERMINATE - The adequacy of the prerequisite test is questionable and further review and/or corrective actions must be established l
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NO - The adequacy of the prerequisite test is questionable and further review and/or corrective actions must be established jf2 A e W cofa w
.Sc.ne W E b e la u Evaluated by/Date Reviewed by/Date
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Note:
Signoffs above not required, see Prerequisite Test Instruction Evaluation Form.
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TEXAS UTILITIES GENERATING COMPANY lIL c 3 A SIM-85047 OFFICE MEMORANDUM To cien Rose. Texas February 19, 1985 M nte Wise TRT Item III.c - Action 4.1-5 Subject Ref.:
SIM-84281 SIM-85045 This memo supe = des SIM-85045.
Evaluation of the results of the review of prerequisite test results as described by SIM-85045 has been revised based on your comments and will proceed as follows:
1.
Generate a list of prerequisite tests that have been transmitted to the vault.
The list should be sorted by the vault document identification number.
This
- 11st will be the basis for other evaluations to be performed.
It should be noted that the total number of records that'will be listed may. differ from the total presented by SIM-84281 due to the manual counting and estimations used for the evaluation performed for the preparation of SIM-84281.
2.
Identify each record listed as " safety related" or "non-safety related."
This determination will be based on the classification of the equipment tested.
3.
Re-review each record listed to determine if initial conditions of the '
test was signed off by an STE certified in accordance with CP-SAP-19.
If the initial conditions were validated by an STE certified per CP-SAP-19, the following evaluation actions are not required.
If the initial conditions were not validated by an STE certified per CP-SAP-19, continue with the following actions.
4.
For each record that theinitialtestconditionswerehiotvalidatedbyan STE certified per CP-SAP-19, determine if the individual that validated the initial conditions for the test was a B&R craft.
If the individual was a B&R craft, the following evaluation actions are not required.
If the individual was not a B&R craft, continue with the following actions.
5.
For each record that the initial test conditions were not_ validated by a B&R craft, identify the individual by name, organization and-department that the individual worked for at the time of the test.
2,c.3A 2/3 SU-85047 Page 2 6.
For each record that the initial test conditions were not validated by an STE certified per CP-SAP-19, identify the STE that was responsible for review of the test data as indicated by the name in the "STE reviewed by" space on the data sheet and the date that the test prerequisites were signed off.
Results of the above actions will be tabulated in a format consistent with Attachment I.
Upon tabulation of the above, further evalution actions, if required, will be -
determined.
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Dick Camp i
REC /jb Attachment cc: TRT Working File - Item III.c a
H. A. Lancaster S. M. Franks i
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U5Nkt CERTIFICATE OF SERVICE
'87 0 -2 P2 52 I,
R.
K. Gad III, hereby certify that on October 29, 1987, I FFICE Or mat 1Aijy made service of " Answers to Board's 14 Questions (
@,hh[Wd4I Memo of April 14, 1986)'Regarding Action Plan Results Report III.c" by mailing copies thereof, postage prepaid, to:
Peter B.
Bloch, Esquire Asst. Director for Inspection Chairm.n Programs Administrative Judge Comanche Peak Project Division Atomic Safety and Licensing U.S.
Nuclear Regulatory Board Commission U.S. Nuclear Regulatory P.
O.
Box 1029 Commission Granbury, Texas 76048 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 Janice E. Moore Mrs. Juanita Ellis Office of the General Counsel President, CASE l
U.S. Nuclear Regulatory 1426 S.
Polk Street l
Commission Dallas, Texas 75224 Washington, D.C.
20555 Renea Hicks, Esquire Ellen Ginsburg, Esquire Assistant Attorney General Atomic Safety and Licensing Environmental Protection Division Board Panel P.
O.
Box 12548 U.S.
Nuclear Regulatory Capitol Station Commission Austin, Texas 78711 Washington, D.C.
20555 l
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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, Esquire Administrative Judge Office of the Executive Oak Ridge National Laboratory Legal Director P.
O.
Box X, Building 3500 U.S.
Nuclear Regulatory Oak Ridge, Tennessee 37830 Commission Washington, D.C.
20555 Nancy H. Williams 2121 IL California Blvd.
Suite 390 i
Walnut Creek, CA 94596
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