ML20236H413
| ML20236H413 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/29/1987 |
| From: | Rushwick J TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| References | |
| CON-#487-4741 OL, NUDOCS 8711040107 | |
| Download: ML20236H413 (11) | |
Text
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' y 79 l S.
October 29, fkkfPC Filed:
UNITED STAFES OF AMERICA 17 NUV -2 P2 :52 NUCLEAR REGULATORY COMMISSION GFFICE U N 00CKE!!M 4 :h(T A D before the if.
BRAND:
ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
)
Docket Nos. 50-445-OL 1
50-446-OL TEXAS UTll.ITIES GENERATING
)
COMPANY et al.
)
)
(Application for an (Comanche Peak Steam Electric
)
Operating License)
Station, Units 1 and 2)
)
)
ANSWERS TO BOARD'S li QUESTIONS (Memo; Proposed Memo of April 14, 1986)
Regarding Action Plan Results Report III,b In accordance with the Board's Memorandum; Proposed Memo-
)
randum and Order of April 14, 1986, the Applicants submit the l
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 b,
" Conduct of CILRT."
Opening Request:
l Produce copies of any CPRT-generated checklists that were used during the conduct of the action plan.
l
Response
A copy of the checklist and an explanatory memorandum from the working file are attached.
8711040107 871029 PDR ADOCK 05000445 O
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Question No.
1:
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 dis-cover about the QA/QC documenta ti on for those areas?
How extensive did it believe the problems were?
Response
The method by which the containment integrated leak rate 1
was calculated and the isolation of three electrical penetra-tions during testing were questioned b.y the NRC-TRT because the industry standard from which these actions were derived had not been endorsed by the NRC.
The containment leak rate methodology was resolved by the NRC-TRT.
The NRC-TRT also questioned the manner in which the Startup organization identified and reported deviations from FSAR commitments to the NRC.
The report addresses the methods by which the Startup organization had a
reported deviations from FSAR commitments and determined if a generic problem existed.
I The Review Team Leader reviewed the NRC-TRT description of l
the issue to determine whether a problem did exist.
Then, to ascertain the extent of the problem, he developed an Action Plan j
l and a sampling program to determine whether there was a program-l I
matic deficiency in that other deviations from FSAR commitments i
occurred during implementation of the startup testing program, j
The problem arose because the FSAR stated that one standard l
was to be used to perform the containment integrated leak rate test, while, in fact, two exceptions to that standard were taken
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and not documented in the FSAR.
The test was performed in i
1 accordance with industry practices that had been endorsed by the l
I NRC on a case-by-case basis for a number of years.
The Review Team Leader believed that the failure to correct the FSAR was an i
oversight on the part of the Startup organization, since the l
test was witnessed by two NRC inspectors who specialize in con-tainment testing, and the method of calculation was more con-servative than NRC requirements.
The Review Team Leader reviewed actual Startup test records rather than QA documentation.
Based on this review, he con-
)
cluded that the problem was not extensive.
Question No. 2:
2.
Provide any procedures or other internal documents that are 3
necessary to understand how the checklists should be inter-preted or applied.
Response
I i
Other than the attached memorandum, no internal documents were generated that explained the checklist.
The Review Team Leader believes the checklist to be self-explanatory.
Question No. 3:
3.
Explain any deviation of checklists from the inspection report documents initially used in inspecting the same attributes.
Response
No checklists of this type were used prior to the Review Team Leader's review.
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Question No. 4; 4.
Explain the extent.to which the checklists contain fewer i
attributes than are required for conformance to codes to j
which Applicants are committed to conform.
I 1
Response
No codes or standards are applicable to this type of l
1 review.
-l Question No. 5:
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 response I
to question 1.
1 I
1 Quest ion No. 6:
)
6.
Set forth any changes in checklists while they were in use, i
including the dates of the changes.
1
Response
)
l No changes to the checklist were made.
Question No. 7:
7.
Set forth the duration of training in the use of checklists l
l and a summary of the content of that training, including l
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.
Response
The checklist was self-explanatory, used only by the Review Team Leader, and no training was required.
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1 Question No. 8:
8.
Provide any information in Applicants' possession concern-ing 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 was used only by the Review Team Leader; i
I therefore, inter-observer reliability was not a concern.
Question No. 9:
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
i The work was performed by the Review Team Leader.
No audits were performed.
Question No. 10; i
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.
Explain what the earlier drafts said and why they were modified.
Explain how dissenting views were resolved.
Response
I No draft Results Reports were modified in any substantive manner.
_ s-
f Question No.
11:
11.
Set forth any unexpected difficulties that were encountered in completing the work of each task force and that would be j
helpful to the Board in understanding the process by which conclusions were reached.
How were each of these un-expected difficulties resolved?
Response
1 No difficulties were encountered while the work was being performed.
Question No.
12:
12.
Explain any ambiguities or open items in the Results Report.
Response
No items remain open, and the Review Team Leader believes the Results Report contains no ambiguities.
Question No. 13:
13.
Explain the extent to which there are actual or apparent conflicts of interest, including whether a worker or super-l visor was reviewing or evaluating his own work or supervis-ing any aspect of the review or evaluation of his own work or the work of those he previously supervised.
Response
l l
Mr. Rushwick was previously involved with the TUGCO Startup l
l organization.
This involvement is discussed in the objectivity evaluation in the action plan working file, as well as 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 con-sisted of general contract administration, general employee-related administration, and the assignment of personnel for the >
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1 startup program.
Mr. Rushwick was responsible for R.
E.
Camp's assignment as Lead Startup Engineer with TUCCO in 1975.
At no time did Mr. Rushwick become involved in the startup program other than as stated above, i
Mr. Rushwick is now self-employed and in no way obligated j
to the corporate entities involved prior to 1978 in marketing the program to TL'GCO.
1 1
I question No.
li:
14.
Examine the report to see that it adequately discloses the l
thinking and analysis used.
If the language is ambiguous i
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 S
believes it contains no ambiguities or obvious questions.
Respectfully submitted, 1
l b-n 1
Ja es E.
Rushwick Ac ion Plan III,b I.'ue Coordinator and eview Team Leader The CPRT Senior Review Team has reviewed the foregoing responses and concurs in them.
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7 AthdwetI TO: FILE III.b.38 FROM:
J.
E.
RUSHWIC Ib~
SUBJECT:
CHECKLISTS DATE: 10-16-86 THE CHECKLIST DEVELOPED FOR THIS ISAP FOLLOWS THE FORMAT GIVEN IN THE ISAP ACCEPTANCE CRITERIA.
DATA WAS RECORDED IN A dBASE III+
DATABASE.
THE IDENTIFICATION OF THE COLUMNS ON THE DATA BASE REPORTS CORRESPONDS TO A CHECKLIST.
THE REPORT HAS AN EXPLANATION OF THE TERMS USED AT THE END OF THE REPORT REPORT.
ATTACHED IS A COPY OF THE FORMAT OF THE CHECKLIST.
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R _ S A _ R O
00(xcrce USNht CERTIFICATE OF SERVICE l
N * ~2 P2 32 I,
R.
K. Gad III, hereby certify that on Oct 29, 1987, I u? ncqw, emhkkfj6pdshd made service of " Answers to Board's 14 Questions (
Memo of April 14, 1986) Regarding Action Plan Results Report III,b" by mailing copies thereof, postage prepaid, to:
Peter B.
Bloch, Esquire Asst. Director for Inspection Chairman 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 U.S.
Nuclear Regulatory 1426 S.
Polk Street 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
i 4
i Anthony Roisman, Esquire Mr. Lanny A.
Sinkin l
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 I
Administrative Judge Regional Administrator-1107 West Knapp Region IV y
Stillwater, Oklahoma 74075 U.S. Nuclear' Regulatory 1
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 i
Oak Ridge, Tennessee 37830 Commission l
Washington, D.C.
20555 Nancy H. Williams l
2121'N. California Blvd.
I Suite 390 Walnut Creek, CA 94596
,)
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R.
K. Gad III t
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