ML20236N820
| ML20236N820 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/03/1987 |
| From: | Arros J, Levin H TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| References | |
| CON-#487-4798 OL, NUDOCS 8711170021 | |
| Download: ML20236N820 (10) | |
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DOCMETED Filed:
November 3, 188tT.
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UNITED 1TATES OF AMERICA
'87 MN 10 P12:39 NUCLEAR REGUIATORY COMMISSION OFFICE OF SECFElt.F' 00CXETiH'; 4 SfMici.
before the BRANDi ATOMIC SAFETY AND LICENSING BOARD l
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In the Matter of
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Docket Nos. 50-445-OL
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50-446-OL TEXAS UTILITIES GENERATING
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COMPANY et al.
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(Application for an 3
(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)
Recardino Action Plan Results Report II.e In accordance with the Board's Memorandum; Proposed l
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 II.e, Rebar in Fuel Handling Building.
Onenina Recuest:
Produce copies of any CPRT-generated checklists that were used during the conduct of the action plan.
Response
No checklists were generated or used in the implementa-tion of this action plan.
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'Ouestion 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 areasLfurther?
How did.it-believe the problems arose?
l What did it discover about the QA/QC documentation for those areas?- How extensive did it believe'the. problems-I l-were?
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ResDonse:
The subject problem addressed in the report was the structural adequacy of.the concrete floor of the Fuel;
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Handling Building in' view of'the possibility that during l installation of the Hilti bolts to attach rail clips,
. unauthorized cutting of the second layer of #18.rebar may.
. have occurred.
No sampling was used.
The concern arose because aLformer Brown & Root employee' stated that he had possibly drilled holes deep enough to cut a second layer.of.
rebar, when cutting of only the uppermost rebar was authorized by Design; Change Authorization'(DCA).
QA procedu-res were' determined to require inspection of Hilti bolt ll installations; however, Inspection Report forms for these
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inspections did:not include a requirement to verify whether rebar was-cut.
The Project performed an analysis assuming the rebar was out and confirmed.that the floor mat still satisfies the requirements of the design criteria.
As a result, the conclusion was reached that.no problem existed i
with the subject case.
l Three additional tasks were performed to address possible generic applicability of the rebar-cutting problem. :
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1 a-One: task'was a. review of all cases in which cutting of rebar.
I was authorized for the installation of Hilti bolts or for the
' installation of shear lugs on pipe supports, to determine-whether~the possibility existed that additional'rebar could i
d have been' cut'in an unauthorized manner.
In allocases in which the possibility of. unauthorized cutting existed, i
analytical evaluations were performed to determine whether-adequacy would have been compromised as a. result of the possible unauthorized cutting.
The second task was a review of procedures,' including QC instructions applicable to rebar cutting.
The third task was a review of the'NRC's conclusion on the issue of potential unauthorized use of diamond ~ drill' bits.
None of these tasks indicated any generic applicabil-ity with respect to the rebar cutting problem.
Details of-each of these tasks are included in the Results Report.
1 Ouestion No. 2:
2.
Provide any procedures or other internal documents that i
are necessary to understand how the checklists should be interpreted or applied.
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Response
No checklists were generated or used in the implementa-4 tion of this Action Plan.
!'l Question No. 3:
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3.
Explain any deviation of checklists from the inspection
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report documents initially used in inspecting the same attributes.
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i Resoonse:
This question is not applicable becauce no checklists were used in the implementation of this Action Plan.
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.
ResDonse:
This question is not applicable because no checklists were used in~the implementation of this Action Plan.
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 to cuestion 4.
t Question No. 6:
6.
Set forth any changes in checklists while they were in use including the dates of the changes.
Besconse:
This question is not applicable because no checklists were used in the implementation of this Action Plan.
Question No. 7:
7.
Set forth the duration of training in the use of checklists and a summary of the content of that train-ing, including field training or other practical training.
If the training has changed or retraining j -
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occurred, explain.the reason'for~the changes'or. retrain-ing/and set forth changes in' duration.or content.
t Resoonse:-
- This' question is not applicable because-no checklists were-used in the' implementation offthis. Action ~ Plan.
i Question-No.'8:
i 8.
. Provide any in' formation in' Applicants' possession concerning the accuracy of use of the' checklists (or the inter-observer reliability in using the; checklists).
Were there any time periodo.in which checklists;were used_with questionable training or QA/QC supervision?
j If applicable, are problems of inter-observer.reliabil-q ity addressed: statistically?
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ERE7'fisti This. question is not applicable because no checklists
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.were used in the implementation of this Action Plan.-
Question No. 91 d
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 1
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.
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Resconse.
1 No checklists were used;.therefore, no audits were
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performed on training or the'use of checklists.
An overall audit of the performance of this ISAP was conducted in accordance with established procedures and guidance provided by the'SRT in the Program Plan.
No observations or Correc-tive Action Requests were issued as a result of the audit.-
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~ Ouestion No. 10:
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Report any instances in which draft' reports were
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modified in a:.t important. substantive. way as the result of management action. ~Be sure to explain anyl change that was objected to'(including by an employee, super-visor or. consultant) in writing or in a. meeting in which
'at-least one-supervisory or management official or.NRC-l employee was present.
Explain what the earlier drafts t
said and why they were modified.
Explain how dissenting-i l
views were resolved.
Response 1.
i No' substantive changes were made to the Results Report as a result of management action.
Question'No. 11:
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Set forth.any unexpected. difficulties-that were
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encountered in completing the, work of each task-force
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the pl.acess by which conclusions were reached.
How were each of these unexpected difficulties resolved?
Response
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No unexpected difficulties were encountered in the
' implementation of'this Action Plan.
i Question No. 12:
12.
Explain any ambiguities or open items in the'Results
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Report.
Response
To the best of our knowledge, no ambiguities or open items are left in the Results Report.
q Question No. 13:
13.
Explain the extent to which there are actual or apparent conflicts of interest, including whether a worker or supervisor was aviewing or evaluating his own work or
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supervising any aspect of the review or evaluation of his own work or the work of those he previously super-vised. l 1
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l Resconse:
Activities not performed by third-party personnel were closely monitored by third-party personnel; this precluded potential bias resulting from possible conflicts of interest.
Question No. 14:
14.
Examine the report to see that it adequately discloses i
the thinh.lg and analysis-used.
If theilanguage is l
ambiguous or the discussion gives rise to obvious l
questions, resolve the ambiguities and anticipate and l-resolve the questions.
Response
The Issue Coordinator and others who aided in the prep-aration and approval of the Results Report have reviewed and
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u checked.the Results Report for clarity and believe that it con-i
.tains no ambiguities.
l Respectfully submitted,
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/M J. TX. Arros Action Plan II.e Ispue OOrdinStor./
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. Levin
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Review Team Leader The CPRT' Senior Review Team has reviewed the foregoing responses and concurs in them.
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' CERTIFICATE OF' SERVICE 71 EV 10 Pl2:39
' I,f David. A. Martl-Ind, hereby certify.that on November 3, H
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' 1987, 1 made service ofi" Answers to Board's'~14 Ques h h h [y dr BRANCH
' Proposed' Memo of April-14,-1986)!Regarding Action' Plan Results' Report II.e" byl mailing copiesLthereof, postage prepaid,-to:~
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Peter:B. Bloch, Esquire JAsst.: Director for Inspection' U
. Chairman ~
Programs:
Administrative Judge.
Comanche Peak 1 Project Division t
Atomic Safety and Licensing
'U.S. Nuclear Regulatory-Boardt
. 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.
j Oak-Ridge, Tennessee. 37830'
.Appleton, WI 54911-4897 i
Ch' airman' Chairman ~
Atomic Safety 1and-Licensing Atomic Safety and Licensing.
I Appeal Panel ~
Board Panel.
U.S. Nuclear Regulatory U.S. Nuclear Rugulatory Commission' Commission-Washington, D.C.-.20555 Washington, D.C.
20555 a
4 Janice E..' Moore Mrs. Juanita Ellis I
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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 LAssistant: Attorney General Atomic Safety and Licensing 1
Environmental Protection Division Board Panel P.-O.
Box 12548 U.S.. Nuclear. Regulatory Capitol' Station Commission Austin, Texas' 78711 Washington,HD.C.
20555 i
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Anthony Roisman, Esquire Mr. Lanny A.'Sinkin Suite 600
- Christic Institute l
1401 New York Avenue, N.W.
1324 North Capitol Street 1
I Washington, D.C.
20005 Washington, D.C..
20002 Dr. Kenneth A. McCollom Mr. Robert D. Martin Administrative' Judge Regional Administrator 1
1107. West Knapp Region IV Stillwater, Oklahoma 74075 U.S. Nuclear Regulatory Commission
' Suite 1000 611 Ryan Plaza. Drive j
Arlington, Texas 76011 1
I Elizabeth B.' Johnson Geary S. Mizuno, Esquire Administrative Judge Office of the Executivo i
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-t Nancy H. Williams-
'2121 N. California Blvd.
Suite 390 Walnut Creek, CA 94596
-David A. Ma'rtland m-
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