ML20236N877

Answers to Board 14 Questions (Memorandum,Proposed Memorandum of 860414) Re Action Plan Results Rept Vi.B.* Submit Answers to Board Questions Re Polar Crane Shims,In Accordance W/Board 860414 Memorandum.W/Certificate of Svc

ML20236N877
Person / Time
Site:	Comanche Peak
Issue date:	11/06/1987
From:	Arros J, Levin H TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
References
CON-#487-4799 OL, NUDOCS 8711170040
Download: ML20236N877 (11)

Text

4 mg 00CKETED USNRC Filed: November 6, 1987.

@ s to e1:50 UNITED STATES OF AMERICA 0FricE c ?io;FW'

. NUCLEAR REGULATORY COMMISSION 00CKElma 4 MMCf.

BR E H before the ATOMIC SAFETY AND LICENSING BOARD -

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In the Matter of ) Docket Nos. 50-445-OL

) 50-446-OL TEXAS UTILITIES GENERATING ) i COMPANT et al. )

) (Application for an (Comanche Peak Steam Electric ) Operating License)

Station, Units 1 and 2 )

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ANSWERS TO BOARD'S 14 QUESTIONS  !

(Memo; Proposed Memo of April 14, 1986)

Recard$na Action Plan Recults Report VI.b In accordance with the Board's MemoraDum; ProDosed Metnorandum and Order of April 14, 1986, 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 VI,b, Polar Crane Shims.

Openina 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 by the CPRT during implementation of this Action Plan.

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Ouestion No. 1:

b 1. . Describe the problem areas addressed in'the report.

L 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?

ResDonse:  ;

The problem areas identified by the TRT and addressed in the report were: (1) the concern about bearing surface at l the girder seat connections because of. observed gaps between 1

the shims ~and the girder or the support bracket, (2) the continued rail movement observed as the crane was operated, and (3) the possibility of other deficiencies that may exist.

and be safety-significant.

A sampling program was not appropriate for this inves-tigation. In order to define the problem further, however, the fabrication, construction, and performance ^nistories as well as the design of the polar crane runway system were reviewed measurements and tests to determine the extent'of rail motion were performed, and additional analyses of the I rail and its attachment under normal and seismic loads were performed. j l

The problems with the girder seat connection were j identified because apparent changes in the gaps between shims

.and support brackets over a period of time raised questions about the adequacy of the connections. The determination was made that, although sole plate bolts and girder connection

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'4 contact' bearing stresses were not addressed in the runway.

i system' design, subsequent-evaluation verified that even'in l the presenceuof gaps, the bolting. stresses are within their allowable. values, and the bearing-stresses are not of

-concern,Lsince they are~self-limiting in nature. ;Therefore, the. gaps observed-by the TRT are not significant, and.no corrective action was required.

The: original' design of.the rail attachment to the girder also permitted railEmovement, resulting,in gaps'and misalign-' '

ment's between rail ends that,Lin turn, adverselyLaffected 1 movement ofLthe: crane. bridge over the rails.- The review effort: determined that the design of the. crane rail and crane rail hold-down clip were not' supported by calculations and:

analyses. -Determination was also made that seismic loads' identified.by the1 crane manufacturer had not been used by G&H in the design of the runway system. 'l

-1 The third-party review discovered no QC inspection l

records of the original erection'of the crane runway. system.

Subsequent measurements by B&R personnel performed before

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placement of the crane'on the rails'provided some as-built-documentation of the gaps. Later measurements taken by the Project during investigation of the various runway problems were documented by QC as required by the operations Traveler process.

'l Based on the results of the analyses performed on the i design of the crane and runway system, only two hardware 1

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A, items. required modification. The rail hold-down clips had to .(

be' strengthened, and a splice plate was!added.to maintain l; alignment;of rail-ends and.to limit relative movement.of q adjacent rail; sections.- The Results ReportLcontains.addi-  ;

tional details. M

~ Question No. 2:

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2. Provide.any procedures or other internal! documents 1that j '

are necessary.to understand how the checklists should be 1 interpreted or applied.

Resoonse: ,

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No checklists were generated or used by the:CPRT during-- q implementation of this Action Plan.  !

[ ' Question ik).'3: ]

3.: Explain any deviation of checklists from the inspection' )

report documents; initially used in inspecting the same attributes.

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.Resoonse: i

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. This-question is not applicable by reason'of the l l

responce to question 2. 'l

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Question No. 4:

4. . Explain the extent to which the checklists contain fewer attributes _than are required for conformance to codes to j which Applicants are committed to conform. j

< a Resoonse: i l

This question is not applicable by reason of the ,

L response to question 2. 1 L >

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-Ouestion 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'hy reason of the  !

i response to question 4.

Ouestion No. 6:

6. Set'forth any changes in checklists while they were in  !

use including the dates of the changes.

l Resoonse:

This question is not applicable by reason of the l response to question 2.

Question No. 7:

7. Set forth the duration of training in the use of

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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 occurred, explain the reason for the changes or retrain- <

ing and set forth changes in duration or content.

Response

This question is not applicable by reason of the response to question 2.

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Ouestion No. 8.1

~> y o '8. Provide'any information in Applicants' possession 9" e concerning.the. accuracy of use of the checklists (or the inter-observer reliability in using the checklists).-

i , Were there anystime periods in which: checklists were used with' questionable training or QA/QC. supervision?

If applicable, are problems of inter-observer reliabil- *

.ity addressed statistically?-

E Responsei This question is not applicable by reason 1of the

' response to question'2..

J Opp Question No. 9: q

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 7 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.

,7 Resoonse:

No checklists were used; therefore,-no audits were l

. performed on training or the use of checklists. An overall i

audit 5of the. performance of this Action Plan was performed'in accordance with established procedures and guidance provided' I

by_the SRT in the Program Plan. l one observation'about the format of third-party review l

documents and one observation about the training and objec- -l 1

tivity records for the Issue Coordinator'and two' consultants were noted and resolved.

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Ouestion-No.-10

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10. ' Report ~anyfinstances in $hich: draft! reports.were ,.

j modified in an important substantive waynas the: result of management action. Ihn sure ,to . explain any change j

?that was objected.to (including by an.' employee, super- 1 visor cur consultant) Lin writing or. in a: meeting in 'which atileast one supervisory or management;officialtor'NRC'

. employee;was present. Explain what .the: earlier drafts said and whyLthey'were modified. Ltxplain how dissenting- q

. views were'-resolved.

Response

No substantive' modifications.were made to the Results: l

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' Report as~a result of management action.- l

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i c Question No.'11:

'I 11'. Set:forthiany unexpected difficulties that were

'l 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. l each of these' unexpected difficulties resolved? -!

ResDonse: l 3

Determination was made that the original: runway system Ldesign'was'not' supported by design calculations.^. Consequent- -

ly a complete set'of calculations.was generated. As.a result-  ;!

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of?the analyses;^ design modifications were made to (1)  ;

increase 1tbe strength of bolts on the crane truck bearing q caps, (2) increase-thesizeandhtrengthofcranerail-hold--

down clips on the inside of the rail, and (3) add rail splice bars to maintain' alignment of the crane rails and to limit' L ' relative movement between rail sections.

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' k .ap Ouestion'No.112:

12. Explain any ambiguities.or open items'in the Results.

1. Report.

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Rosconse:

To the best of our knowledge, no ambiguities or.open e

items are'left in the Results Report. Ongoing activities by l

, i the Project are identified'in Section 7.0 of.the Rssults.

Report.

Ouestion No' l'3:

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 super-vised.

Resoonse:

No actual or apparent conflicts of interest existed.

The final evaluations and design modifications were made by.

Stone & Webster engineers. These individuals had no involve-ment with the original design of the polar crane runway system in. question.

Investigatory activities not performed by third-party personnel were closely monitored by third-party personnel, i

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Question-No. 144

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.

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Resnonae: j The Issue coordinator and others who aided in the prepara-  !

i tion and approval of the Results Report have reviewed and '

ohecked the Results Report for clarity and believe that no ambi- ,

guities exist.

l Respectfully submitted,  !

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J.7K. Arros 1 Action Plan VI.b Issue Coordinator j 9

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. A.' Levin Review Team Lesder j i

The CPRT Senior Review Team has reviewed the foregoing t responses and concurs in them.

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y 00LKETE0 USNRC CERTIFICATE OF SERVICE 1g MW 10 .P150 1'

I, R. K. Gad III, hereby certify that on gogmger g y S87, I 00CK MpmmM (F Proposed

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made service of " Answers to Board's 14 Questions TING A SERVIl Memo of. April 14, 1986) Regarding Action Plan Results Report VI.b" by:mai' ling copies thereof, postage prepaid, to:.

I 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. Nucl' ear 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

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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 i 2121 N. California Blvd.  !

Suite'390 Walnut Creek, CA 94596

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R. K. Gad III,/

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