ML20236P871
| ML20236P871 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/12/1987 |
| From: | Levin H, Sanan R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| References | |
| CON-#487-4863 OL, NUDOCS 8711190044 | |
| Download: ML20236P871 (10) | |
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USNRC Filed:. November 1 Ig7 UNITED STATES OF AMERICA
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0FF!CE N TEdrETip-NUCLEAR REGULATORY COMMISSION 00 Cnid G wry n EME f before the
' ATOMIC' SAFETY,AND LICENSING BOARD:
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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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COMPANYeet al.
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(Application'for an-
. (Comanche' Peak Steam Electric
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. Operating License) l Station, Units.I and 2)
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ANSWERS-TO BOARD'S 14 QUESTIONS' (Memo; Proposed Memo of April'14, 1986)
Regarding Action Plan Results Report II.a In accordance with the Board's Memorandum: 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 i
published by the CPRT in respect of CPRT Action Plan II.a.
" Reinforcing Steel in the Reactor Cavity."
Opening Request:
j 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 in the l
implementation of this Action Plan.
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l-U Question No.
1-l 1.
Describe the problem areas.a'ddressed,in the:-report. ' Pr i o r.
l toJundertaking to1 address those areas through' sampling,-
0 what.did Applicants do to; define the problem areas further?
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.Howndid.it believe'the problems arose? : What: did it dis-
. cover about the QA/QC documentation for those areas?
How extensive did.it:believe the, problems were?
Response
Two areas were' addressed in'this Action Plan Results Report.
The first concerned.a documente'd occurence in which re -
s inforcing steel was omitted from a Unit I reactor cavity con-crete' placement-between the elevations of 812'. and 819'1/2".
The TRT was informed that an analysis of the as-built condition-
'had not been performed.
No sampling was undertaken by the Project or the' third party relative to this area.
.The problem arose because the Structural Job Engineer-decided on the addition of rebar to control superficial cracking at the corners of neutron detector slots in the cavity wall in the event of a LOCA.
A drawing revision (Revision 3) was issued to include additional rebar, but the revision reached the field after concrete was poured at the identified elevation.
The i
field is' sued an NCR to document the discrepancy between the j
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drawing and the as-built condition.
Revision 4 of the drawing was issued to reflect the as-built condition, but G&H concluded that additional analyses were not necessary because the design calculation of record support ed Revision. 2, which was identical
'to Revision 4.
Analyses performed in response to the TRT I
request confirmed the adequacy of t he cavity wall, and third-l 1 1 I
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party review:of documentation of the circumstances surrounding
.the~omitted.rebar concluded that1the documentation was consis-
-tent:with Project procedures.
The second area 1 addressed wasuan overall review of rebar
.6 installation activities /tofidentify any potential problemfareas.
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.This investigation included a review of NCRs that documented l
cases of rebar-omission, a comparison of pour cards with current design drawings, a - comparison of installation records of major l
embedments with current design' drawings, an evaluation of pro-cedures governing rebar installation and inspection, and an i
L investigation of areas exposed during the~ performance of ISAP 1
l II b,." Concrete Compression Strength."
Sampling was used only to determine the specific pour cards to.be reviewed.
The review 1
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of-QA/QC and other documentation for the subjects identified l
above revealed that NCRs were appropriately resolved, that pour cards and installation records were in agreement with design drawings, and that procedures governing document control and installation and inspection were adequate.
Question No. 2:
1 2.
Provide any procedures or other internal documents that are
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necessary to understand how the checklists should be inter-preted or applied.
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Response
No checklists were generated or used by the CPRT in imple-mentation of this Action Plan.,
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..i Question'No. 3:
3.
Explain'eny. deviation of checklists from.the; inspection reportLdocuments' initially.used in inspecting.the same-
-attributes.
- Response:
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This-question is not applicable because no checklists were.
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- l usedfin= implementation of this Action Plan.
v 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.
Responset This question is:not applicable because no checklists were
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- used in implemen'tation of this Action Plan.
QuestionJNo. 5:
5.
(Answer' Question.5'pnly if the answer to Question 4 is that the checklists'do contain fewer attributes.-)
Explain'the engineering basis, if any, for believing that thelsafety margin for components (and the plant) has not been degraded byLusing checklists that contain fewer attributes than are required for conformance to codes.
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- Response:
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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.
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Response
This question is not applicable because no checklists were used.in implementation of this Action Plan.
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Question No. 71 7.
Set forth the duration of training in-the use of checklists andia. 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.
Response
This question is not applicable because no checklists were.
use'd in implementation of this Action Plan.
Questien 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 questionab'le. training or QA/QC supervision?
If applicable, are problems of. inter-observer reliability addressed statistically?
Response
This question.is.not applicable because no checklists were used in implementation of this: Action Plan.
i Question No. 9:
j 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 checkli,sts were used; therefore, no audits were per-formed on training or the use of checklists.
However, the Issue Coordinator and other third-party personnel reviewed the results of Project investigations, and the CPRT Statistical Advisor re-
. viewed the sampling of pour cards and the associated working i' <
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. files.
In. addition,c an overall audit of.'the implementation'of' the Action Plan.was. performed.
i The.statistica11 review and overall audit were conducted'in l
l accordance with established procedures and guidelines'provided by the SRTLin th'e. Action-Plan.
No audit findings or: observations were issued concerning training or checklists.
Recommendations were made relative to.
l the content and-format of the Results Report, and these were i
incorporated.
i Question No. 10:
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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 for management official or NRC employee was present.
. Explain what'the earlier. drafts said and why they were modified.
Explain how dissenting views were resolved.
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Response
No 'subst ant ive modificat ions were made to the Result Report l
i as.a result of management action.
Question No. 11:
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 un-expected difficulties resolved?
Response
Reinspection, reviews, and analyses performed in implemen-tation of this ISAP presented no unexpecited difficulties.
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-Question'No. 12:
12.'iExplain1any ambiguities or open items in the Results Report.
Response
AnLopen itemLin:the Results Report is described below, a
During field verification of areas exposed in the perform s
ance of/this Action Plan,..
the non-contact lap splices for two q
-vertical-reinforcement bars appeared to exceed the ACI code requirements, and two vertical reinforcement bars appen.ud to be missing.
This concern was documented as DIR D-0477, Rev.
1.
In-order-to gain full understanding of.the situation,1the Project chipped additional areas, revealing that the number of vertical reinforcement bars specified by the design are'present but spaced non-uniformly, and at four locations'non-contact lap splice spacing exceeds ACI code requirements.
Project evaluation of this condition demonstrated that the as-built condition has no effect on structural integrity of the wall.
The evaluation of these lap splices uses calculations i
based on the strength of the splice.
Testing currently being j
performed at Cornell University focuses cn the relative strength of non-contact lap splices of different spacing.
The test results are expected to be used to support these evaluations.
-Question No. 13:
13.
Explain the extent to which there are actual or apparent conflicts of interest, 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 or the work of those he previously supervised. - -. -. _ _ -.-
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Response
' All reviews.an~d analyses performed by the Project and-inspections.of the' exposed areas conducted by.the Project to verify,conformance of as-built' conditions with design drawings were independently verified'by the third party.
No conflicts of interest arose.
Question No. 14:
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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Response
The Issue' Coordinator and others who aided in the prepara-t' ion and approval of the Results Report have reviewed and checked it for clarity.and believe no ambiguities remain.
Respectfully submitted, H /5"l87 '
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R.
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Sanan Action Plan II.a Issue C ordinator
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/ b uheln llf-KNievin\\
U Review Team Leader
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The CPRT Senior Review Team has reviewed the foregoing responses and concurs in them.
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. U 3hiiC CERTIFICATE OF SERVICE eg Nov 16 PS:33 I, R. K.GadIII,herebycertifythatonNovg 2p.ykk, BRANCH I made service of " Answers to Board's 14 Questions (Memo; Proposed Memo of April 14, 1986) Regarding Action Plan Results Report II.a" by mailing copies thereof, postage prepaid, to:
Peter B. Bloch, Esquire Asst. Director for Inspection l
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
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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 1
Elizabeth B., Johnson Geary S. Mizuno, Esquire.
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Administrative Judge Office of the Executive l
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 N. California Blvd.
I Suite 390 Walnut Creek,' CA 94596
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R. K. Gad III
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