ML20236X201
| ML20236X201 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/04/1987 |
| From: | Dougherty F, Levin H, Wais E TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| References | |
| CON-#487-4990 OL, NUDOCS 8712090046 | |
| Download: ML20236X201 (14) | |
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l Filed:- December 4,'lhhC
-UNITED STATES OF AMERICA
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17 DEC -8. A9 :50 -
NUCLEAR REGULATORY COMMISSION
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before the
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ATOMIC SAFETY AND' LICENSING BOARD m
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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 (Comanche Peak Steam' Electric
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Operating License)
- Shtion, Units 1-and 2)
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ANSWERS TO BOARD'S 14 QUESTIONS (Memo; Proposed Memo of April 14, 1986)
Recardina Action Plan Results Recort IX In accordance with the Board's Memorandum; Proposed Memo-randum and Order of. April 14, 1986, the. Applicants cubmit 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 IX, " Piping and Pipe Supports."
openina Recuest:
Produce copies of any CPRT-generated checklists that were used during the conduct of the action plan.
Response
CPRT-generated -.ecklists used to support the conclusions summarized in the DS;
- X Results Report are described as follows and included
- Attachments I, II, and III
8712090046.871204I PDR ADOCK 05000445 O
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The Design Criteria Review Checklist served as documenta-tion to verify the piping analysis and support design criteria.
The Design Review Summary Checklist was used to verify the review team's implementation of the review criteria.
The Piping Analysis / Support Design Procedure Review Check-list was used to document the review of SWEC procedures against selected criteria from the Design Criteria Review Checklist.
Implementation Review Checklists were also prepared in order to implement Appendix H of the Program Plan.
These include the Piping Analysis Irt.plementation Review Checklist, 1
Pipe Support Design Implementation Review Checklist, and Pipe Stress and Support System Review Checklist.
They are not included in this response, as they were not used to support the conclusion reached in the Results Report, since Revision 4 of the Program Plan terminated implementation reviews (Appendix H) in the design area.
As indicated in the Results Report, follow-up responsibility in this area is now within the scope of the TU Technical Audit Program.
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 documentation for those areas?
How extensive did it believe the problems were?
Response
The Results Rep:rt for the Discipline-specific Action Plan (DSAP) c.. piping and
.pe supports summarizes the results of third party review of SWEC resolutions to a number of issues
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identified by sources external to the-Comanche Peak Response Team (CPRT);, including the Independent Assessment Program (Cygna)', ASLB, CASE,.and NRC review teams (TRT, SIT, and CAT).
i To resolve the external source issues in piping and. support i
1 design and ensure,that all ASME piping and' supports are appro-1 priately designed and qualified, TU Electric committed to per-i form-a requalification program.
. Consequently, this Design
' Adequacy Programf(DAP) Action Plan does not include sampling to identify problem. areas that were a part of the previous analysis for large-bore piping.
In order to define fully the potential piping issues, the DSAP IX Action Plan required that external issues be identified and documented in the DAP, tracking system for.the purpose of monitoring closure and resolution of each.
The SRT determined that the review was extensive enough to con-clude that all substantive piping-related external source issues had been identified.
Root cause of external source issues was redofined by Revision 4 of the CPRT Program Plan to be outside the scope of the large-bore piping Results Report.
The third party did not review QA/QC documentation as part of this Action Plan.
We did not quantify the extent of the problem: however, the requalifi-cation program is extensive enough to ensure that piping and 1
supports are in confernance with applicable commitments.
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.
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P Resconse The following DAP procedures were used in generating and f
implementing the checklists:
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.DAP-1, Preparation and Review of Criteria List
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DAP-4, Preparation of Checklists l
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.DAP-5, Review of Calculations, Evaluations, and'Other J
l Implementing Documents
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DAP-6,-
Review of Drawings, Specifications and Other Design
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Output. Documents-DAP-20, DAP Overview of Activities Performed by the CPSES '
Project or Other External Organizations.
These are included as Attachments IV through VIII.
Each DAP procedure contains descriptions of scope, responsibilities, and instructions', including documentation requirements.
A' copy of an interoffice memorandum issued to offer additional guidance j
for.the preparation of " Type B" checklists is also included l
(Attachment IX).
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Question No. 3:
3.
Explain any deviation of checklists from the inspection j
report _ documents initially used in inspecting the same attributes.
Resoonse:
For the purpose of answering this question, the assumption 1
is made that " inspect:cn report documents initially used" refers j
l to'Gibbs and Hill des;gn review documentation.
Gibbs and Hill design verification "r::edures and documentation were not reviewed as a part c: this DSAP.
The checklists generated by 1
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l the CPRT resulted from a comprehensive review of CPSES licensing commitments and criteria and the external issue source documen-tation, as described in response to question 1.
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.
Resconse:
The Piping Analysis and Support Design Criteria List is a comprehensive itemization of codes, including editions, addenda, and code cases, to which CPSES is committed.
(The executed Design Criteria Review Checklist documents the completeness, consistency, and adequacy of design criteria.)
The Design Criteria List catalogs (1) code requirements specifically relating to the design and (2) general requirements of ASME Codes as determined by review of the FSAR, Design Speci-fications, and licensing correspondence.
The checklists used during conduct of DSAP IX do not include revisions to commitments subsequently made by CPSES as part of the overall requalification effort.
The evaluation of revised commitments was documented through DIRs and engineering evaluations.
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. !
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Response
This: question'is not applicable by reason of the response to question 4.
Ouestion No. 5:
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Set forth any. changes in checklists while they were in use, including;the dates of the changes.
Espoonse:
The Piping Analysis / Support Design Type A and B checklists were not revised'during the reviews.
The Piping Analysis /
SupportLDesign Procedure Review Checklist was revised.as
' described in the completed Design Review Summary Checklists included as Attachments X and XI.
Question No. 7:
'7.
' Set forth the duration of traiSing 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-changen or retraining occurred, explain the reason for the changes or retraining and set forth changes in duration or: content.
Response
Personnel assigned to review of criteria lists and proce-dures-were trained before and during reviews es revisions to procedures were issued.
Training consisted of reading assign-ments and/or instructional sessions and was intended to produce an overall understanding of the CPRT Program Plan, DSAP IX, and the Design Adequacy Program procedures, coordinated with specific review resper.sibilities.
DAP-15, " Training and Quali-fications," specifies requirements of the DAP training program.
DAP files include tra:ning documentation. -________________a
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 a
questionable training or QA/QC supervision?
If applicable, j
are problems of inter-observer reliability addressed
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statistically?
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Response
As stated in response to question 4, training was conducted in a timely fashion to ensure proper implementation of check-lists.
All training was finished before evaluations using the checklists were completed.
Inter-observer reliability is not applicable to this Action Plan.
Question No. 9:
9.
Summarize all audits or supervisory reviews (including reviews by employces or consultants) of training or 7f ase i
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 I
-resolved in a way that is consistent with the validity of conclusions.
Response
j Internal audits performed by DAP Quality Assurance con-cluded that the reviews to evaluate checklist implementation were conducted in accord with DAP-4 and that implementation of i
the Type C checklist was " thorough and substantial."
A concern was raised that the cumpleted Type-C checklist did not reference Discrepancy / Issue Resolution Reports (DIRs) as required by the DAP procedure.
This cas satisfactorily resolved by issue of a revision to the comp'.eted checklist, which added the DIR numbers
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o for all observed discrepancies.
(Reference Audit Nos.
o DAP-QAAR-29 and DAP-QAAR-05.)
Question No. 10:
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.
Resconse:
The draft of the DSAP IX Results Report, Revision 0, was changed to reflect redirection of the DAP by the Senior Review Team (SRT) as of April 10, 1987, as a result of TU Electric's commitment to the Corrective Action Program (CAP).
Conse-quently, the Results Report was revised to redirect tasks not completed by the DAP to other efforts, such as the TU Electric Technical Audit Program.
No dissenting views are known.
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?
Resconse:
No unexpected difficulties arose of the type that would likely be helpful to the Board.
I Ouestion No. 12:
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12.
Explain any ambiguities or open items in the Results j
Report. l
Response
L As discussed in the response to question 10, because of TU
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Electric's commitment to completing the CAP, certain tasks included'in DSAP IX were not completed by the DAP.
These.open f
items are discussed in the Results Report.
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.
Response
As part of the training and qualifications requirements of the DAP, reviewer objectivity was evaluated, based on responses uo Attachment'D of DAP-15.
These evaluations indicate no evi-dence of any conflicts of interest.
Question No. 14:
14.
Examine the report to see that it adequately discloces the thinking and analysis used.
If the language is ambigueus or the discussion gives rise to obvious questions, reso1'e the ambiguities and anticipate and resolve the questions.
Resconse:
In the process of preparing responses to questions 1-13 above, the Review Team Leader, DAP Manager, and Discipline Co-ordinator reread the Results Report specifically to identify any such ambiguities.
None were noted.
Respectfully submitted, E.
A.
Wais Discipline Coordinator - _ _ _ - _ _ _ _ _ _ -
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- T. A. Dougheirty Y
Design Adequacy Program Manager H.-A.
Levin Review Team' Leader
.The'CPRT Senior Review Team has reviewed the foregoing responses and concurs in them.
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Resuonant As discussed in the response to question 10, because of TU 1
Electric's commitment'to completing the cap, certain tasks included in DSAP IX were not completed by the DAP.
These open
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1 items are discussed in the Results Report.
gggggion No. 13t 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 super *tised.
Responser As part of the training and qualifications requirements of the DAP, reviewer objectivity was evaluated, based on responses to Attachment D of DAP-15.
These evaluations indicata no evi-dance of any conflicts of interest.
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.
Response
In the process of preparing responses to questions 1-13 above, the Review Team Leader, DAP Manager, and Discipline Co-ordinator reread the Results Report specifically to identify any such ambiguities.
Her.e were noted.
Respectfully submitted, M
E.
A.
wais Discipline coordinator _ _ _ _.
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3 F. A. Dougherty Design Adequacy Program Manager
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If A. Levin ' '
"U Review Team Leader The CPRT Senior Review Team has. reviewed the foregoing responses and concurs in them.
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CERTIFICATE OF SERVICE T EC -8 49 50 '
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Gad III, hereby certify that on December 4,'1987, I made. service of " Answers to Board's 14 Questions (Memhghp}syggy BRANCH Memo of April 14, 1986) Regarding Action Plan Results Report IX" 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 54911-48??
Chairnan 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 j
Environmental Protection Division Board Panel
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P. O.
Box 12548 U.S. Nuclear Regulatory Capitol Station Commission Austin, Texas 78711 Washington, D.C.
20555 l
1
Anthony Roisman, Esquire Mr. Lanny A.
Sinkin Christic Institute Suite 600 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 Jack R. Newman, Esquire Nancy H. Williams Newman & Holtzinger, P.C.
2121 N. California Blvd.
q Suite 1000 Suite 390 1615 L.
St., N.W.
Walnut Creek, CA 94596 Washington, D.C.
20036
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Gad III h -_m