ML20237H021
| ML20237H021 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/17/1987 |
| From: | Broad T, Rushwick J TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| References | |
| CON-#387-4284 OL, NUDOCS 8709030076 | |
| Download: ML20237H021 (9) | |
Text
'
- y 2.g il O X * ~iir Filed:
August 17, 1987.'
UNITED STATES OF AMERICA
'87 E 21' P 1 :49 NUCLEAR REGULATORY COMMISSION 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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COMPANY et al.
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(Application for an (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)
Reaardina Action Plan Results Report III.a.2 In accordance with the Board's Memorandum: Proposed 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 III.a.2, JTG Approval of Test Data.
Openina Recuest:
Produce copies of any CPRT-generated checklists that were used'during the conduct of the action plan.
Response
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I No checklists were generated.
i 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 B709030076 870817 PDR ADDCK 05000445 G
PDR h6f3 s
P
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s areas further?
How did it believe the problems arose?
What did it discover about the QA/QC documentation for l
those areas?
How extensive did it believe the problems were?
B_esponse:
The NRC-TRT expressed concern that the Joint Test Group approval of Hot Functio'nal Test completed test data was not obtained until after cooldown from the test.
The NRC-TRT found no document that described a TUGCO commitment to have the JTG, or a similarly qualified group, approve data for post-fueling preoperational hot functional test prior to proceeding to initial criticality, and they re-l quested that TU Electric make such a commitment.
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In order to comply with the NRC-TRT request, all FSAR 1
l sections and station procedures that would establish the commitment were reviewed by the CPRT.
The CPRT reviewed the actual documents used by Startup and Operations personnel, not QA/QC documentation.
The FSAR commitment was implicit in the language used, but the NRC-TRT required an explicit FSAR commitment.
The FSAR was amended to accomplish this.
i Ouestion No. 2:
2.
Provide any procedures or other internal documents that are necessary to understand how the checklists should be interpreted or applied.
Response
No checklists were generated; therefore no procedures l
were generated.
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Question No. 3:
3.
Explain any deviation of checklists from the inspection report documents initially used in inspecting the same attributes.
. Response:
No checklists were generated, so no comparison can be made.
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.
Response
No checklists were generated for 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
The question is not applicable by reason of the answer to question 4.
Question No. 6:
6.
Set forth any changes in checklists while they were in use including the dates of the changes.
Response
No checklists were generated.
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 occurred, explain the reason for the changes or retrain-ing and set forth changes in duration or content.
Response
No checklists, and therefore no training, were generated for this Action Plan.
Question No. 8:
8.
Provide any information in Applicants' possession concerning 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 reliabil-ity addressed statistically?
Response
No checklists were generated for this Action Plan.
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
No checklists were generated for this Action Plan.
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, super-visor 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.
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ResDonse:
No draft Results Reports were modified in an important substantive way as the 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 unexpected difficulties resolved?
Response
i No difficulties were encountered in performing the work.
Question No. 12:
i 12.
Explain any ambiguities or open items in the Results Report.
Response
There are no open items, and the Review Team Leader believes no ambiguities exist.
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Question No. 13:
l 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.
Response
Mr. Rushwick has had a previous involvement with the TUGCO startup organization, which is discussed in the objectivity evaluation in the Action Plan Working File and in the paragraphs below.
Mr. Rushwick was responsible for marketing startup program services to TUGCO in early 1975.
At that time, he
l was employed by EDS Nuclear, Inc., in San Francisco.
From 1975 until 1978, the nature of his involvement with the TUGCO startup group consisted of general contract administration, general employee related administration, and the assignment of personnel for the st'artup program.
Mr. Rushwick was responsible for R.
E.
Camp's assignment as Lead Startup I
Engineer with TUGCO in 1975.-
(Mr. Camp is currently under contract to TUGCO but not in a startup capacity.)
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 obliga-ted to the corporate entities involved prior to 1978 in A
marketing the program to TUGCO.
Mr. Broad has had a previous involvement with TUGCO, i
which is discussed in the Action Plan Working File and in the paragraphs below.
As Division Manager for EDS Nuclear, Inc., in. San Francisco from 1978 to 1980, Mr. Broad was responsible for general contract administration, general employee-related administration, and assignment of personnel to the CPSES operating staff.
These personnel were involved in the preparation ofiprograms and procedures in the areas of maintenance, engineering, operation, chemistry and health physics. - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ ___ _ _ _ _ _ _ _ _ _ _ _. _ _ _ _ _ _ _ _ _
Mr. Broad-is now employed by Management Analysis Company and in no way obligated to the corporate entities involved prior to 1980.
His knowledge is very useful as a third-party.
reviewer.
The CPRT feel that no actual conflict exists with either individual.
Question No. 14:
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14.
Examine the report to see that it adequately discloses the thinking and analysis used.
If the language is i
ambiguous 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 report and believes there are no ambiguities or obvious questions.
1 Respectfully submitted, 1
A-Th'tiss Broad j
Action Plan III.a.2 Issue Coordinator h
ames E. Rushwick eview Team Leader The foregoing responses have been reviewed and are concurred in bpIthe CPRT Senior Review Team.
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1 CERTIFICATE OF SERVICE I,
Kathryn A. Selleck, hereby certify that on August 17, 1987, Imadeserviceof"AnswerstoBoard's[14,
\\
Questions (Memo; Proposed Memo of April 14, 1986) Regarding l
Action Plan Results Report III.a.2" by mailing copies thereof, postage prepaid, to:
Peter B.
Bloch, Esquire Mr. James E.
Cummins i
Chairman Resident Inspector
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Administrative Judge Comancho Peak S.E.S.
Atomic Safety and Licensing c/o U.S. Nuclear Regulatory ~
Board Commission U.S. Nuclear Regulatory P.
O.
Box 38 Commission Glen Rose, Texas 76043 Washington, D.C.
20555 l
Dr. Walter H. Jordan Ms. Billie Pirner Garde Administrative Judge GAP-Midwest Office 881 W.
Outer Drive 104 E. Wisconsin Ave.
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Oak Ridge, Tennessee 37830 Appleton, WI 54911-4897 l
Chairman Chairman Atomic Safety and Licensing Atomic Safety and Licensing I
Appeal Panel Board Panel i
U.S.
Nuclear Regulatory U.S.
Nuclear Regulatory l
Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Lawrence J.
Chandler, Esquire Mrs. Juanita Ellis Office of the Executive President, CASE Legal Director 1426 S.
Polk Street i
U.S.
Nuclear Regulatory Dallas, Texas 75224 l
Commission
- i Washington, D.C.
20555 Renea Hicks, Esquire Ellen Ginsburg, Esquire Assistant Attorney General Atomic Safety and Licensing i
Environmental Protection Division Board Panel P.
O.
Box 12548 U.S.
Nuclear Regulatory Capitol Station Commission Austin, Texas 78711 Washington, D.C.
20555 l
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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 I
Washington, D.C.
20005 Washington, D.C.
20002 l
Dr. Kenneth A. McCollom Mr. Robert D. Martin Administrative Judge.
Regional Administrator 1107 West Knapp Region IV Stillwater, Oklahoma 74075 U.S. Nuclear Regulatory
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. Commission Suite 1000 611:Ryan Plaza Drive Arlington,. Texas 76011 Elizabeth B. Jchnsen G;ary.S. Mizuno, Esquire Administrative' Judge Office of.the Executive
' Oak Ridge National Laboratory Legal Director P.
O.' Box X, Building 3'500 U.S. Nuclear Regulatory l
Oak' Ridge, Tennessee,',37830 Commiss' ion j
l Washington,.D.C.
20555 l
Nancy H. Williams i
217.1 N.
California Blvd.
Sutta 390 Walnut Creek, CA 94596 v
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8athryn A. Sellec'k i
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