ML20237H025
| ML20237H025 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/20/1987 |
| From: | Levin H, Streeter P TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| References | |
| CON-#387-4285 OL, NUDOCS 8709030078 | |
| Download: ML20237H025 (11) | |
Text
_
/9 2 JEdi Awp4egntt Filed:
nyricc
~67 AU3 24 R2:17 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
)
)
Docket Nos. 50-445-OL TEXAS UTILITIES ELECTRIC
)
50-446-OL COMPANY et al.
)
)
(Application for an (Comanche Peak Steam Electric
)
Operating License)
Station, Units 1 and 2)
)
)
l ANSWERS TO BOARD'S 14 QUESTIONS (Memo; Proposed Memo of April 14, 1986)
Regarding Action Plan _Results Report V.c In accordance with the Board's Memorandum; Proposed Memorandum and Order of April 14, 1986, the Applicants submit the answers of the Comanche Peak j
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 V.c, Design Consideration for P.iping Systems Between Seismic Category I and Non-Seismic Category I Buildings.
9709030078 B70823 PDR ADOCK 05000445 G
PDF; y
3)S s
1 s
t.
n..
l 1
l Opening Request:
Produce copies of any CPRT-generated checklists that were used during the conduct of the action plan.
)
l
Response
i No checklists were used during the conduct of this action plan.
Question:
1.
Describe the problem area's addressed in the report.
Prior to undertaking to address those areas through sampling, what did Applicants do to l
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?
l Response-I During its review, the TRT determined that certain piping systems were routed from the seismic category I electrical / control building to the non-seismic categcry I turbine building without seismic isolation.
In order to satisfy FSAR commitments, it is necessary that either such isolation be provided or that the effects of failure of attached non-seismic category I piping be considered in the design of the seismic category I piping.
In particular, for those lines passing into the turbine building, the effects of a turbine building failure connected with a seismic _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ -
event must be accounted for in the design of the J
connected seismic category I piping.
Sampling programs, generation of checklists, and j
reviews of QA/QC documentation were not performed for this action plan.
The problem arose because, at the time of the investigation, the existing documentation for the design of some of the piping between seismic Category I structures and non-seismic structures was l
1 not sufficient to assure that the effect of Turbine l
Building structural failure has been adequately addressed.
The extent of the problem and any required corrective activity are being determined by SWEC as l
part of the Piping Requalification Program.
Question:
j 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 used in this action plan.
Question:
l 3.
Explain any deviation of checklists from the i
inspection report documents initially used in inspecting the same attributes.
l j
l i
Response
I Not applicable by reason of response to Question 2.
Question:
4.
Explain the extent to which the checklists contain fewer attribu'.es than are required for conformance to codes to which Applicants are committed to conform.
Response
Not applicable by reason of response to Question 2.
l Quection:
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 tne plant) has not been degraded by using checklists that contain fewer attributes than are required for conformance to codes.
Response
Not applicable by reason of response to Question 2.
Question:
6.
Set forth any changes in checklists while they were in,use, including the dates of the changes.
i
Response
Not applicable by reason of response-to Question 2.
Question:
i 1
7.
Set forth the duration of training in the use of checklists and a summary of the content of that training, including field training or other practical training.
If the training has changed or retraining occurred, explain the reason for the changes or retraining and set forth changes in duration or content.
Response
Not applicable by reason of response to Question 2.
Question:
8.
Provide any information in Applicants' possession concerning the acct. racy 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 reliability addressed statistically?
Response
Not applicable by reason of response to Question i
2.
Question:
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 1 i l
i l
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
Not applicable by reason of response to Question 2.
Question:
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.
Response
No substantive modifications were made as a result of management action.
- Question, 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
It was determined early in ISAP V.c implementation that it woul'd be most reasonable to transfer implementation to the piping requalification program.
As such, there were limited activities associated with V.c implementation.
The a_____
area of difficulty which was encountered involved the identification of pipes with seismic /nen-s<eismic boundaries.
I It was intended that this list would be identified and included with the results report.
However, because the requalification program was resulting in modification to l
som'e stress problem boundaries, it was considered more l
i practical to also transfer this identification effort to the j
requalification program.
Overview of the identification effort and other associated activities will be performed as part of the TU Electric Quality Assurance Tehnical Audit j
)
Program.
J Question:
12.
Explain any ambiguities or open items left in the Results Report.
Response
l There are no ambiguities left in the Results Report; the major portion of the implementation activities have been l
l incorporated into the piping and supports requalification efforts.
Closure of those items will therefore occur with completion of the requalification program and overview of
~
the V.c aspects of the program by the TU Electric Quality l
i i
l 1
l J
1 1
I Assurance Technical Audit Program.
This process is i
addressed in the DSAP IX Results Report.
Question:
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 supervised.
l l
Response
l All the review /evaluttion activities were performed by third party individuals.
There were no conflicts of interest.
Question:
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
The Issue Coordinator, and others who aided in the preparation and approval of the Results Report, have i
i 1,
b
reviewed and checked the report for clarity and believe that there are no ambiguities.
)
I Respe ully eubmitted, j
l
~-."
UStr6et'er l
Action lan V.c Issue Coordinat c f
l 1
3 Mdkard Levin
'J l
Review Team Leader j
The foregoing responses have been reviewed and are concurred in by the.CPRT Senior Review Team.
l l
l i
k l l
i
'. : E :;
CERTIFICATE OF SERVICE
,87 Aug 24 gg;;,
I, R. K. Gad III, hereby certify that on August 20g:1987, out-I made service of " Answers to Board's 14 Questions (Memo; Proposed Memo of April 54, 1986) Regarding Action Plan Results Report V.c" by mailing copies thereof, postage prepaid, to:
d Peter B.
Bloch, Esquire Mr. James E.
CumP.ns Chairman Resident Inspector Administrative Judge Comanche Peak S.E.S.
Atomic Safety and Licensing c/o U.S. Nuclear Regulatory l
Board Commission U.S.
Nuclear Regulatory P.
O.
Box 38 Commission Glen Rose, Texas 76043 Washington, D.C.
20555 Dr. Walter H. Jordan Ms. Billie Pirner Garde Administrative Judge GAP-Midwest Office l
881 W. Outer Drive 104 E. Wisconsin Ave.
-B l
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 Lawrence J.
Chandler, Esquire Mrs. Juanita Ellis Office of the Executive President, CASE Legal Director 1426 S.
Polk Street U&S. Nuclear Regulatory Dallas, Texas 75224 Commission Washington, D.C.
20555 Renea Hicks, Esquire Ellen Ginsburg, Esquire l
Assistant Attorney General Atomic Safety and Licensing Environmental Prot'ection Division Board Panel P. O.
Box 12548 U.S. Nuclear Regulatory Capitol Station Commission Austin, Texas 78711 Washington, D.C.
20555 i
i
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 l
1 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 2121 N. California Blvd.
Suite 390 Walnut Creek, CA 94596
(-
/
.?
'N R.
K. Gad III l
9