ML20238E542
| ML20238E542 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 09/02/1987 |
| From: | Turi P TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| References | |
| CON-#387-4347 OL, NUDOCS 8709150056 | |
| Download: ML20238E542 (19) | |
Text
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,1 UNITED-STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the ATOMIC' SAFETY AND LICENSING BOARD
)
In the Matter of
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Docket Nos. 50-445-OL TEXAS UTILITIES ELECTRIC
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50-446-OL
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COMPANY et al.
)
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(Application for an (Comanche. Peak Steam Electric.
)
Operating License)
Station, Units 1 and 2)
)
)
ANSWERS'TO BOARD'S'14 QUESTIONS
'(Memo; Proposed Memo of April 14, 1986)
Regarding Action Plan Results Report II.c In accordance with the Board's Memorandum; Proposed Memorandum and Order of April 14, 1986, the Applicants submit the enswers of the Comanche Peak Response Team ("CPRT") to the 14 questions posed by the r
Board, with respect to the Results Report published by the CPRT in respect of CPRT Action Plan II.c, 1
Maintenance of Air Gap Between Concrete Structures.
8709150056 870902 hDR ADOCK 05000445'
.PDR,
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I Opening Request:
Produce copies of any.CPRT-generated checklists that were used during the conduct of the action plan.
Response
Two checklists were developedLand utilized during the implementation of ISAP II.c (see Attachment 1).
These were both limited purpose checklists intended to_
aid'in'the root cause evaluation associated with the technically incorrect disposition provided within NCR l-C-83-01067. 'The checklists were not part of a sampling-
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effort.
Question':
,1.
Describe the problem areas addressed.in-the
- report.
Prior to undertaking to address those aream 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?
Response
The problem area addressed by the ISAP Results Report is the adequacy of seismic building gaps.
The initial phase of the Action Plan sought to determine 1the. extent and significance of the presence of foreign material in the air gap between structures.
Project QC conducted the inspections with third-party overviewing
, a
the activity (sampling was not utilized in this Action Plan).
These investigations confirmed the existence of l
debris in the gaps as well as identifying instances where the as-built gap width was less than that specified by design.
The findings of these initial investigations led to the Project decision to implement corrective actions.
A second problem addressed by this report involves an instance in which TU Electric Civil Engineering closed out an NCR identifying debris and an
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undersized air gap with a technical analysis that did not address the applicable FSAR load case combination.
This led to the development and use of the checklists attached to thin response.
The seismic gap problems are believed to have occurred because of inadequate attention to the protection of the gaps during and after construction of adjacent walls, and inadequate post-pour inspection and verification of the as-built gap width.
The related NCR disposition is believed to be an isolated technical error on the part of the responsible engineer.
A review of QA/QC documentation revealed that the j
concrete placement inspection procedures, while i ]
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r requiring. pre-pour inspection for dimensions and
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protection from debris, did not include explicit requirements for a similar post-pour inspection.
It was further determined that there were-no procedural ~
requirements'for timely. resolution of open inspection items.
As stated above, the seismic gap problems were considered-by the Project to be extensive enough to lead to the decision to: implement corrective actions.
It was concluded that the NCR disposition was an
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isolated. error, with the possibility of any
. programmatic problems relative to NCR dispositions to be identified and corrected through a self initiated NCR review being conducted by the Project.
Question:
2 ~,
Provide any procedures or other internal documents that are necessary to' understand how j
the checklists should be interpreted or applied.
Response
4 The only checklists generated and utilized for this Action Plan related to a root cause. investigation concerning the technical adequacy of an NCR disposition (NCR C-83-lO67, Revision 0).
The first checklist (NCR I l 1
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Selection Checklist) was used to document the screening of NCRs provided by the Project.
The second checklist (Technical Adequacy Review Checklist)-documented the adequacy review applied to those NCRs containing technical justifications..
No procedure or instruction was prepared in association with the two checklists; the first checklist required no special training or judgment, only an observation of the content of the NCR, and the second checklist was used exclusively by an engineer with sufficient experience to make a judgment on the technical adequacy of the NCR disposition in question. is a summary of this investigation and provides a discussion of the use of the checklists.
Question:
3.
Explain any deviation of checklists from the inspection report documents initially used in inspecting the same attributes, f
Response
No Project activity was undertaken to perform this same review.
No comparisons can be made.
Question.
4.
Explain the extent to which the checklists j
contain fewer attributes than are required for 1
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1 conformance to1 codes to which Applicants are
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committed to conform..
Responses j
A Standard, applicable to the NCR' review is ANSI 45.2, Criterion'16 (See Attachment 1 for Background).
The focus of the review was the assessment of the technical adequacy of the dispositions provided on
-NCRs.
Accordingly, only the provisions related to l
- disposition categorization (i.e., use-as-is, repair, J
rowork,'and scrap) and the documentation verifying the acceptability of dispositions in the "use-as-is" or
" repair" categories.were of interest.
Other aspects of' the Standard are.not related to technical adequacy and therefore were not at-issue.
Question:
5.
(Answer question 5 only if the answer to. question
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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 by reason of the response to Question 4, i.e.,
the checklists focus on the assessment of the technical adequacy of the i
disposition provided on the NCRs, not on inspection l
attributes involving plant components.
The safety margins for components for the plant are not involved.
Question:
6.
Set forth any changes in checklists while they were in use, including the dates of the changes.
Response
No changes were made to the subject checklists.
Question:
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
No training was required for this review.
(The qualifications of the personnel involved in completing the checklists were sufficient, no additional training was necessary.)
Question:
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, i
I are problems of inter-observer reliability addressed statistically?
Response
'Both checklists, developed by the Issue Coordinator, were simple to use and applied to a very specific task.
The'first required no special training or judgment -- only an observation of the content of the NCR.
The second was used exclusively by an engineer with sufficient experience.to make a judgment on'the technical adequacy of the NCR disposition in question.
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 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
An audit was performed on the overall implementation of ISAP II.c.
An observation was made that the training records for the two SWRI inspectors were not present in the ISAP files, These personnel were not involved in any way with checklist activity and it was determined that no training requirements beyond the normal SWRI requirements !
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The audit observation was closed accordingly.
The audit was performed in accordance with established procedures.
Audit guidance is provided by the SRT in the Program Plan.
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 cr 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 to Results Report.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
No unexpected difficulties were encountered during the implementation of the Action Plan.
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4 Question:
- 12..
Explain any' ambiguities or open items left in the Results Report.
Response
There are no ambiguities left in the Results Report.
Ongoing activities that 'ill involve some degree of third-w party _ activity are defined in Section 7.0 of the.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.
Response
Activities not performed entirely by third-party.
personnel were closely monitored 1by third-party personnel to preclude potential bias resulting from possible conflicts of interest.
Project QC inspectors involved in.the gap investigation have not been involved with any previous (prior-to CPRT) gap inspections.
There were no conflicts of i
interest.
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J Question:
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14.
Examine the report to see that it adequately discloses i
the thinking and analysis used.
If the language is j
ambiguous or the discussion gives rise to obvious
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1
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1 I 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 reviewed and checked'the report for clarity and believe that there are no ambiguities.
Respectfully submitted, f/d W.
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Action Plan II.c Issuq Coordinator j
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Review Team Leader The foregoing responses have been reviewed and are concurred in by the CPRT Senior Review Team.
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ATTACHMENT 1 70: CPRT, FILE II.e.4c cc: Mark wells Dick Pages FROM: Peter Turi John Miller DATE: 5/20/86
SUBJECT:
NCR Investigation - Generic Implications Assessment To investigate the possibility that the individual who signed the subject NCR (C-83-1067) may be the source of a generic problem, all NCRs in a six month timeframe (three months on either side of the subject NCR date - 4/18/83) signed by this individual were reviewed for technical adequacy.
The Project was requested to provide copies of all NCRs signed by the individual during the sample period.
Upon receiving the copies, the third-party initiated its review.
This review was conducted in two steps:
1.
Screen NCRs to identify these where a technical adequacy review would be required, and 2,
Perform technical adequacy review.-
Step 1 required a review of each NCR package to determine if it, or a particular revision) was signed by the individual under study and was in the established timeframe.
Other aspects of the NCRs were also checked:
Is the disposition closed?
Disposition category (use-as-is, scrap, repair, rework)
The last screen applied in this step of the review was for whether a technical justification was provided on the NCR.
Attachment I provided background information for conducting this review.
This selection process was documented on the NCR Selection Checklist (Attachment II).
The second step involved a technical adequacy revicw of these NCRs that passed the screen in step 1.
This review (conducted by a DAP C/S engineer) evaluated each of the screened NCRs in three ways:
1.
Is the disposition adequately documented to allow for effective checking?
2.
Is the disposition technically correct?
3.
If Engineering is identified as the root cause of the nonconformance, have measures to prevent recurrence been defined?
The checklist for the technical adequacy review is included as 1
Attachaent III.
Twenty-two NCRs passed the screen (step 1) and were evaluated for technical adequacy.
The review found that each NCR disposition was adequately disposed of (see Attachaent IV).
Based on this conclusion, there appears'to be no generic concern associated with the individual who signed the subject NCR.
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BACKGROUND NCRs are ciready under review within the OA/QC Review Team (ISAP Vll.a.2),
but the technical odequacy of dispositions has been assigned to DAP for review.
l ANSI N45.2, Criterion 16, provides the following guidance in this oreo l
Nonconforming items may be disposed of by occeptance os-is, by scropping or repairing the defective item, or by rework to complete or correct to o drawing or specificotton.
Such measures shell provide assurance that the item is identified as nonconforming and controlled.
The measures shall require documentation verifying the acceptability'of nonconforming
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ltems which have the disposition of repcir Tir 'use os is.
A description of the change, wolver, or deviation that hos been accepted shall be documented to record the change and denote.
the os-built condition.
A more complete definition for each of the four types o' dispositions is os follows:
Scre: Discesition: Assigned when it is determined thct en item is unsuitcole for its intended purpose and cennot be fecsibly or economically reworked or repaired.
Rewerk Disposition: Assigned when actions are required to correct the nonconforming conditions and bring the offected items into comp!!ance with the speelfled de. sign requirements.
Reoctr Olsoosition:
Assigned when actions are required to repoir the nonconGrming condition to on occeptable state, not necessority in compliance with the existing design.
Repoir dispositions should include appropriate technical justificotton for acceptance of the item with chorocteristics that do not comply with specified design requirements.
Use As Is Disposition: Assigned when suf ficient technical justi-fication con be established such that the nonconforming choroc-teristics do not result in odverse conditions, and that the of fected item will continue to meet oil functional requirements Including performance, moIntoinobility, fit, and safety.
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.v NCR SELECTION CHECELIST ISAP IT,c 1.
NCR8_____________________________________ Revision #_________.
2.
Is NCR closed'(i.e., disposition final)?
~~~~~~~~~
~~~~~~--
If "No",
skip to S tep 5.
3.
Disposition category shown.on subject NCR.
._____ Scrap
_____,_ Rework
._____. Repair
___,_,,_Use as is 4.
'Does the NCR, or an NCR revision, signed by R. M. Kissinger contain a disposition which includes a' technical
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Justification?
________YES
_________NO 5.
Reviewed By:_____________________________Date:
RE*7"EWEB COMMENTS l
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.E TJ.C-2iICAL ADEOGC.f. RE'/IIN C-2CC.ISY i
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.1.
HCR i:
2.
Is the disposition adequately dce.=r:ted (sufficient referen:es cr I
e.glar.ation) to have allewd fer effe:.ive chac. king ar2 app = val?
Ye.s No If "No", prepart DIR.
3.-
Is the dispositive technie=y correct (i'.a., arit.5:rratic operatiens cor.act, rathcdolcgy scurd, aryatant consistant with licens!.ng ani design c=rzittrants, etc)?
Yes No If ' "Ne", prepJL:n DI2.
Ncte to revice:. If an alta=ata cale:latien er ary.= ant is preparsi, i.-Zicata in "Oc: rants: spaca belcw a.-4 a: =^. t: this c'.r..klist.
4.
I! t'.e =c: cr.:se ci tha v.c.c::.~.!:=a=:e i:xt:as a. T.gi..es ing e:=r, hrte r:eps been defi.ed t: preci'.:da ree.~:er.ca (p=__
atic/gs. erie e_ : rs) ?
N/A Yes No If "Nc", prepara DII.
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Review.r's Ccmrants:
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A T r k d H c4 i*
TENF.RA Q CORPORmON (To C t,sf$
MEMORANDUM
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To: Peter'Nri ca;1: 5-12-36 77.o.e D. Pages COPUL5To: Issue IIc
. st sJc: Results of Pevice of 22 los In order to perfom the re/ies I was required to 1.w4-doc' rents at t'.e Dec' :wne Contrcl Center, the CA Precedures File Poem,'the Occ::rert Vault and the " Damage Evaluation" Group. In all but one case, a ref-
- erenced " traveler file" was not in t.% vault but was still with the reference equipnent, all files were readily available and contained the material refere.x:ed to support the NCR.
a Of the 22 NC'Rs,13 were unquestionably correct both in doctanentation l
and in technical' disposition. Of the rarnaining, 6 did not appear to
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provide adequate dec.anentation, but did not 'W-to imolve techni-
- cal issues which eight have safety sig.ifier.co. Three of the NCRs-do net, in af cpLa. ion, c:ntain enough infezzatien to fully justiff
- em technical de-ision made. Ecurver, upcn revies of these docma.ta with 'ItECO Engineering it was detamined that in one case the Engireer
, miredars-d the cuestien and'the preper response was made upon re-rdinittal ard that in e4 other te cases the preblect was either in
- a mire.dars a.-Zir.g cf the. field situatica by the inspe:::r# tother l
deere. s clearly i-dicated t'4 jus ifica**
- -- the todr.ical de-cisien.
I wculd s=arire m decisiens were jus y revies by sayi.g t*.at in all cases the tede.ical ified by existir.g decraents.
I believe the cnly I
criticisn, which is definitaly hi..dsight, is that nere t'creugh dccu-
. er.u i n 'culd be~ ef assis a.ca t: 6:ure revie.eers a*.thcugh in all cases of technical significance reference dee.:ments could be fou-4.
Attached are copies of the 22 E2's that were revie.ed, the revive l
checklists, with pertinent notas and reference decrents.
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'M' CERTIFICATE OF SERVICE I, R. K. Gad III, hereby certify that on Septembg j P -8 P3 :08 1987, I made service of " Answers to Board's 14 Questions-(Memo; Duuni
,a Proposed Memo of April 14, 1986) Regarding Action Plan ResNlts Report II.c" by mailing copies thereof, postage prepaid, to:
Peter B.
Bloch, Esquire Mr. James E.
Cummins Chairman Resident Inspector Administrative Judge Comanche 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.
205b5 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 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 Assistant Attorney General Atomic Safety and Licensing Environmental Protection Division Board Panel l
P.
O.
Box 12548 U.S.
Nuclear Regulatory Capitol Station Commission Austin, Texas 78711 Washington, D.C.
20555
1 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 j
Dr. Kenneth A. McCollom Mr. Robert D. Martin Administrative Judge Regional Administrator i
1107 West Knapp Region IV Stillwater, Oklahoma 74075 U.S.
Nuclear Regulatory Commission Suite 1000 l
611 Ryan Plaza Drive Arlington, Texas 76011 Elizabeth B. Johnson Geary S. Mizuno, Esquire Administrative Judge
. Office of the Executive I
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 l
Nancy H._ Williams 2121 N.
California Blvd.
Suite 390 Walnut Creek, CA 94596 a
s R.
K. Gag III l
I I
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