ML20203P051

Submits Response to ASLB 860414 Proposed Memorandum & Order Posing 14 Questions Re Action Plan Ii.B.Certificate of Svc Encl

ML20203P051
Person / Time
Site:	Comanche Peak
Issue date:	10/10/1986
From:	Levin H, Webster F TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Atomic Safety and Licensing Board Panel
References
CON-#486-1092 OL, NUDOCS 8610200212
Download: ML20203P051 (16)

Text

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/ O h 1-Filed:

Octob r-10, 1986 00CKETED USNRC 16 BCT 15 P1 :12 GFDCJ :

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T l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of

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Docke t 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.b In accordance with the Board's Memorandum; Proposed Memorandum and Order of April 14, 1986, the Applicants submit the answers of the Comanche Peck 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 II.b.

s 8610200212 861010 PDR ADOCK 05000445 G

PDR 33c3

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First Request:

Produce copies of any CPRT-generated checklists that were used during the conduct of the action plan.

Response

A traveler was utilized wnich stipulated concrete preparation, testing,-and restoration.

A blank copy is included; copies with actual data are in the working files.

Questioni 1.

Describe the problem areas addressed in the report.

Prior to undertaking to addre'ss those areas 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?

Answer:

This Action Plan was prepared in response to a specific technical concern raised by the TRT.

The TRT investigated allegations that. concrete records had been falsified during the period January 1976 to February 1977, by reviewing other tests and by interviewing allegers.

The NRC staff concluded that "the uniformity of concrete placed appears to minimize the likelihood i

that low concrete strengths were obtained."

However, because resolution of this and other allegations depend !

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on the concrete strength tests, the NRC directed the.

Applicant to conduct tests to investigate concrete strength on a sampling basis.

These tests were to be conducted on concrete placed during the January 1976 -

February 1977, time frame.

To provide a relative strength comparison, tests were also conducted on concrete placed during-the six month period following the period in question.

Details of the plan and results are set forth in the Results Report.

QA/QC documentation in the form of pour cards were reviewed to identify the location of concrete poured during the period of interest.

Test cylinder data sheets were then reviewed to identify the

-recorded strength of concrete in those pours.

Comparison of this data and the surface hardness tests conducted under this action plan lead to the conclusion that no systematic falsification occurred.

Question:

2.

Provide any procedures or other internal documents that are necessary to understand how the checklists should be interpreted or applied.

Answer:

The traveler is self-explanatory in stipulating those activities to be done in the field in preparation........... _. ~..

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'for and. surface testfitg of the concrete.

ASTM C805-79, the test performed as part of the' traveler, is a procedure to.be followed in determining concrete b

hardness.and is not a checklist.

The results report describes the test and how it was used in support of this ISAP.

No other documents are.necessary.

Question:

3.

[ Original acceptance checklists.

See_ Transcript of_the' Pre-Hearing Conference of April 22, 1986, at 24,-353-57.]

Answer:

Although neither pour cards or cylinder test-records ~are. checklists, we have attached a blank' copy

'of each.

These illustrate the-records that were alleged to be falsified.

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Question:

I 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.

Answer:

i.

For the tests conducted, all' required attributes are addressed.

F,

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e Question:

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.

Answer:

Not applicable; the answer in 4 above does not indicate that CPRT documents contain fewer attributes than original checklists.

Question:

6.

Set forth any changes in checklists while.they were in use,. including the dates of the changes.

Answer:

The documents used did not change ~during the period in question.

Question:

7.

Set forth the duration of training in the use of checklists and a summary of the content of that l

training, including field training or other i

practical training.

If the training ha's changed l

or re' training occurred, explain the reason for the changes or retraining and set forth changes j

in duration or content.

' Answer:

l The traveJer requires of the craft participants i

no skills or judgment that need training (beyond what t

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.a they are normally trained and expected to perform routinely) except performing the-hardness tests.

For the hardness test itself, the Southwest Research Institute personnel received thorough training, consisting of a four hour course in which they performed the hardness test, dismantled and reassembled the test device, and performed the hardness test on a test anvil.

Training records are in the working file.

Question:

8.

Provide any information in Applicants' possession

-concerning the accuracy of use of the checklists i

(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?

Answer:

In a number of cases the SWBI personnel ver'ified

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that the correct sample location had been identified.

The SWRI personnel also verified that surface conditions met traveler requirements, thereby constituting a check of the preparation.

QA/QC sign-offs were required prior to restoration of the test

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area.

Therefore, we feel that training and supervision i ;

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were at all tires adequate.

Inter-observer reliability

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was not addressed statistically.

Question:

9.

Summarize all audits or supervisory reviews (including reviews by employees or consultants) of training er 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.

Answer:

Evaluation Research Corporation (ERC) reviewed the qualifications and training of the SWRI personnel

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and found them catisfactory' for the tasks performed.

No other evaluation or audit was performed.

Questioni 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 er 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 received.

Answer:

Dr. Webster, the Issue Coordinator for this plan, could not recall any instance cf substantive or ;

P-'t-g-important modification in the 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?

Answer:

The project was tasked with identifying all 3

accessible category I concrete poured.during the 13 month period of interest and in the control period (i.e.,

the subsequent 6 month period).

During this activity, the third party review team overviewed the calculations used to make these determinations and disagreed in some cases.

After discussion and review, it'was determined that about 20 to 30% of the concrete volume (i.e., truckloads of concrete) had not been identified or had been improperly identified.

As i

indicated in the Results Report and supported in the Results Report files, the reasons for this discrepancy 4

were arithmetic, accessibility determinations, and volume modeling assumptions. 4 1

To complete the truckload population determination, an attempt was made to identify all previously unidentified truckloads, and a proportional sample was selected.from those additional truckloads identified.

This augmented sample was then added to the original sample.

The resulting evaluation of the hammer data (presented in the II.b Results Report) included 119 data points for the Concrete At Issue (CAI) and 132 for the Control Concrete (CC).

The added data did not change the conclusion that the CAI hammer indication is within 5 percent of the CC hammer indication at the tenth percentile level.

A final verification of the truckload population was made by the third party.

As indicated in the results report a small percentage of the truckload population was determined to be in error, either over -

or under - estimated.

If the truckload population could have been completely determined an addit;.onal seven samples for the CAI population and two samples from the CC population would have been taken.

Based upon the previous results, a decision was made not to take these additional samples.

If these additional samples were randomly selected from the remaining

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,r truckloads excluded, these tests v$ lues would likely be dispersed among other data (as was observed ~during the effort. described above.)

Therefore, the distributions of the data would be changed very little, and the conclusionc not at all.

Question:

12.

Explain any ambiguities or open items left in the results report.

Answer:

There are no open items, and, to the best of our knowledge, no ambiguities.

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

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of the review or evaluation of his own work or the work of those he previously. supervised.

Answer:

No conflict of interest on the part of third-party personnel exist as far as.the RTL can determine.

This subject is expressly discussed and explored in a general sense when CPRT n. embers are brought on board.

Activities not performed entirely by third-party personnel were closely monitored by third-party..

personnel to preclude potential bias resulting from possible conflicts of interest.

Question:

14.

Examine the report to see that it adequately discloses the thinking and analysis used.

If the language io ambiguouc or the diccuccion givec rise to obvious questions, resolve the

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ambiguities and anticipate and resolve the questions.

Answer:

t Dr. Webster has reviewed the report p. gain and believes it to be clear and unambiguous.

No questions, obvious or otherwise, are apparent at this time.

Respectfully submitted, A

'D r. Ef ed' Webstef A tion Plan II.b Issue Coordinator ew ~)

HbwarH A. Levin' V Civil / Structural Review Tean Leader The foregeing responses have been reviewed and are concurred.in by the CPRT Senior Review Team. ** TOTAL PAGE.04 **

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@SFE~.J:cCJCiG.:N3 R.Sv2 below f See below PRE?t.RC 3'r CATE CEp-CE i

REVIE'#C Tf CATE AN I REVIE'N _

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CONST"5! f,NG.

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This Traveler is written to comply with NRC-TRT Issue Number II b.

1.

CE Location of area to be tested.

2.

BD Prepare are for testing per ASTM C805-79 as follows:

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a) Remove 2" topping by sawing and/or chipping concrete.

(N/A t'-is step if not applicable)

SRI b) Chip concrete using Bush Hammer to a minimum of 1/4" (y) uniform depth.

c) Apply Chip-Mate Tool in order to remove surface irregularities.

d) Grind concrete surface using Carborundum Abrasive

, Stone until. smooth.

3.

SRI Perform Test per ASTM C805-79.

l Test Report Number 4.

BD Repair concrete surface per CCp 12.

QC IR#

(V)

QC to verify per QI-QP-11.05 R.

5.

PAINT

' Replace coating to original c6ndition Per AS-30 and AS-31 NOTE:

In Containment Building where coatings are i

applied, a coating operational traveler shall be issued.

TRAVELER NUMBER 6.

CE Return to Civil Engineering to verify completion of Traveler.

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DATE CE?007 ON COMPRESSIVE TESTS OF CONCRETE PROCEDURE _

COM*iETE Y#

H OCA TOTAL WATER /BAMH M F WG 2

DATA...S. ~.

Les LeS Le$,

Les LBs A

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FROM BATCH CEMENT / Cu VC-H2C A00E0 H 0/ CEMENT RATIO AlR CU YC.

TOTAL Aim SPECIFIED DEStGN STRENGTH 2

TICKET LES G A-02.

OZ PS.

DAYS E4 MAND OF CEhENT TYPE OF CEMENT BRAND OF AIR 'ENTR AINING ADM;XTURE BRAND OF WATER REDUCING ADMIXTURE MAY SIZE C A k

Ewy SOURCE CA 58 GS CA SOURCE F. A.

SP. GR. FA FINENESS MODULES F. A.

2 TYPE OF M xlNG EATCH LCA:

TICFET NC.

$ AMPLE TAKEN AT:

O CENTRAt MirER ROAMS O POINT or oiSCHARoE CY g

METHOD OF PLACINS Ps M P BuCXET f3TE SAMPLED HOUR WEATHER AIR TEMP.

CONC. TEMP.

SLUMD AM BUGGIES BELT O CHUTE

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TIME OF MixtNG AT UNIT WT. CU. FT WIX 10 SPECIMEN TAMEN BY SPEOMEN CAST BY AIR CENTR AL PL ANT g,y LBS l CAPPED CYLINDER 10 WEASJEEO AVG DA CATE TIME DATE MAX. LOAD COasmES3vt TYM OF g

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DA IN IN CAppE D BY TESTED TESTED LB STRENGTH ev ev BREAK i

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sWw DATZ 8 TIME STR'PoE : REMARxS AM:

PM !

CURIN G CONTROL TEST RESULTS FOR 28 DAY BREAK L A B AG AT ORY CURED Cvif NDEE $1 FIELD CUREC CYL'NOE8G STREh37H (PS 1)

(C)

STRENGTH ( P.S I )

(Ci fd) f b:

1 (c u(b) - (C)+ (do 2.

(0) + (b) + 2 -

• NOTE

(!) ABO E MJST BE EQJA. TO OR GREATER THAN 0 85; OR (2) ABOVE NEEC NOT EXCEED THE DESIGN STRENGTH 8Y MORE THAN 500 PSI EVEN THOUGH THE C.85 CRITERION IS NOT MET WiCECVETEa OR Ca lPER S NO w

COM PR E S SION MadH;NE NO T DAY RE M ED BY CHECKED BY CA* PING MOLD NO 28 DAY PREPARED BY CHECKED BY DE M N > 0 NLLillMMECi f1 AFPMAC F' FORM ll f-41 TUGCO LAB SUPERVISOR s.

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p,.} 3 3 ;; / f;& Q

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[SWRA l~_*

- C8s s P gg Taftes C

N POUR RD QATE OF POUR:

POUR NUMBER:

ESTIMATED CONCRETE QTY' DESCRIPTION (IF NECESSARY):

FINISHED REQUIRED:

ITEM CRAFT SUPERVISOR OATE ENGINEERING OAT!

OESIGN MIX I.O. NO.

XXXXXXXXXXXXXXXX LINE & GRADE XXXXXXXXXXXXXXXI PORMS 4

RESAR f-EMBt03 CADWELDS M

r PIPING SLE!VES V

EMBEDED 8IPE ELECTRICAL i

CLEANLINESS T I M

3 IMSTRUMENTATION SLYS.

CPP PROJECT CIVIL ENGINEER:

ELECTRICAL Q.C.

MECHANICAL Q.C.

CIVIL Q.C.

The following notes apply to non-Q placements other than the turbine and switchgear buildings.

1.

Concrete field testing to be per each six 10, daily only.

CIVIL ENGINEER CATI 2.

For less than 50 cubic yards of six ID per day, strength, slu:r.p. air content, unit weight, and temperature tests are waived.

CIVIL ENGINEER DATE l

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DOCxrrtp USmsc CERTIFICATE OF SERVICE 16 0CT 15 P1:12 GFFICE ct 9.

I, Robert K. Gad III, one of the attorneys for the0A 1plac;a,rd. y' '

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BRANCH herein, hereby certify that on October 10, 1986, I made service of the within " Answers to Board's 14 Questions (Memo; Proposed Memo-of April 14, 1986).Regarding Act, ion Plan Results Report II.b" by mailing copies thereof, postage prepaid, to:

Peter B.

Bloch, Esquire Mr. Thomas F. Westerman Chairman Comanche Peak S.E.S.

Administrative Judge c/o U.S.

Nuclear Regulatory Atomic Safety and Lice ~nsing-Commission Board P.O.

Box 38 U.S.

Nuclear Regulatory Glen Rose, Texas 76043-o Commission Washington, D.C.

20555 Dr. Walter H.

Jordan Mr. William L.

Clements Administrative Judge Docketing & Ser7 ices Branch 881 W.

Outer Drive U.S. Nuclear Regulatory Commission Oak Ridge, Tennessee 37830 Washington, D.C.

20555 Chairman Chairman Atemic 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

.Stuart A.

Treby, Esquire Mrs. Juanita Ellis Office of the Executive President, CASE i

Legal Director 1426 S.

Polk Street U.S.

Nuclear Regulatory Dallas,. Texas 75224-Commission l

Washington, D.C.

20555 l

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4 Renea Hicks, Esquire Ellen Ginsberg, Esquire Assistant Attorney General Atomic Safety and Licensing Environmental Protection-Division Board Panel P.O.

Box 12548, Capitol Station U.S.

Nuclear Regulatory Commission Austin, Texas 78711 Washington, D.C.

20555 Anthony Roisman, Esquire Mr. Lanny A.

Sinkin

~ Executive Director Christic Institute Trial Lawyers for Public Justice 1324 North Capitol Street 2000 P Street, N.W., Suite' 611 Washington, D.C.

20002 Washington, D.C.

20036 Dr. Kenneth A.

McColl'om 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

Ms. Billie Pirner Garde Geary S.

Mizuno, Esq.

Midwest Office Office ~of the Executive 3424 N.'Marcos Lane Legal Director

' Appleton, WI 54911 U.S.

Nuclear Regulatory Commission Maryland National Bank Bldg.

Room 10105 7735 Old Georgetown Road

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Bethesda, Maryland 20814 Elizabeth B.

Johnson Administrative Judge Oak Ridge National' Laboratory P.O.

Box X, Building 3500 Oak. Ridge, Tennessee 37830 l

l Nancy Williams l

Cygna Energy Services, Inc.

101 California Street l

Suite 1000-l San Francisco, California 94111 he

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- g.!_

Robert K.

Gyd III 1

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