ML20148K210

Answers to ASLB 14 Questions (Memo;Proposed Memo of 860414) Re Action Plan Results Rept VII.b.3.* Certificate of Svc Encl

ML20148K210
Person / Time
Site:	Comanche Peak
Issue date:	03/28/1988
From:	Hansel J, Tableriou J TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
References
CON-#188-5965 OL, NUDOCS 8803310038
Download: ML20148K210 (15)

Text

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t 00CKETED USNRC Filed: Mag h g pg1py[40 UNITED STATES OF AMERICA -

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NUCLEAR REGULATORY COMMISSION 0CM , - - -

before the ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of ) Docket Nos. 50-445-OL

) 50-446-OL TEXAS UTILITIES GENERATING )

COMPANY et al. )

) (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 VII.b.3 In accordance with the Board's Memorandum; Proposed Memo-randum 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 VII.b.3, "Pipe Support Inspections."

Opening Request:

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

Response

Three checklists in the form of Quality Instructions were developed and utilized during implementation of ISAP VII.b.3.

These are identified in Section 4.4 of the Results Report.

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Attached are copies of the checklists that summarize the requirements of the quality instructions.

These checklists were limited in purpose in that they were developed to aid in substantiation of TRT concerns.

The checklists were not part of a sampling effort.

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 problem area addressed by the ISAP VII.b.3 Results Report is evaluation of the TRT findings on pipe supports. The initial phase of the Action Plan sought to determine the extent and significance of the these findings. Third-party inspections were performed. (Sampling was not utilized in this Action Plan.) These investigations substantiated a number of TRT find-ings. Several of these led to recommendations for corrective action and implementation of such by the Project.

l A second issue in the TRT findings was consideration of the implications of findings on the quality of construction of pipe l

[ supports but not necessarily limited to the areas or activities

! selected by the TRT. In this respect, the Results Report for ISAP VII.b.3 is supplemented by the reinspections and findings in ISAP VII.c, Appendices 25, 26, and 27, which with this Results Report give a clear picture of the adequacy of i

l construction and generic implications of the findings.

l

The Project considered the pipe support problems extensive enough to lead to tho decision to implement the corrective actions, as well as a complete design review.

Question No. 2:

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

Response

Following is a list of quality instructions that were prepared to provide the necessary interpretations and understand-ings for each checklist:

QI-037 Reinspection of Pipe Supports TRT Issues -

Pipe Supports in Rm 77N, Safeguards Bldg.,

Unit 1/I-S-PS7N QI-058 Reinspection of Pipe Supports TRT Issues -

42 Pipe Supports /I-S-PS42 QI-061 Documentation Review of TRT Issues - 42 Pipe Supports /R-S-PS42 Question No. 3:

3. Explain any deviation of checklists from the inspection report documents initially used in inspecting the same attributes.

Response

This Action Plan examined a very specific scope of attri-l l

butes related to concerns identified by the TRT. Consequently, the checklists were not required to conform to explicit project j documentation but rather to substantiate identified concerns.

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

Attributes were limited to those inspected by the TRT.

Code requirements were included when the attribute reflected a specific Code requirement (e.g., locking devices for threaded fasteners).

However, in assessing the overall quality of construction, the Results Report for ISAP VII.b.3 is supplemented by ISAP VII.c, which inspected a random sample of more than 60 pipe supports for a full range of attributes and addressed applicable code requirements.

Question No. 5:

5. (Answer Question 5 onlv 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

Not applicable; see response to question 4 and Section 3 of the Results Report.

Question No. 6:

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

Response

Changes to checklists (Quality Instructions) while they were in use were accomplished by revision and reissuance of the

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Quality Instructions. In the revised instructions, changes were indicated by change bars on the affected page(s) of the docu-ment. Additionally, cover memoranda for revisions indicated the type of change, why it was made, and its effect on previous re-inspections. The date of each change was recorded on the appli-cable cover sheet, which accompanied the revision.

This documentation is located in the files supporting the ISAP VII.b.3 Results Report.

Question No. 7:

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 train-ing has changed or retraining occurred, explain the reason for the changes or retraining and set forth changes in duration or content.

Response

Before checklists were issued, they and their Quality Instructions were reviewed in detail with the inspection personnel assigned to the VII.b.3 inspection program. Before inspections began, each attribute was reviewed to determine how clear and easily understood it and the accept / reject criteria were. During use, checklists were sometimes revised for the purpose of further clarifying the particular inspection activity. Appropriate training was given for each change.

Thus, training was an ongoing activity while inspection was in l progress.

i 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 l

l

any time periods in which checklists were used with questionable training or QA/QC supervision? If applicable, are problems of inter-observer relisbility addressed statistically?

Response

The CPRT QOC group instituted an overview program of inspection that surveyed the inspectors. A portion of each inspector's work was reinspected by another inspector, similarly trained and instructed, using the same checklist, training, and instruction. This resulted in reliability data for each inspec-tor that was reviewed weekly by the QA/QC Review Team Leader.

Any significant change in the inspector's performance was noted, and corrective action was taken in a timely manner.

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

The audits and supervisory reviews performed were conducted 1

f by the ERC QA Department. The results are part of permanent file documentation for the CPRT and not part of Results Report

( files. Audit concerns were minor in nature and were resolved I

satisfactorily. The ERC QA files contain documentation of resolutions.

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.

Response

No substantive modifications were made to the Results Report as a 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 un-expected difficulties resolved?

Response

No unexpected difficulties were encountered during implementation of the Action Plan.

Question No. 12:

12. Explain any ambiguities or open items in the Results Report.

Response

No ambiguities or open items are left 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.

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Response

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.

No conflicts of interest existed.

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 discuesion gives rise to obvious questions, resolve the ambiguities and anticipate and resolve tha questions.

Response

The Issue Coordinators and others who aided in preparation and approval of the Results Report have reviewed and checked the report for clarity and believe no ambiguities exist.

Respectfully submitted, M LO '.

. . TalpleriQu Act'on Pian VII.b.3 ue Coordinator i _#/s L. Hansel eview Team Leader The CPRT Senior Review Team has reviewed the foregoing responses and concurs in them.

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Attachment 6.4 QI-OJ7 Rev. 2 Page 1 of 1 INSPECTION CHECKLIST COMANCHE FEAK RESPONSE TEAM CEECILIST

• FOFULATION DESC VERITICATION FEC Wo.

FIFE St*FFORTS 1-5-PS 7W FACE 1 0F ,,4,

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QUALITT INSTECCT10m QI-037 QREINSFECTION Q UNIT 1 EQUIPMnrf MA31/ TAC 30. C DOCtDGNTAT10W RDIEW [ Uutt 2 O co' wow TERIFTCAflog ACCIFT REJECT Dat'E 1 Identification 2 Fipe Clasp

• 3alves Parallel 3 Spherical Bearing Cap 4 $nubber Adapter Plate Bolt Thread Engagement tength

$ Fin & Rolt/ Stud Locting Device l

FREFARED ST AFF10TED 51:

DISCIFLINt ENCt. CATE LEAD DISCIFt1NE DeCt. DAT1 Lnt m u 31: AFFROTED BT l k n r h avu DATI LEAD IN5FICTCt Daft CFF-007.lA. Revision 0 i

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Attachment 6.1 COMK CHE PE.G RESPONSE TE.Oi QI-058 CHECXL*ST Rev. 4

?0P7LATION DESC VERIFICATION PKG NO.

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PAGE ! OT 2 QUALITY INSTRUCTION QI-058 REINSPECTION

[]} UNIT 1 EQUI? MENT MARK / TAG NO. DOCIMENTATION RIV!EW

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((] COMMON VERITICATION

^ EE AEES ACCEPT REJECT DATE Support l l 5.1) Identification i 5.1.1 Mark Number 5.1.2 Installed Components 5.2) Configuration 5.2.1 Components 5.2.2 Materials N/A N/A 5.2.3 Orientation 5.2.4 Installation 1

5.2.5 Offset 5.2.6 Clearances 5.3) Threaded Fasteners ,

5.3.1 Locking Device .

5.3.2 Tiahtness 5.3.3 Safety Wire 5.3.4 Record Markings N/A N/A 5.4) Welds 5.4.1 Location 5.4.2 Size 5.4.3 Reinforcement 5.4.4 Undercut 5.4.5 Cracks / Fusion 5.4.6 Surface 5.4.7 Welder ID N/A N/A 5.4.8 Offset PREPARED SY: APPROVED BY:

DISC!PLINE ENGR. DATE LEAD DISCI?LINE ENGR. DATE INSPECTED SY: APPROVED 3Y:

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COMASCHE ?!AX RESPONSE TEAM Attachment 6.1 CMECKL!ST QI-058 Rev. 4 POPULATION DESC VERIFICATION PKG NO.

PS42 PAGE __,pF 9 VERIFICATION AI AI ACCEPT REJECT DATE REMARKS 5.5) Pipe Clamps 5.5.1 Pipe Clamp Halves ,

Parallel 5.5.2 Record Dimension N/A N/A 5.6) Load Pin Locking Devices 5.6.1 Cotter Pins

5. 7) Spherical Bearing 5.7.1 Spacers 5.7.2 Record Spacers N/A N/A 5.7.3 cap 5.7.4 Contamination 5.8) Snubber Adapter Plate Bolt Thread Engagement

_5.8.1 Engagement length 5.8.2 Record Dimensions N/A N/n 5.9) Threaded Rod Thread Engagement 5.9.1 Engagement Length 5.10) Record Snubber Cold Set ,

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$ $ 28 P1 :40 before the CFVI CE 0; u ;

ATOMIC SAFETY AND LICENSING BOAR 8

)

In the Matter of ) Docket Nos. 50-445-OL

) 50-446-OL TEXAS UTILITIES ELECTRIC )

COMPANY et al. )

) (Application for an (Comanche Peak Steam Electric ) Operating License)

Station, Units 1 and 2) )

)

CERTIFICATE OF SERVICE I, Thomas A. Schmutz, hereby certify that the fore-going Applicants' Answers To Board's 14 Questions was served this 28th day of March 1988, by mailing copies thereof (unless otherwise indicated), first class mail, postage prepaid to:

• Peter B. Bloch, Esquire *B. Paul Cotter, Jr., Esq.

Chairman Chairman Atomic Safety and Licensing Atomic Safety and Licensing Board Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555

• Alan S. Rosenthal, Esq. Assistant Director for Chairman Inspection Programs Atomic Safety cnd Licensing Comanche Peak Project Division Appeal Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission P.O. Box 1029 Washington, D.C. 20555 Granbury, TX 76048 1

• / Asterisk indicates service by hand or overnight courier.

He

• Juanita Ellis Robert D. Martin President, CASE Regional Administrator, 1426 South Polk Street Region IV Dallas, TX 75224 U.S. Nuclear Regulatory Commission William R. Burchette, 3 squire 611 Ryan Plaza Drive Heron, Burchette, Ruckert, Suite 1000

.& Rothwell Arlington, Texas 76011 Suite 700 .

1025 Thomas Jefferson St., N.W. Dr. Kenneth A. McCollom Washington, D.C. 20007 Administrative Judge 1107 West Knapp

• William L. Clements Stillwater, Oklahoma 74075 Docketing & Service Branch U.S. Nuclear Regulatory Joseph Gallo, Esquire Commission Hopkins & Sutter Washington, D.C. 20555 Suite 1250 1050 Connecticut Avenue, N.W.

• Billie Pirner Garde Washington, D.C. 20036 Government Accountability Project *Janice E. Moore, Esquire Midwest Office Office of the General Counsel 104 E. Wisconsin Avenue - B U.S. Nuclear Regulatory Appleton, WI 54911-4897 Commission Washington, D.C. 20555 Susan M. Theisen, Esquire Assistant Attorney General

• Anthony Roisman, Esquire Attorney General of Texas 1401 New York Avenue, N.W.

Environmental Protection Division Suite 600 P.O. Box 12548 Washington, D.C. 20005 Austin, Texas 78711-1548 Lanny A. Sinkin Robert A. Jablon, Esquire Christic Institute Spiegel & McDiarmid 1324 North Capitol Street 1350 New York Avenue, N.W. Washington, D.C. 20002 Washington, D.C. 20005-4798 Nancy Williams

• Elizabeth B. Johnson CYGNA Energy Services, Inc.

Oak Ridge National Laboratory 2121 N. California Blvd.

P.O. Box X Building 3500 Suite 390 Oak Ridge, Tennessee 37830 Walnut Creek, CA 94596

• Dr. Walter H. Jordan David R. Pigott 881 West Outer Drive Orrick, Herrington & Sutcliffe Oak Ridge, Tennessee 37830 600 Montgomery Street San Francisco, CA 94111

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• Robert A. Wooldridge, Esquire Worsham, Forsythe, Sampels

& Wooldridge 2001 Bryan Tower, Suite 3200 Dallas, Texas 75201

• W. G. Counsil Executive Vice President Texas Utilities Electric .

Generating Division 400 N. Olive, L.B. 81 Dallas, Texas 75201 Thomas A. Schmutz (j Dated: March 28, 1988 l

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