ML20214W028

Answer to Aslab 860414 Proposed Memorandum & Order Questions Re Results Rept on Comanche Peak Response Team Action Plan III.a.4.Certificate of Svc Encl

ML20214W028
Person / Time
Site:	Comanche Peak
Issue date:	12/05/1986
From:	Broad T, Rushwick J TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Atomic Safety and Licensing Board Panel
References
CON-#486-1819 OL, NUDOCS 8612100054
Download: ML20214W028 (11)

Text

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/s/9 DOC KE TED U5NPC T6 00: -8 P4 :49 (Fr 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) )

)

ANSWERS TO BOARD'S 14 QUESTIONS (Memo; Proposed Memo of April 14, 1986)

Regarding Action Plan Results Report III.a.4 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.4.

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Opening Request:

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

The CPRT generated the one attached checklist.

Question:

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 discover about the QA/QC documentation for those areas?

How extensive did it believe the problems were?

Answer:

The NRC-TRT requested that information relating temperature monitoring locations to specific temperature measuring devices be added to the 1CP-PT-55-11, " Thermal Expansion," preoperational test data package. The NRC-TRT also requested that administrative controls be established to assure measuring and test equipment (M&TE) traceability compliance during future testing and plant operations.

The CPRT Third-party examined TUGCO's compliance with these requests.

In order to comply with the NRC-TRT request, all procedures which would establish compliance with the

6 M&TE. traceability requirement for future testing and plant operation.were reviewed by the CPRT.

The problem arose because testing personnel had not recorded the data required by the test procedure in the format required by the test procedure _at the time the temperature measuring devices were checked out from TUGCO's I&C shop. When the NRC-TRT reviewed the test data package, verbatim compliance with the Startup f

Administrative Procedures had not been achieved. I The CPRT reviewed the actual documents used by Startup and Operations personnel, not QA/QC documentation.

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Question:

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

l Answers l

The checklist was self-explanatory,:and no additional procedures or documents were prepared.

Question: '

l 3. Explain any deviation of checklists from the ,

l inspection report documents initially used in inspecting the same attributes.

l Answer:

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a There were no. checklists of the type used to perform a similar document review prior to the CPRT review.

Question:

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:

The checklist was developed to incorporate codes and standards, and is a record of the documents reviewed for proper compliance. Therefore, by design, the checklists do not contain fewer attributes than are required for conformance to codes and standards.

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:

The question is not applicable due to the answer to question 4.

Question:

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

Answer:

There were no changes in the checklist.

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.

Answer:

No training was required. The Issue Coordinator and Review Team Leader created and used the checklists, therefore they did not require training.

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, are problems of inter-observer reliability addressed statistically?

Answer:

The checklicts were used by the Issue Coordinator and Review Team Leader for the document review; therefore, inter-observer reliability was not an issue.

Question:

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9. Summarize all audits or supervisory reviews (including reviews by employaes 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.

Answer:

l The Review Team Leader and Issue Coordinator l

developed the checklist prior to implementation and l subsequently reviewed the results. No other audits or l reviews were conducted'.

Question:

l l 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.

Answer:

No draft results reports were modified in an I

important substantive way as the 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:

There were no difficulties encountered in performing the work.

Question:

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

Answer:

There are no open items, and the Review Team believes no ambiguities exist.

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.

Answer:

Mr. Rushwick has had a previous involvement with the TUGC0 startup organisation. The involvement 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 was employed by EDS Nuclear Inc. in San i

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j. Francisco. From 1975 until 1978, the nature of his l

l involvement with the TUGCo startup group consisted of l general contract administration, general employee

l. related administration, and the assignment of personnel i

for the startup program. Mr. Rushwick was responsible for Mr. R. E. Camp's assignment as the Lead Startup 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 j in the startup program other than as stated above.

t l Mr. Rushwick is now self-employed and in no way I

( obligated to the corporate entities involved prior to 1978 in marketing the program to TUGCO.

Mr. Broad has had a previous involvement with TUGCO. This involvement is discussed in the objectivity evaluation in the action 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 of programs and procedures i,

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-3  :.:. 3 E , hh in the area 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.

Question

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14. Examine the report to see that it adequately discloses the thinking and analysis used. If the language is ambiguous or the discuselon gives rise to obvious questions, resolve the ambiguities and anticipate and resolve the questions.

Answer The Review Team has examined the report an4 believes there are no ambiguities or obvious questions.

Respectful y submitted Thomas Broad N Action Plan !!!.a.4 !ssue Coordinator

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',Jamos E. RushwicM _

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! Testing Review Team Leader The foregoing responses have been reviewed and are concurred in by the CPRT Senior Review Team.

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i f l CERTIFICATE OF SERVICE I, Kathryn A. Selleck, one of the attorneys f t hidEts herein, hereby certify that on December 5, 1986,hk$agelserviceof nn;y,j P Vid j the within " Answers to Board's 14 Questions (Memo; Proposed Memo of l

April 14, 1986) Regarding Action Plan Results Report III.a.4", by j mailing copies thereof, postage prepaid, to:

i Peter B. Bloch, Esquire Mr. James E. Cummins Chairman Resident Inspector Administrative Judge Comanche Peak S.E.S.

i Atomic Safety and Licensing c/o U.S. Nuclear Regulatory i Board Commission U.S. Nuclear Regulatory P.O. Box 38 Commission Glen Rose, Texas 76043 Washington, D.C. 20555 Dr. Walter H. Jordan Nancy Williams Administrative Judge Cygna Energy Services, Inc.

' 881 W. Outer Drive 101 California Street, Suite 1000 Oak Ridge, Tennessee 37830 San Francisco, California 94111 Chairman Chairman l Atomic Safety and Licensing Atomic Safety and Licensing i

Appeal Panel Board Panel l U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission l

Commission Washington, D.C. 20555 Washington, D.C. 20555 Stuart A. Treby, Esquire Mrs. Juanita Ellis Office of the Executive President, CASE

Legal Director 1426 S. Polk Street

, U.S. Nuclear Regulatory Dallas, Texas 75224 l Commission 7735 Old Georgetown Road Room 10117 l Bethesda, Maryland 20814 l

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,,,- 7 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 Joseph Gallo, Esquire Executive Director Isham, Lincoln & Beale Trial Lawyers for Public Justice 1120 Connecticut Avenue, N.W. il 2000 P Street, N.W., Suite 611 Suite 840 '

Washington, D.C. 20036 Washington, D.C. -20036 Dr. Kenneth A. McCollom Mr.. Lanny A. Sinkin Administrative Judge Christic Institute 1107 West Knapp 1324 North Capitol Street Stillwater, Oklahoma 74075 Washington, D.C. 20002 j' >

Ms. Billie Pirner Garde Midwest Office Mr. Robert D. Martin Regional Administrator,

/t 3424 N. Marcos Lane Region IV Appleton, WI 54911 U.S. Nuclear Regulatory Commission ,j Suite 1000 611 Ryan Plaza Drive Arlington, Texas 76011 l

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 Commission Oak Ridge, Tennessee 37830 Maryland National Bank J31dg.

Room 10105 7735 Old Georgetown Road Bethesda, Maryla'id 20814 f4  ;

Kathryn A. Selleck l

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