ML20011E429
| ML20011E429 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/30/1990 |
| From: | Miraglia F NRC |
| To: | Murley T Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20011D121 | List:
|
| References | |
| NUDOCS 9002140015 | |
| Download: ML20011E429 (5) | |
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January 30, 1999
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MEMORANDUM FOR:
Thomas E. Murley, Director Office of Nuclear Reactor Regulation l
t FROM:
Frank J. Miraglia, Chairman CPO Review Panel on Comanche Peak
SUBJECT:
ANONYMOUS DIFFERING PROFESSIONAL OPINION (DPO) ON COMANCHE PEAK On October 10, 1989, a DP0 Review Panel was established at your direction to review a memorandum from anonymous NRC staff inspectors to the Chaiman dated October 4,1989 (Enclosure 1). The anonymous memorandum asserts that the Comanche Peak draf t SALP report is neither factual nor complete, and implies that the draft SALP report was edited to exclude or minimize nega-tive findings. Although the memorandum does not contain all of the necessary elements of a DP0 as specified in NRC Manual Chapter (MC) 4125, " Differing Professional Views or Opinions," it was handled as a DP0 in accordance with NRR Office letter No. 300, Revision 1, and MC 4125.
e This memorandum summarizes the activities completed by the DP0 Revie 'anel and provides our recommendations regarding the subject DPO. The DPD Review Panel consisted of James H. Sniezek, James G. Partlow, and myself. The panel was assisted by William D. Travers, Ralph E. Architzel, and Loren R. Plisco.
The objectives of.the DP0 Review Panel were to detemine if the Comanche Peak SALP process had been conducted in accordance with agency guidance in NRC t
Manual Chapter 0516. " Systematic Assessment of Licensee Performance," and whether factual information had been manipulated or excluded from the draft report in a manner that altered the conclusions regarding Texas Utilities' (TV) performance.
In addition, specific concerns about the SALP process and draft SALP report which were discussed in the anonymous memorandum and in a letter from Ms. Billie Pirner Garde, dated November 20,1989(Enclosure 2),
were reviewed and considered by the panel in arriving at it's conclusions.
The DP0 Review Panel met seven times during the review process, and a listing of the meetings is provided in Enclosure 3.
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In order to determine if factual information or views on performance had been
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manipulated or excluded from the draft report, J. Snierek initiated a special independent review of the specific differences between the various draft SALP reports and certain inspection reports (Enclosure 4). The special review was conducted to (1) determine the differences in the description of perfomance between the draft and final reports, and (2) determine whether there was a reasonable basis for such differences and whether the differences had any prac-tical safety significance. The independent review was conducted by W. Travers and R. Architzel and was provided to the review panel by J. Sniezek on December 20, 1989 (Enclosure 5).
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1 In addition, D. Crutchfield. Associate Director for Special Projects, con-ducted a survey of the NRC staff involved in inspection activities related to Comanche Peal to solicit coments on the draf t SALP report (Enclosure C).
The survey was initiated on October 10, 1989, prior to the establishment of the DP0 Review Panel. The results of the survey were provided to.the panel for use in the review (Enclosures 7, 8, and 9).
The special independent review of the draft SALP reports conducted by W. Travers and R. Architzel concluded that the changes made to the draf t SALP report, generally, did not significantly alter the characterization of the applicant's performance during the assessment period. While there were numerous changes to the draft SALP report (both positive and negative) re-garding the utilities' performance during the process, many were editorial and most changes appear to be insignificant in the context of the evaluation.
Although some negative discussions were rephrased, abbreviated, relocated, expanded or added, the impact of most of these changes was not significant to the evaluation presented in the report.
The changes which occurred to the draft were typical of the evolutionary process associated with the development The special independent review did identify, however, that of a SALP report.
in two functional areas. Engineering and Technical Support and Plant Operations, a few of the changes appeared to have a potentially significant impact in the characteri26 tion of the utilities' performance. The special report submitted to the panel recomended that these areas be reviewed further.
Since the reasons for the changes to the Engineering and Technical Support and Plant Operations functional areas were not apparent during review of the draft reports, the basis for the changes were evaluated by the panel during subsequent discussions with the two lead site inspectors and two additional SALP Board members. The panel concluded that the changes were properly evaluated and justified.
In addition, the actual report changes were written by the drafters of the original SALP report input.
As discussed above, the panel met with selected SALP Board members on January 4, 1990. The review panel considered interviewing all of the SALP Board members, but decided to interview the Board Chainnan and the site inspection staff l
members on the Board since they could provide the most in-depth discussion of the entire SALP process.
In addition to discussing the evolution of the SALP report, the panel also reviewed the SALP procedures with the Board members to determine if the process had been conducted in accordance with agency guidance, The primary emphasis of the discussions involved the SALP Board composition, c
l development of the SALP report inputs, conduct of the SALP Board meeting, and the history of the SALP process at Comanche Peak. The panel again reviewed the results of the survey of inspection personnel when reaching its conclusions concerning the SALP report process. During the discussions with the SALP Board members, the panel reviewed the three specific examples cited in the i
l-anonymous letter:
f "1.
The SALP Board did not adequately consider the full implications of certain ASME issues identified during reporting period by staff inspectors.
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-2.
The SALP Boari did not adequately ' consider the inability of the applicant _to recognize conditions potentially or actually adverse to quality as demonstrated by events surrounding service water system and the auxiliary. feedwater system (check valves and motors).
3.
The SALP Board did not adequately consider the inability'of the applicant to. identify and evaluate root causes of the deficiencies and program failures necessary for effective r,orrective actions."
'In each case, the panel found that the SALP Board adequately considered
.the findings identified during the SALP period when reaching their conclusions.
The panel.found that the SALP procedures followed by the Comanche Peak SALP Board clearly met the intent of the SALP MC 0516.- The SALP Board composition
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was not exactly as specified by title in the MC, but after careful review, the panel determined that the Board members were in equivalent positions when con-sidering the unique organization of the Comanche Peak Project Division.
In fact, since the Comanche Peak Project Division is specifically concerned with I
the activities of.this one project, seven of the ten Board members were from the. Comanche Peak Project Division and were uniquely qualified to be SALP Board members because of their active participation in the NRC activities at Comanche Peak.
During the interview of the selected SALP Board members, it was determined that an observer, R. Ramirez, from the Perfomance and Quality Evaluation Branch (POEB), NRR, was present during the SALP. Board meeting to monitor and evaluate the SALP process. PQEB, the NRC oversight group for SALP, periodically observes SALP Boards in all regions in order to evaluate the conduct'of;the SALP process and to remain current on the status of the util-ities' performance. Mr. Ramirez was interviewed by the DP0 Review Panel on January 4, 1990.
The interview ftcused on his observations at the SALP Board i
and his conclusions on the adequacy of the process. This interview confimed Pat the SALP process was conduct 4rd properly. Mr. Ramirez also confirmed tMt individual inspectors present-at the SALP Board meeting, although not a
voting members, did freely enter _into discussions of plant perfomance.
Based upon our review of the subject DP0 and reference material, and inter-views with selected staff, the Panel concludes the following:
o 1.
The SALP process for Comanche Peak was conducted consistent with agency guidance contained in MC 0516, given the unique structure of
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the Comanche Peak Project Division. Although specific deviations f
from the MC existed, these were appropriate and justified.
2.
The draft SALP report is an accurate reflection of Texas Utilities Electric's performance during the SALP report period. The site and regional inspectors developed input to the report, and either directly participated or were represented by a supervisor at the Board meeting.
3.
The SALP Board properly considered the significant inspection findings relative to the SALP period, and the conclusions were based on
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January 30, 1990-l 4
inspectors' inputs and meeting participation.
The survey of NRC inspectors involved in inspection activities related to Comanche Peak identified only several minor corrections to the draft SALP report.-
The DP0 Review Panel recommends that:
- 1.
'The SALP report be forwarded to TV Electric, with the changes in the Security functional area discussion proposed by the Associate-Director for Special-Projects (See Enclosure 7).
In addition, for clarification purposes, the final SALP report should reflect all attendees at the Board meeting.'
2.
The MC guidance should continue to be used in the conduct of the i
SALP process at Comanche Peak.
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In addition to the enclosures to this memorandum, other references and docu-ments were used during the DP0 Review Panel process. A listing of these j
other documents is'provided in Enclosure 10.
In accordance with NRR Office Letter No. 300, Revision 1, copies of the enclosures to this memorandum and 1
- the documents listed in Enclosure 10 are in the official Office file being maintained by Chief, Planning, Program and Management Support Branch, PMAS.
Tne DP0 Review Panel is prepared to brief you on the subject matter if you
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Original signed by
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Frank J. Miraglia j
Frank J. Miraglia, Chairman DP0 Review Panel on Comanche Peak l
Distribution:
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JLarkins LPlisco j
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Enclosures:
L(See next page)
-1.
Unsigned Anonymous Memo to the C
Chairman,- dtd 10/04/89 2.
Ltr fm Billie Pirner Garde to James M. Taylor, dtd 11/20/89 3.
Listing of DP0 Review Panel Mtgs-
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Special Review Assignment Memo fm J. Snierek to-W. Travers and
' R. Architzei, dtd 11/2/89 5 ~.
Report of 5;tcial Review Assign-ment fm W. Travers and R. Architzel to J. Sniezek, dtd 12/20/89 6.
Memo i; D, Crutchfield to All NRC T ~.tp 346
~ed in Inspection Activities it G.t:c g Comanche Peak, dtd 10/10/89 7.
Mem 54 Cru tch fi a' " to F. Miraglia, 1
dtd 11/3/89 i
8.
Memo fm D. Crutchfield to F. Miraglia, dtd 12/6/89 9.
Memo fm D. Crutchfield to F. Miraglia, dtd 12/20/89
- 10. Additicca.1 Documents Reviewed by DP0 Review Panel e
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GCT 4 1949 3.
Memorandun' Fort Chairman, U. S. Nuclear P.evul? tory Commission Washington, D. C.
20555 From:
HRC Staff Inspectors Sub$ect:
Comanche peak's Fuel Load Readiness and the Systematic Assessment of Licensee Per f ormance (SALP)
This memorandum is to inform the commission:about the readiness to load f uel at Comanche Peak, and the recent SALP evaluation process and the proposed report.
As NRC inspectors, it is our concern that the pending SALP report is neither accurate nor complete reflection of TU ' Electric's per f ormance during this S ALP period.
We believe that the Commission should be aware of what we view as
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manipulation and the exclusion of f actual inf ormation.
If such L
inf ormation were properly considered and evaluated, it would indice.te a less than satisf actory perf ormance rating in some areas, a need for increased attention and applicant action prior to NRC approval to load fuel.
The SALP conclusion, which gives the applicant a rating of
'2" in every area and identifies no adverse performance trends is L
incorrect and invalid.
Ten NRC managers made up the SALP Board.
l ThreeLwere Region IV managers who had no direct and siginificant involvement with the site.
Two other board members were involved with site matters but they administered their-pro $ect management and licensing duties from. their White-Flint offices.
NRC Senior Resident / Resident and Consultants who were entirely knowledgeable i
of licensee perf ormance had no vote on the board.
All of the i
recommendations for-below average, coming from those who were knew the real perf ormance, were outvoted by managers on the SALP Board.
Add i t i ona lly, inf ormation and findings brought to the attention of the SALP Board were deliberately excluded, giving a false impression about the plant.
For example, I
1.
The SALP Board did not adequately consider the full implications of certain ASME issues identified during -
reporting period by staff inspectors.
L 2.
The SALP Board did not adequately consider the inability L
of the applicant to recognize conditions potentially or actually adverse to quality as demonstrated by events surrounding service water system and the aux 11ary feedwater system (check valves and motors).
3.
TheSALPBoarddidnotadequatelyconsidertheinability L
of the applicant to identify and evaluate root causes of of deficiencies and program failures necessary for effective corrective action.
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' In orde:r to provide the~ Commission evidence of some of the issues that at e _ not being properly considered, we are attaching example pages f. tom draf t inspection reports and ' internal memos.
Although other agens were also improperly considered, we believe these examples will support our concerns and provide the Commission a chance to correct this situation.
our greater concern, which is shared by many TU Electric's site personnel is that Comanche peak is simply not yet ready to load fuel.
In addition to the TU Electric's poor performance in some areas, TU Electric has a large number of open and unresolved items
- and a large construction / engineering staff on site who are and
' will continue working on Unit 1.
This indictes they are not ready to lead fuel.
Disregarding financial considerations, both the NRC-o and TV Electric know that a realistic fuel loading date is about six. months from now, if no additional ma$or problems are found.
An additional consideration is TU Electric's excessive over reliance on contract personnel.
We are concerned that the applicant's-unrealistic schedule to load fuel in October 1989 will l
compromise the agency's inspection efforts and the applicant's progress since'1984.
Attachments:
l (1) pages of Draf t Reports (2) Hemoranda cc: CGrimes, Director OSP l
JTaylor, Deputy EDO BGarde, Esq. Garde Law office l'
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