ML20011E438
| ML20011E438 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/10/1989 |
| From: | Crutchfield D Office of Nuclear Reactor Regulation |
| To: | NRC |
| Shared Package | |
| ML20011D121 | List:
|
| References | |
| NUDOCS 9002140041 | |
| Download: ML20011E438 (2) | |
Text
-.
. ~. -.
. _ _ -.... ~.
-. _ ~ - _
p tag
./g g't, UNITED sT ATE s
['
i NUCLE AR REGULATORY COMMISSION e.
k MLHINGTON. D C. 205EL 5
.),,. #'
October 10, 1989 KEMORANDUM FOR: All NRC Staf f Inycived in Inspection Activities Related to Comanche Psak FROM:
Dennis M. Crutchfield. Associate Director for Special Projects Office of Nuclear Reactor Regulation
SUBJECT:
NRC STAFF DIFFERING PROFES$10NAL OPIN10h Oh COMANCHE PEAL in a memorandum to the Chairran dated October 4,1989, an anonymous group l
identifying themselves as 'NRC Staff Inspectors' assertec that the pending SALP report relatec to TU Electric's performance in the preparation cf Unit 1 5
for plant operation is neither accurate nor complete. The memoranourn is critical of both the SALP Board's findin1s and the qualifications of the Board members to draw conclusiores on TU ilectric's performance.
In order to assure that all cor.cerns related to TU Electric's performance are clearly understood prior to the issuance of the $ ALP report, I request that each of you involved in the inspection activities for Comanche Peak review the enclosed initial SALP report and submit any connants you may have'en the Board's findings within 15 days from the date of this memorandum.
In commenting on the enclosed report, you may want to review the procedural i
requirements atec purpose of the SALP, as oescribed in Manual Chapter 0516.
You should also note that the enclosed SALP report is considered to be L
'predecisional' and, as such, this draft should not be releaseo or discussed with unauthorized personnel, i
Your comments should be as specific as possible and be submitted directly to me. They may be submitted anonymously if you so desire. Depending on the nature of the connents received, further action may be warranted before the report is issued.
Should you have any questions regarding this matter, please do not hesitate to contact me at FTS 492 0722.
.p&d/
L ru chf a G 1ste Director nn s for Special Projects Office of Nuclear Reactor Regulation
~-
G Cp d'tI' pp
=.
F.ultiple Accressees
-t-october 20, 1989 Er. closure:
- c..
initial SALP Report cc w/o enclosurc:
T. Nurley J. Snieret J..Partics F. Miraglia C. Grines 0
{
M
't u
)
t ADDIT 10llAL DOCUt'iLTL REVIEWEli 0Y THE DP0 T.EVIEW PAf;[L 1.
tier.o of October 10, 1989, from T. Murley to J. Taylor, entitled
Differint Professici,61 Opinion Concerning Comanche Peak's Fuel Loac Re6diness ard SALP Report."
2.
Menic cf July 21, 1989, fron ll. Phillips to R. Warnich, entitled
" Systematic Ar.alysis of Licensee Performance."
3.
Memo of Jure 21, 19E0, from H. Phillips to C. Crimes, entitled "TV Electric Resporse to EA 88-310."
4 Mer..o of December 18, 1989, frem T. Murley to J. Taylor, entitled
- Differing Professional Opinion Concerning Comanche Peak's Fuel Load headiness and SALP Report."
5.
Letter of Decenber 8, 1989, from J. Taylor to B. Garde.
6.
Letter of February PC,1985, from R. Martin to M. Spence.
7.
!!RC Manual Chapter 412E, Differing Professior.a1 Views or Opinions.
E.
NRC Manual Chapter 0516, Systematic Assessinent of Liter.see Performance.
9.
f;RR Office Letter No. 300, Revision 1, Differing Professionel Views or Opinions.
10.
Letter of December 4,19Ef from S. Ebneter to W. Couns11.
13.
Comanche Feak SALP report dated October 21, 1988.
l l
l l
! 0 l
p
.,f *' ' N g.
UNIT E D sT ATts
[',,~%i NUCLE AR REGUL ATORY COMMISSION s'
n ASH!NC10N. D C 20bbb kg1 November 3, 1989 I:LkORANDL'I' FOR:
Frank J. Niraglie,_ Chairpersen hkR Standing Review Panel FROM:
Der.r is M. Crutchfield, Associate Dirtctor 1or Special Projects Office.of Nuclear Reactor Regulation SLC ECT:
DP0'ON COMANCHE PEAK SALP On OctoLer 10, 1989 e nietrio was sent to "All NRC Staff Involved in Inspection
-Activitiss Related to Comanche Peak."
It went to 8 HQ inspection personnel, 7 site or former site inspection personnel, 24 regional inspectors and 14 consultants, in that memo, the inspectors were asked to review the initial SALP repurt and subriit any coments on the SALP Board's fincings by October 15, 1989.
It wat indicated that the coments could be provided anonymously bl,t they should be as specific as possible.
To date 21 responses have been received. Copies of those responses are enclosed for your use.
In general, the respondents have no problems with the report as writter or the process used to prepare the SALP. Also, there were no negative findings on the qualifications of the Board members. Cossnents received in the areas of Security E0P's and the AIT check valve problem have received additional consideration and are discussed below in further detail.
1 A Region IV Physical Security Inspector provided some added views on the Comanche Peak Security Program and SALP rating. Two of the views deal with errors that are straight forward to correct and do not affect the overall rating. The third comment deals with the fact that the security inspector feels that the pre-op security program is far superior to other utilities at this phase. Also, the applicant's desire to lockdown without having construction delayed or completed unfairly casts the security program in a bad light. Consequently the' security inspector and his sectic*n citef feel I
Peak pre-op phase. program should be rated a Category 1 for the Comanche that the security I recommend that the Security section of the report be changed to better reflect the impact of the lack of coupletion of construction had on the rating but that the ratinj of *2" for Security stand.
Copies of the changes that are appropriate are enclosed.
N N Sp
i i
Frank J. Viraglie
.I.
November 3, 1989 1ht second aree of comment rtlated to the E0P's. The responder did not have a prvbleri with the oberall rating or the inforraation provided in the SALP.
Rother, he felt that the EOF team':, inspectier. report (not available et the t wo cf the Board toeeting) cculd provide 6doitional details concerning engineeris.9 review of the ERG's and the applict.ht's QA involvement in the review of the EkG's.
Including this inf ormatior. in the SALP report would provide aeditional exsruples to support the fincings. Sirice it would not result in a change to the SAtP Board's findings, I do not think the report should Le changed te it.clude this information.
The next area raised in tht responses de615 with the AIT check veive problor:.
No issues with the SALF were raisec but the individual was concerned with followup of the borg.Warr,er valve problem at Comanchar Peak.
Both issues raised (i.e., need for corrective action before startup and generic action) have been addressec by Tu and the staff. No action for the SALP report is reconmended.
Another responder.t felt that perhaps the Borg-Warner problem could have beer. ciscussed in more detail, but did not obsect to what was done in the SALF report.
Fintily, most had no corrrnent on the SALP process. A nus.ber of thuse ar.swering the merno felt th6t the process and report were fairly done, der.e in accorocnce with tht Manual Chapter, and accurately reflected the applicant's performance.
I have included copies of all responses received to date.
If others are subritted, copics will be sent to you also, h
Z:u)
Dennis
- 1. Crutch'f ssupsu pirector for Special Projects
/
Office of Nuclear Reactor. Regulation
Enclosures:
1.
Mark-Up SALP Pages 2.
Responses Received cc w/ enclosures:
J. Snierek
- d. Partlow g
iv!!y's t p g g SQtJ % < l./vt' 1/ l e i I.. i..' l 1 in..
c'
- t..
L'.. WsJ3: en.h..
NMs' I g,'p g,r/;.t J.
ba r n. nghani af
- / T. F.X Nor 4.1 n. NRh F. htenashc w 4. E.jtAshe. NAh 6' T f,g, W.
Richanst 5 J.
6.
64 ete. Nhh J.
TayJort
,g e 5 N.
H.g li ver rner e. Nhh F'. Lhen (
- W Li.
1.
Hubreec. Nhh Consultents - CFSEE Stte H h.
G.
Attcott. W h h-H R. 7.)(Ho g an, Nr,h reaggp*,jhk J.
N3 c hol es (.
h.
18 J o h n s o '). NFR bette41e Northweest Laboratory
- 5 E.
D./ba t t er, IAA
- I A
- bettell e bi ve. Si gn.e O B2 cg.
- M.
F.X hun y en. Nhh /'*' " " *'O hach)ano. Wash 1hgton 990i2 p A.
M.
L i t t c..
Nhh O.E. F.X Eur r a s. NRh /# M * ff* b M F.
V e t cart',
' k/ J. He,:en. Nkh Sonelysts. Inc.
W 0.
Dac Rothber g. *R E4 #*/s s. ns' PM" F. O. bon 260, 22 L F'er 6.wa. Nor t h A(A Wat epf ord. Connect 3 cut OoOE5 A.. S a r.c n. hit RIV-taht..ll/re,rvr10frob'infref F.
C.X Wu.gner.
t
/1 L.
J.
F e u l 1., RIV 6.
R.
Eryan, Conen Lorp. c 4
C. J.yHale. R1V * /DN 5
- F'. D. bon 2150 20010 Fugh hoed L
4 h.
V.
nrue. R 1 '.'
Foulsbo. Washangton 49070 l
' 4.3. E.*Geoaaercc. h1V 8- ' l.
O.
Mc6 ernon. F.1 V X). B.sf Wa t er s. F r a suta-Fec t n.en c.
R.
1.
vacier,. h a.'
5006 Sweetbriar brave ge-t/f '
Nor th Carol a ne
[c,@M J.
L. Lun.ms n e. klY
- Releagh, 4
J.
L.
FeJ4et. h1V 4 D.
N.
uraves. RIV G.
M.
Wa l f ord, SAIC C 4 J.
E.
Wr.i t t en.or e, h!V 1021 hesearch F'arl. Drive 4 f t.
H.
Iennecy, RIV Dayton, Ohio 45402 4 D.
A.
Fow.rs. RIV 4 N.
M.glerc, R3V-
/0[*F r')# /Fr# N'**rp.ti.sGood C. M
- e 680"~ "" F * #
4 J.
A.
l.ul l v. RIV M.
N.
Stein (-.
)d W.
diR. L.gCaldwell, RIV /p /g/
&# j 6 D. H.E Schul tz ID/i'r "* MW k# Earnest. R1V e \\=_
0/e7,*t G.
A.
btoktrol
'd A. J.(Everrett. R1 VM -*# 8We'I Facafic Northwest Laboratory 4 E.
M.ar r e v. RIV A H. DJ( Chaney, RIV - "'b k/0 MO A R.-EA beer, R I V.rM -M 'We d '
' b.
L'. N2cho)ac. N!V J
L. 1. Ract.etson. N'lV l.
C k a V I es-r E ss lt-e WW f'*
-..,-w..
c
L j
l
! y>
probless and is workiri olution'of the remainder.
The applicant's security or;anization has implemented en aggressive program for tw self identification of i
i security problems to ensure compliance with the requirements of 10 CFR Part 73 and,the Physical Security Plan (PSP). Corrective actions initiated as a result of the applicant t : M ; n;,7;7.. or NRC y
Mentifiec prcblums have been technically correct and effective.
Plant and corporate management has been supportive and actively involved in providing timely solutions to issues identified by the security staff.
The applicant has been responsive to hRC initiatives.
The applicant appears to have a sufficient number of security supervisors, fully qualified security i.
officers, and security support personnel assigned to the security department to implement a proper security program during nomal operations during the transition fron. construction to operation. However.
during the transition from construction to operations overtime use appeared to be excessive and, ttus, could have a ne effectiveness. gative impact on security staff i
Applicant management has recognized this problem and has initiated acticas to hire more security personnel. The lines of authority within the securit force are clear and well-understood. 4tr, < s A no n o e-' " M
- Y i : c/; identified with the security training program. A more accurate assessment of the training program will be possible following the completion of lockdown, but it appears that security force personnel have a good understanding of the applicant's policies and procedures. The applicant i
has established the necessary procedures to provide for the issilementation of a proper security program, i
The transition to a security organization responsible for safeguanling an operating nuclear power plant from a long-ters security organization responsible for industrial protection has not been implemented to a degree that has permitted the inspectors to establish the assurance of acceptable performance in this area. The applicant initiated a three-stage L
phased lockdown of the protected and vital areas on l
July 1. 1989. Phase 1 was completed and portions of I
Phase 2 were accomplished prior to the end of this assessment period.
It appears that applicant managesent did not recognize that the plant was not ready to enter into the final phase (haNI lockdown).
but has since acknowledged that fact. The applicant has cessitted to performing an internal security i
a w-e' es--
--wwe--+me-wm-m
-s-w-+-w'*+--w---r*-et
h.
1 24 6 4i program self-evaluation, to correct any deficiencies identified and to inforrr. the NRC when they consieer the plant ready for completion cf the preoperational i
inspection. based on the preoperational inspections completed to date. It appears the applicant has t
established the basis for an acceptable security program.
i l
The applicant's suterittels with respect to safeguards matters were technically sound and consistent.
These submittals indicate that the applicant has well-developed policies and procedures for control of securhy.71sted activities. During this assessment period, there was consistent evidence of prior planning and involvement by utility management.
l 3
2.
Performance Rating The applicant's rating is performance Category 2 in this area.
The change in rating from a Category 1 (last SALP perica) to a Category 2 does not necessarily reflect a change in applicant's performance. The last SALP rating was based primarily on the acquisition, installation, and activation of state-of-the-art i
security equipment which demonstrated the applicant's commitments to the security program. The a had not yet implementee the security plan. pplicant The present 5 ALP rating is based on additional ctivittes necessary to demonstrate implementation of a
physical security plan which was schedul to occur after the SALP period ended.
3.
Board Recommendations a.
Recessended hRC Action Tkt
/#
hone.
U" b.
Reconuended Acc11 cant Action
,;fg,,
oJ
- hone, j[c 4M "
wCis.Kw ww ~
G.
Radiolocical Controls
,yg 1.
Analysis gWM y
The assessment of this functional area consists of activities directly related to radiological controls.
including occupational rediation safety (e.g.,
occupational radiation protection, radioactive
l f " %,
UNifIo sf Atts NUCLEAR REGULATORY COMMISSION
- [
a q
5
/
RioloN 'V k
011 RYAN PLAZA DRIVE, sulff 1000 ARLINGTON. TEXAS M011 October 17, 1989 MEMORANDUM FOR:
Dennis M. Crutchfield, Associate Director for Special Projects Office Of Nuclear Reactor Regulation 4
J FROM:
Nemen N. Terc, Emergency Preparedness Specialist Security and Emergency Preparedness Section Division of Radiation Safety and Safeguards
SUBJECT:
DIFTERING PROFES$10NAL OPINION ON COMANCHE PEAK I read my original SALP input and the SALP report on Texas Utilities performance and did not find any substantial difference between the two.
I believe that the SALP report honestly and accurately describes the subject l
matter submitted by myself for the Comanche Peak SALP.
NemenN.Terc,EmergencyPreparednes/pecialist Security and Emergency Preparedness Section Division of Radiation Safety and Safeguards cc:
' T. Murley, NRR/DONRR J. Snierek, NRR/DONRR
-J.
Partlow, NRR/ADP F. Miraglia, NRR/ADT C. Grimes, NRR/CP l
I
+ <
. -. _ - -. _. ~.. - - -
l 4
uWITED sT ATE %
[
1 NUCLEAR REGULATORY COMMISSION f
RtoloN IV af
$11 RY AN PLAZ A DRIVE, sVITE 1000 4,,
,8 ARLINoToN. TERAS M011
]
i October 20, 1989 MEMORANDUM FOR:
Dennis M. Crutchfield, Associate Director for Special Projects i
Office Of Nuclear Reactor Regulation FROM:
Ronald A. Caldwell, Physical Security Inspector Security & Emergency Preparedness Section Division of Radiation Safety & Safeguards SUEJECT:
DIFFERING PROFE5510NAL OPINION ON CDMANCHE PEAK SALP Pursuant to your memorandum of October 10, 1989, requesting comments on the Comanche Peak SALP Board's findings, the following information is submitted in response:
There are at least three errors appearing in Part F, security:
t The word " audit" in line six of the first paragraph on page 23 incorrectly implies that a formal audit activity was conducted by the applicant.
I am responsible for this error in part that ] did not intend to provide this meaning to the paragraph. The applicant has not conducted formal audits of the security program.
The fifth sentence of the second paragraph on page 23 erroneot, sly states.that no problems were identified with the security training program. As of my input date, this statement was true. My input date reflected a SALP terminal date of July 31, 1989.- The SALP i
period was changed to include the month of August 1989 and a i
subsequent inspection in the month of August uncovered a minor a
deficiency in the security training program rendering this statement inaccurate.
Refer to NRC Inspection Report 50-445/89-68, page 5, paragraph 7, dated September 14, 1989, for clarification. Neither the SALP Board nor I discovered this error until your memorandum encouraged a more critical review of the Comanche Peak SALP report.
l The last full paragraph of Part F, Security, Performance Ratino, is in error. The SALP Board's conclusion that the applicant's-performance rating is Category 2 in this area is inaccurate.
The second paragraph of Part F.2 on page 24 was written and published without any input from me, the original author of Part F.
This-applicant is far superior to other applicants for a power reactor license at this stage of the pre-operational inspection process in the security l
pregram area.
I have performed four previous pre-operational security program l
inspections of Region IV applicants for a license.
In three of the four L
pre-operational inspections, which I have performed in Region IV, the
%)OW{n%h 7M)
-Dennis M. Crutchfield applicant had a marginal security program that apparently was the consequence of.inadecuate planning by security management. Such is not the case for this applicant.
This applicant has a strong security management, a well planned security progam, and a security posture which already exceeds some of Region IV utilities which have operating plants.
The SALP Board's rating of this applicant as a Category 2 facility in the security area is entirely inaccurate and is based on factors other than inspection of the security program. The applicant's security program is being unfairly judged because CPSES senior management has apparently asked the security program managers to perform security tasks for in excess of the security programs operational capability. The applicant's security organizations inabiljty to lockdown is not a measure of the security organi2ation's performance, but a measure of upper management's inability to complete construction activity in a locked down posture. The app'licant's desire to "lockdown without any appreciative delay in construction activity is an unrealistic decision that characteristically impacts on the image of the security program rather than the decision by management.
The applicant, in my professional opinion, should have received a Category 1
$ ALP rating in this program area.
The SAW Board decision to project the probable inability of the security organization to implement the security plan while extensive construction activity is being completed was made independent of the inspector.
.However, the CPSES SALP Board's action is not without precedence.
In the summer of 1989, I felt strongly that another Region IV utility should receive a SALP rating of Category 3 for the security area. The utility received a rating of Category 2 based on factors other than the security inspection i program. This utility subsequently has had an enforcement conference and has a pending civil penalty. As in the case of the CPSES Board, I was not consulted on the rating assigned.
There appears to be a communication gap with information passed upward into the Region IV management structure. The inspector appears to be seldom heard until he threatens writing a differing of professional opinion. However, a formal written differing professional opinion is rarely executed in Region IV because of the perceived adverse impact on the inspector.
Ronald A. Caldwell Physical Security Inspector Security & Emergency Preparedness Section Division of Radiation Safety & Safeguards cc:
T. Murley, NRR/DONRR J. Sniezek, NRR/DONRR J. Partlow, NRR/ADP F. Miraglia, NRR/ADT C. Grimes, NRR/CP
i Gwle.Apl '
X m*Ed y$
oc.b.$a19ifM, W
+Le G%A S65 6+t 9
.o-pd (3sd-cr/ftP,:Ps i 3D -+%/fr-ft) Ad f4
)
W br% %
f m c w & 8 p d i.y>.
P w, A u,, W t b Ac I
" % Le\\ sgrccD k kis " 0> &
, at wd D W.
l I
i' 6 029
" isp 2,99 (
ut2c Rape 10; prSg-t=ers i
s$r*#
Y
- $a y
1 4.
[ps ese
'c UNif ED sTATts l'
{
I NUCLE AR REGULATORY COMMISSION c.
t
/
usmwotow. o. c. rosss
%, 'e..../
October 23. 1989 MEMORAhDUM FOR: Dennis M. Crutchfield, Associate Director i
for Special Projects Office of Nuclear Reactor Regulation 1
i FROM:
Donald P. Norkin Comanche Peak Project Division Office of Nuclear Reactor Rtgulation
SUBJECT:
NRC STAFF DIFFERING PROFESSIONAL OPINION ON COMANCH Your memorandum dated October 10, 1989 requested that those of us involved in the inspection activities for Comanche Peak review the initial SALP report and c'oement on the Board's findings.
During the rating p'eriod of September 1, 1988 through August31, 1989, I was the team leader for three NRC team inspections (Inspection Reports 8g-14, 89-28, and 89-51).
from 800 Warnick's organization; Frank Ashe participated in one of the inspections addressed the Post Construction Hartlware Two (the confinnation process for calculation assumptions).
The SALP report references the three team inspections under " Engineering and Technical Support.'
alludes to NRC inspection of PCHYP.In addition, ' Construction and Corrective Action for these two functional areas as indicated in the SALlI agree with usin' the inspections as input report.
For both areas, the team inspections considered alone would support a Category 1 SALP rating since we generally found good applicant programs and identified few issues.
I have no further' coments on the SALP report.
nbP.Norkin Comanche Peak Project Division Office of Nuclear Reactor Regulation 4
- g 4 9eo w -Pq
+
ocv-aT-oo T' u c s'o : e 2 1
- CUrGEin M
M M M &57
-compomanoN q
l Mr. Dennis M. Crutchfield Associate Director for special Projects Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 i
Subjects NRC STAFF DIFFERING PROFESSIONAL OPINION ON COMANCHE PEAK Dear Mr. Crutch'fieldt
-l This correspondence responds to your request (Memo dated 10 October 1989) for comments on the Comanche Peak SALP process.
I was one of the contract personnel supporting the Region ZY Reorgency Preparedness Appraisal performed during the period 5 -
9 June 1969.
I have completed a review of the final Emergency Preparedness Appraisal report dated 30 August 1989, issued by Region ZY on Comanche Peak.
I found no inconsistencies in the draft asterial L
I submitted to the team leader, Mr.-Nemen Terc, and the final s
. contents of the Appraisal Report.
In as much as I am not consulte$ in the SALP' process for any plant, including Comanche Peak, I had no input to the draft SALP report that was the o
subject of your memo.
Nowever, in my opinion, the words of the l.
SALP report, section R., are consistent with my limited knowledge l
i and exposure to the plant's current status.
I apologise for my inability to make substantive input to this matter.
If I may be of any further service,-! say be contacted l
through my corporate number of 206 857-5789, or at my home, 206 l
692-0153.
vid N chults I
Copy-to J. Jamison, Battelle, PNL s
N..Terc, USNRC, RIV.
COMEX File q u a 's I N U d C Ap.
j um Teo etAtse i
NUCLEAR Rt00LATORY COMMISSION k.....]f neotom iv ett avaw PLA A on ve surra me Anuweton.taxas mois ET 25 m i
MEMDRANDUM FOR: Dennis M. Crutchfield. Associate Director for $pecial Projects WRR FROM:
J. E. Gagliardo. Chief. Operational Programs section Region lY
$UBJECT:
COMANCHE PEAK $ ALP REPORT This confims our tale! hone conversation of October 23. 1989. regardin!k1 ALP i.
infomation that shoul 6e considered for inclusion in the Comanche Pe
)
report.
i As I noted in our conversion, I do not have a differing opinion with the r
infomation and.the analyses provided in the draft report, nor do I have a differing opinion with tie conclusions drawn by the SALP board.
l My question regards the fact that the report does not describe some of the
. concerns that were identified by the ECP (EPG) Inspection Team in their inspection of August 14 25, 1989 In fairness to the SALP board, the E0P inspection report (50-446/89 59) was not issued until September 29. 1989. The only infomation available to the board from this inspection was that included in our september 9.1989, memorandum to Bob Warnick (copy attached). As you esill note from this inpet, the board did not have sufficient details to L
adequately speak to the concerns addressed by this inspection.
Since we now have.the specifics of the E0P inspection effort. I believe the team's findings should be reflected in the final report.
I have also attached pages 16 and 17 from the E0P inspection report, which you may wish to consider for inclusion in the SALP report.
consider adding a statement on page$ reconeendations are that the board 11 of the draft report regarding our concerns on the engineering review of the tRes. I also recommend that the board consider adding a statement on page 16 of the draft report regarding the concerns we had with the applicant's OA involvement in the review of the ERGS as they were being developed one implemented.
I have no objections if the SALP board chooses not to include these statements because I do not believe
)
that these findings change the conclusions drawn by the board.
~.,
I Dennis Crutchfield
-?-
I would be pleased to discuss this materisi is more detail with you or the 6
5 ALP board, f
o I
J. E.
fardo, Chief 9perati 1 Programs Section l
Attachnent:
(as stated) r tt:
+
R. D. Martin L. J. Callen C. l. Grimes T. P. Gwynn J. P. Jaudon-H. H. Livennere J. E. Lyons P. F. McKee R. F. Warnick t
i J. 5. Wiebe J. H. Wilson l
L. A. Yancell t
l e
.t
?
t b
3 P
16-inspection. In 64dition, the A0s conducted plant walkesens of ERG attach-monts and local action steps to ensure consistency with plant nosenclature and fastitarity with reevired actions. The training provided to the A0s appeared to be asequate for familiarizing them with the actions required in their areas of responsibility during accident sitsations.
2.7 Onnoins tvaluation of ERGS (25692) fTask l)
Section 6.t.3 of WRtG-0899 reestres that licensee's establish a program for the ongoing evaluation of E0ps that the on0eing evaluation program (ER$s). 98URtt-0899 further requires include the evalbation of the technical adequacy of the ESPs on the bas's of operational esperience and use, training esperience, stavlater esercises, and control room walkthroughs.
The team noted that in a memorapeva dated Jdne 8.1989. the applicant directed all operations department employees to notify the appropriate personnel of any procedural changes taat are consteered to be necessary, procedure 00A 207. 'Suidelines for the Preparation and Review of Operations procedures,' Revisten 2. August 18. 1987 PeQuired (Step 6.1.6) that all operations procedures (including the ER6s) be revised against the design basis during the development of a revision or every 2 years. All of the active ERGS had been revised in 1989 and had been scheduled for this next biennial review. Precedure 00A 207 prSvided a fera (Figure 7.1 to be used as a checklist for verifying the adequacy of a new or) that was revised procedure.
Section 6.3 of Precedure 00A 207 provided guidelines and a form (Figure 7.2) to be used for res:smonding changes or ta The mended changes to the tRes. "he recesmon)provements to proc team reviewed selected forms CFigure 7.8 on which todividuals had recom-dations had been entered into the apolisant's tracking system, and printouts were routed to the annagers and supervisors of the operations department. Appiteent representatives interviewed stated that the Figure 7.2 fore was not always returned to the tadtvidual esteittlag the recommendation. They acted that tf the recommen.
eation was tesorporated into the procedure, it would appear in the next revisten, tot if the roccamendation was not approved, the tedividual making the recommendation was essa 11y notified. Some of the individuals interviewed acted that they had not yet received feedbeck on recossensations submitted. An appiteent representative stated that the status of an employee raccusendstion was sheen en the priatout of the tracktag system, but it was apparest that some of the. Supervisers ree were not sheries them with all of their employees. stving the printoutsMeasures were n to ensure that the originators were sede aware in a tieely esamer of the resolution of recamendations. Failure to de to con be a distacentive to individuals contiestag to submit recernendations.
. The appitcast bed also issued procedure 004 804. ' Preparation of taergency Response eutdeltatsd.804. guide 1Ines were pro.1989. In Sections 6.t and
- Revision 7 on July 18 6.3 of precedere R vided for sutaittlag I
'I 17 recomendations for changing the ER$s using procedure Fore 06A tM-2. The team notes, however, that for all of the recomeneations reviewed the fore in procedure 00A RW. Figure 7.2. was used and not procedure Fem 00A tM.t.
The appitcant needs to resolve this issue and define which fers is to be used for making recessen64tions for changing the (R$s.
he team reviewed the applicant's process for reviewine the original (RGs and changes thereto. Recent revisions of procedure 00A FM reeutres a switidisetplinary review of ERGS and changes to the teGs before the f411 i
' of Itaf; however, the engineerine department had little er no intelvement
']
in the review of the (RGs. At that ties, the applicant developed a process for reviewing all of the tRes to determine actual er potential differences between the ER$s and the applicable design basis documents. Engineering i
personnel teentified a total of 294 inconsistencies that required further review and evoluntlen. At the time of this inspection appresiastely half of the inconsistencies has been resolves. The applicant cemitted to resolve all of the differences or provide justification for the inconsistencies e
before fuel lead. Dis is an open its that will be reinspected before fuelload(445/896903). The esplicant also committed to have these inconsistencies, that require revision of the ERGS incorporeted into the applicable ERG and the appropriate training completed before achieving pose t operations. This is an open item (445/446/8999 04).
The team found that QA personnel had been involved in the review of the IRGs since 1984. In the 1984 reviews. the OA reviewer had used e checklist based on pURil 2006 that was generally completed with the exception of that portion of the checklist requiring a centrol resm/in plant walkeenn.
The team found that GA personnel had been performing only seble-top reviews of the ER$s and had not perforsed in plant er centrol reen walkesens. The taas also noted that for the reviews performed in 1905 and 1989. the NuttG-f005 checklist had not been used. The 0A reviamer interviewed stated that he used precedure 004 tM as a eutdeline for the review. The i
team site found that the resolution of the OA revleuer's cassents had not been forwarded to his and he was not aware of their reseletten. The taam considers a review without walking down at least portions of the pescedure L
to be only stains 11y aeseptable.
t
- h team else revleued the OA audit and surveillance activities relating to the E0ps.. The applicant had perfemed en omdit (TUS 4912) of the ERSs and controlling decemen welkdeun of the IRBs. ts in June 1989. but the audit did not inclede a
(
Tne audit did include a revie of the operator
)
training program related to the IRBss het not the sonitoring of actual training en the IRBs. The team found that no QA serveillances hed been perfereed that meettered the training of the operators en the M.
Applicant represostatives committed to inclues en annual antit of the ER$s in their master audit plans and to perfers a easiannual serveillance of steviator treint on the ERGS. They also censitted to usik down future revistens to the
-,,r.
m,-
-,...~.
~...~,._.,mr,._-
...,_,,---.m
.m.
t i
]
j m
- go nac i
)
f
(
NUCLEAR REGULATORY COMMISSION
'g UNITED STATES -
e
.lj
.g WAbtlNG TON, D. C. 30M6
'4 7
OCT 2 51989 L
p MEMORANDUM FOR:
D. N. Crutchfield, Associate Director E
L for Special' Projects Office of Nuclear Reactor Regulation g
p
.FROM:
R. F. Warnick, Assistant Director l-for Inspection Programs f
comanche Peak Project Division Office of Nuclear Reactor Regulation
<t g
SUBJ'CT:
COMIENTS ON THE SALP AND THE DPO E
I am responding to your memo and request dated October 10, 1989.
.I do agree with the draft.SALP report, in which you asked for our comunents on the recently prepared draft SALP report.
In addition, I desire to inform you and. members of the panel reviewing the differing
[
professional opinion of:
the process used in preparing the SALP L
report and in :enducting the SALP Board meeting; measures established R
to. identify ^early indications of unacceptable applicant performance; clarification of information in the DPO which might be misleading; and the measures. utilized by the NRC onsite staff to identify and track inspector concerns.
Since the organization-of the Office of Special Projects in February 1987,:we have prepared two draft SALP reports for consideration by
.:SALP. Boards.-
In both cases, Manual Chapter 0516 was followed.. In both cases', the report input was written by the individuals involved in'the-licensing and' inspection of1 Comanche Peak.
For the 1989'SALP,
'one of the onsite staff combined-inputs provided by the onsite linspectors and consultants, Region IV, and Headquarters.
At least two x'
and maybe-three revisions were.made by the onsite staff before the draf t was submitted to RIV and Beadquarters for comuments.
All coasments were considered-and the report revised and distributed for consideration.by the SALP Soard at the September 19, 1989' meeting.
The.onsite.MRC mar.ager, five NRC onsite inspectors, and three NRC-onsite. consultants attended the SALP Board meeting.
The-Senior Resident. Inspector-(SRI), Operations did not attend the SALP Board because-heLhad just transferred heres however, the former SRI,
' Operations who had provided SALP input attended the Board meeting.
Three consultants:did not attend the SALP Board meeting.
I felt it was more important for them to perform onsite inspection work.
They were: represented at tha, Board meeting by their lead inspectors and by i
the. Lead Senior Inspector, a voting Board member.
Inspectors and consultants present at the Board meeting were asked questions and were involved in the discussions.
Three-onsite NRC personnel (the
~ Assistant DArector for Inspection Programs, the Senior Project
'r Inspector, and the Lead Senior Inspector) were voting Board' members in 1988 and again in~1989.
N D d lh ot9 N /A GY
+.
~...
g OCT ^ '5 iPo
- D.- M. Crutchfield 2
The SALP Board convened at approximately 8 a.m. at the-Plantation f.nn and discussions continued until approximately 7:30 p.m.
The draft write-up of.each ares was discussed page by page and paragraph by paragraph.
Comments were made; questions asked and suggestions for improved explanation, justification, or flow were made.
Assignments i
for rewrites were made or it was rewritten at that time.
Each functional area was written and discussed by the Board approximately in the order of the seven SALP rating criteria.
Then, each rating j
criteria was. voted._ A total of seven votes'were taken for each functional area'except for security and radiological controls and then 4
a final-performance rating was determined.
Only one overall vote was taken.for each of the functional areas of security and radiological controls, as agreed-by the Board members.
In the six functional areas
'i that had individual criteria votes, a total of 93 votes were for perfonnance rating of category 1, 255 votes were for category 2, 33 votes were for category 3, and 39 votes were for not rated, tJaing the definition for " performance trend" found in the MC516, no trends were identified in any area by any Board member.
Recorsmandations were discussed-by SALP Board meeting attendees and agreed to.
Following the SALP Board, the assigned inspectors, consultants, l
supervisors, and managers provided rewrites for their particular areas.
The inputs were pulled together by the onsite staff and the Initial Draft SALP report was prepared and sent to RIV and Headquarters for comment.
Comuments were received and incorporated or otherwise' resolved.
The report was ready to issue on the goal date of October 8, 1989, the day the DPO was received.
NRC staff inspectors were involved in writing the SALP report, they were at the SALP Board meeting (or were represented by Regional or Headquarters management), and they-participated in the SALP Board discussions.
The entire SALP process was consistent with past and gpresent NRC practice and with MC 0516.
' In addition to the above, the onsite resident inspectors and consultants prepared mini-SALP evaluations every time they wrote an inspection report.
This was done to identify trends and early indicators of declining or unacceptable applicant performance.
Out of a total of 91 inspections included in this SALP assessment period, mini-SALP evaluations were submitted for 71 inspections.
Of the 71 mini-SALP evaluations submitted, 2 performance category 1 ratings were
~
.given, 145 category 2 ratings were given, 8 declining 2 or 2-ratings were given, and 10 category 3 ratings were given.
Contrary to the opinion stated in the DPO memo, the SALP report does discuss work or issues covered by the ASME Code (sectica IV.A.1 and Section IV.B.1); the negative aspects of performance demonstrated by the auxiliary feedwater system check valve backloakage events (Section IV.B.1 and Section IV.D.1); and the inability of the
- applicant to identify root causes (Section II,Section IV. A.1, and Section IV.C.1).
D. M.-Crutchfield 3
OCT 2 51989 Regarding the attachments to the DPO:
(1) The attachment to the H. S. Phillips memo gives SALP Evaluation narrative for seven inspection reports that were completed and issued in the previous SALP period.
Only the-last two entries, both of which state " Report 50-445/88-67: 50-446/88 No justification necessary," were for-this SALP period.
(2) The information contained on the two draft pages (31 and 32) is also contained in the Initial SALP Report that i
was concurred in by the SALP Board (Section IV.B.1 and
-Section IV.D 1).
(3) The Phillips' memo "TU Electric Response to
.EA 88-310" dated June 21', 1989, and unissued Inspection Report 50-445/89-23; 50-446/89-23 were referred to the Office of Investigation for review and action.
The subject matter is referred to in the SALP report (Section V.C).
Because the infotination was referred for investigation, it was not proper to discuss in detail in the SALP.
i Finally,;the onsite NRC sOpervisors and manager have tried diligently to see that all inspector concerns were known, tracked, and satisfactorily resolved.
In addition to the inspectors discussing findings-with their supervisor and documenting them in inspection reports, each week there is a staff meeting for all the onsite b
technical staff and consultants.
One of the items _on the agenda each l
week is "any new major concerns."
Inspectors and consultants. inform the rest of the NRC staff of any major findings.
These are tracked to assure adequate management attention and closure.
For'the last item on the statf meeting agenda, each and every individual is given an opportunity to'ask questions, bring up for discussion any topic the individual desires, or talk about anything the individual desires.
I hope you and the panel find the above information to be useful.
I will be glad to answer any. questions you or others may have.
WSOY R. F. Warnick, Assistant Director for Inspection Programs Comanche Peak Project Division office of Nuclear Reactor Regulation 1
l
4 cd 8N,
o UNITED STATES
- 7..
NUCLEAR REGULATORY COMMISSION f
- f
+
mEGION IV 3
.i 9
811 RYAN PLAZA oRIVE SUITE 1000 S
ARLINGTON. TEXAS 70011 OCT 2 5 W MEMORANDUM FOR:
Dennis M. Crutchfield, Associate Director for Special Projects Office of Nuclear Reactor Regulation FROM:
R. E. Baer Health Physicist Facilities Radiological Protection Section e
Division of Radiation Safety and Safeguards
SUBJECT:
COMMENTS ON COMANCHE PEAK DRAFT SALP REPORT l
I was responsible for the NRC's inspection program in Radiological Controls during the. subject SALP period of September 1, 1988. through July 31, 1989, 1
.believe that the.SALP report accurately describes the performance of the E
Comanche Peak staff and the conclusions of the NRC inspection staff as documented.
No significant issues were identified, all inspection report i
findings are~being tracked on the open items record,
/
R. E. Baer Health Physicist I
L
~
o* **
%e, UNITED STATES
- t -x
. e t 6i,
NUCLEAR REGULATORY COMMIS$10N r
' -.[
RiolON IV
' t
- "%,,.* ',,.'/
s11 RY AN PLAIA DRIVE. SUITE 1000 ARuNotoN. TEXAS M011
[
OCT 2 51989 -
r MEMORANDUM FOR: Dennis M. Crutchfield
)
Associate Director for Special Projects s
}
Office of Nuclear Reactor Regulation FROM:
A. B. Earnest, Security Inspector Security and Emergency Preparedness Section
SUBJECT:
NRC STAFF DIFFERING PROFESSIONAL.
OPINION ON COMANCHE PEAK This inspector has no concern in reference to th or omanche Peak.
/
Security and Emerge'hty Preparedness Section Region IV L
Ma
-l 4
4 e
UMITED STATES NUCLEAR REGULATORY COMMISSION p
ig
.7 5
)
atoioN ev -
t sit avAw plaza onivt. sutte ioso
\\,',',,,.*
ARLINGTON, TEXAS 79o11 oct 25 a s MEMORANDUM FOR:
Dennis M. Crutchfield, Associate Director For Special Projects Office of Nuclear Reactor Regulation FROM:
R. J. Everett, Chief Nuclear Material Licensing Section Division of Radiation Safety and Safeguards
SUBJECT:
COMMENTS ON COMANCHE PEAK DRAFT SALP REPORT
'I was responsible for the NRC's inspection programs in Security and Emergency Preparedness during most of the subject SALP period. With regard to emergency planning, I believe that the SALP report accurately describes the performance of the Comanche Peak staff and conclusions of the NRC inspection staff as documented in their SALP input. With regard to Security, some changes could be.
made to more accurately describe the conclusions of the inspection staff. The applicant's audit program consisted of an audit group within the Security-group. The report ~probably gives the applicant too much credit in this regard.
On the other hand, we knock them for their lack of readiness for final phase lock down. Many of the. problems associated with this lack of readiness were beyond the control of the security group 1.e., construction activity and large numbers of personnel onsite.
The. extension of the SALP period allowed more of the readiness issue to come out.. Based upon the experiences of the Security staff in performing preoperational inspections at other plants, Comanche _ Peak should be a SALP 1 in Security, i
R. J
, Chief Nuclear Material Licensing Section
% {>o1 @ v0 @ @ g
f x y
- a g
From:
mn'ckmeI TM yan fpl5T to)z+)s9 i
a D
l.
To -
Dennts c,0tchheld
$4j:
CP5ES
.5 ALP OPo SALP. A. r An
-bi ee-' areas in wkie.k Jt par o.p ahd I
+,u.,
u 1
3 in m y o p i n i o n,- h e 3.
n a. s,g o 4,
_, a s, l e v d,-
u, app ic =W achi pe r6ryana.
l-i Tk. in.clus t.A of - 3 Re ton
~.~a~.
a m at a3 r s on. % e s4LP boud card, on %e Surke. #
appear vnjv5h kul but when -
l a k< in&mt d..f w. ro s.nraj ke kta d M rs dec.ute 7
z wa.
g z c n e. u a c k s n + ;+ wu
,n &
be s+ ~ rnh, e tt of 4-
- unc, i
$Ach e
?
21.on11MooA~V # 1p 4
- S 89 e
g mA,.,
c--
-,y
-,,-y-7
m i ll
a_' 0 '[
t to to sy W
Ckra-Gr.us Ssu m,ke
%ya n
$.Tkahdon.N %snae Pe a k 1s sue.s, W. d a el Aln .I : am not awwe' of ary safe.4 - sgrc6an+ 7 i.s sve 3 assoua4ed wi% (P5ES Uni 4 ) 'h+ h ave nif beu resolv ed or wLid noV he'n3 cu<reelly +nc hed by hems.\\ me.+kods, a r<. Sr.,cualy, Ok ) W .t ' 9. 5. I J ul a.t w ri4e. eer d..I kave a.r7 india b as 4. uho did wr;4t. 4ke. in$an.vs a.naeye.avs (e.Ser. "The. \\stk.e doe.s soF <ellee.& my fediny on }he $A LP prouss-o< 4e. s(pIrean+I readin< ss 4< Sel ks). g g uo9 C 4N Jo 3 w avid sd v ru %s+ so se e.fkr4 he a sse. +a ide d 4 Se auhor(s) of he le41e r erasmuc.L as ee. c o r r e. sh+< of w ea < 4 rad bu veah4 an nk sye<e ed y cirwmsfadial 6"#I+ i '*i1'J " 5' '> *"d di*ial'k'd anorale.. The use. of k cellech 4erm
- urtc shff inspee.4ers' wiMed consulka) all %.se a(6eied _borJw; i
~ - -
a_, 4
- 1 cg1p/_ wane 2sen C
a,a : s~ s etru, xanzwamecx}cm To : pmAzs M, fAmAtas Assx.ars 4xsarc 'f$A $ sC h /, f80 $ M ) hf M CS Nk/f - 1 1 o s csm u c w ps.sg Y$hY hf fhWk YYh l$, $h s swxwaauc, n ne ex<crw, w cseur.r CesicM4WC 'Tht? Just2M C40' ASMA7" t . [ NNS & C$N W Y$ $h b &WWh $$kh,, j & fsfl-77W 7N# Z N.z zz 9 2 G # bd A/64ips FMA7N&< fA277#6 AwK' Ml4N#~54/A'ZCW C oA/c7Ru c z22 w.C. hvw To X2 .7 QC El/M, f HA1/6 AD N4' RO S/073 W A 7XME xf6WW - c c NcEAA./, 8 5 s-a - bsuwt sms<rrx(es.r.)-ca V xh402/'/OOD 'f)}1p
m,....._.- s 'f /t/'0 N-10/23/89 jp To t - Chris Grimes, Director,:CPPD, NRR From: H.H.Livermore, Sr. Ld. Inspector, CPPD, NRR
Subject:
Response to Your_ Memo of October 11, 1989 n In. response to your letter of October 11, 1989, I wish to state that I personally am unaware of any unidentified safety-related concerns that may have a bearing on the licensing'of Comanche Peak, Unit 1. I. feel ~that'the NRC .is-~ aware of all identified problems and is dealing with them in accordance with NRC policy and procedures. The site staff is' continuing surveillances and inspections and I am confident that if-there are any hidden problems, they-will--be uncovered and dealt with in accordance with our procedures. In regar( to the October 4, 1989 anonymous letter written concerning the CPPD SALP process, I wish to state that I completely _ disagree with the contents of that' letter. The SALP process was totally in accordance with NRC policy and procedures ~. All SALP inputs, writeups and revisions to the SALP' report were written and' reviewed by myself and my. inspectors prior to the SALP board.
- To my knowledge, there was no information deliberately or inadvertantly ex-cluded from the SALP board.
I do;not agree with the views-espoused in the letter and I know of no member of my construction group that shares these views. I find the letter to be in bad taste, improper,-misleading, and designed only to sensationalize -one anonymous person's misdirected' opinion. ^ r e c/w A-H. Livermore sr. Ld. Inspector, Construction, CPPD cc W. Warnick @ field gg[_Lbb0 ^M
t, .2p S t8c g#o,_ UNITE D STATES [ sq 't NUCLE AR REGULATORY COMMISSION: j. -- wassiNotoN. D. C 20655 A......,/ October 25, 1989 1 -[' HLMORANDUM FOR: Dennis M. Crutchfield, Associate Director 5 for Special Projects Office of Nuclear Reactor Regulation FROM:- Rosemary T. Hogan Energency Preparedness Branch Division of Raciation Protection m i and Emergency Preparedness Office of Nuclear Reactor Regulation
SUBJECT:
NRC STAFF DIFFERING PROFESSIONAL OPINION ON COMANCHE PEAK I have reviewed _ relevant portions of the initial report of the SALP for Comanche Peak. My review was limited to the emergency preparedness area, .therefore, I reviewed the draft transmittal letter, the Introduction, the Susunary of Results, and the Emergency Preparedness section of the Performance. Analysis. 1 participated in both inspections conducted in the Esergency Preparedness area tiuring this assessment period and I have first hand knowledge r ,of the results of those inspections. I agree with the assessment, the Performance Rating and the board Recomunendations. %. p~ mq~ Rosemary T. Hogan Emergency Preparedness Branch ) Division of Radiation Protection and Emergency Preparedness Office of Nuclear Reactor Regulation 6 0 s pp.H L/ 0 kr
kj ~ + 2 's PRISUTA-BECKMAN ASSOCIATES RD #4. 242A RTE 136 BELLE VERS 4ON, PA 15012 (412) 872-9157- ' OCTOBER 24, 1989 Dennis M. Crutchfield-Associate Director for Special Projects Ofice of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington. D. C. 20555
SUBJECT:
NRC STAFT DIFTERING PROFESSIONAL OPINICH ON COMANCHE PEAK I have received and reviewed the SALP report on TU -Electric's Comanche Peak Steam Electric Station forwarded by you on October 10, 1989.' In addition to a general review of the comments and findings of the SALP review board,-I specifically reviewed the report on the functional area of Plant Operation, considering my interface with that area during the BOP teaa inspection in August 1989.~ The conclusions of-my review are that there are no statements or conclusions of the SALP board which are in conflict with or run counter to the findings resulting from my inspection of that area of comanche Peak operations.- I trust this' information is satisfactory for your use; should you have need for additional information, please inform me. David B. Waters Associate Consultant cci Donald A.-Beckman d} O o TT'l'OdhMS Lp l t l 1 r<l
- I
s Ai .M k, u-,4Jpi-- a-o
5, 4
as/a---t-- 44Lai- - ++-u: A ~eAMaJ --<-,a--ean-e-a- I u, % &n d w ~ M m& & l A og s 4tF war - u &mJ ._o - \\ MM -b v3 G @-ga) .b g w4 a& %hei A A h en um. A k n-L w x nu20-a A eAaA9-u.>S C.
- 1. h + q &
S-oJ A xA (Woggbd%) wJ o woes 1 M # v.
- -e6 w< d fud o
h d I u2u + Qo ^ ^ %. d t k k '
- f. s ; 4 Qi l
- o. J,x e A
m. F.M en,k ~ z.nsv ,o e d u / J r2 _ c ' e Q. ) 2. p c0moJ 1&sd AJ/Lc w ado q ed u) wu, Y a %p ,y _ od Wet ab a w 2( W L <M', yW & % e Li c... W pLp5~ ENN
[ 9 m u k m& y a,y. '~r % W w L Mw Mw w ."h. af w v"N 'k ' % y %m > ~ m% ( LL. b h~adN @w La %4 f I r') q, W l0 (T G h
~ f 's \\ 4 %I y l
- J.
1 ,.::,..q- .;n i .i 1 l l ' Vil ) t. y;.'> .+; < st .1 a i.,;,: i o .13. v. s .ss 6 u-o u.
- ..., 9;.,...,, i
'plati'e.,' P i: ' m.1 i, 4 . a,,. ; 3,, e
- li.....
.;. g / 4 i f ** s %e 9 'J
- i en a g
't ..i r .s.'. - Denny: a- '? Received-call from Mark Good, Comex, on 10/26. He participated in the EP exercise with Region IV and has f no comments on contents on SALP report. It accurately reflects his opinion regarding the state of TU's a -emergency preparedness'. . i.. 3 Il *, ' ' ll S. 1 l: b 1 i I q.
y,. >1 _/W 4,, 9 't~ UNITED STATES NUCLEAR REGULATORY COMMISSION. t. =s g waswincrow. o. c. mss j ?y.... *.* OCT 23 1989 . MEMORANDUM FOR: Dennis M. Crutchfield, ' Associate Director for'Special Projects L Office of Nuclear Reactor Regulation-FROM:- Owen 0. Rothberg Engineering Issues ~ Branch Div'sion of Safety Issue Resolution Office of Nuclear Regulatory Research
SUBJECT:
NRC STAFF DIFFERING PROFESSIONAL OPINION ON CONANCHE PEAK By your memorandum dated October 10, 1989, you solicited coments on the draft i SALP report for Comanche Peak that was enclosed with your memorandum. I have no coments' to offer regarding the SALP report. 9 Owen 0. Rothberg Engineering Issues tranch Division of Safety Issue Resolution Office of Nuclear Regulatory Research l 1 i WWW Lp
2 I' ? ) \\ October 24, 1989 ( e MEMORANDUM FOR ' Dennis M. for SpecialCrutchfield,~ Associate Director Projects Office of Nuclear Reactor Reguistion FROM: Stephen P. Surras, Senior Resident Inspector, WBNP, ADSP Office of Nuclear Reacter' Regulation
SUBJECT:
RESPONSE TO NRC STAFF DIFFERING i PROFES$10NAL OPINION ON CDMANCHE PEAK ~; In accordamce with your concerning the recently request of October 10, 1989 - i completed I Licensee Performance process and Systematic. Assessment of letter for boara, I am submitting-this your review. After reviewing this proposed the recent meeting of the SALP Woerd,SALP repo-i present during agree with my. original I still assessment of the SALP Soard
- findings, LICENSEE *S PAST PERFORMANCE.THE SALP REPOR s
with any speculative or No individual has provided me -findings of the proposedconcrete evidence contrary SALP report. to the 4 Sased.en having SALP processes, been involved with numerous other f acilities I firmly board mee. ting was both accurate and a fair assessmentbelieve defined within the scope of NRC Manual Chapter NRC as was-conducted within c chapter. the guidance of Appendix S of =O516, and this t ! would for, Comanche Peak was correctly conductedlike to state tha S i ss: participant should resiste that The novice SALP-4 integrationt the SALP process is en of numerous and sometimes diverse views and opinions, information is carefully by each member of but as a group the SALP Board, considered and voted on not a single individual not have e nega,tive effect on our mission.to ensure that one indiv and Safety." "#uSlic Health In closing, I have every confidence in the accuracy and outcome of the recent SALP Board results and the methodol used to accomplish this geal. ogy -w ~ YL
4 -.? 1(;
- i.-
s i O' Should--you have Any-Questions or comments COnCerning any-'of my statements, please-feel free to. call me at 615-365-5488.- 9% Stephen P. Burris, Senior.Resieent inspecter, WSNP, ADSP Office of Nuclear Reactor Regulation 4 CCI C.-Grimes R. Warnick-J. Wiebe 'H..Livermore .I' 4
O.. I , [(pesc4 ;,- UNITED STATES S NUCLE AR REGULATORY COMMISSION c 3, 9~
- y'
'g REoioN ll ] 2
- o 101 MA AlETTA STREET.N.W, E
~ e ATL ANT A, GE0AGI A 30323 October 26. 1989 e.. 4 -MEMORANDUM FOR: _ Dennis M. Crotchfield. Associate Director for Special Projects Office of Nuclear Reactor Regulatsen -t FROM: Stephen P. Burr 15 Senior Resident -inspector. WBNP. ADSP Offace of Nuclear Reactor Regulation
SUBJECT:
PERSONAL COMMENTS REGARDING THE RECENTLy RECEIVED COMANCHE PEAK UNSIGNED MEMORANDUM l 3 Since my.former position as Senior Resident inspector at'the' Comanche Peak fac111ty was so prominently mentioned within the referenced memorandum. I felt compelled to respond to-certain comments made in that memorandum. First, I am not one of the referenced "NRC inspectors" mentioned in the memo, which felt that the SALP report was "neather accurate nor a complete reflection of TU Electric's performance during this SALP period." Should this have been the case, you may be' assured, based on prior experience. q thet IJwould be the first person to stand against.any~ report. l which.could Jeopardize the "Public Health and Safety." Secondly. Af the comment concerning a "2" rating in every q area-and no adverse-performance trends "1s incorrect-and invaltd" was a truism, then I did notahear this concern e< pressed or emplified by. any one of-the onsite inspectors. I ~ both before. during or after the SALP process and. board. I believe.the comments concerning the SALP Board members [ were totally unwarranted, unfounded and without substantiation from any quarter. This statement is based on a my experience in other SALP participations, knowing that-the senior managers are made fully aware of all activities and the results of'those activities performed by their R inspection staffs. During-the actual SALP Board meeting, I maintained a L physical count of the actual board votes for the chairman, and-to this day I can not honestly say that one indavadual wishing to' recommend.a "below average" performance was-sovelched, either directly or indirectly. In Sadition I did not hear any comments in which the board outright forbade the inclusion of any information which would have been detrimental'to the outcome of any board member vote. thereby giving:a false impression of the plant. Lastly, I have tried to ignore the various rumors which are E circulating concerning the author.cf the memorandum. 55b$DUGC 7 L
V i:, < However, 1.take exception to the rumor that I was the author, and some petty individual is even saying that I wrote the' memo and had-my wife type it...These types of statements go beyond the bounds of rumors.and'apeculation,- almost to the point of becoming an accusation. The reason ! am so upset _by these irresponsible accusations is that-! 'E have worked hard to achieve a good reputation in this - tndustry and innuendos of this nature could damage my career.. - 1 find this whole memorandum reprehensible, if the person or persons who authored this memorandum were in fact an NRC inspectors or contractors, then they either submitted it for personal. gain or they failed to live up to their oath of office, if in fact they-truly believe that the-health and safety of'the-public is in jeopardy. Based on numerous issues identified by the Procedures Review Team I led, we took the position that the applicant was not ready to operate at that' time. However, I personally did not feel that the applicant would not be ready to operate within a short period of time, provided they corrected the outstanding. concerns. In addition, the applicant personnel with whom I' dealt, were always responsive and eager to ensure that problems were completely.and-correctly resolved.- Both the positive and negative aspects, were discussed during;the exit for the Procedures Review Team Inspection. During.my. tenures as both the Resident inspector Preoperation Test and'aubsequently as the Senior Resident inspector, I never had the impression that anyone onsite or - in any'of the headquarters offices was.out to "give" the applicant a license. Therefore, as I have stated several 3-times before,~1 believe that the applicant is a "2" or an " average" facility for where they currently-are in the licensing process. I honestly believe that the SALP Board was not directed to "give" TU Electric and all clear rating, conversely a SALP Board rating does not guarantee the issuance of an operating license. - ! would like to thank you for taking the time to read this and for the opportunity allow me to " blow off some steam." - Should you-wish to discuss any of this information with me please feel to cantact me at 615-365-5488. a Ste en P. Burris, Senior Resident Inspector. WBNP, ASDP Office of Nuclear Reactor I Regulation
r3:. j$ *isig L' ' UNITID ST ATE S
- i f / -
[ '; NUCLE AR REGULATORY COMMISSION y 4-o' - . v.esmNr.1oN D c tma- .,. g.) '8 December 6, 1989 e.....-- , MEMORANDUM FOR: Frank J. Miraglia, Chairman DPO Review Panel on' Comanche Peak "FROM: Dennis ~M. Crutchfield, Associate Director for Special Projects Office of Nuclear Reactor Regulation
SUBJECT:
DIFFERING PROFESSIONAL OPINION ON COMANCHE PEAK The enclosed chart is in response to item #1 of your memo dated November.16, 1989 regarding differing professional opinion on Comanche Peak. This chart was prepared by Eileen Peyton of my staff. Also enclosed are copies of memos to file documenting telephone contact referenced in my November 3, 1989 memo. } enn Crute tel sociate Director for Special Project Office of Nuclear Reactor Regulation
Enclosures:
-1. Chart 2. Memos cc w/ enclosures: r_ J. Sniezek J. Partlow H. Smith l -dC.1 'O D v-
~, --.e FOLLOWlJ ON COMA 4CFE PEAK DP0 i Date Indivicual Contacteo Report Received Cor.tnent s C. Wilhans .11/22/M Yes No coments. J. Wiebe 11/22/69 Yes ho comments. 3 l .G. Hubbard 11/22/89~ Yes lio comerits. j R. Wescott 11/M/89 Yes Ne coments. l R. Latta .11/22/89 Yes Thought SALP process was gooo; changes that were made were concurred in by staff. l 'J. Ra p 11/22/89-Yes . Reviewed AIT portion which s he was. involved in --no [ coments. i A.-Singh 11/22/89-Yes No coments. R.'Azua 11/22/89 Yes No comments. T. McKernon-11/22/89 Yes lio coments. ~ R. Vickery 11/22/89 Yes No coments. J. Whittemore 11/22/89 Yes - No coments. -L. Ricketson-11/22/89 Yes No coments. D.-Powers 11/22/89 Yes No coments. l J. Birmingham-11/22/89 Yes
- No < coments.
Provided coments to Chris Grimes l in response to his 10/3 and 10/11 memo.
- J. Taylor 11/22/89 Yes
- No-comments.
Protided-coments to Chris. Grimes in response to his 10/3 and 10/11 memo. No specific hardware or plant concerns. Internal politics; no r i. relation to plant.
---..-...-....o (~ n.; i 3 2 Date - individual. Cor,ta cteo Report Receised Comments W. Richins 11/28/80 Yes
- No other comments besides the ones contained in resporise to-10/3 and 10/11 merac from Chris Grin:es.
D.-Graves 11/28/65 Yes No comments. K. Ker.ntcy 11/28/89 Yes No comments. J. Nicholes 11/28/89 .Yes No comments. D. Hurray-11/28/89 Yes No comments. J. Nicholas 11/28/89 Yes No comments. F. Victor 11/28/89 Yes No comments. J. F(11et 11/28/89 Yes No conments. - W. Johnson -11/29/89 Yes No comments. ' G. Bryan - 11/29/89 Yes No comments. . G. Stoetzel 11/29/89 Yes No comments. - M. Stein 12/4/89' Yes No comments. G. Wilford .12/6/89' Yes No comments. The following individuals owe return phone calls: - J. Cummins - returns to office on 12/11 'P. Chen - returns to office on 12/11 J. Kelley - is on sick leave; comes in office when health permits; left message for him to call C. Paulk P.- Stanish - contract expired end of October; may be back in for two weeks in December T 'These individuals' memos are attached to this chart. 1
L, j .Cin\\% e y, - V- /*]e m e. To Chro o rr y ), c l. G r i a, e.s, Di< e c +o w V C#= saeie is <h f'e ry e
- r O i vi r,
' 9 l' / > c e e f N "c /r- # ff e
- a r# e-Bep l<###n.
l 4*i 7 y, o w, / at Th o.i < e a p. + r e ,no ia fr
- r1
- n n s /
t es yo lV e r{ fh r$g e' r n es 7 rls t"r ) i n t A c t-! Vo i' i e s J., Cfr49 L4.,, t /. ,, e e v t r{ e l1 s t os 1 i e 'y
- l A r.
i d s. n -/~ t ! t *l ^ .e we o4t e n yefpoase. sy g,< ,4 /. //* w e : s e / e +y ? rsy < < s y a n.r e
- n., c < < n.1
- *s l r *nf s y s. n f a F o s.
/. ke j a rol/.e y. c o o ; /s. t s o n / i i ol rke 'C A l' rud re-le r asi c o a s r vn s + r * ^... ^ l l aa.-to<s h e I h a. < a - eenp e-r i e n na s o n a. e a.e
- pars h on s
.f-e.7 e ey r So r - rle. e f/r < r o o, la. < y J e n . f e ,, i i. r i.,, a ej i <, n. a j e lo s e. eo tie-e s r i na fa. ka i n y y e., (* < - a rt so Fei L o. </ el a t e. Op e ra t u e, s 4* s e < r~ ) e. e n I c e e r e *,l ol l a e y e-ssymen
- / de es t-p l^ n rE rooms s a ad a re.a.c o e.ry s re e s le n f co o my I ro Je a r e, e fa m a /'s a a a s. ot' c o - /o rre J/e-w i r t rL a i< <* a rra /. r sy i < /,. i r i,,.
is-,, rL., ris-lt s e n ri n g y'A
- s warranrr a /
- m a, al*/sy is
- ynseos, y n rk a < fa s < <
y W sc p<asano-a-i s <e p r e.r<. ro p e
- vi da.
o.rs a s.r.or a n t s / e.< s ole,s a rree n r ~ n a' r*- f re o.r e n.t-op e. e< f i.e/ apesa fin s,on er'- o/a e ~~i~.f a s Assre 7s s e h. e of < /a < p eusere.r. ~40 t>-TImt gl p lt. /fe y e r sf r 4 y t"l* e-lo r e * *s r o/ t t e n. s r
- y e s vs.
e s y i n e e r ra,y ~,. e a n r/ M
- re<voo w, 1 os c o p i
/ p(9 A /s fle.
- rdaf r-As. hon.l slrseanf af onasy
/frMfr
s v. i, yy n.s 7~n 7, cr A r, , v a rA< -
- ,,,,e
. i., a,eeesf,1y, e / *.i c. ela ti e, * ,<.4edn.ferf r, i J,; fu e / l.. A. H - e < < < rkt<a-ia aa .pp a,, nr-c A. y <- i,, r h a./eps 4 e/ rh -.. y 4,, e s s
- a. f
. s di, o.c pr e, / a, e.d er /d<ari r<<se s us.<
- s,
7 % a H is i, i p a /* rar, eat }. s,rasr 4 y e e <e,,. i de f o s.re r, si e s is in , a /r i oe.a rc< /y, s e hs b o ro ' ny vi e w Th e rg fo r c.,,f~ ' h a v e no e r n e *r* r 'br r A s tol*s * / * { a n, a s,,, rd. <.T pe r s, < a. ,, a a d /,<,A to s te i v' s. la [ c<p,,/icort t e o *r' p r o v e res. n r ris~ sees af re s i n e a s I r e se lm r t o e e e.d G A o < c. e v e,,, j r., /* e W. t n r"& fe e n } * - k e 9 e., d I n eg , !, n % f or n e [ +l s. c f n s f r k e t - t *,. a-/ .pa< arias,s-M, < y +,,,,, r Awa a,. e o,...- n.,
- c. w e e p t to re-vi s e r e s e ra i n.
15 7 u ss a / ready e y e.> e d f"E e. issue o h e i v' o } ls sl o n e-fle-<-t t s c y n a // v'y en y ,.$ra-f.,,,.. <enenr s.,..x ,c< 6,, ex r <r i.,pr I ecr< l is y,, y a e /y -- ; g o.s n. d a,,rf the ia e o - a r < <, y rds t-l 4aoe l p a n r ele / r e se n s oc < a,s. p ro o.p. t sly doe < s.* n r es a s s'f rt. *'t e. e **rf fo e ' pe /An t~ ino,o < e t--
- s e.
~ ~ fs~#~ #
- eyo o
- y l.
C**24rht. f est /,8f //Pr rf A ed'* ' / et i / /* /t *!Ab Yt e!M drAe e e.e d j'r a-C* esp lIno, e e.-
- io*d veyaores,eno's
.f.< stoesye ,~A tAs issas a / e. ffe <<tice pr o c e.d*
- e-na vr u a ed ra visirs e i rA e a s,,pr o J a,,.r > < ? e e e /r. t i
+
- l" k s.
te,p a e f a h f** 4 e l a r d-pr t r/* *
- e -l f
Mhy *J o
- ng a el e <,/ - r pro e e d>. < e a a<e. tuo is, a e a ya.
Vioeol i d a n t a r 'i a of,.1'h e o c. l y issaes epree e ra oe no e n, r conto.und yp/s a a n r- .. x' Wp ;W c. a wa,, en.,.
n.,a n m in 4 m. e,A,-- m +pa-s., -.,4, .ma., p. n
- 1 i
t $~ r= m - a b L, < e-se as,/..,1,/,eal c >,sa< i [ ( < o e, ole, <* ria <- f k u e. .ri,,Ie aaar=, 1-la n so r l f 4. I,. e ad< <a / Ar < //. f r4 a n c, eL r c r.ru i, M., r z' is
- 6. //, c i a, r I, o, n a r e.. rio,
.. n,/e i e s4r
- han,
,a. ? ria a c t i e, e,, < ,/ m o,,< < r i n,- o, k o f
- f f re, t h f 'r $s t le j!erenovek to hs-f u n fo fa r d j e r,,,
n o y e t, la ck =q te experi c o, e e o,l o y s e e f s e y t t oe. e. $ ba lu s ee, r k* r' WA 6 r s vi e s.- r l r$ s s in s fre e tir e, c o ny /s t ir - .r r a h s, i .1 e ff e e r o 1
- pa<<t<*-#
sn eir o
- s, n
a s / t l e v r a od'in g.r r o f op +<a rsta.r p e r c o r> *
- l = = rl r o
- a s ola r e <
( co n o ss or a er n iro l e / Cfs f"S tt ir [ wi ll erovirt's y odegn r L e a r.r < a s, c e rLar +- A< alws conse<n ,,,,,,e..,... i, - a.,,,s. To a <p / L j7 n..,4a~ } A Q != M= .,.,,,e. n -v. ~, -.
i ' /0: 0. 07He.S 23 lb /Pf ke-l $CIW, /M~' G dP V+A./ bcoh, 51s<ei Z.) w e no
- k. nac/ ear &mr4//A Aern
/eA6d'emeanu Lyarda edekica/ -s s u n. u - .t nwaA sy a w;& & leu &&r# &a 0:e 42My
- Afw, cneww A.
M
x p3 tf ot, 'o, UNITED s1 ATEs -i NUCLE AR REGULATORY COMMISSION 3 1 cg e wassmoton, o. c. roens - 49.....f OCT 2 41989 a 4 -MEMORANDUM FORi C. I. Grimes, Director Comanche Peak Project Division Office of Nuclear Reactor Regulation FROM:- William D. Richins, Consultant Civil / Structural Engineer
SUBJECT:
IDENTIFICATION OF COMANCHE PEAK ISSUES In response to your memorandum dated October 11, 1989, to all CPPD staff. I have no Comanche Peak Unit I concerns that are not currently being tracked by inspection reports or other public records. I have a good cooperative working relationship with Herb Livermore, Mike Runyan, and - Bob Latta; such that my concerns are adequately addressed and documented by the staff here on site. Regarding the SALP process, I have thc "ollowing conrnents: I compiled the Construction and Corrective Action Programs section based on several infonnal discussions with the construction group here on site (Chen Dale, Latta,- Richins, Runyan,andStanish). Each individual had written input and reviewed the final-product as it went to the SALP board. Joe Taylor also had the opportunity to review this section when he returned from time off. I believe that the group -. agreed with the contents of the section. I received very little guidance regarding which section (Construction and Corrective Action Programs, Engineering and Technical Support, etc.), various applicant activities should be addressed in. The result was, I believe, that several activities were moved to other sections by the SALP board. ~ I personnally wish the AFW events and the failure of the Borg-Warner check valves were more fully addressed by the SALP report as it went to the SALP board. I realize, however, that the AFW events were only part of the puzzle and that length constraints do not allow further detail. Q Q Q fLf y -f -- M
i V l
- c. I. crimes 2-007 2 4 1989 i
I believe that the perfomance ratings were justified and o'ere unaffected by the changes made to the SALP report ,i at the board meeting. If I can provide additional infomation, please conttct me. t \\ William D. Richins, Consultant Civil / Structural Engineer Comanche Peak Project Division Office of Nuclear Reactor Regulation i l S i i i e Wehmune e -g M .d -)e E D
r ?
- ,* si,,
d UNilt D sT A1( s - [ 4,.. /,' *; NUCL E AR REGUL ATORY COMMIS$10N I 3 (; g+pf,/[/ L e us-iscios oe20$$$ I' 4,, Decerter 7,1989 NOTE TO: ADSP Filts FROM: Dennis M. Crutchfield, Associate Director for Special Projects Office of Nuclear Reactor Regulation
SUBJECT:
RESP 0!45E TO COMAliCHE PEAK DP0 Luring a telecon on Octotser 12, 1909, with Philip Wagner, Region IV, he inforrred r;e that he had no coments on my OctoLer 10, 1989 memo regarding the hRC staff differing professional opinion on Comanche Peak, fM h< Der.nis M. Crutchfie , As ociate Director for Special Projects Office of Nuclear Reactor Regulation cc: F. Miraglia 7.- ~ A L..
V l ,,i++'..y'. f'. UNIT [D sT ATE s a i j [ ';8 NUCLE AR REGUL ATORY COMMISSION W A5MINGTON. D C 20tM b , s., p ....+ December 7, 1989 l 1 E NOTE TO: ADSP files e TkDM: Dennis M. Crutchfielo, Associete Director for Special Projects l E Office of Nuclear Reactor Regulation L SUBsECT:. RESPONSE TO COMANCHE PEAK DP0 s L During a telecon on October 26, 1989, between Mark Good and Eileen Peyton, the following was received in response to my October 10, 1969 i rner.c regarding the NRC staff ciffering professional opinion on Comanche f frak. Mr. Good particip6ted in the emergency preparedness exercise with Region IV end had no corments on the contents on the SALP report. He statec that it accurately reflected his opinion regarding the status of TV's emergency preparedness. 1 I
- chtei, ociate Director enn s for Special Projects Office of Nuclear Reactor Regulation cc:
F. Miraglia T.. f l .( 09 J-(7 L
.e p'" .e utaitD51 Alt 5 [ l', / NUCL E AR RE GUL ATORY COMMIS$10N 1 4 s,b ;,;./ E ne.swiscios o c 7w.', 3 4 /l December 20, 1989 MEMORANDUM FOR: Frank J. Miraglia, Chairman DPO Review Panel on Comanche Peak TROM: Dennis M. Crutchfield, Associate Director for Special Projects Office of Nuclear Reactor Regulation
SUBJECT:
DIFFERING PROFESSIONAL OP1NION ON COMANCHE PEAK This supplements my memo to you dated December 6, 1989 regarding the above subject. At that time there were five outstanding contacts to be made regarding the DPO. The enclosed chart provides the status of those contacts. There is still one person not available. We will attempt to make contact with him when he returns at the beginning of the year. /U Den is . Crutch i oci~ ate Director for Special Projects Office of Nuclear Reactor Regulation
Enclosure:
Chart L cc w/ enclosure 8 J. Sniezek J. Partlow H. Smith vA&fTo loi 4 4 q
E -l I J l I l FOLLOLUF ON COMAt.CHE PEAT: DIO i 1 Date ) [nd h icua l Contacted Report iteceived Commerit s J. Cummins 10/]9/89
- Yes, ho comments.
F. Chen 12/;9/S9 Yes. No comments, llot here long enough to form opinion. C. Faulk )?/19/89 Yes. No comments. i F. Stanish 12/20/89 Yes. No comments. Best not to answer memo, t J. relley is ch leave. He sheeld return to the office the first of the year. Messagts have been left for him to call upcn his return. t ? I he O+
m . Q l
- t l,)
i FEB :01985 Dockets:' 50-445 50 446-Mr. M. D. Spence, President. TUGC0 Texas Ut ities Electric Company i Skyway Tower i 400 North Olive Street i Lock Box 81 i Dallas, Texas 75201 i f
Dear Mr. Spence:
}
SUBJECT:
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE As you are aware, the NRL conducts a periodic systematic assessment of the performance of each power reactor licensee. This is referred to as the SALP program and yc., have received such assessments from us in prior years. We judge this program, which entails consnitment of considerable staf f resources, to be effective both in directing utility management's attention to weaknesses in company operations and in helping the NRC to plan its inspection activities and to allocate its resources. However, in light of the considerable attention that has been devoted in recent months by the NRC to evaluating the ~ plant and the company, we have decided to omit the currently scheduled SALP. t The next SALP assessment interval for Comanche Peak will be set when the present special NRC activities conclude. Original signeo ty Paul S. Check i Robert D. Martin Regional Administrator CC: Texas Utilities Electric Company i ATTN: B. R. Clements. Vice President, Nuclear Skyway Tower 400 North Olive Street ' Lock Box 81 Dallas, Texas 75201 Texas Utilities Electric Company ATTN: J. W. Beck, Manager. Licensing Skyway Tower s. 400 horth Olive Street /m ' Lock Box 81 i I Dallas, Texas 75201 }- e DRA/RIV RA/RIV PSChec.J RDMartin GM' 3BM 818886 M M 0 PDR-
December 4, 1997 Docket Nos. 50 44S/446 Mr. W. G. Counsil Texas Utilities Electric Company Skyway Tower 400 North Olive Street, L.B. 81 Dallas, Texas 75?01 \\ Gentlemen: j The purpose of this letter is to infonn you that the NRC plans to perform a j Systematic Assessment of Licensee Performance (SALP) evaluation for the Con,anche Peak Steam Electric Station in the fall of 1988. The evaluation period will be approximately twelve rnonths. The exact length of the SALP period may t>e affected by the status of licensing activities for the plant at that time. For planning purposes, we would like to assume the evaluation , period began on September 1, 1987, and will end on August 31, 1988. Althoilgh there is substantial work yet to be done to resolve the adequacy of i the design and construction of Comanche Peak and special NRC attention will i continue to be directed at TV Electric's activities by the Office of Special Projects, we believe that this is an appropriate time to resume the SALP 3 process. In this way, we expect to begin restoring normal regulatory practices at Comanche Peak. Should you have any questions regarding this letter or the SALP process, please contact Mr. R. F. Warnick. $1ncerely, j M Mh Stewart D. Ebneter, Director Office of Special Projects CC: See next page DISTRIBUTION: DocketFiles(50445/446) CIGrimes NRC PDR PFMcKee Local POR JELyons CPPD Reading RFWarnick OSP Reading AVietti. Cook i SDEbneter MMalloy JAAxelrad j?&kh49 jf PDR g ~ I DFG 1AD/IP:GPPD
- DIR:GPPD
- D DI :
P
- DIR:
M..:..............::............. l ...... :.......... g.... :.................'e r a d......... x
- S nets NAME :RFWarnick
- CIGrimes:
DATE :1?/l/87
- 1P/l/87
- 1?/A/87
- 12/J/87
'N b i m ,.y y
b 9-l /g** 08 %,'o, g-o UNIT E D $T ATEs jii i 3,1 ' ) NUCLEAR REGULATORY COMMIS$lON 4 W AL**tNCTON, D C. 20f,66 ~
- 'h October 21, 1988 in Reply Refer To
Dockets: 50 445/b7-40 50-446/57-31 TO Electric ATTil: 1:r. W. G. Counsil Executive Vice President 400 North Olive Street, Lock Box 81 Dallas, Texas 75201 Gentlerien: 1his forwards the report of the Systematic Assessment of Licensee Perf ormance -(SALP) for tomanche Peak Steam Electric Station (CPSES) Units 1 and 2. Ine SALP Board inet'on October 5,1988, to evaluate CPSES performance for the period of September 1, 1967, through August 31, 1988. The performance analyses and resulting evaluations are documented in the enclosed Draf t SALP. Report. In accordance with 11RC policy, I have reviewed the SALP Board Assessinent. I concur with the ratings. This assessment was conducted in accordance with the recently revised NRC 14anual Chapter 0516 with restructured functional areas. Because of this and also because of signifiu nt changes that have occurred since the last SALP report, coruparison with the last SALP was not considered appropriate. However, it is my view that overall perfornience at tPSES has improved markedly f rom the past performance. fly evaluation of the enclosed report is that performance in all areas at Comanche Peak over the past year has been generally characterited by strong programs, active management involvement, and a dedication to ensuring that the currection of construction deficiencies and preparation fer operations are executed thoroughly and conservatively. While some' deficiencies in the full implementation of Comanche Peak programs have resulted in perform 6nce ratings which are below likC's highest ratings, I believe that a solid foundation f or excellent performance has been established. This report is meant to be helpful in that regard. We expect to perform the next 5 ALP evaluation in conjunction with an evaluation of. the readiness for an operating license for Unit 1. The rating in_the security functional area received a Category 1 rating. This is commendable performance; however, the CPSES security plan is not in place ano, theref or e, performance in implementing the plan has not yet been assessed., it is the likC's experience that considerable management ettention 15 Decessary =j to ensure the security plan is properly implemented and personnel are appro-priately sensitive to security issues. The SALP assessment also did not include recent inspection issues (af ter the assessment perloo) concerning lost safeguards material and other events which indicate that personnel may not be suf ficiently sensitive to security issues. 1 110'.55fI GG102 [4(i gna noonor.oogr.g I ~.
I o 1 l TV Electric The retirigs in the functional areas that primarily enveloped the constructier and corrective action programs were evaluated as Category 2 in four areas (containment, major structures, and ruojor supports; piping systems end supports; auxiliary systems; and electrical equipment and cables) ano no ratings were assigned for three creas (soils and foundations mechanical cortponent:,, and instrurnentation) as a result of limited activity or limited i inspections. There were no predominant strengths or weaknesses that were comon to all these areas. The functional areas of safety assessment and quality verificetion, engineering and technical support, plant operation, and emergency preparecness all receiseo Category 2 ratings. Common strengths were management involvernent and control, and staffing. A common weakness was the timeliness of the analysis of, ano corrective actions for deficiencies. Management attention is necessory to ,l offeet improvements in the handling of deticiencies. Hatings were not assigned to the areas of maintenance and surveillance, eno radiological controls because of insufficient inspections in these areas. A manrgement meeting is scheduled with you and your staff on October 27,1%8 i to review the results of the $Al.P report. Withir 30 deys f ollowing this meeting, you are requested to provice your commen'; if any, to this of fice. Comments which you subrait are not subject to the clearance procedures of the Of fice of lianagement and budget es required by the Foper Wort Peduction Act of 1980, PL %-bil. A copy of your written coreents will t;e included in the final cistribution ci the sal.P report. Sincere ly, t' Original Siinti by-J. G. Partlow, Director Otfice of Special Projccts cc w/ enclosures: See attached . ccncer e e d % phone. CPPD:0$hAD:CPPD:0$P AD:CPP P AD:CPPDs:0SP 04:Y D:0$P CPPD:DSP 'JWiebe:ww HLivermore'RWarnick JLyons b JWilsdngQ PlwK e lb/Di/88 10/0i/88 10/Gi/88 10idt/88 10/O / W 10/ A /88 Ll$Db IV D:CPPD D:0IS V \\ vhtihoan (Grimes JPahthew 10/(i/88 10/01/88 10// /88 si r
. - - - ~ 2 1. INTRODUCTION The $ystematic Assessn,ent of Licensee Performance (SAlf) program is an integrated hkt staff effort to collect available observations and data on a periodlC basis ano to evaluate applicant performance on the basis of thib information. The l program is. Supplemental to normal regulatory processes used to ensure compliance with NRC rules and regulations, it is intenced to be sufficiently diagnostic to provide a rational basis for allocatiog NRC resources and to provide meaningful feedback to the applicant's nanager.ent regardir.g the NRC's assessment of the f acility's perf ormance in each f unctional area. A NRC 5 ALP Board, composed of the staf f nierbers listed below, met on October 5, 1366, to review the observations and data on perf ormance, and to assess applicant performance in accoroance with Chapter NRC.0516. " Systematic Assessment of Litensee Performance." The guidance and evaluation criteria are i suntarited in Section 111 of this report, lhe Board's F findings and iecommendations were forwarded to the hkC Director, Of fice of $pecial Projects, for approval and issuance. This report is the NRC's assessment of the appi tant's safety perturrance at Conunche f eak f or the perit4 Septe ber 1,1987, m through August 31, 1968. ihe SALP Board fur tomanche Fets was cur;civa v' Chairman: C.1. Grires Director, C0manch. Pea k Pro,*ect Divisibn Xem ers: J. L. Milhoan, Director, lite 1sien ui teactor Lefety. s R eg ic t' IV P
- f. McKee, Deputy Director, Coranche Peat Froject Division f
J. H. Wilson, Assistant Director f or i rt 'ects, ) Ccmanche Peak Progett Dig 1sien J. E. Lyons Assister.t Director f or Technical Programs. Cuinanche Peak Project Livision R. f. narn1LL Assistant Director 'or 'nspection Procraris, Lon.anche Pea k Prof ec t Liv is tori
p. 3 H. H. Livermore. Lead Senior inspector for inspection Progrars, Comanche Peak Pro ect s Division
- 5. Wiebe, Senior Project inspector for Inspection v.
Programs, Conanche Peak Project Division The following personnel also participated in the $ ALP Doard [ tree ting. J. L. Birmingham, Parameter Consultant for inspection Programs, Comanche Peak Project Division
- 5. P. Burris, Senior Resident Inspector (Operations) for Inspection Programs, Comanche Peak Project liivision 14 L.* Graham, Parameter Consultant for inspection Programs, Comanche Peak Project Division B. Murray, Chief, Radiological Reactor Programs Branch, Region IV W. D. Richins, Parameter Consultant for 'nspection Programs, Comanche Peak Project Division
[ M. F. Kunyan, kesident inspector for inspertion Programs, Comanche Peak Project Division P. Stanish, Parameter Consultant f or i n s pe t '. i o r. s Programs, t,umanche Peak Project L vision J. L. Taylor, Parameter Consultant f or Inspection Programs, Comanche Peak Project Division e
. f. A. Applicant /fikC Activitie4 The previous SALP report was for the period October 1, 19P2, through October 31, 1983. The SALP process fer the Comanche Peak Steem Electric Station (CPSES) was sus;) ended by letter dated February 20, 1985, because of the considerable attention that was already being devoted by the ilRC to evaluating the plort and the company. Dy letter cated Decerber 4,196', the liRC notified the applicant of the.f4RC's intent to perform a sal.P evelvation in the fall of 1958. The letter stated that although there was $bbstantial work yet to be done to resolve the adeyuacy of the design and construction of Comanche Peak, the IGC tielieved that it was appropriate to re,sume the SAtP process. This is part of the liRC process of restoring normal regulatory prar.tices at Comanche Peak. By letter dated January R 1988, the flRC st6ff approved the Comanche Peak Response Team (CPRT) program plan (Pevision 4) ano the Corrective Action Program l CAP) as the n,eans by which TV Electric would: (1) identify design and Construction deficiencies (2) develop and implement oppropriate corrective and preventive actitts, and Q) conduct these ictivities with ef fectin management controls. 'n l' arch 1968, the f4RC stait issued 55ER.l.' aich evaluated TV Electric's correttive actions related to the design of large enc small t.cre piping anc pipe supports. In July 1968, the staf f issued 55EPs 15 and 1( whiCh documented the staff's review of the applicent's comprehensive program for reschinry technical concerns associated with the design of cable tray and cable tray hangers and with the design of CCnduit supports, respectively. 55ER$ now in preparation address-technical disciplines (mechanical, civil, structural, electrical, l&C), hVAC supports, cQuipment qualification, and (PRT Collective evaluation, k On June 30, 1988, Cituen's Association f or bound Cnergy (CASE) Texas Utilities Electric Company (Applicant), and the fiRC Staff entered into a Joint Stipulation to withoraw the contentions sponsored by CASE in the operating license and construction permit amendrent proceed 1Dgs. CASE, the applicant, and the l4C Staf f
-4 7 Performance Fynctional Ca tego ry Ferformance f.rea (9/1/57 - 6/31/88) Trend' i A. Safety Assessnent and Quality Verification 2 none D. Engineering and Technical Support 2 none i ) C. Soils and Foundati..is NR N/A D. Containment, Major Structures, and Major Supports 2 none E. Piping Systems and Supports 2 none F. Mechanical Components NR N/A l G. Auxiliary Systems 2 none h. Electrical Equipment end i Cables 2
- r. ore l.
Instrumentation NR N/A l J. Plant Operation 2 a e r.e A. Maintehance and Surveillance
- P, N/A j
L. Emergency Prepareoness 2 none l M. Security i none N. Radiological Controls NR N/A Note: NR = Not Rated; N/A = Not Applicable Performance Trend: Applicant perforrtance curing the last quarter of the assessment perioo is examined to determine it' e trend exists that coulc be used to predict applicant performance curing the 1 f trst few ncnths of the next assessn.ent period. It is reserveo for those instances when it is L necessary to focus NRC ond applicant attenticn un on area with a ceclining performance trend, or to acknowledge an improving trer.o in performance.
- j
-}}