ML20011E439
| ML20011E439 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/03/1989 |
| From: | Crutchfield D Office of Nuclear Reactor Regulation |
| To: | Miraglia F Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20011D121 | List:
|
| References | |
| NUDOCS 9002140043 | |
| Download: ML20011E439 (5) | |
Text
r:
~
D 3
g3 C8 2g'o, i
s d
UNITED STATES j". A ff' i -
NUCLE AR REGULATORY COMMISSION 4
e wassincton.o.c.20ssa k, x
/
November 3, 1989 4
I!EMORANDUlt TOR:
Frank J. Miraglia, Chairperson hkR Standing Review Panel FROM:'
Denriis M. Crutchfield Associate Director 1or Special Projects Office of Nuclear Reactor Regulation
SUBJECT:
DP0 CN COMANCHE PEAK SALP 09 October 10, 1989 c aemo was sent to "All NRC Staff Involved in Inspection Activitiet. related to Coraanche Peak."
It went to 8 HQ inspection personnel, 7 site or former site inspection personnel, 24 rq ional inspectors and 14 consultants.
In that memo, the inspectors were asked to review tb initial SALP report and submit any coments on the SALP Board's findings by 0:tooer 15, 1989.
It wet indicated that the coments could be provided anonymously but they shoult: 14 as specific as possible.
Tc cate, 21 responses have been rece b ed.
Copies of those responses are enclosed for your use.
In general, the responderts have no problems with the
-report as written or the process used to prepere the SALP. Also, there were no'negatise findings on the qualifications of the Board members.
Coments received in the areas of Security, E0P's and the AIT check valve problem l-have receivec additional consideration and are discussed below in further
[
ceta W.
A Region IV Physical Security Inspector previoed some added views on the Comanche Peak Security Program and SALP rating, lwo of the views deel with errors that are straight forward to correct and do not affect the overall rating. The third comment dcals with the fact that the security inspector feels that the pre-up 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 section enief feel
'that the security program should be rated a Category 1 for the Comanche Peak pre-op phase, I recommend that the Security section of the report be changed to better i
t I
reflect the impact of the lack of completion of construction had on the rating but that the rating of "2" for Security stand.
Copies of the changes that are appropriate are enclosed.
i Q QUllH S Q
bh V
/
i
frank J. Miraglia
.[-
November 3, 1989 1he second aree of comment clated to the E0P's.
The responder did not have a problem with the overall rating or the inforn.ation provided in the 5 ALP.
Rather, he felt that the E0P team's inspection report (not available at the
.tirae of the Board taeeting) could provide additional details concerning engineering review of the ERG's and the applicant's QA involvement in the review of the EkG's.
Including this information in the SALP report would provide additional exaroles to support the findings. Sirice it would not result in a change to t1e SALP Board's findings, I do not think the report should Le changed to include this information.
The next area raised in tht. responses deals with the AIT check valve problem.
No issuct with the SALF were raised but the individual was concerned with followup of the borg-Werner valve problem at Conanche Peak.
Both issues raised (i.e., need for corrective action before startup and generic action) have Loen addressec by TV and the staff. No action for the SALP report is recorrended.
Ar.cther respondci t telt thct perhaps the borg-Warner problem could have beer, ciscussed in Fore cetail, but did not object to wh6t was done in the 5 ALP report.
Fintily, most had no coment cn the SALP process. A nun.ber of those ar.svering the reno felt thot the process and report were f airly done, der.e in accorcunce with the I:anual Chapter, and accurately reflected the applicant's performanct,.
I havt ir.cluded copict of all respcnses received to date.
If others are suhritted, copits will be scnt to you alco.
Denn C
fec, ss. N ctor for Special Projects Office of Nuclear Reactor Regulation
Enclosures:
1.
Mark-Up SALP.Pages 2.
Responses Received cc w/ enclosures:
J. Sniezek J. Part10w I
i
ip/ly'a y
'a'
&fY
/
- ak
., s b l Ei h a bJ 1 l ui.;
W L.
C.
Wa 1 l l ena. NhR' I pg,[f,,,,,,c/;./
.l. ba rmingham (
- /
D.
F.X Uor.L i n. NRh f
P.
ht ani sh c a F.
5./(Ashe. NER S* U f,g, W. Richanst
.g J.
6.
rJtebe. Nhh J.
Tayl or t
,ygo 5 N. H.xLavermore. NRR P. Cheng
!-/ G.
T.
Hubts ar d. 14hk Consultantu - CPSES 51te 4 R.
G. Weccott. NRN M IR. T.X Hog an. NRh reeaggp*w'EM J. Nicholas (_
> W.
D.
Johnson. NRR 5 E. D.Xba t t er. NhR M 430
'8attelle Northwest Laboratory battc11e blvd. Si gma 3 bl dg.
s M.
F.X Run v e n. N RNA' "'N#> 'O Ri c hl and. Washington 99352 s R.
M.
L e t t t..
NhR S.6.
P.X Burr 1 s.' NRR /#M ' ' f f
- NM F.
Vi c t or(.,
M J.
Rajan. Nkh Sonalysts. Inc.
>l D. D.x R o t h b er g. 'RE S J e/E F n a Fr *Nd"* P. O. bon 2bO. 21b ParLwav North rt A. 52nch. HIV Watepford. Conne.cticut 00385 A P. C y, WE.gner, kl V - ID)7.l<fm. r10 $t p k/fotr 8-C..
J.
f-mull. Rlv G.
R.
bryan, Comen Lorp.c' it C.
J.p( Ha l e.
R1V
/DN 5
- P.D. bon 21b3, 2021". Pugh hoed 4 h.
V.
M u c.. ElY Foulsbo. Washington 98070 8 i3. E.* Gaoli er do. klV 4 1. Q. Mciernon. R]V 2). B.)f Wat er s. Frasuta-Feckmanc.
S R.
b.
Va c 6 er v. h a '.'
5300 Sweetbraar brave @*%%l$
A J.
L.
Lun.mi n t. k1V Raleigh. North Caroli na 2[oM 4
v.
L.
FeJ4et. hlv k D.
N.
bra ms, Rlv G.
M. Walford. SAIC C 4 J.
E.
Nh a t temor e. klV 1321 husearch Pari: Drave d K.
M.
Iennedy, ElV Dayton, Ohio 4S432
- D.
A.
Pcw'ru. RIV-4 N.
M.glerc, RIV
/o['*F N /W# N% M.sGood
(_+t\\**.* 40 M "
- f* # "
(
4 J.
6.
Lull v.
klV M.
N.
S t u a n f--
) 4 R. L.XCaldwell. klV /p /s p. S A ta9 j, ( D. H.ESchultc toh r Ho ProWaw 2 A.
b# Earnest. RI V Wib/a~l,30 G.
A. Stoht:e1 d R. J.YEverrett. R1 VAe: -cd 8 4i Pactiic Northwest Laboratorv
/- b. Murrev. RIV A H.
DJ(Lhaney, RIV
"#b k/0 V80 A R. EX baer. RIV M *D &
A i
b.
b.
- Nichojac, h* 1 V J
L.
- 1. HacLetson. NIV l
$ kn Vle-rdos Lt
, A A$$, f
- S 8 I'l}'
I 4
i j
- 2,3 4, problems and is worktfi olution of the remainder.
The applicant's security or;anization has implemented an aggressive program for tw self-identification of security problems to ensure compliance with the requirements of 10 CFR Part 73 and the Physical Secarity Plan (PSP). Corrective actions initiated as a result of the applicant" :M" 'n'cally correct and
/s 7.;;. or NRC identified prchlums have been tech i 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 officers, and security support personnel assigned to the security department to implement a proper security program during normal operations during the transition fron, construction-to operation. However, during the transition from construction to operations overtime use appeared to be excessive and, tius, could have a ne eftactiveness. gative impact on security staff Applicant management has recognized this problem and has initiated actions to hire more security personnel. The lines of authority within the security force are clear and well-understood. -Ntr e s A
o.,m oc co...
wge :..m 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 L
applicant's policies and procedures. The applicant i
has establisied the necessary procedures to provide for the implemunution of a proper security program.
The transition to a security organization responsible for safeguarding an operating nuclear power plant from a long-term 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 i
phased lockdown of the protected and vital areas on July 1, 1989.
Phase 1 was completed and portions of l
Phase 2 were accomplished prior to the end of this i
assessment period.
It appears that applicant management did not recognize that the plant was not ready to enter into the final phase (hard lockdown),
but has since acknowledged that fact.
The applicant has cemitted to performing an internal security
l T.1 24 fas
., a.
L' i ti'i!.
o program self-evaluation, to correct any deficiencies identified and to infom the NRC when they consider the plant ready for completion of the preoperational inspection. based on the preoperational inspections completed to date. It appears the applicant has established the basis for an acceptable security-program.
The applicant's submittals 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 security related activities.
During this assessment period, there was consistent evidence of prior planning and involvement by utility management.
2.
Performance Rating The applicant's rating is Perfomance Category 2 in this area.
The change in rating from a Category 1 (last SALP perioc) 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 security equipment which demonstrated the applicant's i
commitments to the security program. The applicant had not yet implementeo the security plan.s The present SALP rating is based on additional hetivities necessary to demonstrate implementation of the physical security plan which was schedule /to occur j
after the SALP period ended.
3.
Board Recommendations a.
Recommended hRC Action Tb
,/
None.
Af b.
Recommended Applicant Action p,'3, M
i None.
- /4 "O G.
_Radiolocical Controls Rw we w 1.
Analysis g@M y
The assessment of this functional area consists of activities directly related to radiological controls, including occupational radiation safety (e.g.,
occupational radiation protection, radioactive
)