ML20011E441
| ML20011E441 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/20/1989 |
| From: | Caldwell R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Crutchfield D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20011D121 | List:
|
| References | |
| NUDOCS 9002140047 | |
| Download: ML20011E441 (3) | |
Text
p eM N UNITEG) STATES
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~ j' REGloN IV S
$11 RYAN PLAZA ORIVE, SulTE 1010 ARLINGTON. TEXAS 79011 October 20, 1989 MEMORANDUM FOR: Dennis M. Crutchfield, Associate Director for Special Projects Office Of Nuclear Reactor Regulation FROM:
Ronald A. Caldwell, Physical Security Inspector Security & Emergency Preparedness Section Division of Radiation Safety & Safeguards t
SUBJECT:
DIFFERING PROFESSIONAL OPINION ON COMANCHE 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:
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 I 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 erroneously 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 period was changed to include the month of August 1989 and a subsequent inspection in the month of August uncovered a minor 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 SMP raport.
l The last full paragraph of Part F, Security, Performance Rating, is in error.
The SALP Board's conclusion that the soplicant'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 i_
program area.
I have performed four previous pre-operational security program inspections of Region IV applicants for a license.
In three of the four pre-operational inspections, which I have performed in Region IV, the f
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Dennis M. Crutchfield applicant had a marginal security program that apparently was the consequence of inadequate 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 inability to lockdown is not a measure of the security organization's performance, but a measure of upper management's inability to complete construction activity in a locked down posture.
The applicant'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 SALP rating in this program area.
The SALF 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 5 ALP 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 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, i
07 onald 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
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