Text

Expresses Concerns Re SALP Process & NRC Decision to Issue SALP Rept W/O Adequate Consideration of Negative Findings
	ML20012D210
Person / Time
Site:	Comanche Peak
Issue date:	02/26/1990
From:	Ellis J; Citizens Association for Sound Energy
To:	Taylor J; NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
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ML20012D206	List: ML20012D205; ML20012D210;
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	Download: ML20012D210 (2)
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3 T C A S E==

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(CITIZENS ASSN FOR SOUND ENERGY)

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February 16, 1990 I

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Mr. James H Taylor Executive Dir ect or f or Operations U. S. Nuclear Regulat cry Commission F

Wa s hi ng t on, D. C.

20555 Dear Mr. Taylori Subjects Texas Utilities Electric Company,

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( Comanc he Peak St eam Electric Station.

Uni t s 1 and 2). Docket Nos. 50-445/50-446 Res pons e t o Tobruar y 5.

1990, letter to CASE Attorney Billie Parner Gerde from NRC's. James M. Taylot, and Response to February 5.

1990, letter to j

William J, Cahill Jr.

TU Electric, f rom NRC' s De nni s M. C r u t c hf i el d, r e g ar di ng SALP Report (NRC Inspection Report 50-445/88-B5 and 50-446/88-81)

CASE has received copies of the two above-referenced letrers regarding the r

SALP Repert.

We continue to have the same concerns r egarding both t he SALP pr ocess and its application an this particular instance, and ar e disappointed that the NRC decided to assue the SALP Report wi t hout what CASE belsoves to be adequate consideration of the negative findings whteh were the basis for CASE's original c onc er ns.

appr opriat e f er CASE to provide you with a copy of the A t. t hi s time. it is I

matrix which we have pr epar ed ut111:1ng the dr af ts of t he SALP Report. We I

believe the matrix is s elf -explanat or y.

l' Sincerely.

l CASE (Cata= ens Association f or Sound Energy)

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' Mr ' Chr as.t opher I, G anos. ' Dir oc t or, Comanche J Peak Pr o) set Davision.

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'. Ma i-R; ' G, War nick, As sis t ant Dir ector f er. Inspection Program '- Comanc he Peak Project Divasaon', NRC-Mr; William Couns21. Vace Chairman, TU Electrsc -

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Mt. W. J,. Cahill. Jr i. Executive' Vic e Pr es a dent.- TU Elec t r a c -

Dr. Aus af Husaa n,' Chairman. : Oper ations Review Committ ee.(ORO). ' TU,

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Mr. Georgei t.:. Edgar. Esq., Newman' & Holt: anger. P. C.

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Ms. Susan Palmer. Stipulatson Manager. TU Electrac.

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Robinson, Rchinson, Peterson, Berk, Rudolph, Cross & Garde Mary Lou Robinson Attorneys at Law Nila Jean Robtnoon los East College Avenue

' John C. Peterson Appleton. Wisconsin 14911 Avram D. Berk (414> 78111:17 hiichael Rudolph Green Bay 494wo0 i

Dan Cross Fax 780w41 Bittle Pirner Garde November 20,1989 James M. Taylor Acting Executive Director for Operations j

U. S. Nuclear Regulatory Commission Washington,D.C. 20555 Re: Systematic Assessment of Licensee Performance for TU Electric (September 1,1988 - July 31,1989) l t

Dear Mr. Taylor,

i As you know the Citizens Association for Sound Energy (CASE)is concemed with the integrity of the regulatory process as it affects the Comanche Peak Steam Electric Station (CPSES), Throughout the history of CASE's involvement with Comanche Peak it has been occasionally necessary to take strong exception to the actions or decisions reached by the NRC staff about Comanche Peak when CASE had reason to believe such were not substantiated by the facts and evidence available to the staff. CASE had hoped that the establishment and presence of the Office of Special Projects (OSP) would insure that l_

regulatory process regarding Comanche Peak would be accomplished in accordance with the establishe; regulatory programs for nuclear plants under construction. In fact, on the whole, CASE has been pleased with the perfonnance of the on site OSP inspection effort. Therefore, on the eve of project completion, CASE was extremely disturbed to learn that the NRC's assessment process for Comanche Peak had been j

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compromised.

L CASE, as you know, received a copy of the memo and supporting information that was sent to the j.

Commission by "NRC Staffinspectors." ne memo was very critical of the NRC board's assessment of l

performance and the SALP process. It is our conclusion that evidence exists to demonstrate that the regulatory process was,in fact, compromised to the point that CASE believes a new evaluation should bc considered. Although the basis for our position (that the S ALP was compromised) is discussed below,it is even more importar.t to note that our review and analysis revealed that the use of the S ALP process for Comanche Peak at this time was inapprop-iate and, thus, inherently problematic.

L The restan of the SALP process for the period September 1,1987 to July 31,1988 was inappropriate bec as of rformance (i. e, redesign and tework) were still less than Category "3" as I

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defined in MC 0516.3 'Ihat is. NRC Manual Chapter 0516, paragraph 1, describes an evaluation process that assumes that a nuclear plant either falls under the construction or operational category and meets i

minimum regulatory requirements. Unit I at Comanche Peak fits neither category because the plant was considered ready for fuel load in 1984, but was subsequently deemed not ready to load fuel and operate as a result ofidentified problems. This caused the NRC to increase and maintain a staff at about 10 times above the normallevel.

The SALP pmcess was suspended by the NRC from 1984 until 1987 because of TU Electric's massive corTective action program (CAP) to address eleven specific areas of design and construction problems. It is CAS E's understanding that this suspension recognized that TU Electric's performance was by definition i

less than a Category "3." Using the S ALP process is ill fitted for evaluating TU Electric, a utility that has j

been unable to meet the minimum regulatory requirements for over a decade.

1 In support of this position, CASE points out that at the end of the SALP period, TU Electric had not completed the corrective action program, had well over 37,000 open items, and has cxperienced significant QA program, QA management, and technical problems during this S ALP period. Fortunately, the NRC inspectors recognized that something was just not right about the S ALP process. It is not surprising that applying the SALP criteria and attributes, included in the Appendix of Manual Chapter (MC) 0516, for 1

evaluating licensee performance, would be problematic when the plant being evaluated is under reconstruction, and not yet in operation.

CASE believes that under the unique situation at Comanche Peak the recent S ALP should have followed the NRC's review of operational readiness by the Operational Readiness Assessment Team (ORAT). We do not understand how the board could even perform a valid S ALP without the information provided by the ORAT. The recent NRC's operational readiness team inspection identified serious deficiencies which supported the concems voiced to the Commission that the plant was not yet finished or ready. At the exit the ORAT gave very negative findings and emphasized that all actions necessary for a low power license should be complete before the ORAT is called back to determine if the license should be granted.

If the agency decides to use the SALP process at Comanche Peak, our evaluation indicates that a new S ALP evaluation should be considered and should follow the final operational readiness inspection. CASE believes that the standard SALP process should not be used at this point but a special modified process I The categories for rating performance are defined as follows:

Enclosures:

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i ATTACHMENT 1 DETAILED REVIEW OF S ALP 1989 The NRC requires a Systematic Assessment of Licensee Performance (S ALP) annually. It is an integrated NRC staff cffon to collect and evaluate performance information from a variety of sources. The standard S ALP process for nuclear plants nearing the end of construction includes functional areas that specifically i

pertain to plant operations, i. e., plant operations, maintenance and surveillance, security, radiological controls, and emergency preparedness. In addition, at the end of construction the operations depanment would normally have a strong input in other functional areas snch as procurement.constniction, and design where work is virtually complete. Under normal circumstances the NRC inspection program for construction is also virtually complete and preoperational te sting and operations inspection modules show operational readiness. This was not true at the Comanche Peak Steam Electric Station (CPSES) for the 1989 SALP period.

The history of SALP evaluations at Comanche Peak is unique. After the NRC Technical Review Team (TRT) found serious problems at CPSES the S ALP process was suspended for 1984,1985, and 1986. In July 1987 the NRC restaned the S ALP process and issued a report for the timeframe covering September 1,1987 through July 31,1988. It should be noted that the evaluation of performance documented in the 1

1988 and the current draft SALP reports tre evaluntions of a corrective action nrogram for desien and construction That is, because the initial design, procurement, engineering, construction, and quality assurance actions could not always be pmven, much of the design and construction in Unit I had to virtually be repeated in order to meet regulatory design, construction, and quality assurance requirements.

Because all work in Unit I was virtually complete, subsequent work was actually corrective action and any failures to successfully complete the project a second time should raise serious questions about management's ability to continue the project. The applicant's failure to promptly identify trends of repetitive denciencies and/or correct significant deficiencies demonstrates the inability of the TU Electric QA program to understand the cause of deficiencies and preclude repetition.

- Based on our review of the available materials it is clear that the NRC should have, but did not, perform a formal trend analysis of repetitive deficiencies identified by the NRC. Instead the SALP Board made general statements that major or minor violations were not repetitive and did not indicate a prograrn breakdown. The narrow and subjective use of the term " repetitive" precludes Gnding any repetitive deficiencies. As applied it almost means the exact same thing happening again or occurring within this S ALP period. There were a number of violations in this S ALP period that were similar to violations that have occurred in the past. For example, repetitive is narrow if the failure to adeountelv insnect in the electrical area is considered to be nonrepetitive even though the same problem (i. e., failure to adequately inspect) existed in the mechanical. Even more extreme, the interpretation of repetitive would render a failure to inspect in the mechanical discipline nonrepetitive because the first case involved welding and the second involved a failure to inspect maintenance area. Yet, in all cases there was a failure by the Quality Assurance / Quality Control department to perform adequately and according to procedures.

EVALUATION OF DRAFT SALP REPORTS The following findings are based on the evaluation of the initial information that NRC site inspectors included in the draft S ALP reports, drafts submitted to the board, and the initial draft SALP by the board t

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' and in cenain cases other infonnation about the process which was provided to CASE. Our analysis followed the NRC's own criteria in MC 0516. The S ALP requirements set fonh specific criteria for rating esch functional area: construction / corrective action program, engineering / technical suppon, safety assessment / quality, plant operation, maintenance / surveillance, security, radiological controls, and emer-gency preparedness. The following specific criteria were set fonh for evaluating each functional area:

Assurance of Quality, Approach to Resolving Technical Issues, Responsiveness To NRC Initiatives, t

Enforcement History, and Operational and Construction Events. In Table 1 of the appendix of MC 0516 detailed attributes are set fonh under each respective criterion and required in order to evaluate perfor-mance in an organized and unifo:m manner.

I. Narrow Interpretation Of " Repetitive" The criteria concerning enforcement are not properly addressed even if one were to accept the narrow and

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subjective de6nition of " repetitive." (See the Introduction of MC 0516 which states that, as applied, repetitive deficiencies or NRC violations would rarely be identified). The draft SALP report tables only

~ list the severity levels of NRC violations. No formal trend analysis was performed by the NRC. For example, general criteria, such as failure to take corrective action relative to the criteria of 10 CFR 50, Appendix B were not addressed.

Ahhough no formal trending was performed, it is CASE's understanding that inspectors attempted to point out the repeat program weaknesses in the initial drafts, i. c., TU Elecuic's QA program was still not identifying and correcting problems that are now pan of their corrective action program. (See Section IV.

A). For example, the pipe suppon angularity suppon problem that finally had to be identified by the NRC and resulted in the reinspection of over 5000 suppons and required a significant amount of rework, in subsequent drafts, this negative finding in Section IV. A. was rewritten and the statement about inadequate configuration contml was dropped. In Section IV. B. of the SALP Board's version of the report it only stated that an effective configuration control program was implemented. This change substantially alters the message being given to TU Electric and the public about the repetitive nature of this problem.

11.SALP Board Composition Several years ago S ALP boards were generally composed of fewer managers and supervisors, but had a larger number of inspectors who performed the inspecuons, had a personal and direct involvement with an applicant orlicensee, and voted. As the Regions have become top heavy with more and more managers, the Board composition has steadily changed in the other direction where the senior resident inspector i

(SRI) is the 'only working level person on the Board.

Since the SRI is classified as a supervisor, no working inspectors are usually on the board. The SALP Boards for 1988 and 1989 at Comanche Peak were selected by the Office of Special Projects. They went a step further than the rest of the Agency and removed the senior residents from the board.

The composition of the first board was lopsided and stacked with 5 high managers who had no day to-day involvement with inspections versus one site manager and two site supervisors who did. (See the early draft report which initially indicated that the board would be composed of: Special Projects Director and Deputy Director of Comanche Peak Project, Assistant Director for Projects, and the Assistant Director l

for Technical Programs who were from HQ; the Director of Reactor Safety Division who resides in L

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Arlington's Region IV Office and; the Assistant Director for Site Inspections and two site supenisors who are responsible for inspections but did not do a significant amount of inspection.)

The final board composition became even more lopsided. Two more Region IV managers were added l

who had no day to-day knowledge of the site inspections. This made it appear as if the S ALP board was structured to assure votes that would result in a rating of category "2" or to have undue influence over work that they did not have first hand knowledge of.

Senior inspectors had no vote and would have been outvoted even if they had been allowed to vote as board members. The eleven to twelve site NRC inspectors / consultants who did the work had the least say in the whole matter. It is CASE's understanding that the SALP of 1988 demoralized senior resident inspectors because they were not on the Board. In the 1989 SALP report the SRI for construction was not even acknowledged as participating in the process. Even worse his input, which was very negative and was provided to the Commission in a memo, never showed in any draft of the SALP report or was given any consideration. This is in drastic contrast to the 1982 83 timeframe in which the opinion of the senior resident for construction was relied upon heavily by the NRC staff in the licensing hearings in support oflicensing.

III. Functional Areasinappropriately Weighted And Condensed An original SALP draft showed confusion about whether the main areas to be evaluated were in construction or operations. That is, on page 7 in Section I. A.," Introduction" of the initial draft it addresses the applicant's activities (performed during the S ALP period) necessary to complete the Corrective Action Program (CAP) and other activities necessary to demonstrate operational readiness. Eleven areas concerning design and construction were referenced and were stated to be in the applicant's Project Status Reports but these areas were not specifically addressed in any of the S ALP drafts. The eleven functional areas appeared to be lumped into one or two areas. Accordingly, construction had two areas compared with six areas in operations even though the plant was not operating. Specific areas for construction were not addressed per MC 0516: soils / foundations; containment, major structures and steel supports, piping systems / supports; mechanical components, auxiliary systems, electrical equipment / cables; and, in-strumentation.

Section 1. B of a draft stated that the majority of NRC inspections covered the applicant's CAP and preoperational testing. Then it stated that other NRC inspections covered operational readiness, indicating less inspection in this area. On page 11 of an original draft it showed the eight functional areas, described in the Introduction of Attachment I above, and designated NRC operations as lead in six of the eight areas.

IV. Specific Information Excluded The NRC's draft SALP reports for the period September 1,1988 through July 31,1989 are two examples of a weak regulatory policy regarding TU Electric's failure to determine the root cause of conditions adverse to quality and preclude repetition, in the case of the removal of a coating from service water system there were multiple breakdowns in TU Electric's technical and quality assurance programs but the January 9,1989 Notice of Violation downgraded the Level III violations recommended by all NRC personnel (senior resident inspector, inspector's site supenisor, assistant director for site inspection 3

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program through the Director of the Comanche Peak Program). 'Ihe draft S ALP reports do not really address the senousness of these program deficiencies. The exclusion of these matters appears especially suspect since the final SALP excludes the negative comments about Unit 1, but praises the corrective action taken for work on unit 2 service water system, i

The issue of TU Electric's response to the service water system enforcement action not being accurate i

and complete was not considered in the as yet unissued NRC inspection report 50 445/89 23; 50 446/89-

23. The NRC deferred the evaluation of this issue effectively forever by referring it to be investigated and considered in the next S ALP. The subject performance goes to the character and competence of TU Electric relative to completely and accurately evaluating and reporting matters to the NRC. This is a very important area for an operating plant and should have been evaluated. It is hard to believe that NRC management deferred addressing or considering taking action on the repeated failure of TU Electric to have a program that controls safety related work.

A second example is the failed check valve problems in the Auxiliary Feedwater System. TU Electric performance in this area was also understated in the S ALP report and evaluation of enforcement activity as relates to performance in this area has deferred for another year on the basis of considering escalated

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enforcement. Yet, the dismal performance in this area is a glimpse into how TU Electric will perform during the plant operations. Yet TU Electric has already taken the cavalier position that what happened during the test is typical of preoperational testing. John Beck was quoted as saying, " There's a heck of a difference in how one reacts in a test mode than in an operating mode." (Ft. Worth Star Telegram, dated October 29,1989) What Beck did not state was the valves were not scheduled for testing and the problem was onlv discovered because of this incident. In addition the applicant did not report an earlier and related event May 5,1989) to the NRC.

The S ALP report is otherwise apologetic for the applicant, narrowly interprets repetitive deficiencies, and considers single occunences unimportant. This is like telling the public that a major airline will not view a single incident seriously and take corrective action concerning a pilot whojust caused a crash because he only missed one thing on his checklist -- setting the flaps conectly for takeoff. This type of performance evaluation misses the point that the one item missed, i.e., failure to set the flaps, was fatal, it became 1

irrelevant that the pilot completed all other items on the checklist. So, even if one could contend that missing different items on a checklist was not precisely the same (repetitive) deficiency, the results of missing any single item could be very serious. Thus, unless the corrective action conectly defines the incident as a repetitive failure to follow the pre-flight checklist, no meaningful corrective action can be accomplished.

The NRC policy of deferring key programmatic failures connected with enforcement or investigations that occurred during the S ALP period until the next S ALP is illogical and is a serious flaw in the S ALP process as MC 0516 does not specifically prohibit such practices. There is no indication that fuel loading I

would be deferred for the same period of time in order for the NRC to determine whether TU Electric's performance was and will be adequate before granting a license.

V. Inability To Address Root Cause NRC inspection reports and the draft S ALP reports contain a large number of examples where TU Electric did not address root cause of deficiencies in order to preclude repetition. That is, from 1984 until the 1

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present many programmatic and hardware deficiencies have been previously identified by the NRC inspections and TV Electric consultants. Although, as demons: rated below, there were numerous examples provided that recognized this serious management failure, final draft report D, give s TU Electric a CAT "2" finding in this area. De following are a few examples from the functional areas in the first draft report "A" unless otherwise identified:

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m. Constniction j

page 12, IV A.1. stated, " Deficiencies were noted in some procedures...such as...for installation of fire damper pup piece..."

page 12 also stated,"...However,in the piping and pipe supports area a violation was issued

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due to multiple examples of less than effective reviews of calculations. However, corrective j

l actions were implemented and staff review of calculations later in the SALP period indicated i

improvement."

Another draft ("C") added that management was slow to recognize that a generic problem j

existed even though identified by the NRC and in applicant audits. Also inadequate engineer-

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ing evaluations were noted concerning tube steel welding, design changes, and noncon-formances. This serious finding was downplayed in the draft S ALP D.

Page 12 stated," Records of completed construction were generally complete and adequately

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maintained; however,in some cases the records were not readily retrievable with too much reliance on personal knowledge to locate data in a timely manner." Dropped from S ALP draft D.

Page 13 stated, " Corrective actions were not always effective in root causes, as evidenced by recurrence of some issues. A recurring problem of unrepaired damage or unauthorized rework was an issue that resulted in the applicant performing a detailed walkdown of rooms and areas to' identify issues." Dropped or minimized in SALP draft D.

NOTE: The paragraph ended by saying the NRC would have to walk down the area to assure L

that TU Electric took corTective action was by Yet, the ORAT "walkdown" revealed that the final tumed over rooms had numerous problems, i

Conceming resolution to technical issues page 13 stated " However, certain issues such as the l

' slugged weld' deficiencies found in plant supports or the auxiliary (AFW) backflow event required several engineering iterations before an adequate understanding of the full technical issue was demonstrated." The reference about the welds was not found in S ALP draft D and I

the AFW was downplayed.

Conceming responsiveness to NRC, on page 13 it was stated, " Numerous requests fmm the applicant for extensions to committed response times, however, may be indicative of weakness in the applicant's program to develop meaningful schedules in regard to NRC initiatives."

Dropped form D.

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1 NOTE: Responses to one inspector's violations in repons 50-445/84 32; 50-446/84 11, 50-445/86-08; 50-446/86-06, and 50-445/88 47; 50-446/88 42 were not responsive and were inaccurate.

f Page 13-14 stated, " Major violations were rare but occasional programmatic breakdowns did occur. A pipe support angularity problem identified by the NRC resulted in reinspection of l

over 5,000 pipe suppons and necessitated a significant amount of rework. Also difficulties in implementing a truly effective configuration control program have resulted in repetitive minor violations". In SALP draft D, configuration control was stated to be good and the comment i

about prognm was not strongly worded to fit the issue.

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Conceming significant construction events page 14 stated,"... at times potentially significant information is lacking in the repon. An example... was evident during the AFW backflow incident. Specifically, a related event that occurred May 5,1989 was not included in the -

reported incident until the NRC staff suggested that the event should have been included. Other l

information potentially significant to the operability of the AFW check valves was not made known until late in the NRC AIT inspection." This was dropped in SALP draft B.

Concerning responses to NRC initiatives, page 14-15 stated, "However, certain areas of

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activity were notably weak." Dropped from S ALP draft D.

Page 15 stated,"...the staff has concems for the applicant's required post maintenance testing."

l Dropped or minimized in Draft D.

Page 16 17 stated, "... root cause assessments were not always effective." Dropped from S ALP draft D.

Page 17 stated, "... failure to perform an evaluation of reponability of certain 'unsat' inspection reports. Needed improvements in procedural control for identifying and documenting i

problems identified by operations is a major concern." Dropped in S ALP draft report B.

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Concerning submittals of FSAR changes page 1718 stated,"The applicant relied on meeting

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the ' minimum' NRC requirements, as determined by the applicant, as a basis for not perform-ing certain important preoperational tests (instrument air) rather than providing an adequate technicaljustification." Dropped from D.

i Page 17 of draft C submitted to board stated, " Seven of the violations were for QCinspection L

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errors and appear to be isolated. However, most of the remaining deficiencies were for -

programmatic problems such as, field verification methods (FVMs) failing to provide suffi-cient instruction for verification of inaccessible attributes and QC measurement techniques being adequate to correctly identify valve stem angles." Retained in D but these are examples of problems found in the CAP.

Page 230f S ALP draft report B stated that " management involvement was lacking" concerning l

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the removal of the coating from service water piping. Dropped from C.

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b. Operations NRC did not find as many repetitive deficiencies in this area because inspections have focused on

- construction. However, deficiencies in certain areas can be shown to be repetitive because lessons learned in construction should have prevented similar deficiencies in operations. The following' are examples from SALP draft repon A unless otherwise stated:

Page 19 20 stated that management was not as aggressive as it could have been in all areas and... " operations procedures were not being maintained to a level which the staff felt was necessary for safe operation of a newly licens:4 plant." Dropped from B.

Concerning operational decisions page 20 stated, "Some failures to document minor opera-tional events or identified preoperational problems were noted; however, when issues were escalated to senior management's attention the issues were resolved." Dropped from B.

NOTE: NRC had to inappropriately escalate issues that should have been handled by supervision and senior staff members. This was inappropriate because senior management will not be operating the plant.

Page 20 stated,"The applicant has experienced increased enforcement activity in the operations area during the SALP period." Dropped from B.

Page 21 stated,"The major concern to the staffis the applicant's apparent ' lack of attention to detail' which was evidenced by the results of the recently completed Operation Procedure Review." Dropped from B.

Page 21 stated, "Although the licensed operators, as a general rule do not have a great deal of power plant operations experience senior management recognizes this deficiency and is taking necessary steps...."

VI. SALP Board Dropped Negative Findings Most of the negative findings quoted and discussed in the previous paragraph (Inability To Address Root Cause) were either dropped from the SALP final draft report or reworded to the point that the negative

- finding was minimized. Inexplicably, in some cases, the findings were changed to become positive program / management statements.

VII. Insufficient SALP Data To Suppert Conclusions In general the SALP drafts showed a lack of data or references to data to support conclusions about large complex areas of work performed by TU Electric. Without such a collection of all of the data about each functional area, ratings became extremely arbitrary and lost much of the purpose for the S ALP.

No systematic NRC program was implemented to perform trend analysis of violations of the criteria of 10 CFR 50, Appendix B, and analyze the data to determine if deficiencies were repetitive. Such an analysis and evaluation was especially important and should have been performed to provide data to back up S ALP 7

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conclusions.

- The eleven areas in design and construction were not specifically identified and evaluated in the SALP.

Since most of TU Electric's work in unit I was under the CAP, this was a large part of the NRC's inspection effort. This area of the SALP lacked specific data to support many findings and ratings assigned.

insufficient inspections were done in the functional area of maintenance / surveillance and should not have been rated. (The senior resident for construction was assigned to perform inspec-tions in this area but p rformed very little inspection because TU Electric did not take adequate corrective action on service water violations and extra work had to be done in that area.) It is doubtful that the NRC performed the necessary inspection effort during the two weeks left in the SALP period after the said inspector left.

CASE CONCLUSIONS

1. The SALP pmcess should follow, not precede, the Operational Readiness Assessment Team inspection because that inspection should be considered when evaluating TU Electric's perfor-mance.

2. The SALP report process is viewed as a poor vehicle for evaluating TU Electric at this stage of project completion.

3. The current S ALP process and report have been compromised from many standpoints and some other action must be taken to show the satisfactory completion of corrective action relative to design and construction, plant testing, and operational readiness.

4. If used, the S ALP process should be objectively and rigorously performed in accordance with the criteria and attributes in MC 0516 in order to be uniform, logical and supportable. The conclusions -

for CAT 1,2,3, or below findings should be based on supporting data paraphrased in the S ALP and/or referenced data summaries on file.

5. More inspectors with direct site experience and fewer managers should be voting members of the Board to make t.he process credible.

6. TU Electric performance is obviously, at a minimum, a Category "3" in the area of corrective action and root cause analysis by virtue of their performance in the service water system evaluation j

and check valve incident.

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EXHIBIT C I

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June 28,1988 W

'Xth Juanita Ellis f resident, CASE 1426 South Polk Street Dallas,. Texas; 752 m

Dear Juanita:

We have agreed that when the NRC licensing proceedings for the Comanche Peak Steam Electric Station (NRC Docket Nos. 50-445-OL,50-446-OL and 50-445-CPA) have

- been dismissed'and the Joint Stipulation has become effective, you will be authorized.to release this letter _ to the public and the news media and we will file it with the NRC as part of the record of the-licensing proceeding.

I am duly authorized to make the-statemtnts hesin on behalf of TU Electric and to sign _this letter.

TU Electric recognizes that the Citizens Association for Sound Energy (CASE)-and its President, Mrs. Juanita Ellis, have made a substantial, personal, and unselfish contribution,

to the' regulatory process which assures that Comanche Peak Steam Electric station

-("ComancheL Peak") will be a safer plant.

Through the untiring efforts-of CASE representatives, deficiencies which existed in tii. barly 1980's have been revealed in the design of substantial portions of the plant which no one else, including TU Electrie, the Nuclear Regulatory Commission (NRC), or other third-party experts had fully recognized or ' discovered.. As a result, Comanche Peak -is a:better, safer plant than before and,-

through the reinspection and Corrective Action Program, has a greater assurance of.-

. safety and reliable generation. We commend CASE, together with its technical advisors, -

Jack Doyle and. Mark Walsh, and: other workers, public interest organizations, and-supporters for their courage and devotion-to-CASE's goals of finding' the facts and, informing the pubile. Because of these activities, CASE's President, Mrs. Ellis, has been-appointed to the Operations Review Committee (" ORC") at Comanene Peak, an unpaid but important position which wQl provide CASE with the opportunity to continue to play an active part in assuring itself that Comanche Peak is as safe a nuclear facility as possible.

The ORC is required by the Comanche Peak technical speelfications and functions as an

-independent body assigned the responsibility for review of various safety related matters including nuclear power plant operations, nuclear engineering, radiological safety.and -

quality assurance practices among others. Among its duties, the ORC will be responsible n

for independent review of proposed modifications to the Comanche Peak facilities or procedures, changes to the Technical Specifications and license amendments, any violations or deviations which are required to be reported to NRC and other safety related matters deemed appropriate by the ORC members. The ORC meets periodically to I

400 North olove $srett LB 81 Deuss. Texas ?!.'0!

M-a o -=~

-n---

rew:-------=_.__=--==~~

O

~

' Mrs Juanita Ellis =

June 28,1988 Phre 2

-l review and discuss various issues bearing on the safe operation of. Comanche Peak and reports its findings.and recommendations directly to the Executive Vice Presicent,-

Nuclear Engineering and Operations.

TU Electric also Tecognizes its own shortcomings in assuring the NRC that they fulfilled' NRC Regulations. <Weracknowledge that nuclear expertise did not' exist to meet those demands and that its nuclear management did not have full sensitivity to the regulatory environment. ' CASE, Mrs. Ellis and her colleagues played a substantial part in acnieving our current level of awareness..

L-

_-i Sincerely, fft W. G. Counsil l.

Executive Vice President, l

Generating Division TU Electrie n

6 l

l L

l

= ene m.

---h-e-

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- i ;

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' COMPARISON OF DRAFTS AND FINDINGS SALP Section Pers Ansgust 99 Sepeoneer89 SM 89 Inniet SALP Report Ceaunente Draft A DraR 8 Dron C to Board Draft D

1. ilntroductirm Board Compasstson 4

Managers on Board:

Changes to Board NoChange.

NoClunge.

Grunes McKee, Wilson.Lyons Beach Gwynn.Juadon a&ied.

frosa Special Projects,HQ, Milhoun drogged.Three Region Warnack. Wiebe,tivenacre of IV managers on Board who had Special Propects.See,Mdhoan, liale or noderect day to day Region IV.

involwsment with sete wa Inspectors Participaung Buiningharm. Burns,Graharn.

Changes:

No Char.ge.

NoChange.

Note: Phsibps & Gradiese Murray (RegionIV).Rachins.

Baser.Chen. Dele. Johnson.

enspected mostof year.

Runyas.Stanish. Taylor.

Latta were *Med-Graham C" "..smissina).

droceed.

A.

Activiues 15 Idenuricamon of design,conse NoChange.

NoChange.

Section A Dropped.

op. work danne genod.

B.

Inspecuon 9-t5 NRCinspecten desa (1)CPRT plan provides basis Section B Dropped.

(9i seports comedesed) areas addressedby CAP (103 reportsconsadcred).

(2) NRC Manual threr(91 resorts consideredt II. lSu mm of Results A. Overview None To bc L-A- '

Sasne Same lachsded(AllCAT2)

B. Other Areasof:.aa All Tex - 12 Puschase 11 _ ^

Sanie Sanse lit.

C.M last '

Functeunal areas-trad L ;;

Same Sasse Pase 21. Raned ~2* in final draft._

IV.

Perfonnance Analysis A. l Construction and Co.dve Action "by-s I.

Introducuan I

Appbcant activitsesin Discaission of 11 areas to fix Same Same anisericuan to operase plant.

plant dropped.

CAP tocorrect plant is eleven areas.

2.

Introductaan 2

Discus >aan of numeberof On page 22.50 inspecisons with Combeed with r

.,,;.1 Senescan about 12.Lh umperrats and vedss==is -

12 vioimaions wseh her===== of above (On page 17) was dropped and changed to massina.

errors and Mch

~

positive pronram conunent.

3.

Manag-ment involvement 3

M. -- - -Involved !

-- 2 derciences.

Susement on SWS drugged.

Same.

(No defriencies).

identified. SWS incideas added and debased.

4.

Engincenng Evalustsens 4

Muluple emamples of design Stasesment included.

Statenientincluded.

Staaement 4.wd.

calculatinn problesn idenuried.

N-a.,

A-e,

.-y

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e r

..-. ax a

- ~.,. - _

- -a

.=

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COMPARISON OF DRAFTS AND FINDINGS SALP Section Pero August se Sept m et Sopeemtur se inletal SA4.P Report Conumente Draft A Drelt 8 Draft C to Boeral Derft 9 5.

Records 5

Not readily rcerievatne.no Same Same Drtyped systesa.

6. Correcove Actaan 6

Rous cause so bad NRC ems:

Wneemp e. ----i incorporased Dropped or nunanized assunse conecaert udoranamon shout NRC wa&&wns and resdaamas.

7. TechanicalIssue Resoluuan 7

AFWcheckvalve not pnyerly.

Stasements on applicant Munirnized included i

resolved.

reluctance toidenefy genent b

=_ _-. included.

8.

Responses

a. NRC 8

Weakness in program mosed as Staned =cakness dropped.

Response no structural sneelQC Weakness dropped or eminenessed.

prohmtde seclunques,undersued welds aus addressed.

b.

Self-identified 8

Not in draft A.

Structimal evaham**a= used Samme Example of SDAR sauctural seconect groised waeer.

evatuseon inaake soucsure drosiped.

9. Consuucuan Activities 9

Exarmples of good work was sasung was cause of Maluple conseruction Tramming causung consensetson rework w by impmper work. puotdeses(Thts was added).

defcencies cieed. Kgtan deficiencies moved under umulamon telecencas separanon aramung.

cieed as erh 10.

Enforcenient 10 Mapor violanons rare bis Same.boam pnddeum about Dmpped program tw. nows pmgree ber=heinen musMr not Cominguraean ConWol.

semeesntuit aRdinefIett[9e addressed. Reinspecaos $000 configuramon consol program

<apports ar.at.

canned sepeterve wh iI.

50.55(c) Evenes Ii Sigmiscantinfonnanonlacking Dmpped on AFW backflow incident.

12.

Staffina 12 Over reliance on considiant.

Sanne Same Nesmove m

eM Page 29.Ch i T.

B. lE.m.._...g & Technical Support I.

InsA

-1P- _- - i i

No Conunent Same Sasie Same -

2.

Response to NRC request for 2

CAT 2 (adnymac)but no Paragraph revised and seasemem Same Paragraph K.

. AIICAT 3 mformanon_

supponsag due.One sensence about wealt areas. Negeive language dropped.Pbserve face said areas noestdy week.

czarnple about tech specificasion put on naamerin conwast no is CAT 3 asanbute (AFW).

carher drafts.

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COGAPARISON OF URAFTS AND FifeDINGS SALP Sectioet Para Augiset 89 Septomtper 89 Septemtser 89 InIIInd SALP Report Conunente Dredt A

. Draft 8 Draft C to Soard Draft D

3. Ih-.a Program 3

CAT 2 tot gnogram had to be Same,except a more negative Neganve wneempincorporaaed.

Rewneen to dmp CAT 3 CAT 3 dropped revamped to assure urseased wneeg indrased CAT 3 rodag. Rew that there is a assurance of quahey.NRC had 4..w.TU Ekctnc dties need for improvement. A many conceras about program nut understand program.ambt -

posative staaement was added of procurement showed safety about she appiscant's issuante of valve ineernals pechased as a soup work which was outside non-safety,and other problems the ratmg penod.

andscaec only met minunal a.e..

4.

Techascal Support for 4

CAT 2 redag but she staff Sanie.cacept neganvc emanspies Same.encept sensement about Rewnsen todrop CAT 3 rodag Nose Twosignercantpuublems Maineenance empressed concerns about the '

of check valve resnovel, self assessmentdroppedandshe and maske CAT 2 but resideed kom usadessunse aeseng-appiscant's comeml of sequeed reinstallamon and post

- procedse was saul d~.

.+ descnbed as AFW and servce waser.Should

+ nesang was given to be latting. No post "unarginal." Clearly CAT 3 he CAT 3.

pose.

- nesmag.1he -

appiscantheed shes problem as supporang desa. Smeement snodif' cation testing was kne based on data submeted by NRC

. i and is pursusag a cornceive that no cnacal self. assessment and the AFW event occwed.

nupecaors.

acason. No duas to==ennt.

casssed W to actur awice.

5. Enforcement 5

CAT 2 basedon 3 violanons Mapor chamme:a vnaamasis west Changes mcorpornoed. Appear so Rewnnen no seduce nunsber of Nose: No doen Powided to show i<w=d Twoweseinn -o iM Five wese i=ahad but 3 support CAT 3.

viniannus from a ao 4 because why shey were connJend a

were programmanc in manse. In notice of veoismens for NRC esclased. Dans did not include addsson these west a number of alt report noth e=-of service waner ruuhngs that wese unresolved concerns.

pendmg enfasersment. k wem :

conssdered in 190s SALP but sensed that appbcam cxwvecard wese defcered so 19g9 SAlf.

violanons /defriencies.

Appears to be CAT 3.

6.

PreapTesung 6

Missmg CAT 3 snet numannum ben Deleted Ine redag in parat 4 of this crossed out..

5 ALP many comesse the preup rouhag but CAT 3 language is W or modersed.

7.

7 Massag -

Audit TSU 8941 showed Deleted Deleted.

engineenng wied sodefeat quality syseems Nose-This was crossed out.

g.

Staffing g

Missmg Too dependent on consultants /

Deleted.

Negaeves drtwed.

contractors. No proordures for newly assigned startup eroup.

9. Trainina 9

Missana Adwy==se Same Same 10.

Corporane Manancinent 10 Missana Messma Corptwaee involved wish ssee.

Same -

C. l Sat Ass & Qual Venicanon IM Camerary *25 1.

Management Involvenient I

Adeqisate CAT 2 based on meetings.TU Sanne Same except rescrence so amla -13U 3941 dmpped.

Ihtne Audse TSU R9 al.

TStiM9 D1 dnned

.+

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M 4

^f Y

1 4

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8 4

4

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k I. I 1

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CORAPARISON CF DRAFTS AND FINDINGS SALP Section Pers August 80 Septemtser 89

'tara==sur se inIIIs1 SALP Report Comunente Draft A Draft B Draft C to Board Draft D

2. Operational Decisions 2

Conrervative pima safety but Specific emanple rephme by Same Same Negenve dmpped by especaers-menauwe example was given.

meneralinformanost 3.

Violations 3

lacreased enforceement.

Sunement about incicased Last seneence of paragraph almas Rewrite -dropped seasement Sessementabout2 Iast F

checkvalve edayedropped.

seierencing 6 violomons. Paeseart operamous v=hai=== eupped.

enforcesnent dropped.

s eest group praise =ddad Creet added to dearmotIsam.

AFW. Itemrds v=hm==

ew-ad

4. Operanonal Events 4

Performance marginal.

Same Same CAT 3 drotoed.

Should be CAT 3 rumbna.

5. Operations Procedure Review 5

Major concern about TU Electric Toned down to canent et changed Same Mmor clunges.

CAT 3 down soCAT2 by $see assentiontodetads. A&nin fumbugs.

Supervisor.

cenerals contradict wrong info

-- Bad 1U Electnc stview.

6. Staffing 6

Numbers OK -operanors w/o AAna+ Opersoors/ shift Emt seneence about veoimasons Same None experience.

engineers faded so follow that fogowed dopped.

prrrea=es.NItC vioimasons wkmamsdes.

7. Training RO,SRO*

7 Good impsovement over last Same same Same None SALP

8. ControlRoann Ash 8

Good Same Same Same None-E.

Manneenance/ SurveiM-An:n cevers daagnosuc, pmbctive, prevenhve arvertive momeenance; pre physicalman= EO; -

1. f *. -- ---- Involved I

Active role. ^ ^. =

Same Same lSame Management acave oudy se involved with procedmes - NRC j

tranung.Vioimaan dropped.

found format enors / doc.

control.

2.

Mamtenance QA Program 2

Meets Regulapons. Saican bok.

Sigeficant protAem wnh Same Same Procurement issue drolyed

. -violamon

-_..;. Audit?

^

3.

Plant tours - obs.

3 All OK.

Same Same Paragrugde &opped and senseam None put in OA pograsm 4.

Backlog 4

1690 ieems - reds:ing 50/ monsh Cmased out and comment said to Paragraph nessag -no upduse.

No egidmee prevaled.

Updase of bELILlog not addressed.

updsee numbers. -

5.

Surve: Hance NRC revnew of acnon to develop Same Sanne Sanee None surve:Ilance ness.

6.

Vsolanons 6

Messmg Deleted samenient aboea 19g7 Veolaeon added about soprage I Negauve dropped.

carbon seeel vioammon,

& C work packages mamersunce recc tLViolationonboltsM so be no im*desa.

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l ANALYSIS OF SALP REPORTS Sectioriof SALP

. Draft Dated 19 August 1989 Draft Dated 8 % -- -_1989 Draft Septeentpor 1989 to Boertl InfWel SALP Report I. lIntroductson Board Composame Managers on Basrd-Changes to Boant Same Same Gnmes. McKee.Wden.Lyons from Beach.Gwynn.Jamim added. Mdhoan Spectal Projects. HQ. Warnack.Wiebe, dragged.Thrce Region IV managers on Livermore of Special Projects.Sne.

Board who had betle or no duect day so Mdhoun. Retum IV.

day evolvement with site inspections.

Inspectors Parucspasmg Bumingham. Burns. Graham Murray Changes-Same Same -

(Reg. IV). Richuis. Runyan. Stanish.

Biticr.Chen. Dale, Johnson,l.atta wese Noee: Ptullaps & Grdiare snspectums Taskw fMiilles missena) added: Graharn drooned wese uneartant A. Apphcant/NRC Acuvines IAruments Bomrd fedegs and Appiscant actions to complete cosvective actumi recomsnendarums forwarded for NRR and other to show operatxmal readmess.

approval.

I.

Eleven areas design and constructum On page 12 the eleven areas were Mauw revisam.

M www revesson.

Drogyed Irorn SAlf report intluding design valsdatum and condensed to one area - Constructum Nose-De masenal dropped showed she -

post <onstrucuan valsdauon programs.

(electncal. mechnical & civil / structural).

NRC plan f4w evaluaung But report faded to address cath area individually.

2.

Activeues to show operational readsness.. No Comment.

Miruw revesusn.

Menor revisum.

Dropped from SALP.

a.

Prereqasite/ Preop eesting b.

Graded Site Emergency c.

Ra&ation / Secunty B. INRC Drect Inspecuan / Revsew 1.

Over 21.000 inspectum hours in 91 Most hours were spent on CAP. preop

. Minor revision.

Minor revnsion.

Dropped frorn SALP reptwt Sectum I.B.

inspec. ion reports.

nestag.constarctum mspections_

2.

Inspections to support operational Three team inspectums of CAP.EQ, Mmur revisum.

Mmor revision.

Dropped Irorn 5 Alf report Sectami B.

readines gradedexercise.cmergency '

ascas.2nd operanon/

m

- - -om.--fA-es.

3.

NRC evaluatum of CAP en SSER 20.

No & rect &scusssun in SALP.

Minor revision.

thopped froen SALP.

4.

NRC Augmenaed Inspection Team.

No direct &scussion in SALP.

Minor revision.

Muur revision Dropped from SALP.

5.

NRC Staff noted problems =nh SSER 21. No direct descussum in SALP.

Mmor revisson.

Muuw revisum.

Dropped froen 5 ALP.

==

Conclusions:==

(1)he Board composition was stacked wisit managers from special progetts NRR HQ wtso were not savolved wish day to day anspections. Lyons and Wden had staff members who sufrequently came to w on special mspecuans. Reason IV sent L-.pors from Region to inspect radiation control, secanty. emergency Aa (2) Most of the 21,000 mspectson hours west spent on consenscamm corrective actson and prc<yernoon nesting.The SALP had 8 functumal areas (IV A. thnogh H ). Constructum was leal on two areas whde operauons =as lead on 6 areas. One consenstson Board member had one vuee versans seven members asymnaed for seven operauons related areas. Regum IV sfuwkl have had a nunavial snggss tot had 33% of IlQ had 33% when they wese not involved wiL% snost..w uum.

L (h Ihurd ur hated aus.wtors. +

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e

+- -

-e

+ w m--

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.e r ANAI.YSIS OF SALP REPORTS Section of SALP Draft Deled 19 August 1989 Draft Dated 8 Septemtser 1989 Draft Septemtwr 1989 to 90 erd ~

Infilal SALP Repost (4) Board memters were an involved wah Comanche Peak mspections on a day to day tuses and siune h.ed almost no real knnuledge / involvernent. +

(5) Inspectors who partici uted had no vote thug no real voice in the process. +

t (6)Two inspectus (one provided negauve inpus) were not lested as participants in the final report +

(7) The cleven design and constructum areas were not spamfically addressed in the SALP but mere the largest part of the 21#U0 hours of inspectum. Constructum had one vote winie other areas that had latie or no real work acovity had seven,and (8) S&tions I. A. & B. were dropped from the final seport. These showed what the NRC was AmAing at and, perhaps,infened at was votag on operanonal readmess. De seference to eleven areas may have been drooned as 21000 hours f aux in consenscuan) murha ra.se a red flae about constructum and the lack of eenchasis.

II. ISummary of Resuks -

l A. Overview To be devekiped.

Same Same Owrview devehiped and gave ymarves eith snesus neesteve comments. Does nee represent inspectas.

B. Other AreasofInterest TU Elecinc amendnient to buyout Recornmedned dropping this section.

Dropped Same j

Tex-12 Electnc Coopranve of Temas. Inc.

Iff !Cntena-l Fvat==sinn Cnsens De vanous drafts do not address each cnteria and atenbutes under each functional area in an organized --

Table i

1. Assurance of Qualmy includeg NRC Appendes 0516. Table I gives appropriate aunbines under cmegones I.2.and 3 for each cruena: for example.plsmeng. pohcies. level of derasum mahmg.corpiwate

s. %c.a..; involvement / control.

management evolvement at sale.cngineenng evaluatum, and records, correcove actum for rout cause / prevent rcranence. rout cause analysas.

2. Appro.sch to resolution of technical issues front a safety standpoint.

3. Respasiveness to NRC eniuauves.

4. Enforcement thstory.

5.Operatumal/ Constnutson Events (response to analysis of, regwwting of, and correcuve actums for.

6. Statfor (include management).

7.Etfcctivenessof training /

quahricanoJn proeram lc.seenrv CAT Findenz Defendums pW I - Apphcant enanagement excecds regulatory a

.m.

2 - Applicant management and performance atuwe that needed to ewet reaulsory.

aa.a;.

3 - Apphcant m

....; and rJu...

ees not siarufscantly exceed that needed as meet minunal regulatory ey..m.m;;;.

F.anctumni Arnt Functional areas idenufsed and lead organizatum for each area idenhised construction and (1peraDons sete perstunnel lead.

(for IWut H9)

Construction 2 areas versus 6 operations areas IV. l Performance Analysis A. lConstnatuun I. l Aswarance of Qualary

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ANALYSIS OF SALP REPORTS Section of SALP Draft Dated 19 August 1999 Draft Dated 8 *,

- _1989 Draft *,

_ _198910 noord treIIIslSALP Report

a. Evidence pruw planning puvuses CAT 2 findmg -

Same.cacep No substanuve change exapt service Board made the thanges. Acceperst CAT assigned procedures for control.

Intle data no supptr t damper procedure deficsency dropped water.

2 perfonnance washout specific daea to -

Examples were nts well stated but and problems added support ramags.

suppnet CAT 3:

structural secelinspection xmaa Seal weld procedure for valve seen

Draft Rpt 89/2313 and memoon deficient damper procedures.

also see page 17 (tv.C.), page 15 angle 89/23.23 ignored reference ao service Chetkvalve test procedure Service waser sumement dmpped.

waeer.

(IV.B_).

Mgt involvement service water was madequase Mgt actxus on hundreds of concicae attachment spacing violatums cuid

b. poteies stated /underskud Not evala.sted.

Same Same same

c. Decisum making levels Not evaluased Sarne Same same

d. Corpswase Management involved CAT 2 findmg -Incomplete data to No substantive change.

Same Same suppwt.

The sugyort given stated that 1U Elcerne management was evident because of frequent status meetmgs wah NRC mspectors about ongomg or proposed i'

activines.1he focus stumkt be on TU Electnc involvement with acevases run briefmgs and mecetsngs with NRC inspectors. That sscovered under responses to NRC. Management involved with correcung hundreds of deficiencies on spacing of concrete attachments.

c. Engmeenng Evaluatson CAT 2 fedmg -no data so support eacept Substantsvechange Added No substaansve change.

Sutmanuve CW a reference to seam inspection of CAP.

Managespent slow to recognize generic Dmpped saaeement about genenc probice relased to design calculanon smNem.

errors; madequase evaluauan of sease welds; evaluatum of engmeenng changes Also reports of nonconformances not adequase.

Records were adequate tut not CAT 2 reding not sgported by data.

retnevabic without too much reliance on Facts / data provide nuore support for CAT fersonnet knowle Jge.

3.

Noac-This area t.as been derrient sace '

1984 or before that. CAT 1 c.

~..

a[

f a W

ANALYSIS OF SALP REPORTS Secllonof SALP Dralt Dated 19 August 1989 Draft Desed 8 Septemtwe 1989 Drast Septamtper 1999 to Boortf inillet SALP Report

f. Corrective Acunn CAT 3 fedmg - seased that conecuve Change Added Nochange Change Major..

drtyped surement about carrecove Recumng problem wah imreparred actions for adentsfed defriencies was not always effective an conectmg root cause-

/isisaaluwued west.

acean mm always effectree an Probiera strarred before effcctively coneceng runs causes as evidenced NRC indcated need tolook at 2nd or 3rd iterations of conective actums. Nose No resolved.

by recirrence of some issues.

QC anspectum errors under CAPin data to support this fuuhng such as trend analysis and evaluatum of serumsness of several NRC reptwts before IUE even one repeat derciency.

would take actaw

z. Self AssesanmAtoot Cause Not specifcally addressed Same Sarue Same Conclusums:

(I) The NRC SAlf findings are mm bat ked up by data - whether negauve or pusstive.The evaluatum seems to le based on a haphazard summary of what nHpecetws remember or rend in reports. To eticctively evaluase performance a detaded SALP review would have to be done nusutdy.This was not done.Thess she process was nrshed and superficial.

(2) Findmgs in the report indsate a recumng fadure 10 tic corrective actum. That is. Unit I was complete m 1954, and aH subsequent west is correctrve action. Sidnequent deficiencies are fadures en take conectrve actum af there was work done and accepted by qualay control.

(3) Il S. Phdieps memo to R.F. Warnick outhned the following areas of concern about TU Elet1nc pulcy but they were not addressed-a dasregard for cornmiturg to/followsng ksca.-JW methods for asecting NRC requirements.That is, wiE do at die TU Elecinc way *hach they tinnk ts best.

. wdi work een times harder to prove NRC wrong inssend of fsumg the problem in a tenth of the tane.

. na row legatasuc approach tocorrectsve actum rasher than genere corrective actism results en recorrence.

. practice of having meenng after meetmg to talk their way out of a probiern instead of adrnntag a and fixmg it, and prrtice of not provedma cornplete and accurase informatum NRC unspectors and consukants have expenened this to some degree.

(4) Several of Phdleps fedings were not addressed in the SALP process /r.ptst

. Management envolvement with service wamt inadequase and a refusal to take corrective action while the work was on gamg resuhed in extensive daninge.(88/4742).

. Inacc

.e./..

..A. informatum provided at November 1988 enforcement meetmg (89/23-23)

. Inadequate conective actum in respiese so violations in 84/32-1I and 86M846 concerning she anda prograrn

. Inadequase conective actum

hen AFW motors (fans) reversed and improper bolts used. +

(5) Final SALP drogved nezauve fmaines.

(6) This part of S AI.P (IVAI.) indicated that the appiscant dal not segnufscantiv exceed menemal requirements. In fact. it was probuhly not posssble to significantly enceed nanumal rup.~.

.~. luause a8 the work done was to n..w wwactory work (Ch., M in A the S Alf was not the

--6 vehele toi-the anelscam's nerformances.

2.

Approach to Resoluuan of Technical issues froni Safety View.

a. Understandmg issues CAT 2 fandwig.however,suong No majorchanges.

Same Same exampics of CAT 3 fading with no data to support CAT 2; AIT team found TUE did not understand issues after several iterations Stanned weld was anoeher c. ----J

b. Conservausm Exhstneed CAT 2 fedmg.however.Intle or no data NoChanges.

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. w ANALYSIS OF SALP REPORTS Sectionof SALP Draft Deled 19 August 1989 Draft Deled 8 September 1989 Draft Septembee 1989 to 90ertl intual sat.P flopert

e. Approath tecknically scu.00m-sh CAT 2 finding.5upput referenced as Changed to strengthen CAT 3 finding.

Otarges mcorporated.

Otanged to read Pmtively:ciectrcal observed dured team inspecuans of post

Stated that generic tecluncalissue ate areaimproved m that root cause constructson hardware vahdatici recogered addressed.

program Hissupportisenurely

.inancquate techncal approsth on Nose-Tins (root cause) is scally out of enadequase. A suong example of a CAT 3 seam weidag place as it shaidd be en 1. Assurance of Inadequaseevaluation design Quainy fedmg in this area sisggesacd unsausfactory -sio...w.

c'

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d.Cruscal Self. Assessrnent Not evaluated.

CAT 2.findmg however,no realdata to Changed so negauve-Dropped negauve fuubags and peragraph sphe neganvc stanernent mJcases lhe femal responses m thes self-identafsed was combened wah paragraph IV.2x CAT 3: Numerous request.anay be assues were generauy sound and

above, indicatsve of a weakness in the acceptable but occassonally latked appicant's prograrn todenlop and ehmoughness and precisnm. For exampic naamtam meanmg and som.

mconect ground waier elevauon used an structuralevaluanon.

c. Resolutions AreTimely Not specircally addressed and supported Same Same Same by data.

f. KEfit 50.59 Reviews Not appicable.

Same Sasre Sarne Conclusions-(t) S Al Pimdmgs was not supported by data to show CAT I or 2.

(2) All work in the technical areas ws: design and constnsction engincenng that was bemg sedone.De inspectors input moscaned shat 1U Electrc and conaattors were havmg maps protdems getung se nght the second or third time.nis indensed a CAT 3 perfonnance..

f 31 Aram a S A1.P at this amnnt was me :/. ia--noriane becasese a S ALP is hased on an *=r meetana m" -_8ru

..-..a In a manor correcove actum effort hke this the nerfurnunces rs amuunatacally CATt 3.

Restumsiveness to NRCInstasives a Respmses tunely.

This area was not treated as a special Changed to add paragraphs un Bulletans.

No mapor changes.

No mapw changes except paragraph on tapec but comments indicated numerous Also madequate responses as violabons NRC Bulleens dnyped and neganve acxtasests for extenstuns and a weakness savolved-fundeg that action was not taken en IE was noted.

QCinspectsonsplatforms Nouce 81-20.

- - QC sneasurement techniques

Service water tube sieel Undersizedweldsductsupports.

Re===I rnectings wene held to resolve.

b. Resolutuwis of regulaeory seents.

Nos specircally evalumned cacept as NoChange.

Same Same nosed isnder Draft 2 - 3. a. above.

c. Responses technically viable, sound..

CAT 2 but no supparung data.

CAT 3 - Lackal thoroughness or depth.

Same Same thorough.

responses sometunes u

.;, A

d. Acceptable resoluuons.

CAT 2 - not specifically addressed but Same Sanse Sa" Draft 2 andcates CAT 1.

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x ANALYSIS OF SALP REPORTS Sectioriof SALP Drelt Deted 19 August 1989 Draft Deled 8 Septemtpr 1989 Draft September 1989 to 90 erd InglielSALP Report

e. NRC Imtiatives/Pulicscs Implemented.

Sameon 31 above not specifically Same Same Questumif a&lresed slusically..

addressed.

Conclusions-(I) Latte or rio suppwtang data was provided for 3.b. through e +

(2) 3 A twovided some *Wng data Inc it supported CAT 3 me CAT 2 findenzs. +

0) Re, --- - for NRC violations 84/32 11. and 8608 m were received dunna the SALP penod and were me resensive and. therefore, were mm tunely. +

(4)De board.a.a of CAT 2 was not -.- J and the board ".---- t data that --==1ed CAT 3 4.

Enforcernent History.

a. Major violations.

Mayr violatums wese rare but minor No chmige froen draft.

Changed so stad minor twogranunate Change was mapr.The samed swagram geogramenanz breakdowns did occur tweakdowns did occw. Exarnples remans breakdown was combued wah paragraph Eaamples.

asshangest whrh stseedconstructuwe generaH3 Pope angulanty problem with 5000 perfarnied adequasely and configuratum ameral afonnannte drupped. New pipe supports paragraph seased that QC errurs resuksag

Ineffcctiveconfigurationcontrol en violaines were esAmeed and then resuhed in repetatum maior violatsons.

drscuswd program prut* sis me tweakaswn. No areal analysis to seqqwwt.

b. Mmor violanons.

Not addressedin specific pragraph Sarne Same Same Nose: Nenher maps or memw addressed as a seguc.

c.Timelmessof correctsweaction.

Not ducctly and specifrally addressed Same Same Same under the topic Enfww..a History.

d.Effcctivenessof RootCause Analysis.

Examples under TU Electnc corrective -

Same Same on page 19 the paragraph on enforcement was newnnen. Maps and actums program was considered minor violanons and effectrveness of stum nieffective bestd on two examples at 42.

cauw analysis was not dratussed. :

above.

Rewording etwettere was smwe ymerve.

C4miciusion:

(1) Magr and mima violauons were not usuallyaddressed or were i= - t. - --- 1. ".

4. +

1 (2) CAT 2 fW was nor =4-8v =_--*d by data. +

(3) CAT 3 fishnas and examples were dropped concernes program tweakdown and configuratum-J (combm J became a amisve). +

r (4) Totnes in 4_b. G.o

".d. were not specifstally selressed under the Topec-Erfort-

= Hisarry +

15) No formal cend analysis was perfonned or referenced to e. -; CAT 2 or 3 f -

+

(6)The 1988 SALPdad not address seport 88/47.42 violatums and n eenforcement turause enfoscesnent action was pendmg and a was not addressed in the 1999 5 ALP. +

(7) Responses to NRC violanons in reports 88/17-14.86084, and 84/32 11 were evahme.ed dunng the SAlf pened were found in-tr.p=ar bem slus =as me addresssed en the 1949 5 A inspector) De aarreasse is greaser and appears to support,t%T 3.

L81 Responws 80 'naar or maior violaemons were not _ a conc.... reports 88/17-14.8NUR& and 84/12-ll. Also NDE Van fundmas 188/4843 and 89DR.38) and ASME iswes m

5. 4. a J and Cons..Gwe Events Nose Operatams c m.u:un IV B.then this may be. ; we.

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wr ANAt.YSIS OF SALP REPORTS Sectionof SALP Draft Desed 19 Aesgust 1989 Draft Desed 8 Septernbec 1989

' Draft Septoneer 1989 to Soard -

InestalSAtp Report

a. Significant Events.

CAT 2 fedmg but data Ases not '

CAT 2 agam but page 28 a&fs sat the Same Map Change.

adequasely support CAT 2.The measme resoluaan of deficiencies (50.55e) weve lhs paragraph was dropped and niep of few.txrasumal,or frequent signifcant eventnauy resulung in overlappmg of settocal issues =cre not suhiressed here.

events were not addressed. Repwt stated assue restduuons. The following problems that sagmficant infonnauen lackmg.and were stated Installag cabic tray covers dependmg suggested they ineptly withheld -

mformation on checivalves, on Kapean msulated cable problems.

Resolutson of cable condet sepanasons.

Weak examples of good work were included.

b. Events Reputed..

CAT 2 fendmg but enample supports Stated unemely above in 5.a and Same Not addressed afur paragraph dropped.

CAT 3. Addressed by staamg usually overlapping enfonnauan.

umely but informataan was lacking on an event that was highly segmfcant.

c. Everas IJentified & Analyzed.

CAT 2 fading but example cireport same as 52 Draft 2 above.

Same Not addressed aher paragraph drugged.

sutupurts CAT 3.

d. Man-machine interfxe Not adaressed.

Same Same Same Note: Pythably for Operatams.

Contiussons:

(I) CAT 2 fmdma is not *= ~-1y sutsiorted by data, be infor==n= suggested CAT 3.

(2) CAT 3 e-

were dropped from fmat and other information shech addressed 5 b <.

(h Board a

.u M 4.

J issues. did not assure that the -=res of performance were evaluated. i e. few nccasmal freauent did not assure that -

-a data was mcisaded nr refere ced 6.

Staffme a rosnionsidenufied. authority.

CAT 2 tatis data which spectically Same Same Same respmsibahty.

supports.

(lJenufied,%ett defmed.

Identified /dermed, poorly idenufed/well defined).

b. Vacant pisitions filled.

Not spccafacally aikessed Same Smee Same (quickly. reasonable tame. after extended inne).

c. Esperuse, reliance on consultants.

CAT 3 fmdeng suggested by Same Same Map ctunge.

weak staff.

over-reitance in consultants.

CAT 3fu gmhdrngped.

d. Management emperience.

Over4ehance resuks in consuhants takeg lead.

Nose-Imtead of --- --5. i.

Concluder

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6 ANALYSIS OF SALP REPORTS '

Section of SALP Draft Deled 19 August 1989 Draft Dated 8 September 1989.

Droit September 1989 to Soard InINelSALP Report

{1) CAT 3 findmg suotuwted, but CAT 2 not adequaselv supixmted. +

(2)One area not %~Iy addressed +

(3) CAT 3 findmg dropped frora feat. +

.(4) Service water management (R8/47-4?) was inadeauase - nas incleaded I

7.

Tramma / Oualifratums

a. Personnel errors few - procedures Same Same Same -

Sane followed.

b. Trammg program.

Same Same Same CAT 2 but angeraw submenals not twovided.

c. Inadequate traming trend no problems.

Not specifcally addressed asider trainina.

Same Same Board wrneup sad isolated problems

d. Procedures / potries violased.

Not specifralay evaluated.

Same S4me Same Conclussy (1) Trainmgas desenhed un 71-d. was not %~ly addressed in draft, and ah tals to board. +

t (2) Board evaluated tramina but it is unclear where data came from. +

(3) No eva8aws f training versus procedural / polwy violations. +

o (4) Board M run have suffucient inf<=-

to make a f'" -

B. (Engmeenna and Technical Support. (This is the second functional area to be evaluatedt 1.

Assurance of Quairty a Plannmg Not evaluased fa plan / pnonces /

Not specifrally addressed as a sopr. On Not addressed except for procedures.

Statement about pnxedures drofyed.

IWnues procedures.

page 32 :: was e*vt hat procedures t

ProceduresContro! Acuvenes.

defined but gave an exampic for stanup.

where procedures nos in pixe.

b. Pohcies(stated undenkunft Not evaluated.

Same same Same

c. Decesson mak y.tg '.evel.

Not evaluated.

Sarne Same Same

d. M.inagement acvolved with Site.

Not evaluated.

Little involvernent, planning,and Same Wpw Cbnge" assagameta priornies dunng insual Susement stama ranagement planrmg tecimicalevaluatumof AFWIcakage etc.,dregyed..

event. Corporane management involved with see. -

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hap 9 ANALYSIS OF SALP REPORTS Section of SALP Draft Dated 19 August 1999 Draft Dated 9 Septemter 1988 Draft September 1999 to Board

. Insitsi SALP Repost Eigde examples of madequae Mayw Changes-

c. Engmeenng evaluations.

Appiscant's jttsufcanons of changes to Enguieerung / sechocal support acchncal specifcanons is inadequase engmeenng cvaluauons.

Jusufcanon for not performing sess a generally west perfanned Tlwee - '

NRC poensed out problem but appicam persissed in sutunatung snadequae TS.

probicin for NRC.

czamples to segyort.

FSAR changes to sectmical Meet menunal m, -i.m.a;in Procurement of parts gave NRC concerns.

procuremere of parts.

specircasons clear.tsmely.and ptnt

- eesung a proldem supptuned. No enarnpics.

NRC concerned about post Prerarement program revised to maentenance tesung.

assure qualmy - 2 negateve examples. I pmtsve outside the reporung scrunt :

f. Corrective Acuan.

Not evaluated.

Not specifcally evaluated as a topc.

Comants One general samement that Contams couple of sensements but was Statement atmut corratmg preop action was suas taken on AFW.

m* addressed as a enpic.

prtxedures dromed.

g. Safety revews cornmittee root catrse Not specifically and endtvidually Sarne Same Same analysis - self-assessment.

addressed as a subpect tapac,but words hke notably weak on providag information,inaddequase sechnical specircassons jusufcanon /comrtson, concerns about guccurement pddems not solved in 1988 & 1989 $ ALP penod, concern atmut lessma suazest CAT 3.

Case Conclusions (I) Under Assurance of teualwy seem t tt.c.,and were not specircafly evaluated.

(2) Enginernne evalusions were in many cases -tmune.

(3) Corrective acason so prevent recurrance evaluaned but not supported (4) Inspector's input CAT 3 but SALP fmden CAT 2 after newnse.

2.

Approach to Resoluuan of Technical Issue L

a. Understanding Imie<

CAT 3 fandeng-TU E3xanc did not Same --

understand the issues e s minimally met NRC.i.,-.-.a Emample -Tech Specs.

b Conservaussn.

Not specifcally evaluated.

Same

,cpin Viable / Indepth.

Not specircally evalisased.

Same except CAT 3 languare used in paragraph abense ressnese ao NRC and she...a.-e area.

d. Problems Identified / Solved Not specurrally evaluased.

Not specircally idenufied as a sopic but CAT 3 wording sugyurt for :-

--e saanedcrural self assessment for wahse lee up not evident.

{ Approaches)

c. Resolutumes / Tienely Not specircally ev=e==ard.

Same.except exasnotes indrase resolutans not innelv.c.a. valve hae ap problem, the temurement prt*dem valve.1.frv-121.

f.10 CfR 5459 Reviews Not evaluated.

Same Conclusams:

l(I) Apprnath ks rew>lving techncal essaacs was snot evaluated for 2 b. threisch I sum - *

', ev Amated s;_.

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%.e n ANALYSIS OF SALP REPORTS Sectiott of SALP Draft Deted 19 Atsgust 1989 Draft Deted 8 September 1989 '

Draft September 1999 to Board InIWelSALP Repost (2) Adequate supptwtina data latkma en all areas.

On As discussed in the draftnhis appears to be a CAT 3 findme.

3.

Response to NRC a Timeliness.

Not evaluated.

CAT 2.however. litdc or no sipportmg data except for CAT 3. Response on sah specs, preop ersung sta ennely. Also ptmer piaseaus.

b. Resutatory issuses.

Not specifically ev=I=aard.

Not specircally evaluneed as a tosuc.

c. Responses Viable /11wwomah.

Not evaluated.

Not specircally evaluated as a nope but CAT 3 comment incl aded on startup_tesana.

d. Resoluuans Accer==Ma.

Not evaluated CAT 2 iadma but exampics in seport sunnessed CAT 3 on subentals of sech seccs and prete testens

e. NRC Polscies.

Not evaluased.

Not specifcally evaluared as a sopic but CAT 3 findena on ecch specs showed delay in implemenuna policies and unusuves.

Case Conclusions (1) Response to NRC was not evaluated for items 3.a. through e. or was only superficially addressed.

(2) Suptuxuna data for CAT 2 or 3 findmas insufreient.

0)Inforrnatum in drafts orovide neore support for CAT 1 findina-4.

Enforcement History.

a. Magar Violations.

De cope of major violations was not Same.ezcept one sentence staned 5 Same Same.encept number of 8 violatums addressed. Violations were discussed bin violatums were isolased and 3 were discussed. reduced so 7.

latie or no supporung data - such as trend programm ar - no supparung data.

analysis.

b. Mu!uple Minor Vsolations.

Not addressed. Dat is major - minor not Same,except parnally addressed.

Same Same specircally addressed.

c.Correcove Acuan.

CAT 2 fmdag - no supporung data.

CAT 3 findmgcorrectrveacuan for AFW Same CAT 2 findmg stased that corutsve precursor events inadequate. Industry actions were taken but does not give expenence of revUw could have adequase suppvung data or specircally prevented AFW.two violanons for address prosupt and effective conectswe '

faehare no tske unectsve acuan.

actstm. Dropped nenauves.

d. Root Cause Analysts Not addressed.

Not specircally addressed except a Same Same.cacept men cause of AtT wadatum review ofindussry experience wah valves held up tccarse violanon not issued.

- rout cause could have prevented recunenceJ.up.

violanons probably resulted from not evalanung rotacause.

Case Conclusions O ) Mayr or mwmir violatums and repeuuveness were consistently noe adequasely evalemed and supptried by data.

(2) Root cause (4.d ) was not ssurifcally eval-med for technical suppewt.

(3) Suptwut m drafts indcane support for CAT 3 f m..c m Service waser in 19118 SAIPdeffered to 19189 SAI P seriod las was not A 4

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ANALYSTS OF SALP REPORTS Section of SALP Draft Dated 19 August 1989 Draft Deted 8 September 1988 Droit September 1989 to Board IreIIIst SALP Repost f Corrective actions.

CAT 2.one exampic - insuffrient data.

Same Same Same. CAT 3 susuteste4.

g. Safesy Review Committee.

CAT 2 based only on plant evalustam Same Same Same group when introducuan ofIV.C.

indscates rnany more gnusps involved. -

Insulficient data.

Conclusites-(1) The functional arez n to be redundant as i; is covered in Table t "Evh== Crueria and Atenbuses for Assessment of trensee Perfomance"_.5. Operasanal and Constructson Events.

(2) For whatever reason for this.c' covermee. the specife crieena (IV C 1.) was not snenftally addretted 2.

Approach to R*=d==== of Techncal Issases.

a. Understandina.

Not specifically evalussed.

Same Same Same

b. Camserv===

Not specircally ev=haard.

Same Same Same

c. Approach vsable.

CAT 2 findmg but CAT 3 example -no Same Same Same supportint das. -

d. Problem raurrence.

CAT 2 fmdmg but CAT 3 example -no Same same Same support.nst data.

c. Resolution tunely.

Not evaluated.

Limeted posstive sedeement =Merf about Same Same plant evaluaten aroup.

f.10 CIR 50.59.

Not evaluaaed.

Same Same Same

==

Conclusions:==

If!)Same as forIV C 1 above.

3.

Response so NRC.

at Tamely.

Not specircally evaluneed.

Same Same -

Respmse to Bulletues and Informatum Nossces tunely.

b. Regulatory issues.

CAT 2 supported wah CAT 3 examples.

Same Same CAT 2 famimg wan funned CAT 2 examples and CAT 3 examples.

c. Response viable.

Not specifrally ev=haarvi as a topc.

Same Same-Response BuHetms/Notres aliarough, however supportenadatatenused.

d. Resolutions.

CAT 2 finding with no supportencept Same Same Same CAT 3 cm._

'i e implemect NRC Polcus /Innsative.

Not specifsally evaluneed but response to Same same Same NRC about ausdary syssems and startup

~

test trogram CAT 3.

Contlusions:

(1) Sarne as IV.C.I. J~.;.

M.:.g by the NRCover a kmg perum!of eme (2) Kapeon given as posaive,however, the applcant argued for extended penod pnor to this SALP pmod the these was no problem. Actsun a resdt of and tecause of 4

and alleeansons 4

Fnforcc.T.cn liistory.

2_

A.

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. C.

s.

g-01 ;-

Gr

'.. *3 mn ANAI.YSIS OF SALP REPORTS Section of SALP Drelt Dated 19 August 1989

- Draft Dated 8 September 1999 Draft September 1989 to Board inIpst SALP floport u

a. Major violanons Not specif cally addressed,just Same cscept reduced no 3 violasions.

Same Same i

commened I5 gr4ations.

D. Menor violations.

Same as 4 A above.

Same except reduced so 3 violanons Same Same c.Correctsve action.

Not specifscally evaWM and supported Same Sune Same by data.

d. Root caine.

Same as 4r. above.

Same Same Same Conclusions-(1)Same as IV C I above 5.

Operational / Construenon Events.

L

a. Sigmficant event / frenguent.

Not specifically addressed / cvalmased as Same Same Smne -

topic.

b. Event repon timely.

Not evaheted as specific totac.

Same Same Same

c. Idenuf sed / analyzed.

Not evaluased as spec Gc sopic.

Same Same' Same

d. Man - mactune meerfaces.

Not evaluated as specific topic.

Sarne Same same Conclusions-f1) Same as IV C I abnvc 6.

Staffmn.

a. Key positions.

Not evaluated.

Same Same CAT 2 fedma ma supported by data.

l

b. Vxans key poue==w Not evaluated.

Same Same CAT 2 findmg not seepuned by data.

c. Staff / consultant experuse.

Not evaluated and supponed widt data.

Same Same CAT 2 fandmg but negauve mput from enspecsors not accurasefy descrkd. Than es om selsanceon contractor /

camsultants anempts to excuse a large number of seen stems.

I

d. Experience levels for ----

met.

Not evaluated.

Same Same Same l

Coriciusums-(I) Same as IV C 1.1,.e.

7. TramineOualifi- =

a. Understard work.

Not evaluased and sieponed by data.

Same Same Same

b. Procam defined.

Not evalmased and supponed by data.

Same Same Same

c. Inadeguase traming,cause of problems.

Not evaluased and <==wwsed by data.

Same Same Sanne

d. Procedures folk, i.: after trauung.

Not evaluaned and saeponed by data.

Same Same Same Conclussons-l111 Same as IV C 1 atme D. l Plant G--6.

~

..73.

~

w 1-. s S D

~=

.a

was ANALYSIS OF sal P REPORTS Sectionof sat.P Draft Deled 19 August 1989 Draft Deted 9 Sopeember 1989 Draft September 1989 to Board Infelet SALP Report 1.

Assurance of Qualesy.

a. Planning / assignment.

CAT 2 fmding supptwted by several Same same Same ex_..,.:.

b. Iblicies.

Not evaluated.

Same Same Same

c. Decision making levet.

Not evaluased.

Same Same.

Same d.Corporme management at site.

Corp. mgt not evaluated but negauves Sa:ne Same Same given on plant management and operie==.a eh< samteseed CAT 3.

r

e. Engmeer Evalumuons Not specifrally ev=hemsed.

Same same.except involvement was CAT 3 Same fedma for chak valves.

f. Cortcuve ai,u.6.

Not specifically evaluased.

Same Same Same Contlusions-(l) Crueria 1.b.s..e.. and f. were not specircally and adequaselv evaluased.

(2) Co.--* -

.c..: was not (.

--A Plant - -.

..;*s w.b.-e reflects bndiv on cor=wmar 2.

Aps-s h ao resolving technical issues.

a. Understandmg issues.

Not specircally evahaned but one Same Same Paragraph wah CAT 3 fedmg drW.

example which supported CAT 3 fmdmg -

was riven.

i I

b. Conservatism.

CAT 2 fandag with some supportmg data Same Same Same and CAT 3 examples.

c. Approach vrable/ thorough.

Not specircaHy evalunged but a stiff Same Same Same concern was due to appicants lack of -

attentum to detail.

d. Problems recur before resolved.

Notspecifrallyevaluasedexcept AFW Same Same Same backflow event discussed recurrance and was CAT 3.

c. Time reso.uuons.

Not specifrally evaluaied and supponed, Same Same Same but one statement andrated slow ressamse.

f. 50.59 review.

Not evaluased.

Same Same Same Conclusxms-(1)Cniena and atenbutes 2.a. c..d..e and f. were not specificaur and 4

=b evalmasett (2) Ttuwe evaluated were weakly +-----J w"----1-_ - CAT 2 or 3.

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ML20012D210

Contents

Text

Dear Mr. Taylor,

Enclosures:

Dear Juanita:

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ML20012D210

Text

Dear Mr. Taylor,

Enclosures:

Dear Juanita:

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