ML20033H181

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Lists Concerns Re Deficiencies Identified in Operational Readiness Assessment Team Insp Repts 50-445/89-200 & 50-446/89-200.Organizations Operate Too Independently of Each Other,Resulting in Inadequate Info Flow
ML20033H181
Person / Time
Site: Comanche Peak  
Issue date: 03/30/1990
From: Garde B
Citizens Association for Sound Energy, ROBINSON, ROBINSON, PETERSON, BERK, RUDOLPH, CROSS
To: Crutchfield D
Office of Nuclear Reactor Regulation
References
NUDOCS 9004180334
Download: ML20033H181 (2)


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Robinson, -.

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.a Robinson,.Peterson, Berki.

- Rudolph, Cross & Garde.

Mary Lou Robinson Attorneya at Law ?

Nila Jean Robinson-los East College Avenue 3 Jotut C. Peterson Appleton, Wisconsin 64911'

' Avram D. Berk -

(414) 781 1817 Michael Rudolph Green Bay 494-9600)

Dan Cross '

Fax 78us41.

Billie Pirner Garde Dennis M. Crutchfield,. Associate Director for Special= Projects..

Office of Nuclear Reactor Regulation'~

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Subject:

L NRC Operational $ Readiness Assessment = Team (ORAT),

Report 50-445/446-89/200-200 3

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Dear Mr. Crutchfield:

As you know, the Citizens Association f or-Sound Energy '(CASE) 'has '

Jf been actively involved-in. monitoring the Comanche Peak Nuclear Power P1 ant.

In that regard, we participated in-the-exit of theLOperational j

Readiness' Assessment Team (ORAT).

H.

Shannon phil1ips, Sr., CASE l

Consultant, evaluated =the inspection documented-~in the' referenced

.i report to determine'if:NRC Inspection Procedure 93806 was followed.

Our consultant concluded that the NRC performed a thorougl. inspection j

and that the results'were well documented.

The NRC inspection team l

identified significant deficiencies in.'several different areas..

Although the NRC performed-a through inspection CASE is concerned about several areas where deficiencies were identified in the NRC i

report.

We believe the following areas deserve further scrutiny;.

Organizations appear to operate too independently of each other and,-as a result,- the information flow'between organi-zations is'often adequate.

!j Maintenance work was performed that was outside the scope of the original work order but the shift supervisor'was not notified.

'Organizationsioften make such decisions without j

sufficient authority.

Also no nonconformance report-i

'(ONE form) was initiated when maintenance identified poten-tially adverse conditions'.

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Problems with housekeeping and material control have oc-curred and were-identified by the NRC dating back to 1985.

CASE is concerned that TU Electric has been unable to effec-tively solye the problem.

The NRC GRAT inspection-found the applicant's program ineffective.

9004180334 900330 PDR ADOCK 05000445 PDC g

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Problems withLoverdue preventive maintenan'ceLitems continue.:_

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-Problems lwith developing' procedures'that effectively 4

accomplish-' goals, objectives,:and1 tasks continue.

Prob 1' ems with determining root causes.ofideficiencies.

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-continue.-_The-ORAT. inspection stated =that TU Electricihasta tendency to address;the specific deficiency.and_ rarely mentioni-the, program; f allures.-

If you have in; any: questions: please= contact me at'.(414') 731-1917 :

or Mrs.-Juanita Ellis, The President of._ CASE, at - ( 214 ) '.94 6-94 4 6'.

Sincerelyj7 1 - 2c & g l

Billie Pirner Garde-L i

Attorney-for CASE km-Ef 4

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