ML20114A717
| ML20114A717 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Waterford |
| Issue date: | 04/30/1984 |
| From: | Jay Collins, Harold Denton, Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE), Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20114A683 | List: |
| References | |
| FOIA-84-448 PROC-840430, NUDOCS 8501280407 | |
| Download: ML20114A717 (14) | |
Text
{{#Wiki_filter:.. ENCLOSURE WATERFORD UNIT 3 OPEN ITEMS MANAGEMENT PROGRAM -.~ -. APRIL 1984 Approval: H.R. Dinton, Director, NRR Date R.C. DeYoung, Director, IE Date J.T. Collins, Administrator Date Region IV hDR #*?l07840807 OARDE84-448 pg NV
( 'WATERFORD 3 OPEN ITEMS MANAGEMENT PROGRAM l 1 Contents l l 1 Page I Purpose.......................... II Scope........................... III Methodology / Approach IV Schedule V Development and Retention of Supporting Data VI -Protecton of Individuals VII Special NRC Staff Actions................. VIII Manpower Accounting.................... ATTACHEMENTS 1. Waterford 3 Open Items Management Staff 2. Format for Waterford Open Item Listing 3. Format for Allegation Action Plan
4 ~ WATERFORD 3 OPEN ITEMS MANAGEMENT PROGRAM I Purpose The purpose of the Waterford 3 Open Items Management Program is to provide the basis ~ for a prompt licensing decision on the facility. Specifically, the program will:-_ --. a. Provide for a systematic assessment and resolution of licensing. actions related to the Waterford facility. b. Provide a review of the facility status and a focused inspection effort to assure prompt resolution of all technical and non-technical matters. c. Provide needed support to. address hearing related issues, and d. Provide an assessment of the generic and specific implications of allegations of improper practices during construction at Waterford. II Scope The Waterford 3 Open Items Management Program is intended to encompass all remaining issues that need to be resolved before the staff can make its licensing decision. The Program requires that all NRC Offices with information that could affect the Waterford licensing decision shall forward such information to the Program Staff in a timely manner. l l l L 1 - -
~ 2 III Methodology / Approach The Waterford 3 Open Items Management Staff is an integrated group of representatives from NRR, Region IV, IE, and OELD as identified in l. The Office of-Investigations will assist the team as appropriate. The program is not intended to circumvent any other ~ established NRC management program nor does it relieve any office of its normal organizational and technical responsibilities. To the contrary, the Program is intended to coordinate and complement the -activities of the NRC Offices as they relate to Waterford 3. The Open Items Management Program includes the following elements: 1. Development of a comprehensive listing of all Waterford open items. The format for the listing of an individuel open item is provided in Attachment 2. The distribution of the actual list is controlled 1 and limited. 2. Development of a tracking system using the 5520 word processing equipment. The tracking system will track all open items through close out and will have the capability of being accessed at HQ, RIV or the site office. 3. Definition of an action plan for each open item which'provices an approach to resolution. This action plan shall include such items as: technical approach to resolution; identification of lead / support responsibilities, resource requirements, schedule for completion; and includes an initial assessment of the potential significance of the open item. An example of an allegation action 4 plan,is provided in Attachment 2. 4. The approach to resolution in the action plan will also address the generic implications of 'the open item and management break-downs which are indicated. Responsible Lead Office will review and concur on the action plan for each open item. 5. ' Implementation of the action plan. L 2 -~-
i .s .3 6. Status reporting and preliminary assessments of the significance and programmatic implications of outstanding open items in time to support Commission consideration of Waterford 3 licensing actions. 7. Where allegations are involved, use of procedures to maintain anonymity-and confidentiality of allegers expecially when requested. 8. Confirm with the alleger (when possible) that the NRC has an accurate initial understanding of the concern; and 9. Feedback to'all allegers, when possible, for further assurance that evaluations accurately address the concerns of the allegers. 10.- Publication of an SSER that documents the results of the staff's findings. The format for allegations is included as Attachment 4. IV Schedule Actions associated with Waterford shall be accomplished in accordance with the following general schedules: Approval of Open Item Management Program Action Plan Allegations o Technical Issues to Applicant April 2, 1984C o New Allegations rec'd from 0I when available o New' Technical Issues given to Applicant when available o Enhanced Onsite Assessment of Issues Thru May 25, 1984 o Written Report of Open Items including Applicant's Response to 4/2/84 ltr. June 1, 1984 Inspections o Fire Protection and Appendix R April 13, 1984C o Routine Inspections Thru June 1, 1984 FSAR Licensing Issues Completed (SSERIssued) May 21, 1984
4 4 Basemat Crack Issue o Meeting with Applicant March 26, 1984C o Site Visit March 27, 1984C l o EBASCO Visit April 4, 1984C o Evaluation Complete by DOE /NRR April 27, 1984C Hearing Issues o Response to QA Motion April 6, 1984C o Response to Basemat Motion
- May 15, 1984 CAT Report Issues May 18, 1984 V
Development and Retention of Supporting Data An individual record file shall be developed and maintained for each ~ open issue by the lead NRC office as necessary. This file will contain or reference pertinent documentation associated with the open issue. Resolution of each issue shall be supported with a clearly auditable record trail. Accordingly, the record file shall contain or make reference to all significant records relied upon to reach resolution. Records of personnel interviews shall be developed and retained in those instances where interviews are relied upon by the NRC staff for decisions of technical adequacy. Interview records shall, as a minimum contain: the date, time, location of the interview; the name-l of the interviewer and interviewee; and a summary of questions asked and relevant information obtained. l l l
5 Upon issuance of reports (such as SSER's or Inspection Reports) which close out open issues, those records which are appropriately referenced ~ in the NRC reports and are traceable through some other means (e.g., meeting transcripts, permanent applicant records, etc.) may be removed from the record file as-approved by Program management. VI Protection of Individuals The identity of persons providing allegations to the NRC shall not be disclosed as a matter of practice. In addition, for those individuals expressly requesting confidentiality all efforts shall be made to protect the individuals identity. This will include: limited and controlled distribution of allegation dccumentation and correspondense; minimal use of names, identifying titles, or position descriptions in written material; enlarged sampling of activities so that it is not evident to personnel outside the NRC that the particular sample selection is related to the alleger; and other indirect approaches toward investigation / inspection of allegations. During the' course of NRC reviews or inspection, similar efforts shall be made to protect the identity of licensee or contractor employees who provide i information which may be construed as being critical of licensee or contractor activities. l
i 6 Receiving, clarifying, evaluating, and documenting allegations may involve direct NRC staff contact with allegers and will involve representation of the allegers concerns in NRC documentation and other communications. These oral and written communications shall be professional and objective in nature and shall not reflect a prejudgemental or defensive posture on the part of the NRC staff. Further, these communications shall not infer criticism of the allegers' motives, or technical expertise. VII Special NRC Actions As addressed in certain action plans on allegations, it may be appropriate to initiate actions which are not routinely required for allegation followup. These may include: issuing requests for information to the licensee under 10 CFR 50.54(f), Confirmation of Action letters or orders; or requests to the Department of Justice to grant immunity for certain individuals. Actions such as these, if required, shall be handled in accordance with established NRC procedures. VIII Manpower Accounting Offices shall implement established manpower accounting systems to monitor resource expenditures related to this activity. Attachments: As stated l l WATERFORD UNIT 3 OPENITEMSMANAGEMENTPROGRAMSTAFF Organization Name Position _ ~ -. Program Management D. Crutchfield Program Manager Region IV J. Gagliardo Staff Leader NRR T. Novak Member IE R. DeYoung Member OELD J. Scinto Member WATERFORD OPEN ISSUES Task: Ref. No.: Characterization: Initial Assessment of Significance: Source: Approach to Resolution: 1. 2. 3. 4. 5. 6. 4 Status: Review Lead: Support: Estimated Resources: Estimated Completion: CLOSURE:
R:visicn 1 l t 5/3/84 ATTACHMENT 2 DOCUMENTING FINDINGS Allegation Writeup (SSER) All allegation reviews and close-out will be documented in supplements to tfie SER. The SSER input will be submitted in the format shown below. Note that Items 5, 7, and 8 will not appear in the SSER, but are needed in the input packages to enable preparation of~s'ubsequent enforcement actiori and to .. assure review by team / task force management. -We plan to issue SSER's which are very similar in content and fonnat to those issued for the Diablo Canyon effort. Copies of the Diable Canyon SSER are available in the SRI office and in the trailers. Task ' force members are encouraged to.look at these SSER's and to use them as guidance in preparing our SSER inputs. Additional guidance is provided below. FORMAT / GUIDANCE FOR SSER input 1. Task: Allegation No. A-This is the "A" number in our tracking system. 2. Reference This is the number in the tracking system such as 4-84-A-06-23. 3. Characterization Statement of the allegation in plain English. The characterization should be brief and understandable to nontechnical people. If the allegation was clarified with the alleger, then so state. 4. Assessment of Allegation Briefly sumarize what was reviewed and then discuss the safety significance of the findings with regard to the design, construction, operations, QA, and/or management controls. Also address the generic implications of the findings and the root cause or management issues as. appropriate. If the findings indicate a potential violation of regulatory requirements, then so state in very brief terms. Note - the introduction to the SSER will state that potential enforcement issues will be addressed in a subsequent inspection report. 5. Potential Violations If this violation involves a potential violation, a writeup (preferably in NOV format) is needed to capture this information for later use. This section will not be in the SSER, but will be used to generate the NOV in l the inspection report to be issued later. We need this information at this l point because we want to avoid having to recontact team members to determine l what procedure or regulatory requirement was violated. l 4
5/3/84 i ,= 6. Actions Required Document in this section the actions required by the licensee and state whether or not it impacts on OL issuance, fuel load, initial criticality, etc. The action required by the licensee should include any TS or FSAR changes that are needed. Al o address any additional inspection or investigation efforts to t. scheduled to close or followup on the findings. 7. References This is a listing of the documents which were reviewed in this area and are included in the document file for this allegation. The section will riot be placed in the SSER. 8. Prepared by: Name Date Reviewed by: Team Leader Date ~ ~ Site Team Leader (s) Date Approved by: Task Manager Date
May 3, 1984 ATTACHMENT 3 REVIEW 0F WRITTEN OUTPUT (SSER's AND REPORTS) The review path for all Task Force outputs (SSER's and Reports) is outlined in the attached flow path. This flow path will assure that the appropriate reviews are made and that the outputs are controlled and tracked. The originator's hand-written draft is to be completed in accordance with the instructions in Attachment 2. If copies of the draft are made and retained by the originator (or team leader), they-should be destroyed after the typed version has been retrieved. Each new draft should be dated with the new -revision number indicated. Team leaders will sign or initial all inputs that are sent for typing. The secretaries have been instructed not to type any input that does not indicate such review. Walt Oliu (Technical Reviewer) and Bill Crossman will review all typed drafts that have been significantly revised. Walt and Bill will work wita the team leader,to ensure that the proposed revisions or rewording are understood and concurred in by the team leader. Team leaders are to discuss the revisions with the originator of the document to ensure that he understands the reason for the revision and will correct subsequent outputs based on this feedback. O
. f May 3,1984 TECHNICAL REVIEW & EDITING CYCLE Originator i Karen (hand-written draft) l Typing Karen /Ronnie I l Team LeaderI' I
- l. Karen /Ronniel Typins l
l Karen /Ronnie1 Editing (Walt & Bill Crossman) lTo elarify text, etc. l I Team Leader I Kcren/Ronnie' m... i Typ'ing i Management Review (Gagliardo & Crutchfield) i Final Typing 9
futuqjo UNITED STATES + 4 g g} y, ( '3 g NUCLEAR REGULATORY COMMISSION
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] 'MAY 2 51984 MEMORANDUM FOR: Harold R. Denton, Director, NRR Richard C. DeYoung, Director, IE John G. Davis, Director, NMSS Guy Cunningham, Executive Legal Director Thomas E. Murley, Regional Administrator, R-I James P. O'Reilly, Regional Administrator, R-II James G. Keppler, Regional Administrator, R-III John T. Collins, Regional Administrator, R-IV John B. Martin, Regional Administrator, R-V FROM: William J. Dircks Executive Director for Operations
SUBJECT:
ACTIONS FOR PLANTS WITH NEAR TERM LICENSING ACTIVITY After reflecting on our discussions during the management meeting on May 17 and 18, I have decided upon the following course of action to ensure better coordination of our activities: 1. An integrated schedule of all NRC activities (licensing, inspection, hearing and investigations) is to be developed by June 18 for the following facilities: Comanche Peak Fermi 2 Wolf Creek Diablo Canyon 2 TMI (restart) Byron 1 San Onofre 1 (restart) Limerick 1 The integrated schedule should identify the expected completion dates for activities necessary to meet the projected fuel load or restart date and the organizations and personnel specifically responsible for completing the activities. Critical path items should be highlighted. In adjusting internally for resource allocation for developing and directing the schedules, you should ensure that operating reactors remain adequately covered. Anticipated requirements for supplemental resources, if necessary, should.be clearly identified and contract personnel should be used where possible. Harold Denton is responsible for developing the integrated schedules and managing their implementation. The other Office Directors and Regional Admini,strators are responsible for providing complete and timely input to gM
. MAY 2 51984 Harold Denton. Organizational units are responsibie for conduct of their normal ~ functions as delineated in the NRC Manual in implementing the schedules, subject to coordination with and overall management of the effort by NRR. 2. I desire to be briefed on the integrated schedule for the eight plants identified above initially, on a monthly basis. The briefings should identify all potential problems in meeting the schedules and describe the proposed resolution for any identified problems. Although it is probably too late for development of an integrated schedule, I also want to be informed at the briefings of any problems and proposed resolutions associated with the very near term plants such as Grand Gulf, Shoreham, etc. Harold Denton is assigned responsibility; for arranging and conducting (addressees) and appropriate Regional Administrators in the the briefings and I expect participation of the Office Directors briefings. Integrated schedules should be provided to me at least 3 days prior to the briefing. The first briefing should be scheduled for the week of June 18, 1984. The Director 0I is invited to participate in the scheduled briefings for those plants that have ongoing or pending investi-gations. 3. Regarding Comanche Peak, Tom Ippolito should proceed imediately to staff the organization and implement the necessary actions to complete NRC activities in the time frame necessary to support the Fuel Load date. In staffing the organization, the following guidelines apply: (a) Inspection and Licensing Resources are not to be diverted from Operating Power Reactors beyond a level acceptable to the Director, IE,'and Regional Administrators (inspection) and Director, NRR (licensing). (b) Contracted resources should be used to the maximum extent possible in constituting the review team. (c) Requests for personnel will be on a " functional" rather than a "name" basis. Office Directors and Regional Administrators are expected to provide fully qualified personnel for the requested functions to be performed. Requests should be coordinated with Jack Roe. I expect the organization to be in place and functioning by June 4, 1984. 4. Regarding Wolf Creek, Dick DeYoung, in coordination with John Collins,' Jim Keppler and Harold Denton should develop a recommendation regarding the appropriate role of Region III and Region IV in completing the inspection program. I would like to receive the recommendation by May 31, 1984. 5. Regarding other NT0Ls or problem facilities, integrated schedules should be developed and periodic EDO briefings conducted. At the initial briefing (week of June 18), please be prepared to discuss the time frame for development of an integrated schedule (e.g.15 months prior to fuel load) and the frequency of briefings (e.g., quarterly and.then monthly 6 ' months prior to fuel load).
~ y ~3-hiAY 2 5 Th If there are.any questions regarding this memorandum, please contact me-promptly. I Willi J. Dircks-Executive Director for Operations cc: B. Hayes R. B. Minogue P. G. Norry L. Barry C. J. Heltemes G. W. Kerr ~ .T. Ippolito 't e O a 1 '} 2.- + ,.n
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- E May 30, 1984 MEMORANDUM FOR:
Richard C. DeYoung, Director, IE John G. Davis, Director, NMSS Guy Cunningham, Executive Legal Director Thomas E. Murley, Regional Administrtor, Reg. I James P. O'Reilly, Regional Administrator, Reg. II James G. Keppler, Regional Administrator, Reg. III John T. Collins, Regional Administrator, Reg. IV John B. Martin, Regional Administrator, Reg. V FROM: Harold R. Denton, Director Office of Nuclear Reactor Regulation
SUBJECT:
ACTIONS FOR P-- NTS WITH NEAR TERM LICENSING ACTIVITY This is to inform you of actions NRR has taken in order to complete Step.1 and 2 as identified in the May 25, 1984 memorandum from W. Dircks regarding near term operating license activity. Recall that Step 1 calls for the development of an agency-wide integrated schedule by June 18, 1984. In order to focus the appropriate management attention on the plants identified in Step 1, NRR has designated selected managers to accomplish the development of the integrated schedules. The designated managers are: Waterford D. Crutchfield Comanche Peak T. Ippolito Fermi 2 W. Butler Wolf Creek K. Kniel Diablo Canyon 1/2 C. Grimes TMI-1 (Restart) J. Stolz Byron 1 W. Gammill SanOnofre1(Restart) C. Grimes Limerick 1 W. Regan These managers have been assigned full time to this effort until the completion of the development of the schedules. Coordination of this overall activity has been assigned to the Director, Division of Licensing. 7 4 v3
. c -} In order to ensure that this effort is completed in sufficient time for management to review the end products, I am requesting that you each begin to assemble a listing of all remaining NRC work activities under your 2 cognizance. Your listing should not only identify the detailed work item, but the time frame for completion of the activity, and should identify the NRC crganizational unit assigned to complete.the task..The designated managers will visit appropriate NRC Regional Offices about June 5-7 for the purpose of receiving, reviewing, and discussing remaining NRC work activities required for full power licens.1g of these facilities. Similarly, the designated managers will be meeting with other Office representatives (IE, ELD, NMSS) during the week of June 4 in order to obtain a similar listing.of activities under their cognizance. We request that you each identify a management contact within your Region or Office for accomplishing this effort. NRR will be developing a standard format for use in summarizino all work activities. NRR will also coordinate the interface with 01 for the plants identified in Step 1. Your prompt attention to this matter and your cooperation is appreciated. / n Harold R. Denton, Director Office of Nuclear Peactor Regulation cc: B. Hayes D. Eisenhut T. Novak D. Crutchfield T. Ippolito / W. Butler K. Kniel C. Grimes J. Stolz W. Gammill i W. Regan W. Dircks
p :'. > COMANCHE PEAK PLAN FOR THE COMPLETION OF OUTSTANDING REGULATORY ACTION.S MAY 1984 Approval: R. DeYoung, Director, IE Date H. R. Denton, Director, NRR Date J. T. Collins, Administrator Date Region IV sme/ - _s f Q g, L~a <- U I. f l
. w COMANCHE PEAX' PLAN FOR THE COMPLETION OF OUTSTANDING REGULATORY ACTIONS I. PURPOSE AND SC0pE on !1 arch 12, 1984, the EDO directed NRR to menace all necessary NPC actions leading to licensing decisions for Comanche Peak and Waterford. A copy of that directive is included as Attachment 1. This plan establishes the procram for Comanche Peak. The purpose of this plan is to assure the overall coordination and integration of the outstanding regulatory actions regardina Comanche Peak, and achieving their resolution prior to a licensing decision. This' plan encompasses all licensing, inspection, hearing, and allegation issues. Further, this plan addresses the scope of the work needed, specifies the critical path issues, identifies the responsible line organization, the schedule for completion, and (where applicable.) the need for additional resources to meet the schedule. The planned completion date for all regulatory actions is assumed to be October 1,1084, and resource needs are'
- redicated on that assumption.
p A status report wi'l be issued to mana weeks after the approval of the plan. gement every two weeks startino two II. BACKGROUND 1 Comanche Peak Steam Electric Station Unit 1 is in the final stages of the operating license review process. The Construction Permits for Unit I and 2 were issued on December 19, 1974. Texas Utilities docketed their application for operating licenses on April 25, 1978. The Final Environmental Statement ivas i'ssued September 24, 1981. The Safety Evaluation Report (SER) was issued on July 14, 1981. Because of the large number of outstanding issues identified in the SER, the staff recommended delaying the ACRS review. SER Supplement No. I was issued on October 16, 1981, and the ACRS meetire was held on November 13, 1981. The ACRS, by letter dated November 17, 1981, supported issuance of an operating license. The latest SER supplement was issued on November 23, 1983. Comanche Peak has been in a heavily contested hearing for over two years. All but one contention have been dismissed. The remaining contention questions the ability of the applicant's Quality Assurance /Ouality Control Program to prevent deficiencies in the design and construction of the plant. The Licensing Board has admitted many allegations of design and construction deficiencies into the hearing as relevant to this contention. The Applicants are currently pro.iecting a fuel load date for Unit I to be in late September 1984. The basis for this projection was provided te i the staff on Pay 7, la84. This fuel load date appears achievable but allows n6_ flexibility for unexpected events in a very tight schedule. The nus6er of hearing issues and uncertainty regarding the timino of the Licensin'g Roard's initial decision may impact the fuel load. o -,,s_,....._s a y-.,, ,-_-y
. III. PLAN FOR THE COMPLETION 0F OllTSTANDING REGULATORY ACTIONS This plan describes the method'in which coordinated regulatory actions are to be taken by the staff to be ready to support an NRC decision regarding Comanche Peak licensing. As stated in the Purpose, the plan encompasses all licensing, hearing, inspection, and allegation issues. This summary addras:es the scope of werk needed, identifies the responsible line organization, the schedule for completion, ard the resource needs to, meet the schedule. Thimanagementorg:nizationalarrangementresponsiblefordirecting the overall effort and coordinating actions by the various involved offices is shown graphically in the enclosure to the EDO memorandum of March 12,1984 (Attachment 1). The management is under the overall direction of T. A. Ippolito, who reports to the 1)irector of the Division of Licensing. The managgrs responsible for implementing and directing this organization are the following individuals: Project Directo'r (T. A. Ippolito) - - - - - -{ 0 ELD Contact (d. Scintoll - - - - - -t 01 Contact (B. Hayesll NRRkction Region IV Actions IE Actions (T. Novak)- (R.Bangart) (R. DeYoung) The line o'ffices will continue to manage their own responsibilities regarding Comanche Peak in accordance with the schedule and ' objectives of this plan. Line office activities are to be coordinated with the program management organization via their representative as identified above. Additional resources are expected to be necessary to support licensing, hearing, and inspection issues, and substantial resources are necessary to respond to the approximately 400 allegations regarding Comanche Peak. This plan proposes the formation of an Technical Review Team (TRT) to evaluate and resolve a number of technical issues, including allegations, presently identified. A proposed organizational chart of the TRT is shown below. The groups identified will be assigned to evaluate and resolve technical issues and allegations that have been grouped into five technical areas: QA/QC, Electrical / Instrumentation Civil / Mechanical, Coatings, and Test Programs. The groups will be comprised of a group leader and reviewers that are specialists in the particular technical area, i
.. Comanche Peak Technical Review Team (TRT) Pro.iect Director Decuty Pro 1ect Directnr l Office of Investigations GROUPLEADER5' OAIOC Electrical / Civil /M chanical Co[ tings Test Program Records Instrumentation and Operational Readiness The staffing of these groups will be drawn from the various NRC offices and/or contractors as arranged between the Project Director and line management. The TRT may be called together for a specified period of time, dispersed back to the individual's parent office, and then reconstituted in whole or in rart as needed to complete resolution of like issues. The TRT will be under the direct supervision of the Pro.4ect Director. In accordance with the EDO memorandum of May 25, 1984, the TRT organization is scheduled to be in place and functioning by June 4, 1984 Detailed guida~nce will be issued by the Project Director to the Technical Review Team and other participants in this effort. This guidance will address the following: Method and approach for identification and disposition of allegations Tracking System Preparation of Documentation and Records Protection of Individuals Initiation of Special NRC actions, such as Confinnation of Action Letters or 50.54(f) letters Manpower accountino The basis upon which the schedules and resource estimates have been developed is that the Comanche Peak fuel load date is October 1,1984 Fioure 1 is an overall schedule and Figures 2 throuch 5 are individual schedules for the resolution of Licensing, Hearing, Inspection, and Allegations Regulatory Actions, respectively.
, The major issues, schedules, and resource estimates needed to meet the schedules are sumarized as follows: A. Licensino Renulatory Actions Licensing Actions are those things resulting from the design review of the FSAR. NRR is responsible for the resolution of these action items. .Thetotalnubberofoutstandingactionitemsis37. Four of these action items are considered to have the potential for impacting the schedule. These' items relate to 1) the adequacy of the TDI diesel generators, 2) the the Applicants' exemption request for relief from GDC-4, 3) review of' the Cygna Report of an independent assessment of.. design and construction, and 4) electrical equipment environmental cualification. NRR experience with other facilitie involved in complex licensing reviews (Diablo Canyon, Seabrook, ant Shoreham) indicates that f additional project management resources are necessary. Two additional project managers for the period from June-September will be needed, for a total of 8 man-months of additional effort. The technical resources presently assigned by NRR to evaluate and resolve the remaining open licensing actions are sufficient to meet the schedule shown in Figure 2. Additional IE resources are not expected to be required as the CAT inspection is complete and 0A/QC reviews and emergency preparedness reviews are essentially complete. B. Hearino Reaulatory Actions Hearing Actions are those issues in contention before the ASLP. There are three major issues each with a number of sub-issues. The three major issues are Design Adequacy and Quality Assurance, Construction Adequacy, and Construction Cuality Assurance. There are two critical path actions: Design Adecuacy and Construction Adecuacy. The design adecuacy action concerns an IDVP being performed by the Applicants at the staff's request. CYGNA is performing the review for the Applicants. This is currently.under review by the staff. Cygna personnel actions may have contributed to be prenot.ifi-cation of inspection areas to Applicant OA/QC personnel. Resolution of this concern may make it necessary to request additional independent assessment activities. The critical path issue concerning Construction Adecuacy is containment liner coating (painting).
. The resources presently available are sufficient to resolve all hearing actions 'with_ the exception of the critical path issues. It is estimated that 10 man-months are required to resolve the Design Adequacy Action, and 6 man-months to ovaluate the Construction Adequacy Action (paintfrg). The design adequacy review will recuire J a team composed of IE and flRR personnel, similar to the Cygna IDVP effort. Coordination of Hearing activities is expected to be extensive and involve integrating the activities of NRR, OELD, and Region IV with the Technical. Review Team. An additional senior manager (SES- .. level) is needed to man' age this effort as it is expected that the Project Director will devote full time effort to management of the technical review team actions enmmencing June 4,1984 l These estimates assume that the reviews wilJ conclude that the I ~ existing circumstances are acceptable to the staff and/or no major corrective actions,are required of the Applicants. Should this prove otherwise, additional resources will be required for resolution. See Figure 3 for Hearing Testimony.Comoletion Schedule. C. Inspections Regulatorv Actions I Inspection actions are those that assure that adequate completion of plant construction and the readiness of the Applicants to operate the plant. These actions are the responsibility of Region IV. The total number of outstanding action items is 377 These may be grouped as follows: SER verification: 30 actions Routine construction inspections, preoperational test program and operational readiness inspections and startup test program: 121 actions Operating Licensing: 20 actions Open items inspections (unresolved items, violations, 50.55(e) items, inspector follow-up items and Part 21 items: 201 actions Room inspe TBD CAT follow,ctions: -up: 5 actions All the inspection items require resolution prior to OL issuance. Many reouire applicant actions prior to inspection or relate to hearing issues. Particularly significant is the retest inspection effort as the applicant plans to re-run approximately 25 preoperational tests to confinn system readiness subsequent to varicus modifications and design changes. Many of these tests will be witnessed by the NRC and test results will be evaluated as appropriato. Systems involved include safeguards systems, reactor protective system, service water, component cooling water, and the diesel generator. The number of inspection items represents a sizeable effort that could impact fuel load.
=.. e a 6- 'i Some additional resources will be required to complete the routine inspection program and resolve the many open items. It is expected that this area could require approximately 46 man-months. Considering the number of items and based on Waterford experience, the Region estimates that much of this effort can be handled with existing resources but that approximately 18 man-months additional resources will be requ. ired. See Figure 4 for the Inspections Schedule. D. Allegations Regulatory Actions ~ The Allegation Actions are those concerns reported by various individuals, intervenors and action groups regarding the safety of construction of the plant. Conderns regarding wrengdoings, intimidation, etc. are not included in the, technical review team effort but are referred to OI or OIA as appropriate. To date the number of individual actions is approximately 400 These actions are grouped into specific categories to facilitate c their resolution. Resolution of th6se actions will involve the Technical Review Team, NRR, OI, and Region IV. The organizational group with primary responsibilit of these actions is the Technical Review Team (TRT)y for resolution The resources required to resolve these actions are identified below according to the Team functional group: Resource Functional Group No. of Allegations Estimate (man-months) QA/0C Records 180 17 Electrical /Instrum. 5 2 Civil / Mechanical 97 17 Coatings-11 4 Test Programs 14 2 Estimated Totals 7D7 T The.TRT effort is expected to require additional administrative support (secretarial) of approximately 3 man-months. Hence, the total TRT resource needs are 45 man-ronths. The total program for resolvino the allegations actions is a critical path item. See Figure 5 for the schedule for completion of the review of these allegations. e --e...
... In addition, 97 allegations will be handled by the folicwino offices: Responsible Functional Group No. of Allecations Head Office Intimidation 30 OI Design Pipe /fipe Supports 19 NRR Vendor / Generic 18 NRR/IE Independent 7 NRR ., Miscellaneou$ssessment Program s 23 RIV Design of pipe and pipe supports, and the Independent Assessment Program allegations will be disposttioned by NRR personnel that are handling these issues for the hearings. Intimidation allegations will require additional OI resdurces, as discussed later in this section. Existing resources in the Vendor Inspection Branch, IE and NRR1 will disposition the vendor / generic allegations. Existing resources in, Region IV will be responsible for the miscellaneous allegations.
- E.
Office of Investigation Actions OI actions are those actions necessary to support the resolution of allegations. They involve issues where wrong-doing, intimidation, or harrassment may be involved. It is clear that with the present resources assigned to the Comanche Peak investigation (one investigator) the schedule for resolving the allegations and wrongdoing issues will not be met. We estimate several additional investigators will be required on full time basis from June through September, for a total of 12 man-months of effort. During this 4-month period 01' will reuuf re the full-tine suoport of one individual with a technical background, as many allegations are a combination of technical and wrong-doing issues, for a total of 4 man-months. The NRC staff effort to complete the actions in the licensing, hearings, inspections and allegations areas will be substantial and the impact will be felt by several Offices. The foregoing summary lists a total of 821 separate actions requiring approximately 100 man-months of effort above the existing (budgeted) resources. It is also estimated that approximately $1 million will be necessary to fund contractor assistance in support of Comanche Peak reviews during the remainder of FY 1984. The estimates are somewhat fragile and assume that no major new issues are raised, that the Applicants meet their pro.iected schedule, and that staff review of the identified issues will conclude that the existing circumstances, or the resolution, is acceptable. ,9 l e
.f %A um TsosTA7ss NUCLEAR REGULATORY COMMISS3ON " ~ ~ ~ g 2-. %,... J RIAR 121984 MEMORANDUM FOR: Jahri T. Collins, Regional Administrator Regiog IV Harold R. Denton, Director .~ '3h Offica of Nuclear Reactor Regulation Richard C. DeYoung, Director, i ' Office of Inspection & Enforcement i FROM: William J. Dircks 1
- - t Executive Director for Operations
SUBJECT:
CIMPLETTON OF OUTSTANDING REGULATORY ACTIONS ON CDMANCHE PEAK AND WATERFORD Construction of the Comanche Peak and Waterford facilities is nearing completion. There remain a number of issues that need to be resoived before the staff can enke its licensing decisions. The issues remaining for these plants are quite complex and span more than one Offica. In order to assure the overall coordination / integration of these issues and to assure issues are resolved on. a schedule to satisfy hearing and licensing decision needs, I am directing NRR to manage all necessary NRC actions leading to prompt licensing decisions. Darrell Eisenhut, Director, Division of Licensing, NRR is being assigned the lead responsibflity for this activity. He will coordinate the efforts of NRR, IE, and Region IV, and will coonfinate this activity with OI and OELD. Prior to any of the affected Offices undertaking major activities (e.o., inspections) or making decisions on these plants, that activity should be concurred in by NRR. We are presently in the process of assigning a dedicated senior manager to assist Mr. Eisenhut in the annagement of these activities. The first phase of this program will be the identification of issues needed to be resolved for each plant prior to hearing and licensing decisions. Once the issues have been identified a Program Plan for resolution of each item should be developed and implemented. The Program Plan should address the scope of the work needed, the identification of the responsible line organization, and the schedule for completion. In principle, this effort will therefore be similar to the effort undertaken regarding the allegation review on Diablo Canyon except that this effort should encompass all licensing, inspection, hearing, and allegation issues. i e. WCC73'D^20
, Eaca affected Office will assign a full time senior manager to work with NRR to define, schedule and complete the issues. I expect these managers to be identified by each of you within a few days. All affected offices should i provide dedicated resources and give their full support to this effort, to assure that all existing issues are expeditiously handled and all new issues are promptly provided to NRR so as not to delay the licensing decisions. In addition, copies of all infor1mation, documents, depositions, etc. should be promptly provided to RR to ensure a coorifinated approach. I antidipate that the approach utilized here will be necessary for a number of upcoming OL projects, and an directing NR!t to take the lead for carrying out this activity. ~ Q< M11 J. Dircks Executive', Director for Operations l cc: G. Cunnin B. Hayes gham, ELD OI i 4 o l i l i e.r, .. ~. - _,..-,_-...,m..
r F- '0VERAt.i. MArAGEMENT n ~ COORDINATION (NRR) r 01 Contact f + ELD Contact. t ~ r i Overall Review of ~ ' Review of Construction QA Adecuacy'(CAT) Review of Design and Operation Issues ~ (IE) Issues (Reg IV) (RRR) 9 e g O 9 O O e B e 4 6 i 1 l I e 0 i ... -. -. _. _.,...,.. _. _. ~ -,.
.- e FIGURE 1 COMANCHE PEAK Major Regulatory Actions Schedule REGULATORY ACTIONS , May June July August September October Licensing (SERs) X--------------------------------------------------------------X" H aring Testimony Submittals to ASLB X------------------------------------------------------X Inspections X------------------------------------------------- =-----------X Allegations X-------------------------------------------X .~
FIGilRE ? C0ilAllCilE PEAK LICENSING REVIEW SCllEDUI.E Regulatory Responsible Action Organization May June July August' September Octob I I I I I I I I I I I I I i i 1 1
I 1.
FSAR Open Issues NRR/DE, DST (------------ ------------
)
4 Issues Remain lillFS, IE (THI issue; 3 sub-items) 2. Confirmatory llRR/DE, DSI (------------ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - Issues Required
r; r---------------)
For Unit 1 License; 10 Issues Remain (TMI Issue; 12 sub-items) 3. License Conds. NRR/DE C-------------
X 2 Issues Remain 4
Technical Specif. NRR/DE,DSI (------------- ------------ -,, - - - - - - - - - - -------------------) 5 Issues Remain 5 New Issues Raised NRR/DSI,HMSS C------------. by NRC; 7 Issues
)
i Remain. (including Financial Dualifications) 6 tiew Issues Raised f!RR/DilFS, DE (-------------
X by Applicant DL, DSI 6 Issues Remain 7.
Dustanding Gen. IIRR/DS!, IE (- - - - - - - - - - - - - ------------ Ltrs; 3 Remain
l es likF 3 CNIA'NTliTTEAK (OI Lipiting acTechnical Review Team (TRT) ilEARit!G TESTil10 fly PREPARATIDN AND SilRitITTAL SCliEDULE Regulatory Responsible Action Drganization llay June July August September Octo I ii i I I i l i I I I I I 8 8 8 1. Independent h Assessment a. IAP-Cygna NRR/DE, DL, IE X---- ---X b. Applicant's Plan NRR/DE, DSI, IE C------------- (ll/D concerns)
- 2.
- Intimidation /
tlRR/DL, OELD C------------- s Harassment Issues 3.**0A/0C Program TRT (---------
~---------------
Issues 4.** Pipe Support TRT (--------- --X Issues '5. llelding Issues ilRR/DE, RIV, IE X------- ( (Followup) 6.** Coating Issues R IV (LAtlL ), ilRR/DE-(---------
X 7.
Vendor Generic a. Transamerica TDI Task Force (--------------------X Deiaval Diesel Genera tors 8. Itiscellaneous a.** Staff flalkdown TRT (-------------3 (includes Cable Tray) h. Polar Crane RIV (---------,------x Reinspection c. Ilirror Shield RIV (---------(
______y a FIGURE 4 COMANCHE PEAK SCHEDULE INSPECTION AND REGIONAL RESPONSIBILITIES April May June July _ August September October I i i i i i I 'I I i e i i i i i l g -- j - Construction Inspec. X---------- ------------- ------------------ <------ --X HC 2512 Construction Insp X---------- s, t M' Items Followup *pc.
X 50.55(e) Items, X-----------
X Part 21 Items Followup i
Primarily Preoperation X Prima rily-Test Wit nessing,-Proc edures Review----------t Tes Inspections MC 2513
X Results Review Preopera tional Inspec. Items y___________
_______.;__,_ ____________________3 Followup Startup Test X----------- Procedures Review X Post-OL--------
X Program Inspec.
MC 2514 Witnessing Operational X X X (Final Rpt) R:adiness Report per Module 94300 -l SER Verification X-Items from SSER's 1-4 -Items from SSER 5 X X ( IE Bulletins Inspec. X------------
X ltiscellaneous X------------
X Allegations Resolution Opetainr Iirensing X--------- --------X
FIf.IIRE 5 .T '~ a COMANCilE PEAK Allegations Resolution Schedule April May June July August September Octoher. I I I I I I I I i i I I I i i i i i i i .I 1. Plan Approval X ?. Personnel X-- --- X Arrangement 3. Obtain Logistic X------ - -- X ' ' Support 4. Develop Review X-------------X Packages 5. Task Force X Briefing & Assignments 6. First Site X--X Review Period l 7. Second Site X-- ---X Review Period 8 Third Site X-----) Review Period 9. Prepare Final 1 ----X l Draft SSER 10 ilanagement X---X Review l
- 11. Final Report X----X I?. Sutait Report X
l i to A$1.8
O
- y e
COMANCHE PEAK PLAN FOR THE COMPLETION OF OllT. STANDING REGULATORY ACTIONS MAY 1984 Approval: E. 74 A. 4 Tth m t.Thb s 'e: 44 R. MYoung, Djrector, IE Date Y/: W d E N' H.' r. Denton, Director, NRR Da te ' R'.54.o.t L\\TeItm n v. I,wb. e /e;b. J. T.* Coll 5ns,' Administrator ~ Date Region IV \\ O 9 [
9 COMANCHE PEAK PLAN FOR THE COMPLETION OF CUTSTANDING REGULATOPY ACTIONS I. PURPOSE AND SCOPE On flarch 12, 1984, the EDO directed flRR to nanaoe all necessary NRC actions leading to licensing decisions for Comanche Peak and Waterford. A copy of that directive is included as Attachment 1. This plan establishes the program for Comanche Peak. The purpose of this plan is to assure the overall coordination and integration of the outstanding regulatory actions regarding Comanche Peak, and achieving their resolution prior to a licensing decision. This plan encompasses all licensing, inspection, hearing, and allegation issues. Further, this plan addresses the scope of the work needed, specifies the critical path issues, identifies the responsible line organization, the schedule for completion, and (where applicable)'the need for additional resources to meet the schedule. The planned completion date for all republatory actions is assumed to be October 1,1984, and resource needs are predicated on that assumption.. A status report will be issued to management every two weeks starting two weeks after the approval of the plan. II. BACXGROUND Comanche Peak Steam Electric Station Unit 1 is in the final stages of the operating license review process. The Construction Permits for Unit I and 2 were issued on December 19, 1974 Texas Utilities docketed their application for operating licenses on April 25, 1978. The Final Environmental Statement was issued September 24, 1981. The Safety Evaluation Report (SER) was issued on July 14, 1981. Because of the large number of outstanding issues identified in the SER, the staff recommended delaying the ACRS review. SER Supplement No. I was issued on October 16, 1981, and the ACRS meetire was held on November 13, 1981. The ACRS, by letter dated November 17,19F1, supported issuance of an operating license. The latest SER supplement was issued on November 23, 1983. Comanche Peak has been in a heavily contested hearing for over two years. All but one contention have been dismissed. The remainino contention questions the ability of the applicant's Quality Assurance / Quality Control Program to prevent deficiencies in the design and construction of the plar.t. The Licensing Board has admitted many allegations of design and construction deficiencies into the hearing as relevant to this contention. The Applicants are currently proiecting a fuel load date for Unit 1 to be i in late Septenher 1984 The basis for this projection was provided to the staff on May 7, 1984 This fuel load date appears achievable but allows no flexibility for unexpected avents in a very tight schedule. The number of hearing issues and uncertainty regarding the timing of the Licensing Roard's initial decision may impact the fuel load.
,- III. PLAN FOR THE COMPLETION OF OUTSTANDING REGULATORY ACTIONS This plan describes the method in which coordinated regulatory actions are to be taken by the staff to be ready to support an NRC decision regarding Comanche Peak licensing. As stated in the Purpose, the plan encompasses all licensing, hearing, inspection, and allegation issues. This summary addresses the scope of work needed, identifies the responsible line organization, the schedule for completion, and the resource needs to meet the schedule. The management organizational arrangement responsible for directing ~ the overall effort and coordinating actions by the various involved offices is shown graphically in the enclosure to the EDO memorandum of March 12,1984 (Attachment 1). The management is under the overall direction of T. A. Ippolito, who reports to the Director of the Division of Licensing. The managers responsible for implementing and directing this organization are the following individuals: Project Director (T. A. Ippolito) - - - - - -10 ELD Contact (d. Scintn)I - - -- - -- -i OI Contact (B. Haves )l NRR Action Region IV Actions IE Actions (T. Novak) (R. Bangart) (R.DeYoung) The line offices will continue to manage their own responsibilities regarding Comanche Peak in accordance with the schedule and objectives of this plan. Line office activities are to be coordinated with the program management organization via their representative as identified above. Additional rescurces are expected to be necessary to support licensing, hearing, and inspection issues, and substantial resources are necessary to respond to the approximately 400 allegations recardinn Comanche Peak. This plan proposes the formation of an Technical Review Team (TRT) to evaluate and resolve a number of technical issues, including allegations, presently identified. A proposed organizational chart of the TRT is shown below. The groups identified will be assigned to evaluate and resolve technical issues and allegations that have been grouped into five technical areas: QA/0C, Electrical / Instrumentation Civil / Mechanical, Coatings, and Test Programs. The groups will be comprised of a group leader and reviewers that are' specialists in the particular technical area. I I i i
e 4 ' Comanche Peak Technical Review Team (TRT) Prn.iect Direc' tor Deoutv Pro.iect Director i i t- - - - - Office of Investigations GROUP LEADER $ CA/0C Electrical / Civil /M chanical Coa' tings Test Program 1 Records Instrurentation and Operational Readiness The staffing of these groups will be drawn from the various NRC offices and/or contractors as arranged between the Project Director and line management. The TRT may be called together for a specified period of time, dispersed back to the individual's parent office, and then reconstituted in whole or in part as needed to complete resolution of like issues. The TRT will be under the direct supervision of the Pro,4ect Director. In accordance with the EDO memorandum of May 25, 1984, the TRT organization is scheduled to be in place and functioning by June 4, 1984 Detailed guidance will be issued by the Project Director to the Technical Review Team and other participants in this effort. This guidance will address the following: Method and approach for identification and disposition of allegations Tracking System Preparation of Documentation and Records Protection of Individuals Initiation of Special'NRC actions, such as Confirmation of Action Letters or 50.54(f1 letters ] Manpower accountino The basis upon which the schedules and resource estinates have been 4 - developed is that the Comanche Peak fuel load date is October 1,1984 Fioure 1 is an overall schedule and Figures 2 throuch 5 are individual schedules for the resolution of Licensing, Hearing, Inspection, and Allegations Pegulatory Actions, respectively.
'I 1 The najor issues, schedules, and resource.estinates needed to meet the schedules are summarized as follows: A. Licensino Reculatory Actions Licensing Actions are those things resulting from the desion review of the FSAR. NRR is responsible for the resolutten of these action items. The total number of outstanding action items is 37. Four of these action items are considered to have the potential for impacting the schedule. These items relate to 1) the adequacy of the TDI diesel generators, 2) the the Applicants' exemption request for relief from GDC 4, 3) review of the Cygna Reoort of an independent assessment of design and construction, and 4) electrical equipment environtrental qualification. NRR experience with other facilities involved in complex licensing reviews (Diablo Canyon, Seabrook, and Shoreham) indicates that additional project management resources are necessary. Two additional project managers for the period from June-September will be needed, for a total of 8 man-months of additional effort. The technical resources presently assigned by NRR to evaluate and resolve the remaining open licensing actions are sufficient to meet the schedule shown in Figure 2. Additional IE resources are not expected to be required as the CAT inspection is complete and OA/QC reviews and emergency preparedness reviews are essentially complete. B. Hearino Reoulatory Actions Hearing Actions are those issues in contention before the ASLP. There are three major issues each with a number of sub-issues. The three major issues are Design Adequacy and Ouelity Assur?nce, Construction Adequacy, and Construction Cuality Assurance. There are two critical path actions: Design Adecuacy and Construction Adecuacy. The design adeouacy action concerns an IDVP being performed by the Applicants at the staff's request. CYGNA is performing the review for the Applicants. This is currently under review by the staff. Cygna personnel actions may have contributed to be prenotifi-cation of inspection areas to Applicant 0A/QC personnel. Resolution of this concern may make it necessary to request additional independent assessment activities. The critical path issue concerning Construction Adecuacy is containment liner coating (painting).
.The resources presently available are sufficient to resolve all hearing actions with the exception of the critical path issues. It is estimated that 10 man-months are recuired to resolve the Design Adequacy Action, and 6 man-months to evaluate the Construction Adequacy Action (painting). The design adecuacy review will reouire a team ccmposed of IE and NRR' personnel, similar to the Cygna IDVP effort. Coordination of Hearing activities.is expected to be extensive and involve integrating the activities of NRR, OELD, and Region IV with the Technical Review Team. An additional seninr manager (SES-level) is needed to manage this effort as.it is expected that the Project Director will devote full time effort to management of the technical review. team actions commencing June 4,19M. These estimates assume that the reviews will conclude that the existing circumstances are acceptable to the staff and/or no major corrective actions are reouired of the Applicants. Should this prove otherwise, additional. resources'wil.1 be required for resolution. See Figure 3 for Hearing Testimony Comoletion Schedule. C. Inspections Regulatorv Actions Inspection actions are those that assure that adequate completion of plant construction and the readiness of the Applicants to operate the plant. These actions are the responsibility of Region IV. The total number of.6utstanding action items is 377. These may be grouped as follows: SER verification: 30 actions Routine construction inspections, preocerational' test program and operationel readiness inspections and startup test program: 121 actions Operating Licensing: 20 actions Open items inspections (unresolved items, violations, 50.55(e) items, inspector follow-up items and Part 21 items: 201 actions Room inspections: TBD CAT follow-up: 5 actions j. All the. inspection. items require resolution prior to OL issuance. Many require applicant actions prior to inspection or relate to hearing issues.. Particularly significant is the retest inspection I effort as the applicant. plans to re-run-approximately 25.preoperational tests to confirm system readiness subsequent tn various modificatiers and design changes. Many of these tests will be witnessed hv the.NRC and test results will be evaluated as appropriate. Systems involved include safeguards systems, reactor protective system, service water, component cooling water, and the diesel. generator. The number of inspection items represents a sizeable effort that-could impact fuel load.
.: Some additional resources will be required to cenplete the routine inspection progran and resolve the many open items. It is expected that this area could recuire approximately 46 man-months. f'onsidering the number of items and based on Idaterford experience, the Region estimates that much of this effort can be handled with existing resources but that aoprcximately 18 man-Nonths additional resources will be required. See Figure a for the Inspections Schedule. D. Alleoations Regulatory Actions The Allegation Actions are those concerns reported by various individuals, intervenors and action grcups regarding the safety of construction of the plant. Concerns regarding wrongdoings, intimidation, etc. are not included in the technical review team effort but are referred to 0I or CIA as appropriate. To date the number of individual actions is approximately 400. These actions are grouped into spec'ific categories to facilitate their resolution. Resolution of these actions will involve the Technical Review Team, NRR, DI, and Region IV. The organizational group with primary responsibility for resolution of these actions is the Technical Review Team (TRT). The resources required to resolve these actions are identified below according to the Team functional group: Resource Functional Group No. of Allegations Estimate (man-conths) QA/QC Records 180 17 Electrical /Instrum. 5 2 Civil / Mechanical 97 17 Coatings 11 4 Test Programs 14 2 Estimated Totals 707 42 The TRT effort is expected to reouire additional administrative support (secretarial) of approximately 3 man-months.
- Hence, the total TRT resource needs are 45 man-months.
The total program for resolving the allegations actions is a critical path item. See Figure 5 for the schedule for completion of the review of these allegations.
In addition, 97 allegations will be hardled by the following offices: Responsible Functional Group No. of Allegations Head Office Intimidation 30 OI Design Pipe / Pipe Supports 19 NRR-Vendor / Generic 18 NRR/IE Independent Assessment Program 7 NRR Miscellaneous 23 RIV i Design of pipe and pipe supports, and the Independent Assessment Program allegations will be dispositioned by NRR personnel that are handling these issuec for the hearings. Intimidation allegations will require additional OI resources, as discussed later in this section. Existing resources in the Vendor Inspection Branch, IE and NRR will disposition the vendor / generic allegations. Existing resources in Region IV will be responsible for the miscellaneous allegations. 4 E. Office of Investigation Actions OI actions are those actions necessary to support the resolution of allegations. They involve issues where' wrong-doing, intimidation, or harrassment may be involved. It is clear that with the present resources assigned to the Comanche Peak investigation (one investigator) the schedule _for resolving the allegations and wrongdoing issues will not be met. We estimate several additional investigators will be required on full. time basis from June through -September, for a total of 12 man-months of effort. During this 4-month period OI will recuire the full-time support of-t one individual with a technical background, as many allegations are a combination of technical and wrong-doing issues, for a total of 4 man-months. l' The NRC staff effort to complete the actions in the licensing, hearings, inspections and allegations areas will be substantial and the impact will be felt by several Offices. The foregoing suninary lists a total of 821 separate i actions requiring approximately 100 man-months of effort above the existing (budgeted) resources. Personnel for~much of this effort will be obtained from contractors. It is estimated that approximately $1 million will be necessary to fund contractor assistance in support of Comanche Peak reviews. during the remainder of FY 1984. The estimates are somewhat fragile and assume that no major new issues are raised, that the Applicants meet their projected schedule, and that staff review of the identified issues will conclude that the-existing circumstances, or the resolution, is acceptable. u-6 -e r-
f ',.% p* " 3 UNITED STATES j NUCLEAR REGULATORY COMMISSION y ,c a g waswe=oron. o. e. mosas \\.',,,/ MAR 121984 MEMORANDUM FOR: John T. Collins, Regional Administrator Region IV Harold R. Denton, Director .n', '3!t Office of Nuclear Reactor Regulation Richard C. DeYoung, Director Office of Inspection 8. Enforcement FROM: William J. Dircks Executive Director for Operations l
SUBJECT:
COMPLETION OF OUTSTANDING REGULATORY ACTIONS ON l CDMANCHE PEAK AND WATERFORD Construction of the Comanche Peak and Waterford facilities is ' nearing completion. There remain a number of issues that need to be resolved before the staff can make its licansing decisions. The issues remaining for these plants are quite complex and span more than one Office. In order to assure the overall coordination / integration of these issues and to assure issues are resolved on a schedule to satisfy hearing and licensing decision needs, I as directing NRR to manage all necessary NRC actions leading to prompt licensing decisions. Darrell Eisenhut, Director, Division of Licensing, NRR is being assigned the lead responsibility for this activity. He will coordinate the efforts of NRR, IE, and Region IV, and will coordinate this activity with OI and CELD. Prior to any of the affected Offices uncertaking major activities (e.o., inspections) or making decisions on these plants, that activity should be concurred in by NRR. We are presently in the process of assigning a dedicated senior manager to assist Mr. Eisenhut in the management of these activities. The first phase of this program will be the identification of issues needed to be resolved for each plant prior to hearing and licensing decisions.- Once the issues have been identified a Program Plan for resolution of each item should be developed and implemented. The Program Plan should address the scope of the work needed, the identification of the respor.Jible line organization, and the schedule for completion. In principle, this effort will therefore be similar to the effort undertaken regarding the allegation review on Diablo Canyon except that this effort should encompass all licensing, inspection, hearing, and allegation issues.
/ 2 Each affected Office will assign a full time senior manager to work _with NRR to define, schedule and complete the issues. I expect these managers to be identified by each of you within a few days. All affected offices should provide dedicated resources and give their full support to this effort, to assure that all existing issues are expeditiously handled and all new issues are promptly provided to NRR so as not to delay the licensing decisions. In addition, copies of all infonnation, documents, depositions, etc. should be promptly_ provided to NRR to ensure a coordinated approach. I anticipate that the approach utilized here will be necessary for a number of upcoming OL projects, and am directing NRR to take the lead for carrying out this activity. 9 ( Willi J. Dircks Executive' Director for Operations G. Cunnin
- 3. Hayes.gham, ELD cc:
OI O e 9 9 f
9 e Fl0VERAl!. MANAGDIENT -COORDINATION (NRR) q_ 01 Contact r ~ ELD Contact t i% I A Overall Review of ~ I ' Review of Construction QA Adecuacy (CAT) Review of Design and Operation Issues (IE), g Issues (Reg IV) (NRR) l e O 9 6 t e 0
FIGURE 1 CDMANCHE PEAK Major Regulatory Actions Schedule REGULATORY' ACTIONS Hay June July August September October - Licensing (SERs) X--------------------------------------------------------------X Hearing Testimony Submittals to ASLB X------------------------------------------------------X Inspections X--------------------------------------------------------------X Allegations X-------------------------------------------X o T
FIGilRE ? C0t1ANCHE PEAK LICENSING REVIElf SCilEDilLE \\ Pegulatory Responsible Action Organizatinn May June July August' Septemher Octohei I i i i I i l l a I i i ---i l l l l _l .1.. FSAR Open Issues NRR/DE, DST (------------
)
4 Issues Remain DHFS, IE (TMI issue; 3 I -sub-items) 2. ' Confirmatory flRR/DE, DSI (-------------
)
Issues Required For Unit 1 License; 10 Issues Remain (TMI Issue; 12 sub-items) 3. License Conds. NRR/DE (------------- .- - - - - X. 2 issues Remain 4 Tcchnical Specif. NRR/DE, 051 .(------------- ------------
)
5-Issues Remain ~ s 5. New Issues Raised NRR/DSI, NHSS,(------------- - - - - - - - - - - - - ----------------
)
by NRC; 7 issues Remain. (includino Financial. Qualifications) 6 New Issues' Raised NRR/DHFS, DE ,(-------------
X-by Applicant DL, DSI 6 Issues Remain 7.
Oustanding Gen. IIRR/DS!, IE C------------- ------------ Ltrs; 3 Remain s -9
Cid ll PEAK 0I Liaiting
- Tcchnical Raview Team (TRT) llEARING TESTIMONY PREPARATION AND SilBMITTAL SCilEDULE Regulatory Responsible Action Organization May' June
.luly August-September Octot l l 1 I l l l 1 1 I I I I I I i I 1. Independent Assessment .a. IAP-Cygna NRR/DE, DL, IE X----- ---X b. Appitcant's Plan NRR/DE, DSI, IE (-------------- -------------:: (W/D concerns)
- 2.
- Intimidation /
NRR/DL, OELD (------------- Harassment Issues 3.**0A/QC Program TRT (---------- Issues 4.** Pipe Support TRT (--------- --X Issues 5. Helding Issues NRR/DE, RIV, IE X------- ( (Followup) ~ 6.** Coating Issues R IV (LANL), flRR/DE (-----
X 7.
Vendor Gener,1c., , )* a. Transamerica' TDI Task Force (-------------. ------X Delaval Diesel Generators 8. Miscellaneous a.** Staff Walkdown TRT (-------------3 (includes Cable Tray) b. Pola r' Crane RIV (----------------X Reinspectinn c. Mirror Shield RIV-(---------(
FIGURE 4 COMANCHE PEAK SCHEDULE INSPECTION AND REGIONAL RESPONSIBil.ITIES April May June July _ A_ugu_s t September October-i i i i i i i i i i i i i i i i i = i Construction Inspec. X---------- ------------------------------- "------ --X MC 2512 Construction Inspec. X----------
X Items Followup 50.55(e) Items, X-----------
X Part 21 Items followup Primarily X Primarily-Test Witnessing,-Proc edures Review Test Preopera. on
X Inspect;
..s MC 7513 Results Review PreoParational X-----------
)
Inspec. Items Followup Startup Test X----------- -Procedures R eview X Post-OL-----------
,------ -------------------X Program Inspec.
Witnessing MC 2514 Operational X K X (Final Rpt) Readiness Report per Module 94300 SER Verification X-Items from SSER's 1-4 -Items from SSER 5 X X ( IE Bulletins Inspec. X------------
X Miscellaneous X------------
X Allegations Resolution Operator Licensing X--------- --------X
= FICllRE S 4... COMANCllE PEAK Allegations Resolution Schedule J April May June July August September October-1 I I I I I I I i i i I l i l l l l 1 I l-1. Plan Approval X ?. Personnel X-- ---X Arrangement 3. Obtain Logistic X------ ---X Support 4. Develop Review X-------------X Packages 5 Task Force X Briefing & Assignments 6. First Site X--X Review Period 7. Second Site X-----X Review Period 8 Third Site X-----) Review Period 9. Prepare Final X----X Draft SSER 10 tianagement X---X Review 11. Final Report X----X l?. Sut*11t-Report X to ASI.B -}}