ML20136J356

Forwards Case Preliminary Review of Comanche Peak Response Team Program Plan.Completion of 100% Reinsp of Plant & Design Review Analysis Necessary to Ensure Public Health & Safety Not Endangered by Plant Operation

ML20136J356
Person / Time
Site:	Comanche Peak
Issue date:	08/15/1985
From:	Garde B TRIAL LAWYERS FOR PUBLIC JUSTICE, P.C.
To:	Eisenhut D, Noonan V NRC
Shared Package
ML20136J345	List: ML20136J340 ML20136J356
References
OL-2, NUDOCS 8508200693
Download: ML20136J356 (22)

Text

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TRIAL LAWYERS FOR Pusuc JUSTICE. P.C.

COUN5tuCRS ATtAW SUITE 611 .

2000 P STREET. NORTHWEST

, ANTHONY E ROtSMAN VASHINGTON. D.C. 20036 B6CKETED (202W3m U" " D'"'C' "

USNRC ARTHUR BRvANT STAFF ATTORNtY .

5 W ,5 M" '85 NJG 20 A!0:58 August 15, 1985 1-  : e.

Mr'. Darrell Eisenhut U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Vince Noonan U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Sirs:

The Comanche Peak Response Team (CPRT) Program Plan and the Issue Specific Action Plans were submitted to the NRC on June 28, 1985. The objective of the plan is to insure that the Comanche Peak nuclear power plant receives an operating license. In order to receive a license the Nuclear Regulatory Commission must find that there is reasonable assurance-that the facility, as built, does not endanger the public health and safety.

It is the position of the Citizens Association for Sound Energy (CASE) that such a finding can only be made after (1) the completion of a 100% reinspection of the plant, (2) a complete design review analysis, and (3) the successful implementation of an acceptable corrective action program.

The CPRT Program Plan, even if successfully implemented, lacks significant programmatic controls, and is substantively deficient in a number of key areas. The process and substance deficiencies identified in the document submitted to date are described in this document. Since the CPRT itself is not complete (i.e. the QA/QC program for the plan has not yet been submitted, the inspection attributes are missing, the checklists for retraining are missing, etc.) these comments are not defini-tive. Further comments will be submitted after receipt and review of the other portions of the plan.

i 8500200693 850015 PDR ADOCK 05000445 G PDR

4 It should be noted that it is CASE's position that the plan itself should be litigated before the ASLB, and that additional hearings should be held on the adequacy of implementation of the reinspection effort, as well as the appropriateness of the pro-posed corrective action plan and the implementation of the corrective action program. It is also CASE's position that the ambiguity in the plan is so great that approval should not be granted prior to discovery on the program elements. It is our belief that the Applicant's commitments are not the actual program plan.

Finally, CASE objects to the proposition that the Staff's view of the questions raised in this letter (and the review of TUEC's response to Staff questions) will ime committed to an SSER prior to a public meeting on the final proposed program plan.

1 The efforts of the public and the whistleblowers to review TUEC's final program plan will be meaningless without providing for public review and comment on the CPRT.

We look forward to meeting with the Staff on these matters in the near future.

Sincerely,

$k I Billie Pirner Garde cc: Service List

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PRELIMINARY REVIEW OF THE COMANCHE PEAK RESPONSE TEAM PROGRAM PLAN (DOCKET 2)

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PRELIMINARY CRITIQUE OF THE PROGRAMMATIC

' ASPECTS OF THE CPRT PROGRAM PLAN This critique contains observations on the following aspects of the CPRT program plan:

1. Overall inadequacy of the proposed approach.

2. Programmatic deficiencies with the third party efforts proposed.

3. Programmatic deficiencies in the integration of the various overviews, reinspections, evaluations, and ongoing work activities.

4. . Programmatic deficiencies in methodologies.

5. Programmatic deficiencies in scope, i.e. the depth'and breadth of the review.

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• 6. Programmatic deficiencies in the sampling techniques.

7. Programmatic deficiencies in the ISAP/DSAP approach to "

External Source Issues.

I- 8. Missing elements of proposed program.

9. Comparison of CASE proposal and the CPRT.

In each of these categories there are both specific and general observations. These comments however are not definitive.

There is no attempt to address the specific inadequacies of various ISAPs/DSAPs, nor is there any attempt to guess the inadequacy of the CPRT QA/QC program. Several charts have been attached as Exhibit 1 to this document to demonstrate the missing elements of the proposed program. (We have taken the liberty of modifying the charts contained in the progam plan submitted by the Applicant for illustrative purposes.)

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OVERALL INADEQUACY OF THE PROPOSED APPROACH The most significant defect in the CPRT Program Plan is that e

it perpetrates the iterative process of design and construction failures. TUEC has chosen to " push ahead" with the reinspection and corrective action program, and only incorporate retro-spectively any rework or reinspection requirements which result from the conduct of the CPRT.

According to the CPRT-Program Process (Rev.2, p.15), the scope of the actual work of the reinspection program, as outlined in the ISAPs/DSAPs "will be based on a preliminary assessment of the root cause and potential generic implications of the identi-fied deviations...Accordingly, most of the ISAPs and DSAPs will utilize iterative or phased implementation approaches that include an initial phase that is exploratory in nature."

Since the reinspection work has already begun it is apparent that the exploratory phase has been. completed and preliminary assessments of the root cause and potential generic implications have already been identified. Yet none of the preliminary assecaments have been disclosed, produced to the public or the NRC. Nor have they been completed using a Quality Control /

Quality Assurance program for the CPRT, since such a program has not been developed. It is not clear from a reading of the program plan whether the results of the exploratory phase have ever been - or will ever be - documented.

TUEC's inability to successfully implement the iterative design and contruction process has caused major regulatory, safety and financial problems. The choice of an iterative l

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approach to the reinspection and corrective action program is indicative of current management's inability or unwillingness to e

choose the prudent. approach to getting the Comanche Peak project under control.

It is our view that the only way to successfully approach the reinspection, reanalysis, and corrective action project is to start with a clean slate. That is, to halt construction entirely until the CPRT program plan has received the full approval of the NRC Staff and the Licensing Board. Only then will it be prudent to begin the operation through a phased approach -- first reinspection, then rework.

The second major inadequacy of the program is that it is not comprehensive in scope, breadth or depth. As submitted, the program plan results will not be able to support the reasonable assurance objective sought by TUEC. Some details of the program inadequacies have been summarized in following sections.

Most importantly the CPRT proposes that concerns are resolved at the time that "TUGCo has defined actions" which "when implemented will correct identified deficiencies and preclude similar deficiencies." (Rev. 2, p. 5) The history of implementation failures at Comanche Peak provide no basis for the Staff or the public to be able to rely on the successful  ;

implementation of any corrective action. This is particularly true.since it is.TUGC], not the independent third party, that is l recommending the. corrective action in the first place. This situation makes it even more crucial that NRC hold points be i

mandated for~ review of any correction or rework effort.

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, The third major inadequacy of the proposed program is that it is not controlled by third party personnel, but instead a

remains under the control and direction of TUEC. For example, TUEC controls all modifications of ongoing work in Unit II

.(Rev.2, p.4) and also the " future plant operations" (Rev 2, p.5).

The lack of independence of the third-party teams to control their work eliminates their value, adding only confusion, not credibility.

Fourth, the management team remains a mystery. It is not sufficient for TUEC to have ostensibly removed the former QA/QC executives of the Comanche Peak project and replaced them with a team of borrowed professionals who march to the beat of an unknown drummer. The current management team is a completely diversified group of consultants, loaned employees, contract employees, advisors, and others. It remains unclear what has happened to the former executives, or why,.and it is even murkier who is currently running the project - either the reinspection /.

corrective action program, or the remaining construction project.

This confusion surrounding the management personnel is a critical weakness in the current proposal.

We believe that the reinspection program and any subsequent required corrective action must be done by truly independent third parties. They must have clearly defined reporting respon-sibilities to the NRC under 10 C.F.R., as well as the responsibi-lity for drawing the conclusions about the scope of the problems.

The remaining work to be done on Unit II should be handled by a new team of TUGCO and/or prime contractor personnel who have not '

had anything to do with previous construction problems.

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.c The CPRT program plan also suffers from a confusing and

p. unclear methodology being implemented by numerous separate organizations. This multiple level approach invites programmatic breakdowns and failures in implementation of even the best program plans. To illustrate, the program contains an indepen-i dent design verification program (IDVP) using the vertical slice methodology of one safety system, a horizontal review of two other systems, a sampling program (employing both a random sample and a bias sample), a 100% review of-the large bore piping, a design analysis review, and hundreds of response inspections to ISAPs and DSAPs. Each portion of the program plan is being accomplished according to a different set of criteria, a different company's quality control / quality asourance criteria, and being directed by separate management teams. The standards against which inspections are accomplished are ambiguous and open to interpretation. The organizational structure for the inter-face of the programmatic elements is either non-existent, or appears to be unworkable.

Other problems with sampling methodology, and major elements of the program which are still missing are described below.

Finally, a major fatal flaw of this program is its failure to produce the necessary level of detailed information to preclude misinterpretation. This is particularly important in this plan since there is a myriad of different personnel working on a plethora of reinspections, and the reinspection personnel are not the individuals drawing conclusions, or making recommen-dations about the findings.

Another result of having no comprehensive attribute check-list for reinspections is that there will be no meaningful way to o

assess whether adoption of a previous external inspection is appropriate.

Finally, the failure to produce detailed attribute check-lists renders paperwork reviews by third-party overviewers or the NRC virtually meaningless.

The NRC must at a minimum require the CPRT program (1) to be reorganized into a logical step-by-step process, (2) to be based on the reinspection of systems and components against detailed 3

attribute checklists, (3) to establish NRC inspection hold points at critical junctures, (4) to require an independent overview

of the required corrective action, and (5) to remove TUEC from the task of determining the co'nsequences of generic / programmatic defects.

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PROGRAMMATIC DEFICIENCIES WITH 9

THE PROPOSED THIRD PARTY EFFORTS

1) None of the third parties are independent of TUEC, since all of the consultants are under the direction of the CPRT.

2) The third parties were selected solely by TUEC, dis-regarding the importance of.the concurrence of the public, and the nomination and approval procedures for independent third parties used by the NRC since 1982. This after-the-fact assertion does nothing to restore the confidence of the public in the " fresh perspective."

3) The review team leaders, issue coordinators, and advisors are primarily responsible to, c. are, in fact, TUGCO 4

personnel who have been involved in the construction project for a long time.

4) The asserted qualifications, reputation, and integrity of the third party consultants have not been tested through discovery or cross-examination, nor have the consultants answered questions from the public on their experience, competence, integrity, or the direction from the CPRT regarding the scope of their work.

5) The third party consultants, individually and organiza-tionally, are apparently not being considered a part of the normal regulatory process, and therefore not required to report all safety related information reportable under 10 C.F.R. 50.55(e) and 10 C.F.R. Part 21 to the NRC directly.

6) The third-party consultants can only recommend correc-tive action to TUEC/TUGCO, but they cannot control the implemen-tation of the corrective action. It is not even clear whether the third party has the autho.rity to insist on accomplishment of a particular corrective action as a caveat for any conclusions.

7) The SRT responsibilities, under the direction of a TUGCO Vice President, control the CPRT effort through selection of management personnel, approval of the action plans, review and approval of the " safety significant" determination, and root cause and generic implication assessment, and approval of corrective action.

8) The same TUGCO Senior Vice President, is also in charge of.the issues raised through the SAFETEAM, and other project activities, i.e., there is no procedure for inclusion of new issues without approval of TUGCO management.

PROGRAMMATIC DEFICIENCIES IN THE INTEGRATION OF c' THE VARIOUS OVERVIEWS, REINSPECTIONS, AND EVALUATIONS

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1) There is no status assessment of system commodities or defined baseline of items, subject to the CPRT. Without such a document the completion date or progress made can not be quantified.

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2) Interfaces between the ongoing project and the program reinspection plan are almost non-existent. (Interface between the design, construction, reinspection, and corrective action aspects of the project are critical for successful implementation of the program plan.)

3) The use of the Collective Evaluation Reports providing information at the end of the DSAP/ISAP process precludes consi-deration of critical.information by all disciplines during the reinspection.

4) The circular approach to expanding issues is, as described on page 2 of revision 2, not detailed in a manner which provides confidence that the all generic implications and root causes will be extrapolated to other areas of the plant.

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PROGRAMMATIC DEFICIENCIES IN METHODOLOGY

, 1) The methodology is not supported through references to established professional codes (ASME, ANSI, AWS, etc.).

2) The methodology is ambiguous about commitment to' the FSAR, and provides no criteria upon which an exception will be sought.

3) Reporting procedures for third-party auditors exclude independent contact-with the NRC.

4) Issues " closed out" by the external source for whatever reason are not considered for potential root cause or generic implications.

5) The program plan does not include all vendors, or separate construction activities and therefore presumes that work was accomplished in accordance with regulatory requirements.

There is nothing to justify this position.

6) The hardware categories proposed in the self-initiated evaluation are not comprehensive. There is no explanation for how homogenous populations were selected. There is no explana-tion of how the selected populations will provide the foundation to reach the broad conclusions predicted by the CPRT.

7) There are no attribute checklists for inspections, or for inspectors to be retrained to.

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8) There is no new retraining, recertification programs for TUEC or B&R QA/QC or craft personnel which insures that the identified failures in the training program implementation is not repeated.

9) The criteria for determination of defects is its " safety significance", not necessarily non-compliance with FSAR require-ments.

10) There is no provision for assessing deficiencies in inaccessible hardware components.

11) There is no provisiors for logical consideration of potential programmatic' generic defects, such as inadequate design review. All defects, deficiency reviews, etc. are going on simultaneously.

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i PROGRAMMATIC DEFICIENCY IN SCOPE, DEPTH AND BREADTH

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1) The program plan does not provide the breadth of review

' necessary to reach any_ conclusions about the overall design and construction of.the plant (i.e. insufficient number of systems

= proposed and a lack of attributes on the selected systems).

{. 2) No basis has been provided to justify the selection of the civil / structural, electrical / mechanical, instrumentation systems proposed.

I 3) The external source issues have identified massive specific or programmatic deficiencies. The proposed program

- fails to accommodate the reported failures substituting instead the review of the smaller number of. systems as a first cut.

f i 4) The size of the sample of systems to be reviewed is-4 inadequate to reach any meaningful conclusions about the systems or components which are called into question by external source '

issues.

4 t 5) The information provided on the large bore piping reanalysis is insufficient to determine whether the " major j concerns about the system" are the only concerns which should be

considered. (There are no-submitted procedures, checklists, i programmatic details about the' program.)

4 F 6) The vertical slice approach for the mechanical components is supposed to extrapolate the IDVP results to other

systems, but.the slice is not comprehensive enough, it relies upon other inspection results to eliminate' inspection ~ attributes.

7) The IDVP plan should include the timely consideration and implication of the root cause of all IDVP-issues on other compo-nents and systems.

8) There is no justification provided to exclude the Westinghouse-designed portions of.the! plant. Since the design QA

breakdown apparently stems from implementation failures, all j

vendors must be subjected to the design review analysis to insure the adequacy of the design for CPSES.

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, 9) The scope of the DAP was developed by, eliminating j inspection elements by reliance on the inspection by numerous

-other external sources, which themselves were. separate from the

[ current effort and conducted according to totally different pro-cedures, and intended to discover different information.

10) There is no justification for the creation of arbitrary i

homogenous hardware groups to use as a base to extrapolate results of the DAP.

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11) Expansion criteria for components are ambiguous and-l . rely on no developed acceptability level.

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PROGRAMMATIC DEFICIENCIES IN THE SAMPLING TECHNIQUES 4

1) The proposed sampling approach is generally based on

the conduct of reinspection of both bias.and random samples. The i reinspection itself is done against unknown ~ baseline criteria L (i.e. sometimes the FSAR, sometimes " safety significance,"

sometimes'an unknown attribute checklist) using a 95/5 sampling

. plan. The attributes are, a,s of yet, unidentified so there is no way to determine by: reviewing the plan whether .the reinspection

will be of sufficiently detailed attributes to permit meaningful' conclusions about the acceptability of any one component.

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2) The bases for the CPRT decisions will be. engineering

evaluations of the safety significance of design, construction,

! or process deficiencies, not raw data. Therefore, only those j defects which are judged to have any safety significance will.

i ever be used as a' basis'to reach the threshhold for expanding the j sample size.

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3) Exploratory evaluations which are not recorded are used j to identify the specific sub-p,opulation rendering the. sampling process biased from the beginning.

4) The sampling approach is not committed.

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1 i PROGRAMMATIC DEFICIENCIES IN THE APPROACH TO

- EXTERNAL SOURCE ISSUES AND SELF-INITIATED EFFORTS

1) The ISAP/DSAP approach ignores the critical need to assess the project as a whole, instead of on a piecemeal

. approach.

2) ISAPs are not prepared on any issues not yet identified by the NRC-TRT, including over 700 internal allegations in the SAFETEAM files.

3) ISAP development, done by the issue coordinators or l field consultants, do not coincide with a standard set of f

-requirements (i.e. some ISAPs use the FSAR as the acceptance criteria, some use regulatory guides, some use professional

standards). -Therefore it is not possible to draw conclusions about compliance with the originally prescribed standards.

4) ISAPs do not address the history of other problems related to the specific issue (i.e. each ISAP is self-contained, except for the end-of-line review).

5) Each ISAP has individual close-out criteria which do not qualify acceptability.

6) _ There is no inspection criteria or uniform attribute checklists which can be used by QA/QC personnel, auditors, or third party reviewers to determine the adequacy of the ISAP.

7) The ISAPs/DSAPs do not include the results of the exploratory investigations which are used as a basis to develop the ISAP.

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MISSING ELEMENTS A

The following elements are missing entirely from the program

1. There is no accurate, up-to-date list of remaining work against a defined baseline of actual work necessary to complete Unit 1 and Unit II.

2. There are no work controls on on going work, including ongoing reinspection work and any on-going corrective action work.

3. There are no NRC inspection and review hold points at

' critical reinspection points.

4. There are no inspections attribute checklists available

, for review and analysis to insure that the reinspection effort will be comprehensive.

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5. There is no significant change in the organization and management personnel associated with the construction of the plant (as opposed to QA/QC).

6. There is no internal management analysis to i determine the root cause of the implementation failures of the initial construction and inspection effort.

7. There is no verifiable central control over the multiple reinspection programs to insure that the interfaces necessary for successful implementation and communication exist at the facility.

8. There has been no significant reduction in the con-struction activity of Unit II to accommodate' changes.

9. There is, to date, no quality control / quality assurance program for the reinspection program.

4 10. There is no acceptable protocol between the CPRT-SRT, TUEC, and other contractors.

11. There are no third party controls over the implementa-tion of the' corrective action measures.

i 12. There is no contractual independence of-the evaluators j on the SRT from TUEC management.

13. There is no separation between the reinspection effort and the work-completion effort.

i 14. There has been no review of the third-party organiza-

tions or individuals (either through the hearing or through a public meeting).

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6' 15. There is no program to consider the implications of

-harassment and intimidation on the work atmosphere.

16. There is no program for retraining and recertifying all inspectors to new inspection criteria.

17. There is no justification provided for the identification of the homogenous hardware groups which are to provide the basis for the conclusions of the self-initiated evaluation.

18. There is no adequate plan for implementation of oversight controls on the self-initiated evaluations, or the ISAP/DSAPs.

COMPARISON OF APPENDIX A (SUGGESTED CONSTRUCTION i REVERIFICATION PROGRAM) TO THE CPRT PROGRAM PLAN 9

On February 4, 1985, CASE submitted a proposal for a comprehensive reinspection program as an attachment to their REQUEST FOR AN EVIDENTIARY STANDARD. The Board deferred final ruling on the proposal, suggesting that TUEC's proposal may be acceptable to CASE.

The key elements of CASE's proposal are listed on the left.

The right-hand column denotes which recommendations are included in the CPRT Program Plan.

l l CASE Proposal CPRT Program Plan l

I. Selection of 3rd Party:

l a) Provide for Board selection of inde- No pendent auditor to perform reinspection using following criteria: (1) indepen-dence; (2) competences (3) integrity.

b) Selection after a public No meeting about the nomination prior to staff approval.

c) Poard approval of independent No nuditor.

II. Overall Program Plan - Phase Is a) Reorganize TUEC & B&R upper management. Partial b) Reorganize site and mid-level Partial management.

c) Reorganize work force into teams. No l

d) Installation and status assessment of No current work completion.

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. CASE Proposal CPRT Program Plan e) Establish NRC " hold points" for No review of work plans.

f) Complete revision for all procedures. No g) Issue new procedures and inspection No attribute checklists after NRC review.

h) Review documentatien and incorporate No design changes into final design.

1) Re-qualification of equipment. No j) Review vendor QA programs. No k) Recertify and retrain personnel. No III. Overall Program Plan - Phase II:

a) Reinspect hardware and report No results.

b) Monthly meetings on implementation. No c) Develop corrective action plan, Partial submit for review, and revise.

d) Board approval of corrective action No plan.

IV. Overall Program Plan - Phase III a) Resubmit design for NRC approval. Partial b) Work Authorization Procedure for No items requiring repair.

c) Work completion accomplished.

d) Monthly meetings to review progress. No

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a CASE Proposal CPRT Program Plan

? Cooperative Participation by Parties V.

and Boards a) Board approval of CPRT. Partial b) Continuous documentation oversight by 3rd party. No c) Monthly public meetings. No d) Mandatory compliance with approved No methodology.

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