ML20195G235
| ML20195G235 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/03/1987 |
| From: | Charemagne Grimes NRC OFFICE OF SPECIAL PROJECTS |
| To: | Bloch P, Jordan W, Mccollom K Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20195G199 | List: |
| References | |
| FOIA-88-322 NUDOCS 8811230315 | |
| Download: ML20195G235 (7) | |
Text
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April 3,1987 Distribution Docket File Gra.v File 3.2b PAD #5 Reading LChandler Docket Nos. 50-445 SBlack and 50-446 CTramell MRushbrook OIA AVietti-Cook CGrimes MEMORANDUM FOR: Tha Atomic Safety and Licensing Board for Comanche Peak (P. B. Bloch, W. H. Jordan, K. A. McCollom, E. B. Johnson 1 FROM: Christopher I. Grimes, Director Comanche Peak Pro.iect Division Office of Special Pro.iects
SUBJECT:
CORRECTION TO REPORT OF INVESTIGATION BY THE OFFICE OF INSPECTOR AND AUDITOR (R)ARO NOTIFICATION NO. 87-06)
On December 11, 1986, we forwarded to the L censing Board and parties to this proceeding a Report of investigation b/ the Office of Inspector and Auditor (OIA) regarding Region IV manageme'et actions relative to Comanche Peak (Board Notification No. 86-74).
Since that time, OIA has reported an error to the chart which was contained on pages 34 and 35 of the report. OIA states that this chart did not accurately characterize the analysis of technical issues performed to determine whether Region IV management appropriately downgraded, changed or deleted inspection findings and violations. The complete analysis, which is included in the report, remains uncharged and there is no effect on the conclusions of the report. The corrected chart is enclosed. Areas of change are outlined.
Review of the report and its attachments is still un('erway and no decision on the release of the ccmplete report (and all attachments) has yet been made.
We do, however, expect this decision to be made in the near future, at which time we will issue a further board notification regarding this matter.
(original signed by)
Christopher 1. Grimes, Director Comanche Peak Pro.iect Division Office of Special Projects
Enclosure:
As stated cc: See next page
- See attached pages for previous concurrences.
- PA08f *0!A *0GC-Beth NRR CPP0h ell:jch SConnelly LChandler SBlack CGrimes 3/og7f 03/13/87 03/21/87 p/g/87 4/g/87 1
G 8911230310 001100 DI -322 PDR
Distribution Docket File Gra.v File 3.2b Docket Nos. 50-445 PA0#5 Reading LChandler and 50 446 CTramell SBlack MRushbrook AVietti-Cook CGrimas MEMORANDUM FOR: The Atomic Safety and Lie.ensino Rnard for Comanche Peak (P. B. Bloch, W. H. Jordan, K. A. McCollom, E. B. Johnson 1 FROM: Christopher I. Grimes, Director Cnmanche Peak Prc.iect Division Office of Special Pro,iects
SUBJECT:
CORRECTION TO REPORT OF INVESTIGATION BY THE OFFICE 0F INSPECTOR AND AUDITOR (BOARD NOTIFICATION NO. 87-06)
On December 11, 1986, we forwarded to the Licensina Board and parties to this proceeding a Report of Investigation by the Office of Inspector and Auditor (OIA) regarding Region IV management actions relative to Comanche Peak (Board Notification No. 86-24).
Since that time, O!A has reported on error to the chart which was contained on pages 34 and 35 of the report. OIA states that this chart did not accurately characterize the analysis of technical issues performed to determine whether Pegion IV manacement appropriately dnwngraded, changed or deleted inspection findings and violations. The complete analysis, which is included in the report, remains unchanged and there is no effect on the conclusions of the report. The corrected chart is enclosed. Maroinal lines indicate ams of change.
Staff review of the report and its attachments is still underway and no decision on the release of the complete report (and all attachments) has yet been made. We do, however, expect this decision to be made in the near future, at which time we will issue a further board notification regarding this matter.
I I Christopher I. Grimes, Director Comanche Peak Pro,iect Division Office of Special Pro.iects
Enclosure:
As stated 0 YJ$ }
cc: See next page 7.M 5: OGC-Beth NRR CPPD:
rammell:,1ch LChandler SBlack CGrimes p87 / /87 / /87 / /87
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Distribution Docket F1:e Gray File 3.2b Docket Nos. 50 445 PAD #5 Readino LChandler and 50-446 .
CTramell SBlack MRushbrook OIA AVietti-Cook CGrimes MEMORANDUM FOR: The Atomic Safety and Licensing Board for Conanche Peak (P. B. Bloch, W. H. Jordan, K. A. McCollom, E. B. Johnson 1 FROM: Christopher I. Grimes Director Comanche Peak Project Division Office of Special ,Proiects
SUBJECT:
CORRECTN N TO PEPORT OF INVESTIGATION BY THE OFFICE OF INSPECT 4 t AND AUDIT 0P (B0ARD NOTIFICATION NO. 87-06)
On December 11, 1986, we forwarded to the Licensing Board and parties to this proceedin Auditor (0IA) g a Report of Investigation by the Office of Inspector andreg Peak (Board Notif e.ation No. 26-24).
Since that time, OIA has reperted an error to the chart which was contained on paqes 34 and 35 of the report. OIA states that this chart did not accurately characterize the analysis of technical issues performed to determine whether Region IV management appropriately downgraded, changed or deleted inspection findings and violations. The complete analysis, which is included in the report, remains unchanced and there is no effect on the conclusions of the report. The cesrected chart is enclosed. Areas of change are outl'ned.
23df hview of the report and its attachments is still underway and no
/
decisitTn on the release of the complete report (and all attachments) has yet haen made. We do, however, expect this decision to be made in the near future, at which time we will issue a further board notification regardino this matter.
Christopher 1. Grimes, Director Comanche Peak Project Division Office of Special Pro.iects inclosure: >
As stated cc: See next page
- See previous concurrence pace. i lLA L
0' -Reth NRR CPPD:
- PADa5: *01A '
CTr 1.: j SConnellv X@j\
A U
D3/10/87 LChandler SRlack
/ /87 CGrimes
/ /87
/
/ /87 03/Q/87 1
V
. DISTRIBUTION LIST FOR BOARD NOTIFICATION _
Comanche Peak Urdts 142 Docket Nos. 50-445/446 Peter .9. Bloch, Esq.
William L. Brown, Esq.
William H. Burchette, Esq.
Mr. W. G. Counsil Thomas G. Dignan, Esq. -
?!rs. Juanita Ellis Joseph Gallo, Esq.
Billie Pirner Garde Renea flicks, Esy.
Robert A. Jablon, Esq.
Elizabeth B. Johnson, Esq.
Dr. Walter H. Jordan Robert D. Martin, Esq.
Dr. Kenneth A. McCollom Mr. James T. ?1cGaughy Mr. Harry Phillips Anthony Z. Roisman, Esq.
Mr. Lanny Alan Sinkin Robert A. Wooldridge, Esq.
ACRS(10) r Rev. 03/23/87 l
~
PAGES 34 & 35
.nspection
. Aeport 85-0U05 Inconclusive incorclusive Concerns 1 (and 2 Reactor Vessel Installation
- nconclusive inconclusive Concern 3 Audit of Reactor Yessel Installation No Violation inconclusive Concern 4 Spool Piece Marking 2
Cuestier.able No Problem in Concern 5 Handling of Handling of Cement Mixing Blades Violation Violation i inspection Report 85-14/11 Questionable inconclusive on Concerns 1, 2. and 3 Concern 1 and 7.
Records Shipment to Sto9e Cuestionable on and Webster Cnncern 3.
Inconclusive inconclusive Concerns 4 and 5 Records Shipment of CB&I I Questionable Inconclusive Concern 6 Temporary Storage of Records Inspection Report 85-16/13 Questionable Inconclusive 2 and 3 Concerns 10 CFR 50.
1,55(e)
Questionable Inconclusive Concern 4 NAMCO Switches Not Properly
1 Inconclusive whether
- Thereawas insufficient violation infomation to detennine was appropriate.
2 Questionablecite - There was sufficient infonnation available to a violation.
. . o St.MGRY _
ib Problenn In Inconclusive or 11andling Violation
!b Violaticn cuestionnable 0
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- 1. ED0 NUMBER OSP ACTION NUMBER ~ 87-51 ACTION NUMBER - .
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OTHER NUMBER. , , ,
- 3.
SUBJECT:
RIcomendations oursuant to thd Cominche Peak .Peoorts questions 1 and 2
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- 5. ACTION REQUESTED f N
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- 6. ASSIGNED TO:
b l 5 l 9,'1 3 h EXPECTED COMPLETION DATE:
- 8. "O SLIP ITEM 7 ( 9. PRIORITY ISSUES I
- 10. DOCUMENTATION OF COMPLETIO x - _.
- 11. FILE LOCATION:
- 12. PLEASE RETURN .
THIS FORM TO DIRECTOR'S SECRETA
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\o NUCLE AR REGULATORY COMMIS$10N f 3 *. { FrA8HINoToN,0 C.20$lt April 14, 1987 14E!AOF.ANDUM FOR: Chairman Zech FROM: Victor Biello, Jr.
Executive Director for Operations SUNECT: IMPLEMENTATION OF RECOMMENDATIONS OF COMANCHE PEAlt REPORT REVIEW OROUP In November 1986, the Office of the Inspector and Auditor (O!A) Issued its Report of Investigation, 86-10, addre s s',n g a]!egctions of Region IV management wrongdoing relative to inspeetlen activities regarding the Comanche Peak Steam Electric Station. In broad terms, the O!A Report dealt with three a!!egations: (1) harassment and intimidation of an inspector in connection with the preparation of inspection raports and the consequent downgrading or deletion of violations: (2) fa!!ure of the Region to carry out required inspections of the permittee's quality assurance programs and, (3) deficiencies in the NRC Form 766 reports propered by inspectors to document inspection activities.
With the approval of the Comm!ssion, on Janusry 21, 1987, I estaN!shed the Comanche Peak Report Review Group (CPRRG) to evaluate the OIA Report.
Consistent with the Commission's direction, the CPRRO was charged with providing recommendations on five matters: (1) the safety significance of tha 34 issues identif!ad in the OIA Reports (2) whether the issues identitled in the O!A Report were appropriately handled in terms of process and dispositions (3) whether the current augmented review and inspection effort at Comanche Peak is suff!clent to compensate for any identitled treaknesses in Region IV's quality assurance inspection programs f 0 the purpose and afgnificance of HRC Form 166 and, (6) whether the issues raised with respect to Comanche peak have broader implications in Region !Y, The CPRRO specifically did not duplicate the O!A Investigation nor develop any independent record of testimony (although it did request and receive some additional documentation): it did not address the licensability of the Comanche Peak (sellity; and, it did not investigate or othorwise inquire into any matters of wrongdoing, misconduct or mismanagement excent to the extent that such matters were exp!!citly identified in the O!A Report and its attachments and then only for the purpose of identifying factors that might have esused or contributed to the matters considered in the O!A Report.
!!owever, the CPRRO did perform a complete review of the OIA Repert and a],1, the suppo? ting attachments thereto. Coples of the CPRRO Report etero provided '.s the Commission on March 17, 1987. It is sprcrent that I treated this entine matter very serlously and devoted extensive management and etaff effort to the task.
- tMMG S. rMql,M gQ/A f Oh' y
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The CPRRO. In its Report issueo to me on flarch 12, 1917, addressed each of the five issues identified above. To quote the CPRRO's conclusions:
(1) None of the 34 issues identitled in CIA Report 66-10 was found to be significant in terms of any direct advorae impact on plant safety.
(2) Region IV's disposition, f.v., clas sification, of the identitled issues was appropriate, and the Recion acted within its authority based on the information centained in the inspection reports and on the guidance avaDable for determining the classification of the findings, e.g.,
violation, unresolved [sfe). Certe.in issues were not appropriately processed e.g., inspection findings were in some cases not developed by the inspectors in accordance with agency guidance, and Region IV st.pervision did not always provide the guidance necessary to properly focus and resolve items.
(3) Ifhen ressured against the 1986 inspection program >
requirements, raps were identitled in the total inspection program. The current augmented review and inspection effort at Comanche Peak has, for the most part, compensated for raps in sco Region IV's QA inspection program. pe and coverage in l
(4) Th 766 system, primarily used by IE and Uttle used by the Regions, is not used in making safety decisions. .
The accuracy, completer,ess, and timeliness of the data l are not adequate for many r.eeds. Overau, the 766 l system does not natisfy current agency needs. l l
(5) The CPRRO's judgment is that broader imp!! cations are Ukely for faciutics in Region IV other than Comanche Peak. Additional considerations may influence the significance of these implications. (CPRRO Report at 4-1).
In addition to the foregoing conclusions, both the CPRRO Report and its i
, several Appendices contain numerous recommendations for specific i
, improvements and corrective actions. We have extracted from the CPRRO Report and its Appendices all explicit recoctnendations and have categorired them as follows:
I
- Category 3 additional and confirmatory actions and inspection efforts needed to assure complete disposition of the 34 fasues
' in the CIA Rtport and to compensate for
- sps identified in the Cornanche Peak QA' ;
lnsptetten program
3
- Category 2 clarification of inspection ph!!osophy and practices, authority to determine significance level of inspection findings, and documentation requirements and procedures for inspection findings:
and.
- Category 3 review of existing data management ayatoms with appucation to inspeciion activities, including NRC Torm 766, and necessary revisions to enhante the reporting, management and use of the inspection data for both Headquarters and Regional purposes. (CPRRO Report at 3-1. Item 4 and Appendiz D. Sec. Vill) in order to carry out the CPRRO Report recommendations in the most timely .
manner pcssible and with due recognition of the recent estab!!shment of the l Off5ce of Specla! Projects and the agency-wide reorgan!:htfon the above !
recommendations wiu be asalgned as fol.ows:
- category 1 recommendations apply specifically to the Comanche Peak facility an d, accordingly, wiu be usigned to the Office of Special Profects:
- categories 2 and 3 recommendations, because of their programmatic nature, wiu be assigned to the Off!ce of 1 Nue; ear Reactor Regulation with the assistance of the
, Off!ce of Administration and Resources !!anagement.
In addition to bplementing the CPER O's explicit recommendations. I am i directing these offices to further review the Report to determine whether there are any further actions to he taken based en other statements, imp!! cit recommendations or lessons learned contained therein. Each of the recommendations w!D be implemented except as approved by me upon :
adequate justification. Enclosure 1 is a pre!!minary :! sting containing those recommenduttons which are explicitly set out in the CPARO Report. As noted above, the staff will continue to review the Refort to extract other :
recomtnendations or suggestfons which may be 1Icluted in the text and '
elseuhare in the Report.
1th!!e concluding that
- broader implications are !!kely for feellities in 1 i T.edon IV ether than Comanche Peak" (conclusion (8) above), the CPRRO '
anaNes no express recommendatlona for resolution of this concern. The '
CPRHC does, however, make several observations regard!ng the s!gnif!cance of enhanced inspection activities at Comanche Peak and in terms of characterfr.ing the nature of the esuses of the events at Comanche Peak. ,
which bear on th!s issue. These matters, along with a more deta!!ed discusalon of the evolution of the NRC's inspection program and other Region IV facilftfes, la presented in Enclosure 3. In brief, it would not be t
i l
un expected thot, if measured a gainst the 1986 inspection program, gaps would be found elsesvhere. Moreover. the philosophy of the modularised
!nspection program is such that each line item need not be "completed" by the inspector. Rather, the inspector is to consider each line item fra determining whether the faciUty is being constructed (or operating) safely.
Nevertheless, the operating history of the other faclUtles, the team and other specla) inspections and on-site technical audits that were performed by the staff in addition to the various indepen dent arid utility-conducted verifleation efforts, suggest strongrly that such gaps as might exist would be few and not of safety concern. Consequently. I have no cause to believe that the ressenable assurance which was previously found to edst with respect to other fccilltfes within Region IV has been eroded. Nevertheless, while I have no reason to conclude that the initiation of an inquiry to determine whether specific gaps in the inspection process e: dst for other facilities is ic: mediately warranted. I propose to direct NRR to examine in mcrre detail, the inspection records for a facility within Region IV which did not receive as much atthntion through either NHC- or utility-conducted efforts. If the results of such review require, further staff reviews of other plants will be performed, hsed on the findings and conclus!ons of the CPRRG Report, in pr.rticular thoso regarding the implementation of the inspection program for Comanche Peak. In terms of process and disposition. I also intend to take appropriate personnel setions to assure that, to the extent possible, the c!rcumstances which culminsted in the O!A investigation do not recur. In this regard. I p~3 pose to personally write to the principnl individuals involved to inform thom of the CPRRG Report and provide each with a copy. A draft of my proposed letters is attached as Enclosures 3-8. Further. I intend to meet with each of the principals to inform them of my decisions for rasohing the remaIntng issues and to discuss with them their future roles in the Region.
! vef!! also meet with other Region IV cr.d site personnel to explain my set tons. I intend to strees the importance to be attached to professionalism, teamwork and the need to be sensitive to the views of others which may not coincide with one's own, within the framework of the inspection process as well as within the agency as a whole. In addjtlon to implementation of CPRRO's programmatic recommendatione to provide further clarity, consistency and understanding of the NRC's inspection process, the principaj individuals involved, both inspector and management, will otso be given specific trajning to froprove their interpersorial skills and communication as ap repriate to the individual. The Region-utde training program and dance inittsted by the Regional Administrator, c'escrlhed in hit-ecember 17. 1988 memorandum to me, will be continued for all appropriate Region IV personnel.
In addjtfon to the recommendations whfeh are discussed above, the CPRRO Report contains recommendctions and cbservatlotes directed toward improvement in O!A's investiptfon process. CPRRO Report at 1 14 Appendix P. at 17. Items 3.7.30 and 3.7.11. The Commission may wish to refer these rnstters to OIA for its consideration. An additional, related recommendation is in order. The CPRRO Report fundamer. tally substantiates 4
3 the General Cour.sel's observation, stated in his December 23, 1986 '
mecorandum to the Ocmmissionera, that:
It is unclear .. . why reliance on the Regional Administrator and adherenec to the .N R C 's longstanding ;
procedures for handling Differing Profsssional Op!nfons, as set forth in NRC !.f anual Chapter, NRC-4125, v:ould not have sufficed to perarit a timely and effective resolution of all issues without having the situation escalate at the outset to the po!nt of a full-acade O!A investigation involving charges such as harassment and intimidation. The central issw,4 which gave rise to this matter appear to involve diffeMnoes in professional views on several matters.
It is my judgment that in this instance, the conduct of this protracted CIA inycatigation has served only to further polarise the Individuals involved and by distracting personnel frora their assigned responsibilltfes, has been detrimental to the agency's mission to protect the heajth and safety of the public. This suFgests the need for the Commission to examine the polley question of requesting an O!A investigation when managemont-type issues are involved. Perhaps by improvement in the existing procedures for resolving differing professional opinions, the Commission can better pro-vide for the prompt disposition of such issues.
I recommend the rolesse of the CPRRO Report and its Appendices to the puhtic consistent with any limitations determined approprfcte by the Commission regarding the releast of the OIA Report. Investigation 86-10. I further reco= mend the public release of this memorandum, except for Enclosures 3-6, upon Commission approval of the setions recommended.
Appropriate Congression&J Committess tvil; be notified at thkt time.
The Commission's opproval of the foregoing actions is requested.
Cristui signed by yiot.cz 3t e11er Victor Stello, Jr.
Executive Director for Operations
Enclosures:
- 1. CPRRO Mecommended Actions
- 2. fraplication:, for Ot) er Region IV 7 sed 11tles '
+ h4eiterv F aamsd *<cim4V-pers6nnet Mr. M cc tv/
Enclosures:
Commissioner Roberts Comn.fssioner Asstlatine Commissioner Dernthat commissioner Carr SECY Nonne 11y. 0! A
~~~ 046n IG, e '112
\D . k. W w mc,K Y m *. R . 5 6 ,- n- Wdl.y se V, ut M.J.ha e o4 L g, dea h+,T),'n ) o s n ha 2 ka b,a k as.oo<j 2~) uw w 1 sm o > & sk .
CPARG RECOMENDATIONS Enclosure 1 Comanche Peak Actions 3D RECOMENDATION ORGANIZATIONS REFERENCE 5 .
02 Reinspection of 0$P C ompfde pg 3 8 hardware and design -
during current Commanche Peak re review. (Explicit) recomendations in 5 ge4<c scel sequence numbers 22 I through 50.) '
I 18 Clarify agency 0$P PM Cupfd, ,
pg g.g, da pg 3 25 guidance: Clear lines recomen of responsibility tien #2 between the Comanche
- Kesk augmented inspectiott program and the estabitahed licensing, and inspection and enforcement processes were not established c,r maintained in irslementing the inspect. program 1 20 Confirmatory NRC OSP T hwM pg 51 App A Table sction. Perform a recomends 1, IR,85 07/05 detailed review of tion #1 Item 1 (1)
Westinghouse's
- engineering evaluation g a g p % {)
regarding translation of design criteria Dh )NI 3 I
into installation 8 A 5 5 ' I*r 4 ' M specifications, procedures and 7 n d 4 3 rd .
drawings and failure inew A J s[M6eb a
to control deviations U /,9 regarding Unit 2. i? fT' w/,g
? @ Confirmatory NRC 0!P r pg (4 k;p A, Table actions: Perform a recomenda 1R visual inspection of tion #1 8 3l 07/05, Jtem the accessible reactor 1 (2).AppA vessel surroundings pg3 3 YM during of after het funct' enal test, i
i .
CFARG RECOMENDATIONS Coranche Peak Actions l 3D RICOMENDATION ORGAN!ZATIONS REF!REN0t$ .
l l
1 l
22 Cor.firmatory NRC 0$p T pp 5-1, App A, Table DA.)
action: Perform a recomenda 1, In d tailed review of
- tion #1 85 07/05, Item $f Westinghouse's 2, App A pg i engineering 33 l evaluation. Failure to ,
maintain tolerance I required and failure i to report tolerance
- deviations on an NCR with regard to Unit 2 ,
RV support brackets and shoes, i r Confirestory NRC OSP .I fDecF71 pg 5-1 App A, Table DA)
@ action:Verify that an recomenda 1. IR adequate quality tion #1 85 07/05, Iten Ni control procedure 4 exists for QA App A pg 3 12 inspectors to witness the transfer of marking for material that would otherwise lose its traceability when cut into smaller sections, Tk o m. .s ,
(- 24 Confirmatory NRC 0$p 7- D e c. r ? pg 51 App A, Table \/ou . i recomenda 1. IR - '
action: Issue: FsAR 85 14/11, Item 17.1.17 does not tion #1 1(1),AppA (T j describe TV Electric .
records system. 93 22 Action: Review the revised NE0 procedure.
upon their completion and verify the !
implementation. VerifM '**'"#*
adequacy of applicants j E#~#V O
corrective action, s .
$h4 App A. Table 7 25 Confirmatory NRC 0$P r Cec r7 pp 5 1. da 1 recomen IR I$p' action !sive:QA 8514/11,It**
manuel does not tien il address AN5! N45.2.9 3 requirements /comitmen ti 5 quence 5 5 b 5 Si N d M ll t ' A Jg e t b b y ob3%vh 7, Number 24 above. q.q eg' 4,4 ,, ,4 do m %W.
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WARU RECUP.MENDAT10N5 Comanche Peak Actions f
ID MC0W.INDATION ORGANIZATIONS REFIRENC(5 .
l 7 2s Cc .firmatory NRC OSP T Cec 87 99 5 3, App A. Ta':le YA/
Action: !seve: TU 8 *14/11. Item $@[,; '
e se p e u es to control shipment of design records for piping to $ tone and Webster NY. Actionh refer.*ca see $stuence Number above. .
27 Confirestory NRC 0$P T Pec 27 pg 5-1, App A, Table N ,
9 action: Issue recomenda 1, IR '
, original design tien #1 85 14/11. Item Sf records shipped in
- 4 cardboard boxes to Stone and Webster.
Artion lee $stuence f 5t'"cN k nber V24 above.
n 28 0$P T Dre F7 pp 5 1, App A, Table 5l[
Confirmatorfr.NRC action: No ckup copy recomenda 1, !R of records ende for records shipped to II'" II l$14/11,ItemSf#,
Stone and Webster.
Action:Jee Sequence ,
reIs<eace) ,
Nur.ber Q4) above.
' 29 Confirmatory NRC OSP T Dec 87 pp 5 1, App A, Table 'I) action: !sive: Failure recominga 1 to control and account tion #1 al.!R14/11, Item $f*,
for QA design records 6 transferred from site to $ tone' and Webster, NY. TU Electric stated.... Actiertt See Sequence NumberQy 1
above. .
I sa 30 Confirritory NRC 0$P T Dee F 7 pg 5 1, App A, Table action: Issue: Site recomenda 1, IR records containment tion #1 85 14/11. Item N#
liner and rechanical 7 penetraticn of Chicago Bridge and Iron i shipped to Houston, Texas, in cardboard i
boxes. Action: ta-l Seewente Numberh re l'e r e n c e d l above.
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CPARG RECOMMENDATIONS Comanche Peak Actions ORGAHlZATIONS REFERENCES 3D RICOMMENDATION f 31 Cor.firmatory NRC OSP T O* ' #
pg g.1, App A Table D action: !ssw: No recomenda 1, IR .
_y backup copy of records tion il 85 14/11, Item made for records 3 shipped to Chicago Sridge and Iron.
Action:les 3eevence k.a.ber Q$)skove. fe$t twed
- 32 Confirmatory NiiC 0$P T Ike Y 'PI 5*3, APP A Table D A./
action: Issue: TU IR Electric failed to recomenda tien #1 1{.14/11, Jtem 3 inventary records sent 8 to Chicago Sridge and Iran. Action $ f t[e r e*(ed Sequence Number above.
Osp r th e 3 7 App A. Table 'I IV S 33 Confirmatory NRC action: Issue: Plant PI 5 1. dan 1.
recces-en wn, In Item sP*
4 records stand in
' ion n 34
<oiders or e,en 4
binders in open face ,
' cabinets at records ,
center. Action: he *
[
Secuence Number (2J relersue,) ,
ibove. l 4 34 Confirmatory NRC OSP y Pee 77 pg $*1, App A, Table 7[ I ,
action: !ssue: Failure 8 85 4/11, Item S P < l II i
N NN n!'NUId facility for records App 8 pg 101 l
entered into the
' permanent records
' center then co singled With in process 1 documents in paper l
flow group. Action 5ee Sequence Number @: re fer sv cel jo ,f'fh[;
above.
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" Ci, z rm 9 g ,j,j, rabi, .
@ ggtgyc ti*a n as 1s/13, Item
- 3. >>> A.
5 P" c vevei.,/t.,ie.ent 2 me
,rocedo,e t.
<emon.trate ...isce3
- deficiencies '
i corrected. Actient .
Audit the CDR program I to verify its l edeousty. App 1(cant ., .
i -
l s neluch 34 - 37 '
c ; .,
I should rev se . ,
Procedure Nt0 C81.) '
l l
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1 1
CPRRG KECOMMENDATIONS Corr.anche Peak Actions 1 3D KICOMMENDATION ORGAN 11AT!0NS RtrtRINCt!
b*'
iX h Cc firesto.y NRC OSP T b 8$ pg 5-1, App. A Table a: tion. !ssue: 70 Mcomenda 1, In Electric failed to 1103 II 85 16/13, Item revise implementing 2.
procedures containing 50.55(e) reporting before corporate Nt0 Procedure C51 was implemented resulting in a conflict with 5 -
other procedures.
Actipa) See Sequence Ada. Ql)above. rdarweed 49 h Confirmatory NRC OSP 2 M pg 5 1, 4 p A, Table d fd a ction. Issue Mcomenda 1, la Failure to maintain tien #1 35 16/13, Jtem retrievable 50.55(e) 3.
flies (i.e., could not produce record in '
almost a month).
Action: se Sequence ,
Number 3 above, re fe rem.d 0$p I N d Al !
so @ Confirmatory NRC pg 5 1, App. A, Table Iction. Issue Failure to report to neomenda 1, IR ti'a 81 85 16/13, Jtem Nic actual c,orrective 4.
action taken en 50.55(e)s. Action:
See Sequence Numbar @ re[eremced abbye,
- < h Confirmatory NRC 0$P I IJ" 88] pg 51 App. A, Table Jni action. Issue 1U recomenda 1. IR Electric's 50.55(e) tien #1 85 16/13, Jtem files not auditable. 5.
Nw:, bel J)es Sequence rebem e'd Action5 (: above.
N 40 Additionsi NRC action. 05P PM MW ## pp 51 App. A, Table )II
!ssue: TU tlectric racemenda 1 !A ~
mover responded to all tion #1 8$16/13, Item $I aspects of lll 7914. 6 8 p. 3 33.
Action: Provide applicant with clear &
conci:e written evolvation of uttens taken to date &
specify additional ,
actions required to c1cse the issue of lti 75-14. ,
O t
CPRRG RECOMINDATIONS l Comanche Peak Actice ORGANIZATIONS REFERENCES 10 RICOMINDAT10N Confirmator;i NRC OSP I b pg 5 1, da App. A Table
- 1. IR
- @ actien. Issue: 70 recomen :
bh tien #1 85 16/13, Jtem Electric's 1(8 record 7 4 p.
files were incomplete 3 36,37.
(1982 4 1985).
Action: Evaluate effectiveness of i
applicants' program through an audit. -
(Assure that all '
Bulletins were received, processed, 4 3 corrective i r.i ti ated. . .actions 'nclude %W l
4 @ Confirmatory NRC 05P .I f> 381 pg App. A 51, da 1, IR , Table Jm l recoman action. Issues '
tion #1 85 16/13, Ites SP*
9eficiency in TU p a p. 3 36.
3 precedures to handle Ills. They de not I< descries how
, construction
- manapement personnel
! hand e IIIs requiring '
action,especially .
hardware repair, replacement 4 modification. Ac ent see sequence No 41 r efenmed OSP I Crideal pg 5 1, App. A, Table )M
@ Confirmatory NRC recomenda 1, IR action. Issue! No focal point in.TU tion #1 85 16/13, Item SP*:
- to. l 1 Electric to track Itt j 1 items. Actient A o j Setucnce Number G4 referemed l i above.
I @* @ App. A, Table d A T e @ Confirmatory NRC 05P j action. Issuet TU pg 51, da recomen tien #1 1l 1R 8 16/13, $h#
1 Electric's interaal nema.
! rester itised that Tu i tiectric would not i
~
identify
, nonconfersantes en iLi l
) 79 14 to NRC. Actt . ,n !
l See $equence Number (Q) reIere. ee) !
ateve. l i
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CPARG RECO WINDATIONS Comanche Peak Actions 3D MCOMMINDATION ORGANIZATIONS R!rtRENCES Ty '
' @ ce3firmatory unC Osp .r N v 8 77 pg s 1, App. 4 W -v l action. lanue: recomenda 1, IR ' Tabie I' ' ' ,
Jr. sufficient evidence tion il 85 16/13' It'*
of successful testing cf 415C0 fire seals -
12 Qt i filing of falso reports by 815f0
' validity of 815C0 seal evastioned. Action:
Ver1Q adeevacy of new ,
seal installation.
46 Confirmatory NRC OSP T pg 31 App. A, Table action. Issues recomenda 2, !R Failure to maintain tion #1 85*07/05, Item tolerance and to 2. App A pp report tolerance 36 deviations on an NCR re Unit 2 RV support brackets and shoes. -
Action Examine traveler and NCR procedures, confirm changes are in plant specif. design +
ma latained. . .
1 47 Confirmatory NRC OSP T U" 8 7 pp 5-1 App. A. Table l action. 1: sues recomenda 2, IR '
Failure to perform tion 91 85-07/05, ! ten '
audits of 3 surveillances of -
reactor pressure .
vessel specs, l proeedures e installation. Actions i Monitor applicants' !
response to staff l concerns raised in 35tR 11 regarding their audit program.
J 48 Confirmatory NRC OSP T 0" # 7 pg 51 App. A. Table bb actlens. Issue: No recomenda 2, !R objective evidence tien #1 85 07/05, Item (records) that sizing A. App A p blades had been 4 17 inspected quarterly since 1977. Action:
Review statistical data re uniferatty of concrete and review larger sample of -
concrete compression tests.
. . CPRRG RECOMENDA710NS Comanche Peak Actions 3D TdC0MINDAT!0N ORGANIZATION $ REFERENCES .
' 49 Confirmatcry NRC 0$P T pp 5 1
~
action. Issue: NAM 00 App A Table 2, d M switches lEl 7p 28 recomenda IR were not properly tion #1 85 16/13,ltem 8,p3 41,42: pg SP+
identified on install > tion 38 travelers. Action:
Monitor applicants' EQ CAP. Note (3) .
Applicant actions. list
' @ Confirmatory NRC OSP .I b" b pp 51 App A action !seve: .
recomenda 1,1R. Table Insufficient evidence of successful testin of 81$C0 fire seals,g tien #1 85 16/13, Jtem 12 4 pg 3 46 sP*.
filing of a falso report by tl500 -validity.
Action: Reinspect -
seals and certification documentatica.
h If spool CWi spool OSP 1 [*" A ##l pg 5 1, pg 310. App B DA) piece was not marked ,
racemenda pp 15 at the time of tion #2 $[ 4 ;;
ins pectier. then additional, review would be warranted.
Resolve uncertainty i
! associatad with when -
J t.he spool piece was varked.
4 ;
$2 Inspections int 19ded 0$P .1 hi Mag to App C, in the Ig86 inspection Table 1. bf i program , but not pp.10 12 completed at Unit 1 l should be reviewed, and those determined to be necessary to confirm. plant quality, !
)
I should be a cc er.p11she d. r E
1
=
+p--g- -----.,w- g-.--g -.g..-,-----y- w--w-w9 gw y--e _ - - -m-w.w--a-w----, e - - -e_w-,c- -+.--------+v>-
CPARG RECOMMENDATION 5 Coe.anche Peak Actions ORGANIZATION $ REFERENCE $ .
10 MCOM.MENDATION 0$p FM CompI'k pp 5-),
f5 53 The status of the inspection programs pg 2 me, recomends App C pg 4 for Unit 2 should be tion #3 it.onitored with respect to all NRC inspection activities to assure that inspections keep pace with construction and ' windows of opportunity' are not l lost. _
Further review of 0$P .I [bec IO App : ,g SP O @ operations Traveler - 15 criteria, control and ,
effectiveness is warranted if it has ,
not been done as a part of inspection activities completed te date.
!7 @ A need to varify the CSP I App 8 pg adecuacy of Level ! QC 15 inspection of RPV installation may exist.
v4 61 Turther NRC -eview of Osp T App 3 pg 3d the completness of QC 15 coverage and technical acceptability of the ,
actual inspectbn
- criteria for the
- instellation of all ,
the major N558 components is possibly
- i warranted.
! Inspection of other C3> I { Mud 88] App 8 pg Dd il @ installed 15
. field fabricated soon1 pieces should be considered. ,
l
1 CPARG RECOM.MENDATIONS Cor.anche Peak Actions 3D RIC0K9tNDAT10N ORGAN!ZAT10N5 REFERENCES .
e @ verify 'adequite os, 2 @a ' ')
A,, s ,e W raterial 15 identification and traceability program i for earlier work er review procurement and control progran for ,
the b91k piping stock t at CP$t$ with further -
) inspection directed to the checks and L balances precluding
. install, wrong r.a te rial at 66 Determine if the 05P T 03' I7 App a pg Regulatory Guide 1.97 Ig ,
QA comitments have been properly implemented at the !
CP$t$ and whether Regieet IV has monitored such i
. impler.ie nt6 tion.
G @ The adequacy of the 0$P I @ec TO App B pg licensee's program to 16 update perennent installation i documentation when components ire chtnged 6 or replaced sheviti be reviewed, if ,
not already evaluated l l in inspections to l
\ date. '
. 13 W The need to evaluate CSP T F" F 7 Acp B pg N
- (,9 safety t,ignificance 17 Rec. #
and all pertinent 2.7.9 aspects of the licensee's QA Program way need to be :
eeshasized. !
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CFRRG REC 0KMINDAT10H5 Comanche Peak Actions 3D AICOMMINDATION 0AGAN11AT10NS Rtrt.1 ENC [$
49 (ff) Additional inspection 05p JCb5""#) App 3 pg ""P"'E" i by NRC is required to 4 , g. g* ,)(V\
revier engineerinf Item:28/33 ts to close 1[8 $P g.34 refe r4* e+
v' 73 Region IV selectively 05P : P&i 'd ay 88 App C pg 3 5 i) review records to see if specific inspection ,
gaps were caused by .
non performance. If so Task group recommends 'the Region" (sic) take
, appropriate action to close these gaps where there remains a clear ,
benefit to... plant qua11ty.
zo T Ro I
~173' i l
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CPRRG RECOMMENDATIONS General Programatic Actions-l 3D REC 0WINDATION ORGANIZATION $ REFERENCE 5 D4 AN$1 N45.2.9 is silent on shipping records. A NRR RES pg 313 App g pe 73 77 pg 3 D'
definitive and twopIaces.34 Sfx, documented regulatory position does *:0 exist on hntrols during transfer between organizations.
05 Clarify agency NRR
- pp 5 2 pg 3 25, pg Sf swidence It MC 9900 recomenda 318, App p pg guidance was tien 2 Ig, App p pg misinterpreted on als applicability of 20 CFR 50 Appendix 8 criteria to to the requirer.ents of 20 CFR 50.55(e).
TT 3
31 Clarify agency NRR NM$$ CE pp 5 2,' pg 3 24, pg 5f guidancet recomenda 3 22 Philosophical tien #2 App B p 20 differences ... en two issuost first, to what extent should inspectors focus on
- hardware" v QA "records" second, to what extent should violations be developed prior to issuance. .
4 I 64 The philosophicel NRR NMS$ App 3 pg positten as stated by Region IV (that 26 5f although a procedure required blade inspections, it did riot require 1 documentation of such ispections) requires ;
..reful consideration, i l
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i CPRRG RECOMKENDATIONS General Programatic Actions 3D RICOMMENDATION ORGANIZATIONS
- RETIRENCES 65 Contid6 ration should NRR NM$$ RES App B pg TY be given to the TRT 16 position that 5P "permanent" records removed from storage CH for use or revision revert to an "in process' status, which do not require application of the ,
t'ull AN$! N45.2.9 provisions.
75 NAC Headquarters should improve its NRR App C pp 9 5f regional assessment fur'ction to require 4
core frequent and t1ee1y ?n depth '
ovaluations of the region's plant inspection performance and documentation practices.
57 Lack of formal CE NRR NM$$ App 8 pp App 8 pg 17 discretionary guidance 6 11 Recomendation l provided to #1.7.8 supervisors and i ransgement when dealing with non escalated
- enforcement. When dos ;
a non compliance became a violation? ,
Expand MC 0400 and !
0610 accordingly. Also see Sequence number i 68. .
1 58 Consideration should CE NRR NMs$ A:p 8 pg be given to amplifying 17 Rec # ,
MC 0400 and MC 0620 1.7.9 regarding how to
< develop and document I violations of 10 CFR -
- 50. Appendix 8 Criteria. Also see Seawence number 57. ,
1
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CPRRG RICOMMINDATIONS 1
. General Progra r.atic Actions !
\
3D MCOW.tNDATION ORMH12AT10H3 REFERENCES
]
07 No NRC guidance exists CE NRR NMS$ pg 3 23 7j on t8. time permitted a licenses to retrieve 3p n a document which is required to be retrievable.
22 Clarify esency & %R NMS$ pg 5-1 pg 3 25 suidence: Authority of . recomenda inspectors and tien #2 supervisors to disposition violations ,
! involving isolAthd r.atters having minor ,
safety significance and for which the licensee takes .
isnediatt, effective corrective action.
14 Clarify agency CE NRR NMS$ p p 5 1, pg 3 25 guidance: No recomeria C.finitive guidence tien #2 exists renarding the acceptability of multiple violatione for the saw underlying cause.
17 Clarify agency CE NRR pg 5 1, og 3 25 5P :
guidance: The FSAR is rocceende i part of the tion #2 -
l application for en operating license and l
enforcement submitted i to NRR for review. The i role of the F$AR in the inspection process ,
for facilities under :
construction is unclear (It MC g 00).
t t I
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- _ _ _ _ _ _ _ _ _ . _ - _ _ _ _ , _ _ . , _ . - _ _ _ _ _ _ , _ _ _ _ _ _ _ . . _ _ . , _ _ _ _ _ _ . , _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ . _ _ . m._,,,____,_.____,__
CPARG RICOMINDATIONS l Date Manage. tent Improvemnts RIComtNDATION ORGAhuAT10N5 REFERENCES 3D 1
54 Develop a more comprehensive, unified NRR clRM p g 5 1- pp 3 28 32, recomenda App C pp 3, N '
166 System that meets tien #4 App D pg 12 current egency needs. and gg Vll!
Consider the monitoring of site specific 'nspection programs, periodic reg'onal monitoring of ,
inspection program status, and He overview, Possibly ,
then do Sequis 76 and 77.
i App D pg App D sg V!!!
78 Estabitsh inspection NRR 0!RM 1-2 Rec. I Rec. #2 and enfercoment data 2 quality assurance policies and
, procedures as well as a training program to help assure a ,
consistent, reliable, and timely agency data source. This could be accc2plished after ,
Sequence number 54.
App D pg App D pg VI!!
- 77 Consider cellecting NRR OIRM
!*2 Rec. f Rec. 83 l
! a11 inspection and 3 !
4 enforcement staff resource data in RITS. ;
tvaluate the benefits of collecting
. inspection information -
by sALP functional
, area rather by inspection module.
l This could be '
l accomplished after Sequence number 54. ;
l lI l
I
. Enclosure 2 IMPLICATIONS POR 07!1ER REGION IV TACILIT)f 5 hith respect to the issue of whether Region IV failed to conduci required settvities for comtnche Peak, the principal focus of O!A's investigation was on the inspection of the utility's Quality Assurance Prcgram, mainly at the company's headquarters, pursuant to IE blanual Chapter 2512. (O!A Seport at 37-46) The CPRRO, however, expanded this scope and examined the natter from the broader perspective of all required inspection activities called for by the current lfEC inspection program.
The CPRRO cencluded that *. . . broader impilcations for other facf!jtfes in :
Region IV cannot be ruled out and are !!hely to exist.' Nowever, while no l specific recommendations are made, a number of observations stated by the CPARO do provide useful gujdance. For examp!9, the CPRRO stated that t . . . te the extent that !!mited resources were a factor !
l st Comanche Peak (in terms of defletencies in Merion IV !
i OA inspection activities), some evidence crists that this
- factor may have affected other plants. Construction
- programs at 11sterford, Comanche Peak, South Texas, lfolf Creek, and R!ve? Eend were all under way at the same time. This fact could have aggravated the situation, particularly since Region IV has a relatively l small staff. Testtruny in the record indicates that inspection settvities at Comanche Peak and t'aterford ,
were adversely affected as a result of limited regional ;
resources. :
4 I Further, sorae of the factors that ap;parently lead to the difficultles at Comanche Peak, and ultimately to the OIA :
investigation, appear to be rather fundamental in nature and may not ba "mited to one site. In this regard, it is j not at r.!! clear that for Comanche Peak there wac an i established and understood ph!!osophy for the conduct of I the inspection prcCrams a commonality of purpose en the l part of both inspectors and canagements and good i communications and interchenge in the development and i disposition!ng of inspection findings. . . .
l Ilowever, there are factors apparent free the CPRRG revtew that tend to make it difccult to gauge or assess , r l the significance of such implications. The heart of the ,
j Comanche Peak conflict seems to be a dispute bettveen an I i inspector and hfa manesement. This dispute rcOceted
- I l differences in inspection emphants, enforcement policy. (
and the role of the inspector in the inspection and i AdditionaJ1y, despite much 1 enforcement program. . . . [
t controversy over the issues reflecting this dispute, the :
record does not e st6b!!sh that any unsafe ecndition i
exfr.ts at Comanche Peak. In feet, none of the 34 issues 1 i
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. ~.. _ _ _ __ _ ____ __-.____ _ __ _ _ _ _ _ _ _ _ _ __. _ _ . . _ _
1 l raised by the inspectors and included in the CIA report .
have direct safety significarace, yurther, the record I conta!ns cons!derable testimony that, for the most part, the Comanche Peak activities were being pursued by ,
individuals attempting to properly distharge thedt ,
i responsib!!!tles as they understood them. These findings i suggest that the controversy la this case involves a ,
lletted number of individuals and a limited number of !
I issues. (CPRRO Report at 8 3-4.)
i The language quoted above is presented to provide a perspect!ve on the i
appropriate breadth of settons nectssary to assess whether the situation as i 1 ft ex sted in regard to Comanche yeak, existed with respect to other l facilftfes within Region IV. It is also necessary, however, to understand the t evolution of the NRC's inspection program over the years in order to assess the significance of any gaps that might exist. In fact, the findings of both .
the CIA and CFRRO Reports with respect to the NRC's inspection program !
are. in a general sense, consistent with the Commission's own f!ndings. ,
prasented in "A Repert to Conpess. Improving Quality and the Assurance of i Quality in the Dest ps and Construction of Nuclear Power Plants.
- i
) NUREO-1085. May 1984.- Through the late-1970's, the inspection program i 1 was fundamentally oriented towards a review of a Ifeensse's written quality l I as surance propam and propam documentation with little em on :
I observation of work and inspection of hardware. The program, phacts uhtch has :
always been based on inspections / audits of on?y a fraetton of all such '
activities, be they construction-related or operatten related, exceeded '
manpgwer resottees. Such manpower constraints have been magnified from '
time to time and from Region to Region because of specine Regional j asnpower shortfa!!s and/or because of pecu!!arly heavy inspection demande :
resulting from the number of facilities within a Region requiring like, t manpower-intensive efforts in the same timeframe. In the ll80's, the focus j of the prc,pam was reviced somewhat to put increased emphasis on the l
! inspection and observation of work and less on records review, and to better ,
- accommodate resource limitations. At each stage of the evolution of the i 1 inspection program, the II Manual end its inspection modules, which !
i provides guidance to Nnc inspectors, have been changed to ectrespond to !
I the then-current inspection philosophy. It should aslao be recognised that :
I af teral completion of each inspection module is not req uired. Rather, as the ,
I ve constderation to the II &feaual makes inspection requirements clear, anof insgector is obligated each module to (due to facility-apeelfle whfeh, j
! considerations, may result in any given module not being ' completed".
l ffereover as a practical matter, comp etion of all modules has Cenerally nct
- been achieved ece ,
j 80-HL to 90-300%. pletion of the inspection The foregoing background program has rangedatfrom is discucted about
!cngth in (
Appendix D to the above-r.1entioned Report to Concross. [
! Also rekvent to the question of broader implicetions is the implementation of augmented !!MC inspection and audit activitics (such as CATS. PATS. ID!s and the like) at many sites ss well as the implementation of a variety of independent and utility-cenducted design, construetton and quality assurance ,
i verification programs prior to the lleersaing of all recent plants. While both i
l i
3 of these efforts have tended to focus on selected areas of a faci]!ty, they have taken into cons 4deration appUcable QA/QC requirements and have been sufficently broad in scope, in terms of the spectrum of structures, systems and components of a plant under scrutiny, to provide a welj-rounded retrospective picture of the adequacy and effectiveness of the respective QA program. Both the O!A r.ud CPRRG Reports acknowledge the contributlen of suchthe in efforts, NRC in the case of Comanche Peak, to cempensate for possible gaps routine inspection The existence undertakings elsewhere, therefore. process.Is of significanceofinsim!!ar deciding whether measures are warranted to determine whether such gaps in the inspection program as were found at Comanche Peak are of concern at other facilities.
In light of the impliestions foregoing, the CPRR O's conclusion regarding* broader is addressed. As noted by the CPnRO. a number of facilftfes in Region IV ucre under construction in generally the same timeframe. Thus, on the one hand. Ilmitations on Regfun IV resources logicaJly could have had an effect on inspectkn efforts reisted to all of them. On the other hand, the Region was fully budgeted for these activitles and a variety of special
?.: ? au msMed inshetton and audit setivities were condqcted at reveral of these Iacilities whlch provide confidence that any gap Tin the Region !Y program would not likely have resulted in the failure to detect defletencies with safety signifleance.
For instance as at Comanche peak, extensive staff technical audits were undertahen at the Waterford. South Texas. Wolf Creek and River Band facilities in cennection with the steff's operating license revien. These settvities included dets!!sd reviews of the app!! cants' site records on selected (but widely variod) !ssues and team inspections on selected important safety systems. As pr.rt of these efforts, emphasis was QA programs related to the matters under review.placed on implernentation of Einflar'y, yort St. Vrain has been subjected to detailed scrutiny in connection with facters surrounding the extended plant shutdown compliance with the Commission's environmental qualification rectufrements and thG staff's review of the Chernoby! implications. Although these reviews focused prinefprJ1y on hardware and systems design, related QA elements were lmpiteltly conaldered in the licensee's overall faiprovement profram. In addition. Recton IV conducted an augmented inspection of the !!censee's quality programs as a result of a SALP category a finding.
The Cooper, yurt Cs!houn end Arkansas !!uclear One faellities have been in operation for many years, indeed prlor to the development of the N!!C's increased en,phasis on construction in6pect!on setivit!ss and were not subjected to such deta!!ad audits and inspections. Nonetheless, because their periods of construction preceded by some years some ut the evolutionary changes in the inspection process, the uncertainty as to the proper inspection ph!!osophy fa likely less than was found to exist in later !
years when recre changes occurred. yurtherrnore, e,'though the staff did not
! perform any speefal or augmented audits or inspectione ut these plants, their onc cperational histories etrongly surgest th61 tips that rnight be found are ,
of little rnornent in terms of safety.
I
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4 As noted above, the CPRRG also observed that the conf!!ct re garding Comanche Peak appearc to have at its heart "a dispute between an inspector and his management." This factor, unquantifiable though it may be, could tend to 11mit the potential for far-reaching trop!! cations: we are not aware of sim!)st disputes of such broad scope that have arisen in connection with any other facility in Region IV. Moreover, the CPRRO's found that in general, Region IV's disposition of each of the 34 items at issue in regard to Comanche Peak was appropricte and that none of these issues was of direct safety significance. The CPRRG Report gives no reason to suspect that such disputes as mfght have existed in connection with other facilities were
, not also appropriately dispositfoned or that is sues of direct safety significance are likely to have been discarded or ignored because of process-related conflicts.
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/ \ UNITED 57ATES NUCLEAR REGULATORY COMMISSION W A SHING T ON, D. C, 20$55 g/
g s 4/7 August 25, 1987 MEMORANDUM FOR: Victor Stello, Jr.
Executive Director for Operations FROM: James G. Keppler, Director '
Office of Spec 1 1 Projects
SUBJECT:
CPRRG REC 0KMENDATIONS In response to the Chainnan's May 12, 1987 memorandum, we have reviewed all of your Category I recommendations and related aspects of the Comanche /eak Report Review Group (CPRRG) recomendations as specified in your April 14, 1987 memorandum to the Chairtaan. Enclosure 1 to your memorandum identified 45 recomended actions specifically related to the licensing and inspect. ion activities for the Comanche Peak Steam Electric Station. We agree that these actions are appropriate and sufficient to resolve the 34 issues raised in the OIA Report 86-10. Moreover, we believe that these actions are straightforward and can be accomplished by the Comanche Peak Project Division separately from the Category 2 and 3 programatic recomendations assigned to NRR and ARM.
We have also reviewed the CPRRG report, as required by item 2 of the Chainnan's memorandum, and conclude that there are no additional actions or lessons-learned beyond those identified in your Apri' 14, 1987 memorandum. However, we will continually r:fer to the report to ensure tl.at the intent of the recomendations is being fulfilied and to reflect on this question.
Many of tne assignm'ents evolving from the CPRRG recomendations are closely related to other review and inspection activities being conducted by the Comanche Peak Project Division. We believe it would be impractical and inefficient to attempt to resolve the CPRRG recomendations separate from ,
thest other activities. Rather, we intend _lo_ incorporate the CPERG-recocmendadons into_ eur related ighnical review and inspection _actly.ities and ivill report _ their resol _ution separat.e_1y_. prior to licens_ina l
a l 9 Jam,e g
a N wDirector s G. Keppler, ~
Office of Special Projects cc: J. Taylor T. Reta t T. Murley W. Mcdonald !'
R. Martin C. Grimes !
e r -
)f
. . Document Name:
NEN0 STELL0/KEPPLER Requestor's ID:
SHERRY i j[A Author'.sName:
CIGrimes Document C e nts:
CPRRG recommendations
']
e a
k