ML20205Q809
| ML20205Q809 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak, 05000000 |
| Issue date: | 06/05/1984 |
| From: | Ippolito T, Wessman R NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM) |
| To: | |
| Shared Package | |
| ML20204J134 | List: |
| References | |
| FOIA-85-59 NUDOCS 8606030319 | |
| Download: ML20205Q809 (67) | |
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APPENDIX B 4
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TECHNICAL REVIEW TEAM GUIDANCE
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Vr-ri Prepared By: T.4.1 4/g/gg, j
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1 TECHNICAL REVIEW TEAM GUIDANCE 9
I.
Introduction Actions,*was approved by R. DeYoung, H. Denten, a June 5, 1984 (TRT) has been formed to evaluate and resolve technical allegations presently identified.
The TRT organizational structure and schedule for their activities are as shown in the " Plan" (Copies of these charts are included with this guidance as Attachments 1 and 2).
The TRT will be broken into five technical groups, correspending
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to the five technical issue groupings.
These groups are: QA/QC, The grcups will be comprised of a group leader and specialists in the particular technical area. 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.
may be called together for a specified period of time, dispersed back The TRT in part as needed to complete resolution of like issues.to i
be under the direct supervision of the Project Director.
The TRT will The guidance centained herein will address the following:
Method and approach for identitication and dispositien of allegations Preparation of Documentation and Records Allegations Tracking System Protection of Individuals Initiation of Special NRC actions, such as confirmation of action letters or 50.54(f) letters Manpower accounting for TRT members II.
-Technical Review Team Method and Accreach The Technical Review Team method and approach to resolution and clo technical issues and alle to Technical Review Team"gations is described in the detailed " Instructions which is provided as Attachment 3.
The TRT will allegaticns that are assigned to the TRT.be mostly concerned expected to understand and implement these instructions.Each member of the When possible, the team activities will be planned so that at least partial credit can be taken for closecut of items in non-allegation areas.
For example, in resolving and closing out a specific all This j
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be possible to also close or partially close an open issue that falls under
, it may a separate (but related) category; such as, IES closecut, room turnover inspection, routine precperational program inspection module, etc.
this mode of operation will contribute to the complet Whfic to complete the routine inspection prcgram will be significantly reduced 1
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III. Occumentation and Records An individual record file (wcrk package) shall be daveloped and maintained for each open issue or group of like issues.
by Region IV and will be maintained and used by the TRT.The files have been Each file will contain cu reference pertinent documentation associated with the cpen issue.
Resolution of each issue shall be supported with a clearly auditable record trail.
to all significant records relied upon to reach resolution.Acco Records of personnel interviews shall be developed and retained in those instances where interviews are relied upon by the NRC staff fer decisions of technical adequacy.
Interview records shall, as a minimum contain:
the date, time, location of the interview; the name of the
, interviewer and interviewee; and a sumary of questions asked and relevant information obtained.
Upon issuance of reports (such a SSER's or Inspection Reports) whicn 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 project management.
They must be self-explanatory. Files must be maintair.ed in a ca Upon ecmpletion of the TRT effert, the files will be transferred to the appropriate line office for retantien (e.g., allegations files will be transferred to Regicn IV allegation files)
IV. Trackinc Scheme All Comanche Peak allegations are to be identified and listed on-allega sumary tracking sheets, as shewn in Attachment 4 Although the TRT is primari'y concerned with allegations, it may resolve other cpen technical issues, which are summarized on tracking sheets shewn as Attachment 5.
Open issues may ccme frem (but are not necessarily limited to) the areas:
allegations hearing items licensing items inspection modules that are intemplete SER folicwup itemsinspection ocen items (ncn-ccepliances, unresolved ite Part 21 or 50.55(e) items investigative issues A fundamental part of the listing development is the estimate of similar items. resources required and the schedule for completion of each grcup of The all'egations tracking system will be maintained on the 5520 word processer.
the Project Director's staff. Status of individual allegations will be updated b 3
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.1 To provide unifomity in tracking and ease in accounting, numbering and discipline codes are assigned to each items as follows:
XQY - Z
' Corresponds to the Task Code (Allegations, Hearing issues, etc.)
X Q
Identifies those particular issues that are QA/QC related, irregardless of the discipline.
Y Corresponds to a Discipline Code (Welding, electrical, etc.)
Z Corresponds to a sequential number.
The sequence of numbering starts over with 1 for each new discipline code. provides the table of task and discipline codes.
V, Protection of Individuals The identity of persons providing allegations to the NRC shal'1 not be disclosed as expressly req.a matter of practice.. In addition, for,those individuals uesting confidentiality, all efforts shall be made to protect the individual's identity.
Confidentiality recuests that seek an anonymous relationship with segments of the NRC will also be 1
considered. This will include:
limited and controlled distribution of allegation documentation and correspcndence; minimal use of names, identifying titles, or position descriptiens in written material; enlarged sampling of activities so that is 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 allegaticns. 'During the course of NRC reyiews or inspection, similar efforts shall be made to protect the identity of licensee or being critical of licensee or' contractor activities. contractor emp All interviews of allegers will be conducted by the TRT and/or OI, as appropriate.
Director) will coordinate alleger interviews involving TRT an personnel.
He will assure that technical issues are identified and passed to the TRT for resolution.
VI. Soecial NRC Actions As part of the allegation review effert, it may be appropriate to initiate actions vnich are not routinely required for technical issue followup. These may include: issuing requests for information to the licensee under 10 CFR 50.54(f), Confimation of Action letter or order; or requests to the Department of Justice to grant inr: unity for certain individuals.
Actions such as these, if required, shall be handled with
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the concurrence of the Project Director and in accordance with established NRC procedures.
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VII. Mancower Accountine j
Offices shall implement established manpcwer accounting systems to monitor resource expenditures related to this activity. The new ReguJatory Informatien Syste:n (RITS) will be used to track and account for all ruanpcwer expenditures, both technical and clerical, expended on the Comanche Peak TRT effort.
Special activity codes will be assigned to all task force members to ensure accurate accounting and meaningful l
management reporting.
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TECilNICAL REVIEW TEAlf (TRT)
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- 1. Gagliardo (IF) (Tentative)
R.C. Tang (NRR) l I
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Civil /Hechanical QA/QC Coatings Test Programs I"'
'"**"E*'I Leader Leader Lead r Leader I.eader P. Matt $iews T* Con!
J. Calvo (NRR)
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- Technical Issues
- Technical Issues
- Programmatic
. Technical Issues
- Technical Issues.
l and Generic
- Allegations
- Allegations technical issues
- Allegations
- Allegations and allegations
- QA/QC Related
- QA/QC Related
- QA/QC Related to
- QA/QC Related to to E. IEC to Civil /tfech
- Integrate QA/QC Coatings Test Programs from other Groups
- Interface with other groups,on QA/QC S
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4 INSTRUCTIONS TO TECHNICAL REVIEW TEAM The following*ihr. ions are to be used by the Technical Review Team in the resolutio6tfwition of technical issues and allegations.
provide team guMirra and. sample document formats, as shcun in the Annexes to The instructions these instructixrrs.
A.
Each indiivAifivell team member shall ensure tnat he or she und following g:.msl guidelines:
1.
Pregtilam ac:proach/ method / rational to individual items.
2.
Recemf! milli pertinent discussiens or interviews.
3.
Weipre hented evidence over oral representations.
4 Seek tdre gneric implications of each item; censider implications of narrage ent performance.
5.
Be r. ram:nve to perhutations/ ancillary issues..
6.
Sia: um aTJegatiens to put into perspective; address merit indiiv.%ramilly, collectively, and in conjunction with others' input, SALS,, p e.fcus reviews, IDVP, LERs, IE5s; fit all cieces together in mwiciensive picture.
7 Resumd g:nfessionally, nondefensively, nonagressively, and nes rmilTiy in dealing with licensee and contractor persennel or allegrs. Don't be defensive-minded:
De not prejud the rssue Ocn't criticize or talk dcwn to anyone. ge er prejudice 8.
Whem d$s=1ssing issues with allegers, approach frem alleger's perscWm; seek to understand.
honesty Assume alleger credibility, 9.
Assume w&re there is smoke, there is fira "attituce."
10.
Do me :msnnounce the item of concern to the licensee /centractors, wherene 3:nsible.
11.
Do son iimtify or cause the revealing of any source /date received.
DevcTaa/'rnecain records of all interviews which are relied uce tecintesii#anagerial adequacy decisiens. Maintain record protecticn.
12.
Prvtect mii3egers/persennel contacted. Use indirect accroach/ mixing to avoM fE:::using attentien on individual.
Honor confidentiality (wrere treraasted).
13.
Drrit mm:n-fal is not to be provided. to anybody cutside the NRC. -
l Dis:urdom with group leaders is encouraged.
14.
Proca eilli information; de not ;irerelease conclusions prior to mangememt review.
Do not discuss conclusions with licensee.
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15.
Assure all vour notes /t ecords/ drafts / materials collected will be s2fect to FOIA.
15 Me prempt notic,e to the Project Director of significant issues.
17.
- 25. progress receipt of a.new allegation should be reported to site c:::erdinator to get it into the system.
New alle t:rseted separately frcm the engoing allegations.gations will be (See Section I).
l'8.
Se visible. Wear NRC hard hats, etc.
13.
1r31viduals should maintain an orderly, mechanical and purposeful ac::xcach.
Their efforts shculd be ecmprehensive, timely, thorough, amd systematic.
- 20. Eaes it simple / understandable.
People with many different 3er:igrounds will need to understand what you have dene. -
21.
C::nsider a po,st effort critique.
Keep track of lessens learned.
22.
IJ11 riedia and " interested public" contacts will be directed to the Mfect Director or his assistant.
It is inappropriate to discuss the review of technical issues and allegattens with the media prior tmeir resolution and publishing of the SSER.
B.
Pre::are work package (s) and related infor nation.
sheet iis shewn in Annex 1.
A work package cover tn fchr=ify essentially identical allegatiens. Group leaders should review all The numbers of esrMaily identical allegatiens shculd be recorded in the work packace and documented in the allegation tracking system.
1.
!Fewrite (if necessary) general thrust of the allegation in ' plain english.
If necessary, discuss with alleger.
2.
Dezelop and document apprcach to resolution. A draft outline of am aopreach to resolution plan is attached as Annex 2.
3.
IcL-stify material that needs to be reviewed and documented.
4 Ethstify applicable regulatiens/ requirements.
5.
h ify the individuals who need to be interviewed.
6.
Ac=: sire pertineat records..Do not remove rec'erds ' rem site or region allegation files. Maxe siiglo copy of each record needed fcrr work package. Assure copias of appropriate reccrds are samitized te preserve confidentiality.
7.
Oms:ider generic / management implications.
8.
le.tify related inspecticn items er technical issues (nodules, cn oct tions thereef, folicwup items, nonccepliance, etc.) that c:rwid be completed in conjunction with resolution of allegations wart package.
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The approach to resolution will be reviewed and approved by the responsible 1
group leaders.
The grou's and group leaders will identify open issues other L
than allegations (IES followup, room turnover inspection, etc.) toward dich the allegation resolution effort and findings can be credited.
1.
Iden,tify manpower reeds by specialty (request help where needed).
2.
Develop estimated completion of each allegation.
3.
Group 1.eader shall specify individuals to do the work and approve the work package by signing the cover sheet.
D.
Conduct inspection in accordance with approach to resolution.
'I.
Document conversations that are used in resolution of technical issues or allegations.
In inspectin make signed statements (if possible)g allegations, have. individuals that' indicate what was said, who was there, where, date and time, and purpose of the interview.
These statements should be signed by all present. See Conversation Record form, attached as Annex 3.
2.
Obtain copies of key documents.
If important informat"on is only on a few pages of a larger document, obtain copies of these pages and mark the copies with the information that should lead back to i
the original document (s). This information should be filed with the work packages.
E.
Secup leaders shculd keep the Project Ofrector or his assistant informed cf significant developments.
Meetings for this purpose will be held daily; however, important developments should be reported pr:mptly.
F.
Saluate results of technical issue or allegation review.
G.
Prepare documentation to disposition the allegation.
The allegatien writeup femat is shown in Annex 4 In preparing the documentation, keep in mind the following guidance:
2.
Indicate that the allegatien is understood. Briefly, but fairly, restate the allegation.
If you discussed the allegation with the alleger, then say so.
2.
Respond to the allegation.
Is the alleger correct?
Is there some merit to the contention?
2.
Do not casually dismiss an allegatien.
Even if the alleger is "off the wall," scmeone may see some merit in the allegation.
4 4
Recognize and address (if possible) the underlying pretlem which you raise to the alleged problem; i.e., what m:nagement failure allowed 14,000 undersized bolts into.the Class I syst m? Also address the generic implications and what was do,ne to resolve them.
5.
If there is no safety significane, say why.
Remember, nonengineers will be reading and evaluating the analysis.
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Avoid the suggestien that a sample collected for review is a
" representative" sample (unless it is at least close to a
" statistically vslid" sample).
, sample, without characterization. Simply state tne size of the If ft appears that the problem was caused, even if in part, by a 7.
failure to properly implement QA or inadequate administrative /
management controls, then address this aspect.
An assessment of the overall QA program effectiveness will have to be addressed.
H.
Other open issues, such as, IEB closecut, followup to 50.55(e) reports, followup to previously identified inspection findings (violations, unresolved items, open items, etc.), and other open issues will be documented and closed out in an inspection report using the guidance of IE Manual Chapter 0610.
I.
New allegations may be received at any time, frem any source.' New allegations will.be treated as follows:
1.
Receipient shall report allegation to Project Director, via his Group Leader, and fill out allegation tracking forms.
2.
NRR will make beard notification, if a;;ropriate.
3.
TRT team member may be requested to provide technical j
assistance to 01 in taking statements from allegers.
4 Review alleger's stataments and identify additional technical issues.
5.
The Project Director's staff will enter technical issues into tracking system.
They will assign all technical issues to
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appropriate group in TRT.
6.
When required, a designated technical reviewer will prepare questions to applicant, based on technical issues.
7.
Obtain Project Otractor approval of proposed correscondence to applicant.
TheDirect:r,O(,willdispatenquestionstoapplicant.
8.
9.
The TRT will review the acplicant response and include it in an evaluation.
10.
Document results.
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Cemanche Peak A11ecation Work Packace 1
Allegation Number Numbers of Similar Allegatiens Statement of Allegation:
i Reference Dccuments:
Source of Allegation i
Date Received The above inf:rmation pre;;ared by _
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Ua:e A:signec Team Members vate Assignec Date Assignea l
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Annex 2 COMANCHE PEAX OPEN ISSUE ACTION PLAN Task: AQ-05,AQ-06,AQ-18,AQ-22 Ref. No.: 4-83-A-48, 4-83-A-81 Characterizations: QC inspector certification deficiencies. Past employment not verifiec.
Inspectors not pecperly certified. Answers to exams given.
Initial' Assessment of Sienificance: QC inspectors may have performed of the inspections questionable. inspections wn11e no properiy qualified or certifie Scurce: QA allegations; unknown allegation Acercach to Resolutions?
1.
Review centractors certification program against NRC requirements and ANSI N45.2.6 (73/78), Levels I, II, and III.
2.
Determine whether rec:rds reflect verification cf education and experience (past employment) - in writing (see Circular 50-22).
3.
Interview a sample cf previcus c:ntracter inspectors to detemine if exam answers were routinely given to exams (if possible).
4 See QC inspect:r list for particular ree:rds to b.e reviewed.
5.
Refer any examples of wrcngdoing to 0I.
6.
Evaluate allegations for generic / safety imelications.
7 Report en results of review / evaluation of allegations.
Related 0:en Issue Identification 1.
Using system code, pull related allegatiens, open items, previcus inspection findings, etc., frem the tracking system open item list.
2.
Review activities necessary to clcse or partially c1cse related items, either based en inspection cenducted above or reasonable aediti:nal inspection while the inspector is familiar with the areas.
3.
While per#cming physical inscections above, examine surrcunding system:, ccm:enents, and structures for any apparent defect er indicator of faulty worxmanship.
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If workmen are still in the area cf a physical inspection, interview them for any knowledge of other potential deficiencies.
Sta tus:
_ Review lead:
succore: 01 Estimated Resources: 5 man-days Estimated Ccmoletion: July 25, 1984
_ CLOSURE:
Reviewed by:
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Annex 3
_Cenversation Recory Allegation Number Time Date Type Visit Ccnference Tele;hene l
Incoming Outgoing Name of Person (s) Centacted or in Centact With You t
Organization i
Telephone Nu=ber
SUBJECT:
S'J'. MARY :
Name of Persen Occumenting Conversation Signature Date Name(s) of Other Persons Who Were Present During Cenversatica I have reviewed the sunnary cf the conversation wd belew anc agree that it accurately represents the conver:ation.th the individual (s) na l
Signature of Person Providing Information File: Allegation Werk Package ec: Prcject Directer Group Leader Additional pages may be attached as needed.
identified, signed, and dated, Additional pages sneuld be l
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e-1 Annex 4 Allecatio'n Writeue (SSER)
All allegatien reviews and closecut will be documented in supplements to th SER.
The SSER input will be submitted in the fo11cwing format.
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Allecation Greuo - Title of Werk Package 2.
Allegation numbers 3.
_Characterizatien - Statement of the allegation.
Plain English enaracterization of allegation.
Should be understandable to ncntechnical people.
If allegation clarified with alleger, then so state.,
A.
_ Assessment of safety sienificance - Include what was reviewed (sam s12e if appropria:p).
(Attach documentation of interviews.) Persons an~d titles o Summary of findings. Statement of' CA, or management centro,1s as apprcpriata. significance of 5.
_Cenclusien and staff ecsitten - State if the allegatien is substantiated in wncie or in part texplain if necessary).
If findings were ciscussed with alleger, so state.
5.
_ Actions Recuired - Is future action required?
inscec:1cn, ofr:,AR change?
Soecify. Additional 7.
Potential violatiens - Did this allegatien involve a violatien of NRC reguia:1cns?
If yes~, specify.
be included on an inspection report.Writeup shculd be specific enougn to by team management. Recommendatiens will be reviewed. Violation levels w 8.
Attachments - Attachments shculd be clearly identified.
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Reference documents
- 10. This statement prepared by:
Name Date Reviewed by:
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Accreved by:
Projec; Director Date 1
NOTE:
5520 for retention in the NRC staff files.This writeup will be p for publishing in the SSER.7-10 suppressed, will be printed en t I
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e TASK AND DISCIPLINE CODES I.
_ Task Codes i
A - Allegations B - IE Bulletins, Circulars, Information Notices C - CAT inspection findings 0 - Deficiency Reports 50.55(e), and Part 21 Reports
'G - Generic letter issuesE - Inspecticn findings, (violations, unresolved ite I
H - Hearing open issues I - Investigatien Reports issues L - SALP open issues M - Congressional or Ccamission concerns 0 - Operator Licensing open items P - Inspection Program Status
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Q - Final OA Reinspectics issues R - Recm/ System Turnover status (thos.e done, these to do)
S - SER open items T - Task force special inspection items U - Unfinished punchlist items V - IDVP cpen issues Z - Vender open items II.
Discioline Cedes 0 - 0A/0C (Genersi)
B - Bolts C - Concrete /Rebar E - Electrical W - Welding P - Pipe (Censtruction)
H - Hangers I - Intimidatien 0 - Ccatings T - Test Program 0 - Cesign of pipe M - Miscellanecus / pipe supports A - Independan: Assessment i
V - Vendor / Generic S - Instrumentatien R - Records N - NDE K - Cables / Terminations F - Fire Protection U - Procedures / Instructions Review.
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TECHNICAL REVIE'.4 TEAM GUIDAt;CE JUtlE 1984 9
Prepared By: Y4.~4u %
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a '9 5'4 R. H. Wessman Approved By: Y VIs<p< d J/ly'f4 T. A. f;toilta, Project Director
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' TECHNICAL REVIEW TEAM GUIDANCE I.
Intro *Jction The Comanche Teak Fiian for the Completion of Outstanding Regulatory Actions, was lopmwed by R. DeYoung, H. Denton, and J. Collins on June 5, 1984. Un accordance with the " Plan," a Technical Review Team (TRT) has been &nnred to evaluate and resolve technical issues and allegations pesenfiy identified.
The TRT organizational structure and schedule for Meiirr activities are as shown in the " Plan" (Copies of these charts are iimcluded with this guidance as Attachments 1 and 2).
The TRT will be 5ndan into five technical groups, correspending to the five te&Lil issue groupings.
These groups are: 0A/0C, Electrical /Isstrumemtation, Civil / Mechanical, Coatings, and Test Programs.
The groups willil he emprised of a group leader and reviewers that are specialists in the particular technical area.
The staffing of these groups will he drawn; from the various NRC offices and/or contractors, as arranged 'aetween the Project Director and line management.
The TRT may be called tWr for a specified period of time, dispersed back to the individilali!"s parent office, and then reconstituted in whole or in part as needed! ::s complete resolution of like issues.
The TRT will be under the d.iimr supervision of the Project Director.
The guidanc6 enm:2fmed herein will address the following:
Method Endt aumn:ach for identification and dispositicn of allagsrtums Preparati!cm caf Documentation and Records Allegatisns ilirJcking System Protectism of IIndividuals Initiatiur of S;:ecial NRC actions, such as confirmatiicm of action letters or 50.54(f) letters' Manpower acunwrting'for TRT members II. Technical Rerfem kn Method and ADoroach The Technicat Rewfew Team method and approach to resolutien and closecut of technical issies anci allegations is described in the detailed " Instructions to Technical Tests Team" which is provided as Attachment 3.
The TRT will be mostly corond with the resoluticn/closecut of approximately 3C0 allegations t.1a: ame assigned to the TRT.
Each member of the TRT is expected to :.nd' rstmd and implement these instructions.
e When possible,, the iaam activities will be planned so that at 1 cast partial credit can be tauam for closecut of items in non-allegation areas.
This approach shoui:d! rrsit in the most efficient use of inspection resources.
For example, 5m em7ving and closing out a specific allegation, it may be possible to s'i'so riose or partially close an open issue that falls under a separate (but teilsted) category; such as, IES closecut, room turnover inspection, rur"he greoperational program inspection module, etc.
While this mode of connatin will contribute to the ccmoletion of the routine inspection pr:gnm., it is not envisioned that Region IV's resource needs to complete tie rt:1:tfne inspection program will be significantly reduced.
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III. OcccantartmT and Records An inc5vichaT record file (work package) shall be develoced and maintained for eacht aren issue or gecup of like issues. The files have been develcped
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by Regfon I'll and will be maintained and used by the TRT.
Each file will i
contain on r.eierence pertinent documentation associated with the cpen 3
s issue. RessIfution of each issue shall be supported with a clearly auditable recort iradi Accordingly, the record file shall contain or make reference i
to als rgnificant records relied upon to reach resolution, j
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Recor:s;of :Tarsennel interviews shall be developed and retained in I
those irstauss wnere interviews are relied upon by the NRC staff for j
decisins: c# technical adecuacy.
Interview records shall, as a minimum t
i contah:: cre date, time, location of the interview; the name of the 1
intert ewerrand interviewee; and a sunmary of questions askGd and d
j releymt inWyrmation obtained.
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l Upon fsruancs of reports (such as SSER's or Inspection Reports) which j -
close aut:open issues, those records which are apcropriately referenced t
in t.k NRC recorts ard are traceable thrcugh scme other means 1
(e.g., meedhg transcripts, per anent applicant regards, etc.) cay be i
refrow2i fic:rn:he record file as approved by project management.
Files must te maintained in a careful form with attentien to detail.
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They.tst re self-exclanatory. Upen cocpletion of the TRT effort, tne i
i files wird tie transferred to the appropriate line office for retenticn i
j (e.g.,, alTepreions files will. be transferred to Regicn IV allegation files).
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IV. Trachc' Tc tema i
All Cuantne Feak allegatiens are to be identified and listed cn aUegaticns i
sumury/ traddng sheets, as shown in Attachment 4 Although the TPT is primarily_gerged_with allegations, it may resolve other open technical
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issues,,wnit:rt are summarized on tracking sheets shewn as Attachment 5.
i Open i'suess may ccee frem (but are not necessarily limited to) the fcilowing j
s i
areas.:
i allegati:ns hering; items 15:ensth; f tems 1
irsoec:dtnr modules that are incomplete i
i spetritnr open items (non-ccmpliances, unresolved items, etc.)
SR ftilbwup items i
Part 211 or 50.55(e) items j
isvestig:rt.1ve issues t
A fundamentaT part of the listing development is the estimate cf resources recuired and the schedule for completion of each group of simi?ar items.
i The allegatibns tracking system will be maintained on the 5520 word processerr.. S'tatus of individual allegations will be updated biweekly by I
the Frofect Director's staf f.
4
Fo) pmvide uniformity in tracking and ease in accounting, numbering and 4
i diircibline codes are assigned to each items as fellcws:
a X0VI - Z j
X(
Iorresponds to the Task Code (Allegations, Hearing issues, etc.)
Q.
Identifies those particular issues that are QA/QC related, i
frregardless of the discipline.
Y/
Corresponds to a Discipline Code (Welding, electrical, etc.)
2 Corresponds to a sequential number, The secuence of numbering starts over with 1 for each new discipline
- ntin. Attachment 6 provides the table of task and discipline codes, t
V.
htation of Individuals
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~2ie3 ihentity of persons providing-allegations to the NRC shall not be cii:nibsed as a matter of practice.
In addition, for those individuals e gnessly requesting confidentiality, all efforts shall be made to anctant the individual's identity. Confidentiality requests that seek l
am amnymous relationship with segments of the NRC will also be canssibered. This will include:
limited and controlled distribution 1
of Wiiegation documentation and correspondence; minimal use of names, trend.fying titles, or position descriptiens in written material; i
enibn7ed sampling of activities so that is is not evident to personnel J
outshe the NRC that the particular sample selection is related to the dil'ecar; and other indirect approaches toward investigation / inspection
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of MiTegations. During the course of NRC reviews or inspection, s:iisiiihr efforts shall be made to protect the identity of licensee or i
cantmctor. employees who provide information which may be construed as j
being critical of licensee or centractor activities.
Alm interviews of allegers will be conducted by the TRT and/or OI, as 3
aucn uriate. The Technical Reviewer (reporting directly to the Project i
Dihe:ror) will coordinate alleger interviews involving TRT and OI pens 12nnel. He will assure that technical issues are identified and par:ad to the TRT for resolution.
1 VI. Shedirl NRC Actions j
- s; art of the allegation review effort, it may be appropriate to I
ihLite actions which are not routinely required for technical issue 1
Niii'cwap. These may include:
issuing requests for.information to the
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liitansee under 10 CFR 50.54(f), Confirmation of Action letter or order; i
on'nenuests to the Department of Justice to grant imunity for certain
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indMduals. Actions such as these, if required, shall be handled with i
the concurrence of the Project Director and in accordance with establishec i
NRC ;;mcedures.
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THE. Mancower Accountino i'
Offices shall implement established manpcwer accounting systems to monitor rescurce expenditures related to this activity.
The new Regulatory Information System (RITS) will be used to track and account for all manpower expenditures, both technical and clerical, expended on the Comanche Peak TRT effort. Special activity codes will be assigned to all task force members to ensure accurate accounting and meaningful nanagement reporting..
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On W' TECllNICAL REVIEW TEAM (TRT)
Project Manager T.A. Ippolito As(sgEOD) 01 Interface stant R. Wessman (NRR)
.I. Gagliardo (IE)' (Tentative)
R.C. Tang (NRR) k.
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b, Test $tograms
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Civil / Mechanical QA/QC Coatings Instmmen,tation Leader Leader Leader Leo.dcr
, Leader P. Matthews J. Calvo (NRR)
L. Shao (RES)
T, ConloDift R. Keigfg (RI) 3(g)_
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L _ __ ___ _ __ _ _i- __ _ __ _ __. _J L_ __ __ _ __ _.L
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- Technical. Issues
- Technical Issues
- Programmatic
- Technical Issues
- Technical Issues and Generic
- Allegations
- Allegations technical issues
- Allegations
- Allegcions and allegations
- QA/QC Related
- QA/QC Related
- QA/QC Related to
- QA/QC Related to l
to E, I6C to Civil / Mech
- Integrate QA/QC Coatings Test frog. rams from other Groups
- Interface with 4
other groups on QA/QC y't D.
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INSTRUCTIONS TO TECHNICAL REVIEW TEAM The following instructions are to be used by the Technical Review Team in the resolution / disposition of technical issues and allegations.
The instructions provide team guidance and sample document formats, as shcwn in the Annexes to these instructions.
A.
Each individual team member shall ensure that he or she understands the following general guidelines:
1.
Preolan approach / method / rational to individual items.
2.
Record all pertinent discussions or interviews.
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3.
Weight documented evidence over oral representations.
4 Seek the ceneric imolications of each item; consider implications of management performance.
5.
Be attentive to permutations / ancillary issues.
6.
Size up allegations to put into perspective; address merit individually, collectively, and in conjuncticn with others' input, SALP, previous reviews, IDVP, LERs, IEBs; fit all pieces together in comprehensive picture.
7 Respond professionally, nondefensively, nonagressively, and neutrally in dealing with licensee and contractor personnel or allegers.
Don't be defensive-minded:
Do. not prejudge or prejudice the issue.
Don't criticize or talk down to anyone.
8.
When discussing issues with allegers, approach frcm alleger's perspective; seek to understand. Assume alleger credibility, honesty.
9.
Assume where there is smoke, there is fire " attitude."
10.
Do not preannounce the item of concern to the licensee / contractors, whenever possible.
- 11. Do not identify or cause the revealing of any source /date received.
Develop / retain records of all interviews which are relied upon for technical / managerial adequacy decisions. Maintain record protection.
12.
Protect allegers/ personnel contacted.
Use indirect approach / mixing to avoid focusing attention on individual. Honor confidentiality (where requested).
i 13.
Draft material is not to be provided to anybody outside the NRC.
Discussion with group leaders is encouraged.
14.
Protect all information; do not prerelease conclusions prior to management review.
Do not discuss conclusions.with licensee.
e n
- 15. Assume all your notes / records /draf ts/ materials collected will be subject to FOIA.
- 16. Make prompt notice to the Project Director of significant issues.
17.
In-progress receipt of a new allegation should be reported to site coordinator to get it into the system. New allegations will be treated separately from the ongoing allegations.
(See Section I).
- 18. Be visible. Wear NRC hard hats, etc.
19.
Individuals should maintain an orderly, mechanical and purposeful approach. Their efforts should be ccmprehensive, timely, thorough, and systematic.
- 20. Keep it simple / understandable.
People with many different backgrounds will need to understand what you have done.
- 21. Consider a post effort critique.
Keep track of lessons learned.
- 22. All media and " interested public" contacts will be directed to the Project Director or his assistant.
It is inappropriate to discuss the review of technical issues and allegations with the media prior their resolution and publishing of the SSER.
B.
Prepare work package (s) and related information. A work package cover sheet is shcwn in Annex 1.
Group leaders should review allegation file to identify essentially identical allegations.
The numbers of essentially identical allegations should be recorded in tne work package and documented in the allegation tracking system.
- 1. JcReWritej,(if necessary) feifera.lsthrust of the;3 egaticF[n7h,EaEE 11 t g dengush4 If necessary, discuss with alleger.
2.
Develop and dccument approach to resolution. A draft outline of an approach to resolution plan is attached as Annex 2.
3.
Identify material that needs to be reviewed and documented.
4 Identify applicable regulations / requirements.
5.
Identify the individuals who need to be interviewed.
6.
Acquire pertinent records. Do not remove records from site or region allegation files. Make single copy of each record needed for work package. Assure copies of appropriate records are sanitized to preserve confidentiality.
7.
Consider generic / management implications.
8.
Identify related inspection items or technical issues (modules, or portions thereof, follcwup items, noncompliance, etc.) that could be completed in conjunction with resolution of allegations work package.
C.
The approach to resolution will be reviewed and approved by the resconsible group leaders. The group and grcup leaders will identify open issues other than allegations (IES followup, room turnover inspection, etc.) tcward which the allegation resolution effort and findings can be credited.
1.
Identify manpower needs by specialty (recuest help where needed).
2.
Develop estimated ccmpletion of each allegation.
3.
Group Leader shall specify individuals to do the work and. approve the work package by signing the cover sheet.
D.
Conduct inspection in accordance with approach to resolution.
1.
Occument conversations that are used in resolution of technical issues or allegations.
In inspectin make signed statements (if possible)g allegations, have individuals that indicate what was said, who was there, where, date and time, and purpose of the interview.
These statements should be signed by all present.
See Conversation Record form, attached as Annex 3.
2.
Obtain copies of key documents.
If important information is only on a few pages of a larger document, obtain copies of those pages and mark the copies with the information that should lead back to the original document (s).
This information should be filed with the work packages.
E.
Group leaders should keep the Project Director or his assistant informed of significant develcpments. Meetings for this purpose will be held daily; hcwever, important developments should be reported promptly.
rL F.
Evaluate results of technical issue or allegation review.
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G.
Prepare documentation to disposition the allegation.
The allegation writeup format is shown in Annex 4 In preparing the documentation, keep in mind the following guidance:
1.
Indicate that the aPegation is understood.
Briefly, but fairly,
/#5Eate 1Fe~Diegat'ic#ii.
If you discussed the allegaticn with the 7
.4ci.al.lege rr then sayiso n
- 2. 66cFt'olth~e'~all(gation.WJdtbFill6gehfcct' rect?
Is-there-some g smerj.ig6;thelcgenycn?
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3.
Do not casually dismiss an allegation.
Even if the alleger is "off the wall," someone may see some merit in the allegation.
4.
Recognize andaddresg (if possible) the7dridiilying proble'm&hich yco raise to the alleged problem; i.e., what management failure allowed 14,000 undersized bolts into the Class I system? Also address the i
generic implications and what was done to resolve them.
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- 5. GI'f! hTri;iTiid Js'afety-.signjf.icane,Vsay why,q Remember, corangineersL will be reading and evaluating the analysis.
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6.
Avoid the suggestion that a sample collected for review is a
" representative" sample (unless it is at least close to a
" statistically valid" sample).
Simply state tne_ size of the
_ sample, without character 1zation.
7.
If it appears that the problem was caused, even if in part, by a j
failure to properly implement QA or inadequate administrative /
management controls, then address this aspect. An assessment of the overall QA program effectiveness will have to be addressed.
H.
Other open issues, such as, IEB closecut, followup to 50.55(e) reports, i
followup to previously identified inspection findings (viclations, i
unresolved items, open items, etc.), and other open issues will be documented and closed out in an inspection report using tne guidance of y
IE Manual Chapter 0610.
i 4
I.
New allegations may be received at any time, frem any scurce.
New allegations will be treated as follows:
4 1.
Receipient shall report allegation to Project Director, via his Group Leader, and fill out allegation tracking forms.
2.
NRR will make board notification, if appropriate.
l 3.
TRT team member may be requested to provide technical 1
assistance to OI in taking statements frca allegers.
1,
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Review alleger's statements and identify additional technical issues.
5.
The Prcject Director's staff will enter technical issues into tracking system. They kill assign all technical issues to appropriate group in TRT.
6.
When required, a designatcd technical reviewer will prepare questions to applicant, b& sed on technical issues.
7.
Obtain Project Director athroval of proposed correspondence to applicant.
8.
The Director, DL, will disoatch questions to applicant.
9.
The TRT will review the applicant response and_ include it l
in an evaluation.
- 10. Occument'results..
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Annex 1 Ccmanche Peak Allecation Work Packace Allegation Number Numbers of Similar Allegations Statement of Allegation:
Reference Occuments:
Scurce of Allegation Cate Received The above information prepared by Name Date Grcuo leader Name Date Assigned 4
Team Members Date Assigned 1
Date Assignec Date Assigned Date Assigned
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Annex 2
-- SAMPLE --
CCMANCHE PEAK CPEN ISSUE ACTION PLAN Task: A0-05, AQ-06, AQ-18, AQ-22 Ref. No.: 4-83-A 48, a-83-A-81 Cha racterizations : QC inspector certification deficiencies.
Past employment not verifiec.
Inspectors not prcperly certified. Answers to exams given.
Initial Assessment of Sicnificance: CC inspectors may have perfor ed inspecticns wnlie not properiy cualified or certified - makes the valicity of the inspections questionable.
Source: QA allegations; unkncwn allegation Acoroach to Resolutions:
1.
Review contractors certification program against NRC requirements and ANSI N45.2.6 (73/78), Levels I, II, and III.
2.
Determine whether records reflect verification of education and experience (past emoloyment) - in writing (see Circular 50-22).
3.
Interview a samole of previous contractor inspectors to determine if exam answers were reutinely given to exams (i# possible).
4 See QC inspector list for particular records to be reviewec.
5.
Refer any examples of wrongcoing to OI.
6.
Evaluate allegations for generic / safety implications.
7.
Report on results of review / evaluation of allegations.
Related Ocen Issue Identification 1.
Using system code, pull related allegations, open items, previous inspecticn finoings, etc., fren the tracking system open item list.
2.
Review activities necessary to close or partially close related items, either based on inspection conducted above or reasonable additicnal inspection while the inspector is familiar with the areas.
3.
While per ( ming :hysical inspections above, examine surrcuncing systems, umconents, and structures for any apparent defect or indicator of faulty workmanship, d.
If workmen are still in the area of a physical inspection, interview them for any knowledge of other potential deficiencies.
_S ta tus :
Review lead:
Succort: 0I Estimated Resources: 5 man-days Estimated Comoletion: July 25, 1984 CLOSURE:
Reviewed by:
siU Leacer
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4 Annex 3 Conversation Record Allegation Number Time Date i
Tppe Visit Conference Telephone Incoming Outgoing Name of Persen(s) Contacted or in Centact With You Organi:atien Telephone Numeer
SUBJECT:
SUMMARY
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i Name of Person Documenting Conversation Signature Date Name(s) of Other Persons Who Were Present During Conversaticn I have reviewed the summary of the conversution with the indivicual(s) named belcw and agree that it accurately represents the conversation.
Signature of Person Providing Information File: Allegation Work Package i
cc: Project Director i
Group Leader a
Additional-pages may be attached as needed. Additional pages should be 1
identified, signed, and dated.
4
Annex 4 Allecation Writeuo (SSER)
All allegation reviews and closecut will be documented in suoplements to the SER.
The SSER input will be subnitted in the folicwing format.
+
1.
Allecatien Grouc - Title of Work Package
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2.
Allegation numbers 3.
Characterizatien - Statenent of the allegatien.
Plain English cnaracterization of allegation. Should be understandable to nontechnical people.
If allegaticn clarified with alleger, then so state, a.
Assessment of safety sienifica,nce - Include wnat was reviewed (samole size if apprcorlate). Perscns and titles of individuals interviewed.
(Attach documentation of interviews.) Summary of findings.
Statement of significance of findings with regard to design, construction, operations, QA, or management controis as appropriate.
5.
Conclusion and staff oosition - State if the allecation is substantfated in wnoie or in cart texpiain if necessary).
If findings were discussed with alleger, so state.
5.
Actions Recuired - Is future action required? Specify. Acditicnal inspection, i5/FSAR change?
7 Potential Violations - Did this allegation involve a violation cf NRC regulations?
If yes, specify.
be included on an inspecticn report.Writeup should be specific encugh to Violation levels will be assiened by team managerent. Recoceerdations will be reviewed.
8.
Attachments - Attachments shculd be clearly identified.
9.
Reference documents
- 10. This statement prepared by:
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Name Date Reviewed by:
Group Leader Date Approved by:
Project Director Date NOTE:
This writeup will be prepared in the above format and typed on the IBM 5520 for retention in the KRC staff files.
The same material, with items 7-10 suppressed, will be :rinted on the IBM 5520 to provide pages ready for publishing in the SSER.
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CONTRoiiID COPY COMANOIE PEAK NtlCIIAR POWER PLANT i
3f.ATIM5 AND7DIFMI5Tir.ATTM5'511HMARY TASK CROSS Rif./OR COMPLEllDN ALLECTR-DATI RECE!VID SOURCE IRACrlhG CATEGORY l-1 SOff! NILE SOURCE ALLEGATION 04 CONCERN
_ ACTION / STATUS ANON CONFID BN/ DALE SYSTEM NO.
M OPEN COMM ETE DOCIMENT PAGE r
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TASK AND DISCIPLINE CODES I.
Tesk Cmes 3 - Siliigations 5 - EE Iulletins, Circulars, Information Notices I - G:7 inspection findincs 2 - Ieficiency Reports 50.55(e), and Part 21 Re; orts E - Ins:ection findings, (violations, unresolved items, and cpen i tems)
Ei - Giemric letter issues ii-heing open issues T - Enestigaticn Reports issues
'L - SPL? cpen issues 1
E -Imgressional or Comission concerns I - he ator Licensing open items F - DrsIection Program Status
!)- F5al 0A Reinspection issues 4
'E - hm::/ System Turnover status (those done, those to do) 5 - SER open items a - Yast force special inspection items I - Ulifinished puncnlist items Ti - GJR'open issues 2 - Wrmor open items II. ItWrilfne Ccdes T - 34QC (General)
E - SMid C - Cmcrete/Rebar E - E3actical
'il - %@ ting F - N (Constructica)
Hi - Himqers 5 - N.kidation
- 3) - Nings IT - Test Program T - hgn of pipe /pice succorts
'41 - MYsal1aneous j
U - 27tracendant Assessmen*.
T - Werfor/ Generic 5 - Eistrumentation Ri - Rkmrds 1.-lE E - Curi'es/Temina tions
? - FIST Protection
'JI Tharedures/ Instructions Review
Fifth Session - October 1-12, 1984 9/21/84 Project Manager
, Editors T. A. Ippolito, AE00 Staff W. Oliu Assistant R. l'essman, flP.R K. Brown J. Gagltardo, IE R. C. Tang, NRR 897-3167 x871 A. Vietti, flRR 897-4kE B&R 812 897-2201 B AR 81 2 897-2201 B&R 854 897-3166
- B&R 854 897-3166 x3216 1
Electrical /
Civil / Mechanical QA/QC leader Coatings leader Test Programs 1
Ins trumenta tion leader Leader Leader
- J. Calvo,llRR L. Shao, RES
- 11. Livermore, RIII P. Matthews,flRR
- R. Keimig, R-I l
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t u_.__._______1_,______,,
- A. Johnson - RIV Onsite J. Devers (1st week)
C. Hale RIV
- S..Kirslis NRR
- W. Smith RIV R. Hubbard (1st week)
V. Watson IllEL
- W. Wells Bill i
D. Jeng NRR D. Sumners IriEL
- B. Ilodgson Bill Secretaries S. Ilou NRR C. Morton LLNL f
FDM Secy C. Ilofmayer INEL
- d. Eli LLill Site Phones RIV Secy R. Philleo Parameter
- H. Liu RII Conmercial:
(817) 897-3167, 3166, 2201 IE Secy T. Langowski ETEC R. Vanderbeck IflEL R. Masterson Parameter P. Chan LLf4L Brown & Root:.(817) 897-4881, ext. 871 V. Ferrarini Parameter C. !!aughney Parameter 854, and 812 P. Chen ETEC T. Horkinger Parameter D. Hansen INEL R. Bonnenberg INEL-NRC Resident:
(817) 897-2P01 (Construction)
E. Thompson ETEC R. liarbron
..EL (817.'
1873 (Operations)
- C. Richards ETEC
'll. Mang iflEL
- D. Landers Parameter B Evans IfiEL Region IV J. Devers (2nd week)
V..Henczel IflEL R. Bangart D. Kelley R. Hubbard (2nd week)
-M. Bullock IfiEL D. Ilunnicutt C. Oberg 4
R. lie 1derick LLfil J. Cummins M. Skow.
J. Corbett, EG%G S. Phillips F. Warren, EG&G L.' Jones EG&G J. Melanson, Teledyne "Part time
p6 TEXAS UTILITIES GENERAT G C. IPAhT TXX-4367 E RTWAY TOWER
- 400 NORTH OLIVE STREET. L.B. et
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eslCMAEL D. SPE98CE November 21, 1984 Mr. Darrell G. Eisenhut Director, Division of Licensing U.S. Nuclear Regulatory Cem.ission Washington, D.C.
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Dear Mr. Eisenhut:
I i4 On Cctober 8,1984, Texas Utilities Electric Ccmpany (7UEC) submitted cur respcnse to the NRC-Technical Review Team initial transmittal of potential cpen items. Our response censisted of tva principal elements, the Ccmanche Peak Response Team (CPRT) Program Plan and issue-specific Acticn Plans.
Subsequent to cur meetings of October 19 and 23, during which TtE had the benefit of NRC Staff feedback and com.ents on our October 8 submittal, we have substantially revised cur Program Plan. Enclosed with this letter is Revisien l' to the Program Plan.
The revisions focus en enhancing three aspects of the plan. First, we have added two members to the Senior Review Team (SRT) frcm cutside *IUEC. We have also replaced all the issue Team Leaders with experts from outside TUEC. Our objective in filling these key, decision-making positions by experienced, nuclear industry experts is t'o eliminate any questiens regarding the credibility and cbjectivity of the program by providing fresh perspective.
Second, the Program Plan has been revised to include mere specificity regarding,the determination of root causes and potential generic implications.
The manner in ohich such deteminations shall be incorporated in the secpe and centent of Issue-Specific Action Plans has been clarified.
g' Third, the Pro pam Plan now centains guidance with respect to relevant i
infomation raised by or presented to the Ccmanche Peak Atcmic Safety and Licensing Board in the scope and centent of the specific Acticn Plans.
e We are currently revising Appendix A of the Program Plan (i.e., the issue specific Action Plans) to address the NRC staff ccrrr.ents provided to us at the recent meetings. The Issue-Specific Action Plans will be resubmitted under separate cover after our newly-assigned Review Team Leaders have inccrporated any appropriate.vvisions.
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1 TABLE OF CONTPiS I.
INTRODUCTION II.
PROGRAM PLAN OBJECTIVES III.
PROGRAM PL/d PRINCIPLES IV.
PROGRAM ORGANIZATION RfD FUNCTICNAL RESPCNSIBILITIES V.
PROGRAM PROCESS o
VI.
PROGRAM CCTPUTS VII.
PROGRAM QUALITY ASSCRANCE VIII.
PROGRAM RECORDS II.
SCHEDULE ACAC'sE.71: CPRT CRCANIZATION CHART AT ACHMINT 2: ACTIO2I PLAN FORMAT ATTAC M T 3: ACIICN PLAN RESULTS L70RT TORMAT AC ACEMENT 4: SCle'.ARY CF PRCGRAM 7ROCESS APPENDIX A:
ISSUE - SPECIFIC ACTION PLANS S
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COMANCHE PEAK RESPONSE TEAM P.LOGRAM PLAN Rev. Descriptien Prepared by Date Approved by Date Program Manager Senior Review Team o
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1 Page 1 of 17 Coeanche Paak Stenn Electric Statien Comanchs Peak Response Team Program Plan I.
INTRODUCTION The Nuclear Regulatory Commission (NRC) established a Technical Raview Team (TRT) to review certain aspects of the Comanche Peak Steam Elactric Station (CPSES). The purpose of the TRT is to evaluate certain technical issues and allegations of i= proper construction practices at CPSES. In l
July, 1984,.the TRT began onsite activities as par of its I
4 review plan using a team divided into five groups:
electrical /instrunentation, civil / mechanical, QA/QC, protective coatings, and test programs.
On September 18, 1984, a public meeting var held in the NRC's offices in Bethesda, Mtryland, at which NRC management and the TRT presented Ta'xas Utilities Electric Company (TUEC) with a request for additional information. This request vas based on the results of the TRT efforts to date in the electrical /
instrumentation, civil, and testing progyas areas. The TRT stated that they required additional information in order to make a determination of the safety significance of certain concerns.
The TRT request for information was documented in an attachment to an NRC letter dated September 18, 1984 The request was divided into three primary areas and several sub-areas, each representing a subject of concarn to the IET.
TUEC developed a Program Plan and individual Action Plans for each of the issues identified in the Septe ber 18, 1984, letter. The Program Plan and the Issue-Specific Action Plans were submitted to the NRC by letter dated October 8, 1984.
Subsequently, public meetings were held at the NRC's Bethesda, Maryland, offices en October 19 and 23 at which TURC =ade verbal presentations of the Progras ?lan and the Action Plans, obtained verbal NRC co==ents, and provided clarifications by ansvaring questions.
As a result of the meetings with the NHC, TUEC has revised the Program Plan and is in the process of revising the Issue-Specific Action Plans. These revisions reflect considerat'un of the NRC's comments and observations, clarifications needed to respond to questions that were i
raised, and experience gained during the initial stages of implementation of the original version of the Program Plan and the Action Plans.
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The overall Program Plan, as revised, is presented belev. The revised Issue-Specific Actica Plans will be provided in a future revisien to Appendix A.
Similar Issue-Specific Action Plans will be developed to respond to any additional TRT i.I issues identified to TUIC in the future.
'f II.
PROGRAM PLAN 03JEg m 3 TUEC continues to be committed to the safe, reliable, and efficient design, censtruction, and operatien of CPSES and
,.j vill cooperate fully with the NRC and its TRT to resolve the o
j identified issues. The Program Plan described in this document is intended to establish a framework for responding to the TRT's requests for additional infornation and to assist a
in dispositioning the associated issues. Where necessary, corrective action vill be taken. Appropriate action vill also be taken to preclude similar deficiencies frem occurring in the future. Therefore, the objectives of the Program Plan are to:
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Evaluate and respond to the issues raised by the TRT ph g
Identify the root cause and evaluate the generic b
b 'o implications of identified deficiencies l
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- p Evaluate the collective signift:ance of identified deficiencies C'
cv Define cecessary corrective actions for idettified daficiencies Define steps necessary to preclude si,4'ar occurrences in the future III.
To ensure that the ?rogras Plan objectives are met, the program was developed using the following principles:
A.
Thorouch Reviews The NRC's September 18, 1984, letter and its attach =ent identified specific requests for additional information and provided specific examples of potential deficienefes.
It is recognized that the specific examples identified by the NRC-TRT may be representative of an underlying concern. Accordingly, each of these issues will be thoroughly evaluated, even if a preliminary assessment of a
the specific examples indicates that they have no safety i
significance.
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9
a l-Revision:
1 Page 3 of 17 The NRC-TRT used sampling techniques in the perfor=ance of its reviews. T ar-a
--eas it vill be appropriate to M Vf**T M *4 M M h to explore the issues
~ identified by"the'NR GTRT'more thoroughly. This vill enable IDEC te obtain a more complete understanding of root causes, potential generic implications, and safery significance.cf any identified deficiencies and to achieve a higher degree of ccnfidence in the Program Plan results.
9 Some of the issues identified by the NRC-TRT are directly related to similar questions currently before the Coianche Peak Atomic Safety and Licensing Hearing Board (ASL3). For those' instances where TUEC is aware of additional infor=ation that has been presented to the Board (or matters raised directly by the Board) and that is directly relevant to an issue identified by the NRC-IRT, the Issue-Specific Action Plans will appropriately include consideration of such informatics.
B.
Root Cause Determinations Root causes will be determined for each issue identified by the NRC-TRT and for all valid deficiencies identified by the NRC-TRT or by TUEC. Such determinations will enable TUIC to identify potential generic i=plicatiens, to establish appropriate expanded scopes of reviev, and to define appropriate corrective actions.
In some cases, preliminary determinations of rcot causes can be made during the development of the Issue-Specific Action Plans and, where appropriate, reflected in an expanded scope of review in an Issue-Specific Action Plan. However, in most cases, the root causes of potential or actual deficiencies cannot be inmediately determined. The Issue-Specific Action Plans are being developed to include tasks that are intended to identify root causes of identified deficiencies. These tasks'are oriented both at specific testing of 1:1tial root cause hypothesis as well as more general exploratory efforts that will lead to new root cause hypothesis. The Actien Plans will previde a description of the iterative actions and alternatives used to identify root causes.
It is recognized that the determinatiens of root causes may result in a need for changes to the Issue-Specific Action Plans. The Action Plans will be structured to eliminate the need for unnecessary revisions. TUIC vill strive to identify the root causes conclusively as soon as possible for each Issue-Specific Action Plan.
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1 Page 4 of 17 C.
Generic Inplications Evaluations At such time as the root causes of identified deficiencies have been determined, an evaluation vill be performed to identify any associated potential generic implications. Such evaluatiens will enable TUEC to determine whether the deficiencies represent isolated occurrences, non-isolated or generic weaknesses within a particular area, or generic weaknesses that are programmatic in nature.
The results of such evaluations, in conjunction with an assessment of the safety-significance of the deficiencies and weaknesses, vill enable TUEC to define appr:priate
. expanded scopes of review and to identify appropriate corrective actions.
D.
Safety Significance Evaluations The safety-significance of identified deficiencies, both specific and generic /progranmatic, will be evaluated to facilitate the definition of the scope of appropriate expanded reviews and the definitien of appropriata corrective action.
E.
Collective Sienificance Evaluation The Collective Significance Evaluation vill focus on the integrated t= pact of the identified deficiencies, both specific and generic / programmatic, on the CPSES proj ect.
This evaluation vill be based primarily on the infor=ation developed through the root cause determinations, generic tmp11 cations evaluations, and safety significance evaluations. It will include a determination as to whether the existence of multiple.
apparently isolated and relatively minor deficiencies indicates a co=nen shortcoming in the progrz=s and procedures applicable to the CPSES project. It vill also identify " lessons learned" as they apply to future activities at CPSIS Units 1 and 2.
F.
Corrective Actions Appropriate corrective actions vill be defined and implemented to resolve all specific deficiencies identified by the NRC-TRT and by TUIC during the course of this review and evaluation program.
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In addition to corrective actions designed to. resolve specific deficiencies, actions will be identified to prevent the future occurrence of sisilar deficiencies at CPSES Units 1 and 2.
Such actions will be developed using the results of the evaluations of root causes, generic implications, and collective significance.
Accordingly, the focus of these corrective actions will be to resolve actual or potential weaknesses that are generic or programmatic in nature,
,i C.
Objectivit?
The Program Plan submitted to the NRC staff by TUEC on October 8, 1984, included a number of features that were intended to provide assurance regarding the-es;etti??Y}8 A M_' p g as.
Nonetheless, during subsequent public meetings with the NRC staff, it became apparent that it i
vould be necessary to incorporate additional features to i
further ensure the objectivity and credibility of the Program. Accordingly, additional progra=matic features have been implemented to ensure that the Program is cenducted in such a manner that its objectivity and credibility will be beyond question.
As described in Sect. ion 17, the CPRT Program Organization includes a substantial number of participants in key decision-making positions who are affiliated with organi:ations external to TUEC. 1XEEEEDhe six members cf the Senior Review Team and n -Me,
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p have not been previously involved with the CPSES activities that they will now be reviewing. The Review Team Leaders, subject to Senior Review Team review and approval, have the authority and responsibility to establish the scope and content of the Issue-Specific Actica Plans and to detersine how and by whom the Issue-Specific Action Plans will be implemented. The members of the SRT and the Review Team Leaders have access to all plant areas, docu=entation, calculations, files, and personnel as they deem necessar7 to meet the Program Objectives.
The Senior Review Team has established the following guidelines with respect to the objectivity in implementation of the Action Plans:
Analyses and calculations either will be performed-by an organization not previously responsible for the technical subject area for the CPSES project o_r, an engineering design verification of the -
analysis /calculatien will be perfor=ed by a third-party organization.
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- Majpeca.aons7 either vill be performed by quhlified
. inspeetors agaroraVGu3Ty"MuutFtrEwli#E) project and not currently affiliated with TUIC or its principal contractors for the C?SES project or,
- he inspections will be performed by qualified inspectors who were not personally involved in the inspection activities in question and an inspection validation program vill be conducted on a sampling basis by third-party inspection personnel.
Selection of personnel for inspection activities will be mutually agreed upon by the responsible Review Team Leader and t M 3Tana b ad m fog A
Records reviews and evaluations either vill be performed by third-party personnel g by CPSIS project personnel with,a third-party validation on a sampling basis.
Testing and NDE activities (other than preoperational testing) vill be conducted and test results will be certified by third-party personnel.
H.
Personnel Qualifications / Training Issue-Specific Action Plan i=pic=entation activities (such as analyses, inspections, records reviews, and testing) will be perforned by personnel selected by the Review Team Leaders on the basis of technical competence sud subject to the objectivity guidelines noted above.
(For Action Plan activities performed prior to the adoption of Revision 1 of the Program Plan, each Review Team Leader vill determine the acceptability of that work relative to the additional objectivity and other requirements contained in Revision 1.)
Where applicable, such perscunal Vill also receive training on the procedures to be utilized and vill be qualified / certified in accc: dance with the existing C?SES QA Program provisions.
I.
Sanoling Issue-Specific Action Plan implementation activitfas may include the uns of sampling techniques. The bases for using sampling and the sampling method vill be documented in each Issue-Specific Action Plan when sampling is used.
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In general the following guidelines will apply:
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Samples will be randomly selected fren populations or subpopulations of concern (e.g. of concern to j
safety) for the purpose of identifying the existence and/or the extent of potential deficiencies, ii MIL-STD 105D, or other appropriate procedures, will be used to determine sample size. Sanpling programs will be designed to include a li=1 ting quality of 5 percent with an acceptance probability of 0.05 (i.e.
at least 95% of the population is in confernance with the acceptance criteria at the 95 confidence f
lev el).
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Acceptance / rejection criteria vill be explicitly defined.
Mr. John Reed of Jack Benjamin & Associates will be used as a third-party engineering statistics consultant to provide an objective evaluation of the adequacy of the design of each sampling program and to ensure consistency in the interpretatien of results.
J.
Records and Ouality Assurance The Progrma Plan requires that the activities perfor.ed in accordance with each Action Plan be documented appropriately aleng with the results of the Action Plan.
The resulting records will be =aintained in auditaole form.
Action Plan activities that otherwise veuld be subject to the CPSES QA program shall be performed in accordance with the applicable portions of that program.
Utilizing the general principles presented above, revised Issue-Specific'Efte===h= -@ardev.aicped=4nnarset.MTfgestsa
-tEnsum+f 4 ivnmambr-senr==her 18, 1984, letter with consideration given to ecuments received at the October 18 and 23 meetings. These revised Action Plans will be providei as a a
revision to Appendix A of this document. Similar Issue-Specific Action Plans will be developed to respond to TRT questions in the mechanical. QA/QC, and protective coatings areas.when they are identified to TUEC.
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.Page 8 of 17 IV.
PROGRAM ORGANIZATION AND FUNCTIONAL RESPONSIBILITIES j
A.
Introduerion j
The organization established by TUIC to develop and i
implement this Program Plan has been designated as the Comanche Peak Response Team (CPRT). A chart depicting the organizational structure and principal members of the CPRT is presented as Attachment 1.
The personnel
'I assignments to this project reflect the i=portance that TUIC hac attributed to its successful conduct and completion.
3.
Team Members -- Roles and Reseensibilities 1.
Senior Review Team A Senior Review Team, consisting of senior TUCCO j
line managers and senior nuclear-industry
- i consultants, has been established with overall responsibility for the development, implementation, and management of the CPRT Progra=.
The Senior Review Team (SRT) for the CFRT Program consists of the following members:
Mr. Lou F. Fikar, Executive Vice-President, Engineering. TUCCO Mr. Billy R. Clements, Vice-President, Luclea'r Operations TUGC0 l
Mr. John W. Beck, Manager, Nuclear Licansing, TUCCO 1
Mr. John C. Guibert, Consultant; Manager, l
Nuclear Safety & Licensing, TERA Corporation Mr. Anthony R. Buhl, Consultant; President, Energx Corporation Mr. John L. French, Consultant; Vice-President, Delian Corporation The specific responsibilities of the Senior Reviev Team include the following:
Development of the CPRT Program Plan, and any subsequent revisions thereof Establishment of CPRT Program standards for personnel qualifications and objectivity m'
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-Page 9 of 17 Assign =ent of CPRT Program.Re'iew Team' Leaders v
Review and apptoval of Issue-Specific Action s-Plans, and any subsequent revisions thereof Ensuring that necessary resources are provided
)
to support the successful implementation of the CPRT Progrxs Ensuringthat"rootcause"and"geberic implications" evaluations are conducted as soon' as possible for each issue identdfied by the TRT Review and approval of " root cause" determinations and " generic implications" assessments, including evaluations of the adequacy of the Action Plans to address these-matters Monitoring the status of the implenestation of the Issue-Specific Action Plans Review and approval of the Issie-Specific
.g Action Plan Results Reports Review and approval of the Collective Significance Evaluation Report Advising the President of TUGC0 regarding the
__e adequacy and status of the i=ple=entation of the CPRT Program Mr. Pikar is chairman of the Sr. The SRT chairman m.
has assigned additional respcnsibilities to certain SRT members.
Mr. Beck will serve as the principal
^
interface with the NRC staff's TRT Program Director
^
for CPRT/TRT matters. Mr. Guibert will be responsible for the developnent of the Collective Signift:ance Evnluation Report.
2.
Senior Review Team Suroort Greue In order to assist the SRT in the execution of its kesponsibilities, an S r Support Croup has been estahiished. The functions of the SRT Sarport Group fill within the two general categories of project coordination and project administration and include
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the fo.l. lowing specific activities:
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. Assisting the Review Team Leaders in obtaining accAss to CPSES project personnel, project y
jocumentation, and project physical spaces
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1 Page 10 of 17 Providing necessary on-site clerical and administrative support to the SRT and to the Review Team Leaders Maintaining the CPRT Project Central File Developing programmatic procedures and guidelines at the request and for the approval of the SRT Assisting the SRT in monitoring the implementation schedules for the Issue-Specific Action Plans Other support functions as assigned by the SRT 3.
Review Team Leaders Review Team Leaders have been assigned to develop and manage the implementation of the Issue-Specific Action Plans within each of the six general areas evaluated by the NRC's TRT. Each of the Review Team Leaders is a member of an organization external to TUEC.
Revie'v "erm Leaders were selecte.d by the Senior Review Team using the following criteria:
Knowledge and experience in, quality assurance, nuclear safety, and the review area subject matter, as appropriate.
Managerial competence based on experience in managing technical projects and reviews Integrity of both the individuals and the organizations with which they are affiliated based upon their reputation and standing within the nuclear industry Objectivity of both the individuals and the organizations with which they are affiliated based upon their demonstrated capability and reputation for providing objective, dispassionate technical judgements on the basis of technical merit.
l Objectivity of both the individuals and the
.organizaticus with whieb they are affiliated based upon the lack of previous involvement in i
the CPSES project activities in. question
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I Page 11 of 17 The specific Review Team Leader assig=ments are as
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follows:
Mr. Howard A. Levin; Manager, Engineering TERIA Corporatien; Review Team Leader for the Civil, Structural, and Mechanical Areas Mr. John L. Hansel; Director Energy & Environmental Science Division Evaluation Research Corporation; Review Team Leader for the Quality Assurance / Quality Control Area Mr. Martin 3. Jones, Jr.; Private Consultant; Review Team Leader for the Electrical / Instrumentation Area Mr. E. P. Stroupe; Director, Technical Services Division. Technology for Energy Corporarion; Review Tern Leader for the Protective Coatings Area Mr. Monte J. Wise; President Wise & Associates; Review Team Leader for the Testing Prograss Area
.The specific responsibilities of the Review Team Leaders include the following:
i Serving as the principal interface with the NRC-TRT Leaders in their respective areas for the purpose of ensuring that additional clarifying infor=ation is i
obtained (where necessar7), for obtaining feedback on the adequacy of Action Plans within their area, and for ensuring that responses to NRC questions regarding implementation of Actida Plans within their area are provided Development of the Issue-Specific Action Plans within their area, and any subsequent revisions thereof, using the for=at and concent guidelines set forth in Attachment 2 Ensuring that personnel i=ple=enting the Action Plans (including personnel perfor=ing validatiens or design verifications described in Section III.0, above) within their area meet CP2T Program standards for personnel qualifications and objectivity Assignment of Issue Coordinators Identifying and obtaining necessary resources to implacent the Action Plans within their area Ensuring that the Action Plans within their area are being implemented appropriately Providing periodic status reports to the Senior Review Team on the i=plementation of the Issue-Specific Action Plans within thei area L
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Page 12 of 17 I
I Determining " root causes" and " generic implicatiens" l
of identified deficiencies within their area; i
ensuring that these deterninations are adequately
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addressed in the associated Action Plans cy; ensuring l
that the Action Plans are appropriately revised i
Identifying and defining corrective actions for any identified deficiencies within their area Identifying and defining necessary actions to j
preclude occurrence of similar deficiencies in the j
future Developing Issue-Specific Action Plan Results Reports, using the format and content guidelines set forth La Attachment 3 Maintaining a Project Working File for each Action Plan within their area r
Transferring Project Working Files to the Project Central File at such time that each Action Plan is I
completed (i.e.. Action Plan Results Report reviewed and approved by the Senior Review Team) 4 Issue Ccordinators In order to assist the Review Team Leaders in implacenting the Issue-Specific Action Plans within their area, they have been authorized to assign Issua Coordinators for each of.their specific Action Plans. Review Team Leaders also have the option of assigning themselves as Issue Coordinator for some or all of the Action Plans within their area.
The criteria for selection of Issue Coordinators is essentially the same as that for selection of Review Team Leaders. In cases where an Issue Coordinator has had sena degree of previous involvement in the CPSES project activities in question, specific provisions will be established in the Action Plan to ensure that the objectivity guidelines of Section III.G are net.
Issue Coordinators are responsible for assisting the Review Team Leaders in Issue-Specific activities as directed by the Review Team Leaders.
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1 Page 13 of 17 V.
PROGRAM PROCESS The overal: process for the development and i=ple=entation of this Program Plan and its associated individual Action Plcrs was presented, to a large extent, in the preceeding sections.
A summary of the key elements of the overall program process is presented in Attachment 4.
Additional information related to the process for developing Issue-Specific Action Plans is presented in Attachment 2.
While each Action Plan is unique, the program =atic guidelines set forth in Attachment 2 and the Action Plan review and approval process ensure that each Action Plan is developed and implemented in a manner that meets the Program Plan Objectives and the Program Plan Principles. Each Action Plan includes a description, where applicable, of the following:
scope and methodology identification of procedures and checklists participating personnel qualifications of pa'rticipating personnel training of participating personnel I
sampling plan l
rslevant standards applicable acceptance criteria, and applicable decision criteria.
Additional infor=ation related to the process for developing Issue-Specific Action Plan Results Reports is presented in l.
The programmatic guidelines set forth in Attach =ent 3 and the Results Report review and approval I
process ensure that the following subjects are adequately addressed where appropriate during the inple=entacion of the
}
Action Plan:-
identificati'on of root causes of identified deficiencies, an evaluation of the safety significance of any identified deficiencies.
a determination regarding potential generic i=plications and a description of how they were addressed, identification of necessary corrective actions to resolve identified deficiencies.
identification of necessary action to preclude recurrence in the future.
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Page 14 of 17 To the maximum extent possible, the scope of the Issue-Specific Action Plans will be based on a preliminary Issessment of the root cause and potential generic implications of the identified deficiencies. Action Plans will be sufficiently broad to identify and assess root causes, generic implications, and safety significance. Accordingly, most of the Issue-Specific Action Plans will utilize iterative or phased implementation approaches that include an initial phase which is exploratory in nature. Conclusive determinations of root causes and potential generic implications will be made as soon as possible. Deterninations with respect to the safety significance of identif1'ed or potential deficiencies will also be reached. The adequacy of the scope of the associated Issue-Specific Action Plans will be reassessed in light of these determinaticus. If an Action Plan is determined not to be sufficiently broad to meet program requirements, it will be appropriately revised and new Action Plans may be developed (if appropriate) to ensure that the potential generic implications of identified deficiencies are properly investigated and addressed.
VI.
PROGRAM OunnS The principal outputs of the CPRT Program vill be the m h itre The format and concert to be utilized in ene developce'nf'. these Reports is presented in Attach =ent 3.
Specific conclusicus will be reached regarding root cause, safety significance, and generic i=plications. Necessary corrective actions will be identified to resolve deficiencies, including any corrective actions necessary to preclude recurrence of similar deficiencias in the future.
An additional report documenting the results of the Collective Significance Evaluation will be developed. This report will, j
in large =easure, be based upon an integrated assessment of the Action Plan Rasults Raports. The principal focus'of this evaluatien will be to identify additional progra==atic
" lessons learned" which should be reflected in future project-related activities for both Comanche Peak Unit.1 and Cemanche Peak Unit 2.
f At the cenclusion of the CPET Program, a Final Report summarizing the results and conclusions of the Program will be submitted to the NRC. Interim status reports or briefings will be provided to the NRC staff as requested.
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PROGRAM QUALITY ASSURANCE Activities associated with the implementation of individual Action Plans _ vill be conduct ed *Em
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TIII.
7ROGRAM RECORDS In order to ersure that an auditable record'of the CPRT Program is avail'able, the documentation described belov vill be developed and maintained.
A.
Preject Central File The Project Central File vill be maintained by the SRT Support Group. At the completion of the CPRT Program, it will contain all project docu=entation, including the Project Working Files maintained by the Review Team Leaders during the conduct of the Program. During the conduct of the Program, the Project Central File vill contain the following material:
A copy of the Program Plan submitted to the NRC and any subsequent revisions thereof A copy of the individual Action Plans submitted to the NRC and any subsequent revisions thereof A ccpy of the individual Action Plan Results Reports l
A copy of the individual Action Plan Working File for all Action Plans which have been completed (i.e., Action Plan Results Reports reviewed and approved by the Senior Review Team).
B.
Profect Working Files Project Working Files vill be maintained by the Review Team Leaders for each Action Plan under their cognizance until such time as the Action Plaa has been completed.
At that time, the Project Working File for the completed Action Plan vill be transferred to the Project Central File. The specific caterial contained in each Project Working File vill vary, de.pending upon the nature of the i
associated Action Plan; where applicable, it vill contain, at a minimum, the following material:
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i Copies of letters, memoranda or reports documentin, the results of analysis performed as part of the Action Plan, including any associated documentation reisted to the evaluation of such results.
Copies of letters, memoranda, or reports documenting the results of testing performed as part of the Action Plan, including any associated documentation related to the evaluation of such results.
Copies of procedures or checklists used in the performance of testing.
Copies of letters, memorands, reports, drawings or other means of documenting the results of inspections perfor=ed as part of the Action Plan.
including any associated documentation related to the evaluation of such results.
Copies of procedures or checklists utilized in the perfor=ance of inspections.
Copies of letters, memoranda, or reports documenting the results of record reviews perfor=ed as part of the Action Plan, including any associated documentation related to the evaluation of such results.
Copies of procedures or checklists utilized in the performance of record reviews.
A record of personnel qualifications and a record of training for personnel participating in the implementation of the Action Plan.
II.
SC'dEDULE At the present time, it is impractical to accurately estimate the schedule for ce=pletion of the entire CPIT Program. This is pri=arily due to two ele =ents of uncertainty:
Severr.1 of the Action Plans utilize a phased approach for resolution, consequently the full scope of the necessary review effort cannot be determined until preliminary results beccme available; and The TRT questions in the areas of meenanical, QA/QC, anl f
protective coatings have not yet been provided to TUIC,3 q
consequently the nature of the Action Plan activities (
'g necessary to respond to these questions (and their j
associated schedule) cannot be determined until a later; j
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The Action Plans presented in Appendix A address, to the extent practicable at the present time, the current status and i
projected schedules for ccepletion of selected elenents of the individual Action Plans and, in a few cases, the schedule for completion of the entire Acticn Plan. As additional information becomes available regarding projected completion schedules for individual Action Plans and for the entire CPRT Program, it will be provided to the NRC staff.
TUEC is committed to a thorough and complete review of the safety-related issues identified by the TRT. A satisfactory resolution of these issues which potentially affect the safe operation of the Comanche Peak Units takes precedence over schedule concerns.
As the.'zplenentation of the CPET Progran proceeds and after the addi:1onal TET questions have been received and additional Action Plans have been developed to address then, ~2LcsYutandii?
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SUPPORT GROUP I.
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I ELECTRICAL 1 CIVIL # MECit PROTECTIVE COATING QA#QC TESTING PROGFAMS
,I INSTA. LE ADER LEADER LEADER LEA 0ER LEADER l
n M.S. JONES H. A. LEVIN E. P. STROUPE J. L. H A N S EL M. J. W l3 E b
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1 Page 1 of 3 ATTACIDEIT 2 ACTION P E FORMAT t
ITEM NUMBER (Short Titled 1.
Descriptien of Issue Identified by NRC
-Verbatim statement of the *IT issue as stated in :he l
enclosure to the NRC issue trmmitted latter
-Develop a separate Action Plan for eac'a numbere/. TH~ item 2.
Action Identified by NFC
-Verbatim statement of N2C - directed action an stated in the enclosure to the NRC issue transmitted letter 3.
Backg:cund
-Relzrant information which clarifies the 1suue definition
-Reina*2t information to provide additional perspective and understanding of the issue (including consideration of relevant information befcre the ASI.3)
-An explanatien (where applicable) of why *iUIC has decide.d to purnue the approach described under Sectio 2 1,.0 bolev, where alternative approaches were available
-If possible, a statement regarding the preliminary determination,of root cause and potential generic implicaticas of identified deficiencies 4
TEC Action Plan
-Scope and :!ethodology
-Describe appreach (phased, if applicable)
-tasks to be perfomed without conditions 1
-tasks to be performed under certain conditions (e.g.,
"If we find "x", then we vill take the following additional action...")
-tasks to be performed as part of an expanded review (where applicable and where this has already been decernined)
-describe how potential generic implications are being considered (where applicable and where this has already been determined)
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-Proce62re(s) to be used
-r:sference existing procedures
-describe any new or revised procedures
-Par:1,cipast's Roles and Responsibilities
-which organizations are involved I
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-scope for each organization
-ilentify lead individual
-Qualifications of Personnel
-state qualifications of personnel inplenenting the Action Plan
-reference these qualificatiens to existing requirements
-discuss training of personnel which will be monducted
-Sampling Plan
-if perforning a 100% review, state that a 100 review is being done
-if sampling is used, provide infernation relevant to the sanpling plan, and provide justificatien for the sample size
-Describe any other features of the sanpling plan (e.g. random sanpling of the universe, randon sampling of each discipline, etc.)
-Provide the definition of a "rej ect"
-Standards / Acceptance Criteria
-describe the standards (e.g., FSAR, *.III, Reg.
l Guides, etc.) against which you are ;.erforning the review
-Decision Cr1teria
-describe the criteria to te used for going to the
-next phase of a phased-approach review or for expanding the sample size for a review using sampling techniques t
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-Describe the criteria for closing out this item (this is related to the standards / acceptance criteria and the criteria for subsequent phases) 5.
Schedule / Status Describe schedule and current status, to the extent possible. Reference the schedule to the phases where appropriate. If a schedule for a phase cannot be provided until additional information is obtained, state that a schedule vill be developed at the completion of the previous phase.
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AT*AC3 MENT 3 4
ACTION PLAN RESULTS REPORT FOR%T d
IT2M NUMBER 2
(Short Title) 1.
Description of Issue Identified by NRC (same as Action Plan) 2.
Action Identified by NRC (same as Action Plan)
===3.
Background===
(same as Action Plan) 4.
TUIC Action Plan
-Scope and Methodology
-Same as Action Plan except:
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-where conditional phases were implemented, reword the 4
conditional statement so that it is clear that the phase had been implemented
-where a conditional phase was determined not to be necessary, state that it was not needed and provide a reference to a subsequent part of the report which j
justifies the declaien not to implement the conditional 1
phase
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-describe any other substantive changes to the Action Plan and why the changes were necessary 5.
Discussien of Results 4
-Compar1 son of results against standards / acceptance criteria i
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-Ccaparison of results against decision criteria
-Discussion of corrective actions for any identified deficiencies (e.g., any reinspections, rework, 1
reanalysis, etc.)
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6.
Conclusions i
-Identification of root cause of any deficiencies
-Evaluation of safety significance of identified deficiencies i
-Evaluation of generic implications
-where applicable, describe expanded scope of review to address them
-demonstrate linkage to the root cause
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whers applicable, describe basis for conclusion that no generic implications exist I
7.
Ongoing Activities I
-Describe any activities still'in progress i
-State whether these on-going activities,have safety significance Stato schedule for completing activities. State whether the work zust be complaced by fuel load, initial criticality, or power above 5%.
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8.
Action to Preclude Occurrence in the Future
-Training, Procedural changes, etc.
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SUMMARY
OF PROGRAM PROCESS 1.
Receipt of NRC-TRT request for additional information.
2.
Preliminary review of issue by Senior Review Team and appropriate Review Team Leader.
3.
Review Team Leader obtain additional, clarifying information from NRC-TRT to ensure full understanding of the concern (if necessary).
e 4.
Review Team Leader make a preliminary determinatien of root cause and potential generic inplications of identified deficiencies (if possible) a 5.
Review Team Leader develop Action Plan to resolve cencern using guidance provided.in Attachment 2.
6.
Action Plan approved by Senior Eeview Team.
7.
Review Team Leader implement Action Plan.*
8.
Review Tesa Leader make a conclusive determinatien of root cause and potential generic implications of identified deficiencies.
9.
Review Team Leader obtain concurrence of Senior Review Team in root cause definition and potential generic implications assessment.
10.
Review Team Leader develop revised Action Plan to reflect the conclusive determination of root cause and potential generic implications (if applicable).
11.
Lavised Action Plan approved by Senior Review Team (if applicable).
12.
Review Team Leader implement Rs. vised Action Plan (if applicable).*
13.
Review Team Leader define necessary corrective action for identified deficiencias (if applicable).
14 Review Team Leader define necessary corrective action to prevent recurrence of similar deficiencies in the future (if applicable).
15.
Review Team Leader develop Action Plan Results Report using guidance provided in Attachment 3.
16.
Action Plan Results Report approved by Senior Reviev Team.
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S1T assess Action Plan Results Repott as part of Collective Significance Evaluation.
J 13.
SRT define necessary correctiv-acticus ste:mning from the Collective Significance Evaluation 19.
Submit Final Report to NRC, including implementation schedule for necessary corrective actions.
20.
TUEC dmplement necessary corrective action.
- Action Plans and tevised Action Plans will be submitted to the NRC staff for review and comment at the time they have been approved by the SRT; however, i=plementation of Action Plans will not be delayed pending receipt of NRC staff cccuents. Any necessary changes to Action Plans resulting from NRC review and com=ents will be incorporated expeditiously.
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