ML20207A604
| ML20207A604 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 09/02/1987 |
| From: | Murley T Office of Nuclear Reactor Regulation |
| To: | Rehm T NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20206E778 | List:
|
| References | |
| FOIA-88-322 NUDOCS 8709090215 | |
| Download: ML20207A604 (9) | |
Text
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NUCLEAR HEGULATORY COMMISSION p () l ~p cl wAssiNovos. o. c. rosss
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SEP 2 1987 n cy Docket Nos. 50-445
/4C'hC4S 50-446
- priov s be. Gu s D%c2. GN MEMORANDUM FOR: Thomas A. Rehm 64/31/8 7 Assistant for Operations
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Thomas E. Murley, Director assessnem prtoGrmt, O'1 Office of Nuclear Reactor Regulation
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SUBJECT:
COMANCHE PEAK REPORT REVIEW GROUP The purpose of this memo is to provide NRR's plan and schedule for responding to the Chairman's May 12, 1987 request (COHLZ 87-25).
COMLZ 87-25 specifies seven action items, three are within NRR's scope of responsibility:
Items 1, 2 and 3.
This memo focuses on Items I and 2, our plan and schedule for completing Item 3 was provided via my June 9, 1987 memo to the EDO.
Item 1 of COHLZ 87-25 states:
"Please extract from the Comanche Peak Report Review Group's (CPRRG) report and its appendices all explicit recomendations and categorize each in one of three different categories.
Assign all Category I
_recomendations to the Office of Special Projects (OSP) for action.
Category II and III recommendations should be assigned to the Office of cpj Nuclear Reactor Regulation (NRR) with the assistance of the Office of Administration and ResouNes Management. (ARM)."
, to this memorandum provides the plan and schedule for completing this item.
In developing this plan, the NT4R staff extracted explicit recommendations from the CPRRG report and its appendices and Enclosure 1 to the E00's April 14, 1987 memo to Chairman Zech on implementation of the CPRRG recommendations.
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Item 2 of C0MLZ 87-25 states:
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"0SP, NRR and ARM should further review the report to determine whether y
there are any additional actions to be taken based on other statements, W
, implicit recommendations, or "lessons learned" contained therein. to this memorandum provides the plan and schedule for completing this item.
Contact:
Martin J. Virgilio, NRR:DRSP:PD31 YN M WDOf*
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SEP 2 1987 Thomas A. Rehm.
In developing our program for completing Items 1 and 2 we coordinated with ARM.
Through this effort we defined the overlap and independent responsibilities on recommendations related to the 766 Systems.
/s/ R. Starostecki Uor]
Thomas E. Murley, Director Office of Nuclear Reactor Regulation
Enclosures:
As stated DISTRIBUTION Central File T. Murley J. Sniezek F. Miraglia D, Crutchfield F. Hebdon M. Virgilio R. Wright R. Bevan T. Mendiola K. Ecclesion M. Peraaich D. Mossburg (Yellow Ticke 879254) l See Previous Concurrence
- D:PD31*
NRR/ILRB*
NRR/DRSP*
NRR/ADP*
N NRR MVirgilto:ts FHebdon DCrutchfield FMiraglia J
zek 8/31/87 8/31/87 8/31/87 8/31/87 9/ (/87 ud R
TM rle 9/ /87
PLAN AND SCHEDULE FOR IMPLEMENTING RECOMMENDATIONS FROM THE CPRRG REPORT 10 Number k(Stellomemo)
Recommendation ANSI N45.2.9 is silent on shipping records.
A definitive and documented regulatory position does not exist on controls during transfer between organizations.
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Planned Action NRR will develop a regulatory position on this matter for incorporation as guidance in IMC 9900.
If necessary, NRR will recommend that RES work with the committee responsible for ANSI N45.2.9 to make any needed changes in the standard.
Completion:
12/87 ID Number 05 (Stello memo) and NUREG-1257, page 3-25, item (10)(b)
Recommendation Clarify agency guidance:
IE MC 9900 guidance was misinterpreted on applicability of 10 CFR 50, Appendix 8 criteria to the requirements of 10 CFR 50.55(e).
iL Planned Action C'n / The applicable guidance in IHC 9900 will be reviewed and revised by to clarify the applicability of 10 CFR 50, Appendix 8 criteria to the go f q40 reporting requirements of 10 CFR 50.55e (e.g., the applicability of C
f Appendix 8 criteria to licensee control and maintenance of 50.55e records).
Completion:
12/87 10 Number X(Stelloscmo)andNUREG-1257,page3-24, item (10)(a)
Recommendation M
Clarify agency guidance:
Philosophical differences... on two issues:
96 4,'firit, to what extent should inspectors focus on "hardware" versus QA M ords"; second g o/
to issuance. ", to what extent should violations be developed prior v
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Planned Action NRR will take the lead in working wit 0E,in reviewing existing IMC policy and instructions applicable to D # two areas in question and in determining what additional guidance needs to be incorporated in various IMC(s) and inspector training programs to clearly emphasize the intended h,
approach.
Completion:
12/87 10 Number X (Stello memo) g Recommendation j
s The philosophical position as stated y Region IV (that although a y
procedure required blade inspections, it did not require documentation of such inspections) requires careful consideration.
Planned Action
. Consideration will be given by NRR to the need to issue additional guidance relative to this matter.
Past and present NRC quality
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assurance guidance applicable in this case (N45.2, N45.2.5 and NQA-2) does require that records of inspections be prepared.
Completion:
I?/87 10 Number X (Stello memo)
Recommendation Consideration should be given to the TRT position that "permanent" records removed from storage for use or revision revert to an "in process" status, which do not require application of the full ANSI N45.2.9 provisions.
I Planned Action NRR will evaluate adopting the TRT position and determine whether a change to the current regulatory position should be made.
Colepletion:
12/87
3-10 Number 75 (Stello memo) f Recommendation
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NRC Headquarters should improve its regional assessment function to require more freque and timely in-depth evaluations of the region's I
plant ing ection performance and documentation practices.
Planned Action NRR is currently revising the regional assessment program in light of the reorganization.
This recommendation will be addressed and coordinated
\\A with the actions stated below for 10 54 to achieve the objectives of these recommendations.
Completion:
10 Number X(Stellomemo)andNUREG-1257,page3-25, item (10)(j)
Recommendation No NRC guidance exists on the time permitted a licensee to retrieve a D
2 document which is required to be retrievable.
Planned Action This Item was initially assigned to OE.
OE and NRR agree NRR will prepare guidance addressing the question of timeliness of licensee retrieval of records.
Completion:
12/87 10 Number 17 (Stello memo) and NUREG-1257, page 3-25, item (10)(h)
Recommendation s
Clarify agency guidance:
The FSAR is part of the application for an D *,
operating license and enforcement submitted to NRR for review. The role O
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of the FSAR in the inspection process for facilities under construction is 8
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4 Planned Action This Item was initially assigned to OE.
OE and NRR agree that NRR will develop guidance on the relationship and role of the PSAR and FSAR in the inspection process for facilities under construction and will incorporte the guidance in the appropriate IMC.
Completion:
12/87 10 Number 54 (Stello memo)
Re:ommendation Developamorecomprehensive,unifiedd66SysteMthatmeetscurrentagency needs.
Consider the monitoring of site spectfic inspection programs, periodic regional monitoring of inspection program status, and Headquarters overview.
Possibly then do Sequence Numbers 76 and 77.
Planned Action g
NRR has recognized this need for revision of the 766 system and is working closely with ARM towards that goal.
In light of the NRC g,00 reorganization NRR is working with ARM to develop plans for achieving the desired regional and headquarters monitoring including the coordinated utilization of:
766 System Data Guidance for achieving uniform region self monitoring of the inspection program NRR management and staff assessment visits to regional offices and rear. tor sites.
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Comple_tj g 6/88 t
10 Number 76 (Stello memo)
Recommendation
(*Ild,/R1TC) gDO Establish inspection and enforcemer.t data quality assurance policies and gR precedures as well as a training program to help assure a consistent, reliable, and timely agency data source.
This could be accomplished after Sequence number 54.
.. Planned Action NRR plans described above for ID 54 will also include consideration of guidance to be established and implemented for ensuring the quality, uniformity, reliability, and timeliness of 766 System Data and of training required to achieve that end result.
Completion:
6/88 ID Number 77 (Stello memo)
Recommendatien Consider collecting all inspection and enforcement staff resource data in RITS.
Evaluate the benefits of collecting inspection information by SALP functional area rather by inspection module.
This could be accomplished after Sequence number 54.
Planned Action NRR plans to revise the 766 System will include consideration of how the (766 and RITS data)ntry systems can be utilized to collect and track data W nspection program implementation by SALP functional areas.
Completion:
6/88 l
l 10 Number NUREG-1257, page 3-25, item (10)(f) p Recommendation Agency guidance is lacking with regard to:
(1) what changes can be made in a report once any of the principal parties have signed or concurred in the report; (2) the meaning and intent of signing or concurring in the report; and (3) deciding under what circumstances issues should be elevated to higher management, forwarded for headquarter for review, or ge p. g resolved by a peer panel.
Cp Planned Action NRR is currently revising the guidance in I 0610 or documeMetion of inspections.
This guidance will be incitded dress the three areas discussed in the recommendation.
Completion:
12/87
s JDNumber NUREG-1257, page 3-25, item (10)(g)
Recommendation The use of open and unrcsolved items was not always controlled such that the necessary actions, responsible party, and schedule were assigned to provide for adequate, timely followup of the issues,
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Planned Action IMC 0610 will also be revised to (1) indicate the method that the p#
regions should use to identify open or unresolved items in inspection report documentation, and (2) the cetions to be taken to ensure the
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tracking and timely followup by a responsible party of identified open or unresolved items.
Completion:
12/87
EVALUATION OF THE CPARG REPORT TO IDENTIFY NEW ACTION ITEMS PURPCSE To determine if NRC should initiate new actions in response to the CPRRG report other than those already identified in the report itself, its appendices and the E00's April 14, 1987 memo tc Chairman Zech on implementation of the CPRRG recommendations.
REVIEW TEAM ORGANIZATION A three member review team has been established consisting of technical assistants to the Division Directors in NRR.
OBJECTIVES Based on its review of the CPRRG report, its appendices and the ED0's April 14, 1987 mema, the team will determine if there are new actions or "lessons learned", not currently being pursued that NRC should consider.
Findings and recommendations stemming from this effort will refle:t the following:
(1) a review of applicable regulatory requirerants, guidelines and industry standards, (2) the need for inter-office coordination, (3) alternative courses of action, when appropriate and (4) the lead NRC organizations for development and implementation.
These findings and recommendations will be documented in a memo from the team leader to the Deputy Director, NRR, SCHEDULED COMPLETION October 30, 1987
.