ML20207A645

Responds to 871130 Memo Re Recommendations Per Comanche Peak Rept Review Group Recommendations.Guidance Adequately Implements Recommendations Id 12,14,57 & 68.Policy Should Be Revised to Emphasize Safety of Violations of Quality Stds

ML20207A645
Person / Time
Site:	Comanche Peak
Issue date:	12/14/1987
From:	Murley T Office of Nuclear Reactor Regulation
To:	Lieberman J NRC OFFICE OF ENFORCEMENT (OE)
Shared Package
ML20206E778	List: IA-88-322, Submits Input to Plan for Implementing Recommendations from Facility Rept Review Group Project Rept.Definitive & Documented Regulatory Position Does Not Exist on Controls During Transfer Between Organizations Re Shipping Records ML20206E774 ML20206E780 ML20206E784 ML20206E790 ML20206E825 ML20206E858 ML20206E871 ML20206E887 ML20206E900 ML20207A599 ML20207A604 ML20207A645 ML20207A670 ML20207A676 ML20207A681 ML20207A693
References
FOIA-88-322 NUDOCS 8712210113
Download: ML20207A645 (2)

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o NUCLEAR REGULATORY COMMISSION UNITED STATES

$ WASHINGTON, D. C. 20555

%,,,,, DEC 141981 MEP.ORANDUM FOR: James Lieberman, Director Office of Enforcenent #

OC ,@py6-FRON: Thomas E. Murley, Director Office of Nuclear Reactor Regulation

SUBJECT:

REC 0KiENDATIONS PURSUANT TO THE COMANCHE PEAX PURT REVIEW GP.0UP (CPRRG) RECOPJtENDAT10N3 This is in response to your memorandum dated November 30, 1987, sdbjectas above. We believe the proposed C q nche Peak Report Review Group (CPRRG) recomendations guidance adequat 10 12, 14,._imolementi 57, and 6 L,lM However, we have some coments in response to your request for improvements in Supplement II of the Enforcement Policy.

We suggest that you consider revising the policy to emphasize the safety siCnificance of violations of quality standards by those individuals who actually perform the activity as opposed to those who audit or inspect the activity. This errphasis would be directed toward the craft personnel who perform activities such as Welding, installation, calibration, testino, etc.

It would recognize that failures to meet quality standards specified for ensuring safety function of plant items at the craft level generally have more '

direct safety significance than failures at the audit or inspection level.

This action would serve to emphasize the importance the NRC places on ensuring that crafts meet performance standards and that performance groups should not i depend entirely on the quality verification functions to determine whether quality standards have been schieved.

Secondly, we suggest that you consider expansion of the discretionary action concept to include certain minor QA/QC violations identified by NRC personnel. This category would be limited to those that meet the following criteria:

, 1. A single Level Y violation of QA/0* procedures within a i specific area.

2. Did not involve craft personnel.

3. Did not result in a reduction of the intended safety function ,

of a structure, system, coirponent, or eperational activity.

4. Prior to the end of the inspection, the licensee initiated l l

appropriate corrective actions, including u tions to verify that the prograrratic failure did not result in affecting the intendedj afety function of a plant item or activity.

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James Lieberraan 2 CC 14 T-In such cases, the region should Le allowed discretion to not issue a violation but to document the facts in the inspection report. If the licensee's corree-tfve actions were not complete before the end of the inspection, then the matter would be pursued in a subsequent inspection to ensure that corrective actions were taken. Of course, should the licensee's corrective actions indicate that as a result of a deficiency in OA/0C piecedures that deficien-cies in hardware or a craft activity went undetected, an appropriate violation would then bt issued.

Since the regions would have an interest on the above proposed action, copies of this memorandum are provided for their consideration.

We would be pleased to discuss these riatters, if you desire. Our contact is

. Mark Peranich of the Inspection, Licensing and Research Integration Branch, PMAS, NRR, and he can be reacFed at 49-28085.

Original signed bf no=as E. Yurley Thomas E. Murley, Director Office of Nuclear Reactor Regulation ec: Regional Administrator, RI Regional Administrator RI! i Regional Adninistrator, RIII Regional /.dministrator, RIY Regional Administrator, RV Distribution:

Centrul Files ILD.B R/F T. Murley J. Snierek F. Gillespie

, F. Miraglia

! C. Thomas J. Blaha F. Hebdon '

M. Peranich R. Paulus D. Mossburg (No. 879376)

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