ML20207A681

Concludes That No Further Action,Other than Those Already Planned,Necessary to Address Fundamental Thrust of Criticisms of Region IV Mgt & Supervisor Performance Contained in Comanche Peak Review Group Rept

ML20207A681
Person / Time
Site:	Comanche Peak
Issue date:	11/20/1987
From:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
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 8801290040
Download: ML20207A681 (2)

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!Di 2 O 14R7 rd "0uNDI:* FM - J. M. Taylor, Deputy Czecutive Director for Pegional Operations 3 WS 20be't r D. M.tvtin, Regiona1 Administrator

$UNCCT: REVIEW OF C MANCH! P(At 4! PORT REVl[W GROUP (ARLOTTO REPORT)

Reference:

M,morandum dated August M,1987, R. D. Martin to J. M. Taylor, "Actions Planed in Regard to the Report of the Comanche Peah Report Review Group" I have Completed the review whiCh ! promised in the referenced rnemorandym, and have Considered the actions already underway in Region IV, including the reorganization and augmentation of technical resources, and the addition and replacement of selected managers. When these changes are considered in light of the training and policy development acti.ities that have already taken place, as well as those still being finalized, I conclude no further specific actions other than those already planned are necessary to address the fundamental thrust of the criticisms of Region IV management and supervisor performance contained in the CPRRG report.

I em unable to agree with all of the criticisms in that report. I beliJve that a few of the conclusions were drawn as a consequence of the group's decision to fornulate those conclusions based on the written record without supplementary interviews of involved personnel. Therefore, they formed certain judgements in the absence of complete information, However, those particular areas with which I differ are not such thtt it would be fruitful for the agency to expend anymore resources in trying to further expand that record, Rather, the fact remains that the effort of the (PRRG was a conscientious effort of a substantial group of senive managers to put the large number of contentious issues in the Ol A report into proper perspective regarding technical and safety significance.

There were two specific issues identified in the CPRRG report for which NRR guidance will be requested. These two items are identified in the attachment.

While I believe my views on the subject are well based, I plan to obtain concurrence in those positions before moving forward with any revisions to e dsting Region IV guidance,

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!. DESIGN CDCOMENTS K/ t., <

Ihe CPRRG report noted that the procedure for installation of the reactor b 2. a vessel, since it recorded installation dirensions and deviations from .1i allowed tolerances whtCh required evaluation for acceptability, thould have been Controlled by the licensee at 4 DESIGN DOCUMENT.

'a' hat is not Clear ' rom the CPRRG report i5 whether this conclusion about ho. Such records 5hould be handled differs in any substantive ey, in this instance, from the quality controls applied to any record =hich records differer..es in physical installation or System performance, (samples of these records would be NonConfor1 nance Reports and Preoperational Test Procedure results which dif fer f rom original test acceptance criteria, These kinds of examples are covered by the Quality A55urance Program of a licensee which, in accordance with Appendt B to 10 CFR 50, has established controls for resolving such discrepancies. Region IV believes such Controls are appropriate, the CPRRG distinction of handling such records as DESIGN DOCUMENTS is not clear.

2. INSPECTION REPORT CONTENT The C?.1RG report r.Med that when an inspector has inspection findings

=hich are di5 cussed with the licensee at an emit meeting, but are later found to be in error, the issued inspection report test should include all of the evolution of the issue leading to its eventual elimination as an issue of significance, Region lY disagrees and believes our disagreement is supported by practices followed in the regions. An inspection report should focus on a succinct presentation of real issues and conclusions. It should not be permitted to be encum.bered by any non 155ues or to be a 109 book of inspector actions. We telieve keeping the report focused on issues and compliance Conclu5 ions is very important, Any needed revisions to statements made at an tait reeting can be corrected by a telephone Call te the licensee representative.

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