ML20236G635
| ML20236G635 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/14/1987 |
| From: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Zech NRC COMMISSION (OCM) |
| Shared Package | |
| ML20236G632 | List: |
| References | |
| FOIA-87-564 NUDOCS 8711030175 | |
| Download: ML20236G635 (25) | |
Text
O
'.IMITED DISTRIBUTION l
![
'o UNITED $TATES 6[
f.#
g i4UCLEAP REGULATORY COMMISSION j
.e wasMisavow,o c.rosss
- -r r
.hv April 14, 1987 Cy l
MEMORANDUM FOR:
Chairman Zech FROM:
Victor Stello, Jr.
l Executive Director for Operations
SUBJECT:
IMPLEMENTATION OF RECOMMENDATIONS OF COMANCHE PEAK REPORT REVIEW GROUP In November 1986, the Office of the Inspector and Auditor (OIA) issued its Report of Investigation, 86-10, addressing allegations of - Region IV management wrongdoing relative to. inspection activities regarding the Comanche Peak Steam Electric Station. In broad terms, the OIA Report dealt with three allegations: (1) harassment and intimidation of an inspector in connection with the preparation of inspecticn reports and the consequent downgrading or deletion of violations;'(2) failure of the Region to carry out '
required inspections of the permittee's quality assurance program; and, (3) deficiencies in the NRC Form 766 reports prepared by inspectors to document inspection activities.
With the approval of the Commission, on January 21, 1987, I established the Comanche Peak Report Review Group (CPRRG) to evaluate the OIA Report.
Consistent with the Commission's direction, the CPRRG was charged with providing recommendations on five matters: (1) the safety significance of the 34 issues identified in the OIA Report; (2) whether the issues identified in the OIA Report were appropriately handled in terms of process and disposition; (3) whether the current augmented review and inspection effort-at Comanche Peak is sufficient to compensate for any identified weaknesses in Region IV's quality assurance inspection program; (4) the purpose and significance of NRC Form 766; and, (5) whether the issues raised with respect to Comanche Peak have broader implications in Region IV.
The CPRRG specifically did not duplicate the OIA investigation nor develop any independent record of testimony (although it did request and receive some additional documentation); it did not address the licensability of the Comanche Peak fseility; and, it did not. investigate or otherwise inquire into any matters of wrongdoing, misconduct or mismanagement except to the extent that such matters were explicitly identified in the OIA Report and its attachments and then only for the purpose of identifying factors tl't might 4
have caused or contributed to the matters considered in the OIA Report.
However, the CPRRG did perform a complete review of the OIA Report and all the supporting attachments thereto.
Copies of the CPREG Report were-provided to the Commission on March 17, 1987.
It is apparent that I treated -
this entire matter vary seriously and devoted extensive management and staff effort to the task, information ic !D recd gn :Wed in accordance 't.M Re Fmde-n cuatgratig Act, exempt;cra 5
F0lA. 87-SM LIMITED O!STRIBUTION Fm.A-B1-5W l!i 1
~
8711030175 871030 PDR FOIA TAYLDR87-564 PDR i
e 3
?
9 The CPRRO, in its Report issued to me' on ? larch 12, 1987, addressed each of the five issues identified above.
To quote the CPRRG's conclusions.
(1) None of the 34 issues identified in OIA. Report 86-10 was. found to be significant in terms of any direct adverse' impact on plant safety.
(2) Region IV's disposition, f.e.,
classification, of the identified issues-was appropriate -and the Regicu acted within its authority based on the'information contained in the inspection reports.and on the guidance.available for determining the classification of. the findings, e.g.,
i violation, unresolved [ sic). Certain issues were not
)
appropriately processed; e.g., inspection findings were in some cases not ' developed by the inspectors in accordance with agency
- guidance, and Region IV supervision did not always provide the guidance i
necessary to properly focus and resolve items.
l (3) When measured against the 1986 inspections program requirements, gaps.
were identified. in the total inspection program.
The current augmented review and inspection effort at Comanche Peak has,. for the most part, compensated for gaps in scope and coverage in Region IV's QA inspection program.
(4) The 766 system, primarily used by IE and little used by the Regions, is not used in making safety decisions.
'ihe accuracy, completeness, and timeliness of the data are not adequate for many needs.
Overall, - the 766 system does. net satisfy current agency needs.
(5) The CPRRO's judgment is that broader implications are likely for facilitics in Region IV other than Comanche Peak.
Additional considerations may influence the-significance of these implications.
(CPRRG Report at 4-1).
In addition to the foregoing conclusions, both tre CPRRO Report and its-i several Appendices contain numerous recomrnendations for. specific improvements and corrective actions.
We have extracted from the CPRRG Report and its Appendices all explicit recommendations and have categorized them as follows:
Category 1 additional and confirmatory actions and inspection efforts needed to assure complete disposition of the 34 issues in the CIA R(port and to compensate for gaps identified in the Comanche Peah QA inspection program
,-I,
-3 1
o Category 2 clarification of inspection philosophy and practices, authority to determine significance level of inspection findings, and documentation requirements and procedures for inspection findings;.
- and, Category 3 review of existinF data management systems with application to inspection activities, including. NRC Form 7G6, and necessary revisions to enhance. the reporting, management and use of the inspection data. for both Headquarters and Regional purposer.
(CPRRG Report at-l 5-1,. item 4 and ~ Appendix D. Sec.VIII) in order to carry out the CPRRG Report recommendations in the most timely manner possible and with due recognition of the recent establishment of the i
Office of Special Projects and the agency-wide reorganization,. the above recommendations will be assigned as dollows:
category I recommendations apply specifically to the Comanche Peak facility an d,
accordingly, will be assigned to the Office of Special Projects;
{
categories 2 and 3 recommendations, because of their i
programmatic nature, will be assigned to the Office of Nuclear Reactor Regulation with the assistance of the Office of Administration and Resources f f anagement.
in addition to implementing the CPRR O's explicit recommendations, I an directing these offices to further review the Report to determine whether there are any further actions to be taken based on other statements, implicit recommendations or lessons learned contained therein.
Each of the recommendations will be implemented except as approved by me upon adequate justification. is a preliminary listing containing those recommendations which are explicitly set out in the CPRRC Report.
As noted above, the staff will continue to review the Report to extract other recommendations or suggestions which may be included in the. text and elsewhere in the Report.
tihile concluding that Orcader implications are likely for facilities in Region IV other than Comanche Peak"- (conclusion (5) above). the CPREG maakes no express recommendations for resolution of this concern.
The CPREC does, however, make several observations regarding the significance of enhanced inspection activities at-Comanche Peak and in terms of charecterir.ing the nature of the causes of the events at Comanche Peak, which bear on this issue.
These matters, along with a more detailed discussion of the evolution of the NR C's inspection program and other Region IV f6cilities, is presented in Enclosure 2.
In tsrief, it would not be
s '
unexpected that, if measured against the 1986 inspection program, gaps would be found elsewhere.
Moreover, the philosophy of the modularizec inspection program is such that each line item need not be " completed" by the inspector.
Rather, the inspector is to ecnsider each line item in determining whether the facility is being constructed (or operating) safely.
Nevertheless, the op; rating history of the other facilities, the team and other spccial inspections and on-site technical audits that were performed by the staff in addition to the various independent and utility-conducted verification efforts, suggest strongly that such gaps as might exist would be few and not of safety concern.
Consequently, I have no cause to believe i
that the reasonable assurance which was previously found to exist with respect to other facilities within Region IV has been eroded.
Nevertheless,
l while I have no reason to conclude that the initiation of an inquiry. to determine whether specific gaps in the inspection process exist for other facilities is immediately warranted, I propose to direct NRR to examine in more detail, the inspection recorda for a facility within Region IV which did not receive as much attention through either NRC-or utility-conducted efforts.
If the results of such review require, further staff reviews of other plants will be performed.
l l
Based on the findings and conclusions of the CPRRG Report, in particular those regarding the implementation of the inspection program for Comanche Peak, in terms of process and disposition, I also intend to take appropriate personnel actions to assure that, to the extent possible, the circumstances which culminated in the OIA investigation do not recur.
In this regard, I propose to personally write to the principal individuals involved to inform them of the CPRRG Report and provide each with a copy.
A draft of my proposed letters is attached as Pnclosures 3-6 Further, I intend to meet with each of the principals to inform them of my decisions for resolving the remaining issues and to discuss with them their future roles in the Region.
I will also meet with other Region IV and site personnel to explain my actions.
I intend to strees the importance to be attached to professionalism, teamwork and the need to be sensitive to the views of others which may not coincide with one's own, within the framework of the inspection process as well as within the agency as a whole.
In - addition to implementation of CFRRG's programmatic recommendettons to provide further
- clarity, consistency and understanding of the NRC's inspection process, the principal individuals involved, bcth inspector and management, will also be given specific training to improve their interpersonal skills and communication as appropriate to the individual.
The Region-wide training program and guidance initiated by the 1
ReE onal Administrator, described in his December 17, 1986 momorandum to me, will be continued for all appropriate Region IV personnel.
In addition to the recommendations which are discussed above, the CPRRG Report contains recommendations and observations directed toward improvement in O!A's investigation process.
CPRRG Report at 1 1-4; Appendix P at 17, items 1.7.10 and 3.7.11.
The Commission may wish to refer these matters to OIA for its consideration' An additional, related recommendation is in order.
The CPRRG Report fundamentally substantiates
i I
' )
the Cencral Counsel's observation, stated in hir ' December 23 1986 memorandum to the Commissioners, that:
It is unclear why reliance on the Regional '
Administrator and adherence. to the. - NRC's longstanding procedures for handling Differing Professional Opinions, as set forth in NRC.Yanual Chapter, NRC-4125, would not have suffleed ~ to permit a timely and effective resolution, of all issues without having the situation escalate' at the outset.to >
the point of a full-scale OIA -investigation involving charges
. such as' harassment and ~ intimidation.
The central issues.
which gave rise to this matter appear to involve differences -
in professional views on several metters.
-It is my judgment that in this instance, the conduct of this protracted OIA investigation has served only to further polarize the individuals involved and by distracting. personnel from their assigned responsibilities, has been detrimental to the agency's mission to. protect.the health and safety of the public.
This suggests the need for' the Commission to examine the policy cuestion of requesting an OIA investigation when management-type issues are involved.
Perhaps by improvement in the existing procedures for.
resolving differing professional opinions. - the Commission can better pro-vide for the prompt disposition of such issues.
I recommend the release of the CPRRG Report and its Appendices to. the l
public consistent with. any limitations determined appropriate by the Commission regarding the release of the OIA Report, Investigation 86-10.
I further recommend the public release of this memorandum, except for Enclosures 3-6, upon Commission approval of ' the actions recommended.
Appropriate Congressional Committees will be notified at that time.
The Commission's approval of the foregoing actions is requested.
/ Q [sf.
A i
Victor Stelfo, Jr.
Er.ecutive Director for Operations
Enclosures:
1.
CPRRG Recommended Actions 2.
Implications for Other Region IV Facilities 3.-6. Letters to named Region IV personnel oc w/
Enclosures:
Commissioner Roberts Commissioner Aaselstine Comraissioner Bernthal Commissioner Carr j
tSECY I
OGC i
Connelly, OIA i
1 l
1 i
- - - _ = - - _ - - - - - - - - - - - - - - - - - - -
1
s 5"
CPRRG RECOMMENDATIONS Comanche Peak Actions ID RECOMMENDATION ORGANIZATIONS REFERENCES l
02 Reinspection of OSP pg 3-8 hardware and design during current Comanche Peak re-review. (Explicit recommendations in sequence numbers 22 through 50.)
18 Clarify agency OSP pg 5-1, pg 3-25 recomenda guidence: Clear lines tion #2 of responsibility between the Comanche
- -eak augmented inspection program and the established licensing, and inspection and enforcement processes were not established or maintained in implementing the inspect, program l
20 Confirmatory NRC OSP pg 5-1, App A. Table action. Perform a recomenda 2., IR 85-07/05 detailed review of tion #1 Item 1 (1)
Westinghouse's engineering evaluation regarding translation of design criteria into installation specifications, procedures and drawings and failure to control deviations regarding Unit 2.
21 Confirmatory NRC OSP pg 5-1, App A, Table actions: Perform a recomenda 1 IR visual inspection of tion #1 85-07/CS, Iter the accessible reactor 1 (2) AppA vessel surroundings pg3-3 during or after het functional test.
CPRRG RECOMMENDATIONS i
l Comanche Peak Actions ID RECOMMENDATION ORGANIZATIONS REFERENCES l
l 22 Confirmatory NRC OSP pg 5-1 App A, Table recommenda 1 IR action: Perform a tion #1 85-07/05, Item detailed review of Westinghouse's
- 2. App A pg 3-3 engineering evaluation. Failure to maintain tolerance required and failure to report tolerance deviations on an NCR with regard to Unit 2 RV support brackets and shoes.
23 Confirmatory NRC OSP pg 5-1, App A, Table recommenda 1 IR action: Verify that an tion #1 85-07/05, Item adeavate quality 4
control procedure App A pg 3-12 exists for QA inspectors to witness the transfer of marking for material that would otherwise lose its traceability when cut into smaller sections.
24 Confirmatory NRC OSP pg 5-1, App A Table recommenda 1, IR action: Issue: FSAR tion #1 85-14/11. Item 17.1.17 does not 1 (1),AppA dnerth TV Electric p3-22 records system.
Action: Review the revised NEO procedures upon their completion and verify the implementation. Verify adequacy of applicants corrective action.
25 Confirmatory NRC OSP pg 5-1, App A. Table recommenda 1, IR action: Issue:QA tion #1 85-14/11, Item manual does not 3
address ANSI N45.2.9 requirements /commitmen ts. Action: See actions of Sequence Number 24 above.
CPRRG RECOMMENDATIONS Comanche Peak Actions ID RECOMMENDATION ORGANIZATIONS REFERENCES 26 Confirmatory NRC OSP pg 5-1, App A Table Action: Issue: TU recomenda 1 IR Electric failed to tion #1 85-14/11, Item have/use procedures to 3
control shipment of design records for piping to Stone and Webster, NY. Action:
See Sequence Number 24 above.
27 Confirmatory NRC OSP pg 5-1 App A Table action: Issue:
recomenda 1 IR Original design tion #1 85-14/11, Item records shipped in 4
cardboard boxes to Stone and Webster.
Action: See Sequence Number 24 above.
28 Confirmatory NRC OSP pg 5-1, App A, Table action: No backup copy recomenda 1, IR of records made for tion #1 85-14/11, Item records shipped to 5
Stone and Webster.
Action: See Sequence Number 24 above.
29 Confirmatory NRC OSP pg 5-1,-
App A, Table action: Issue: Failure recomenda 1, IR to control and account tion #1 85-14/11, Item for QA design records 6
transferred from site to Stone and Webster, NY. TV Electric stated.... Action: See Sequence Number 24 above.
30 Confirmatory NRC OSP pg 5-1, App A, Table action: Issue: Site recomenda 1 IR records containment tion #1 85-14/11 Item liner and mechanical 7
penetration of Chicago Bridge and Iron shipped to Houston, Texas, in cardboard boxes. Action: See Secuence Number 24 above.
O-6 e
6 e
a
CPRRG RECOMMENDATIONS Comanche.Deak Actions ID RECOMMENDATION ORGANIZATIONS REFERENCES 31 Confirmatory NRC OSP pg 5-1, App A. Table action: Issue: No recommenda 1, IR backup copy of records tion #1 85-14/11. Item mace for records 8
shipped to Chicago Bridge and Iron.
Action: See Sequence I,smber 24 above.
32 Confirmatory NRC OSP-pg 5-1 App A, Table action: Issue: TV recommenda 1, IR Electric failed to tion #1 85-14/11, Item I
inventory records sent 9
to Chicago Bridge and Iron. Action: See Sequence Number 24 above.
33 Confirmatory NRC OSP pg 5-1, App A, Table action: Issue: Plant recomenda 1, IR records stand in tion #1 85-14/11, Item folders or open 14 binders in open face cabinets at records center. Action: See Sequence Number 24 above.
l 34 Confirmatory NRC OSP pg 5-1, App A, Table action: Issue: Failure recomenda 1. IR to provide temporary tion #1 85-14/11, Item or permanent storage 15 facility for records App B pg 101 entered into the permanent recordt center then co-singled l
with in-process documents in paper flow group. Action:
See Sequence Number 24 above.
35 Confirmatory NRC OSP pg 5-1, App A, Table action.
Issue:
recomenda 1. IR Failure to tion #1 85-16/13, Item develop / implement 1, App Ap procedure to 3-28/9 demonstrate 50.55(e) deficiencies corrected. Action:
Audit the CDR program to verify its adequacy. (Applicant should revise i
l Procedure NEO CS-1.)
l
CPRRG RECOWENDATIONS Comanche Peak Actions ID RECO.HENDATION ORGANIZATIONS REFERENCES Confirmatory NRC OSP pg 5-1, App. A, Table action.
Issue: TU recomenda A IR Electric failed.to tion #1 85-16/13, Item revise implementing 2.
procedures containing 50.55(e) reporting before corporate NE0 Procedure CS-1 was implemented resulting in a conflict with 5 other procedures.
Action: See Sequence No. 35 above.
H 37 Confirmatory NRC OSP pg 51 App A. Table action.
Issue:
recomenda 1. IR Failure to maintain tion #1 85-16/13,' Item retrievable 50.55(e) 3.
files (i.e., could not produce record in almost a month).
Action: See Sequence Number 35 above.
38 Confirmatory NRC OSP pg 5-1, App. A, Table action.
Issue:
recomenda 1. IR j
Failure to report to tion #1 85-16/13, Item j
NRC actual corrective 4
j action taken on 50.55(e)s. Action:
See Sequence Number 35 above.
)
39 Confirmatory NRC OSP pg 5-1,-
App. A, Table J
action.
Issue: TU recomenda 1 IR Electric's 50.55(e) tion #1 85-16/13, Item files not auditable.
5.
Action: See Sequence Number 35 above.
40 Additional NRC action.
OSP pg 5-1, App. A, Table Issue: TU Electric recomenda 1. IR -
never responded to all tion #1 85-16/13, Item aspects of IEB 79-14.
6 & p.-3-33.
Action: Provide applicant with clear &
concise written evaluation of actions taken to date &
specify additional actions recuired to close the issue of IEB 79-14.
l
I i
CPRRG RECOMMENDATIONS Comanche Peak Actions -
ID RECOMMEN')ATION ORGANIZATIONS REFERENCES 41 Confirmatory NRC OSP pg 5-1 App. A, Table action.
Issue: TU recommenda 1. IR Electric's IEB record tion #1 85-16/13, Item files were incomplete 7 4 p.
(1982 & 1985).
3-36,37.
Action: Evaluate effectiveness of applicants' program through an audit.
(Assure that all Bulletins were received, processed, &
corrective actions initiated...
42 Confirmatory NRC OSP pg 5-1.
App. A, Table action. Issue:
recommenda 1 IR Deficiency in TU tion #1 85-16/13, Item procedures to handle 9 & p. 3-36.
IEBs. They do not describe how construction management personnel handle IEBs requiring action, especially hardware repair, replacement &
modification. Action:
See Sequence No.41.
43 Confirmatory NRC OSP pg 5-1, App. A, Table action. Issue: No recomoenda 1, IR focal point in TU tion #1 85-16/13, Item Electric to track IEB 10.
items. Action: See Sequence Number 41 above.
44 Confirmatory NRC OSP pg 5-1, App. A, Table action.
Issue: TU recommenda 1,.IR Electric's internal tion #1 85-16/13, letter stated that TU Item 11.
Electric would not identify nonconformances on IEB 79-14 to NRC. Action:
See Secuence Number 41 above.
~
CPRRG RECOMMENDATIONS l,
Comanche Peak Actions ID RECOMMENDATION ORGANIZATIONS REFEPINCES 45 Confirmatory NRC OSP W51 App. A. Table action. ' Issue:
reconrenda 1 IR Insufficient evidence tion #1 85-16/13, Item ef successful testing 12 cf BISCO fire seals -
filing of false reports by BISCO, validity of B'SCO seal questioned. Action:
Verify adequacy of new seal installation.
1 46 Confirmatory NRC OSP pg 5-1, App. A, Table action.
Issue:
recomnda 2, IR Fail-i to maintain tion #1 85-07/05, Item tolerance and to 2 App A pg report tolerance 3-6 cieviations on an NCR re Unit 2 RV support brackets and shoes.
Actipr* h amine trawler and NCR procitures, co7. firm changes are in plant-specif. cesign +
maintained...
47 Confirmatory NRC OSP pg 5-1, App. A, Table actiem.
Issue:
recomenda 2 IR Failure to perform tion #1 85-07/05, Item audits of 3
surveillance of reactor pressure vessel speer.,
procedures &
installation. Action:
Menitor an.plicants' response to staff concerns raised in SSER 11 regarding their ndit program.
48 Confirmatory NRC OSP pg 5-1, App. A, Table acticas. Issue: No recommenda 2 IR objective evidence tion #1 85-07/05, Item (records) that mixing
- 6. App A p bbdes had been
'3-17 inspected quarterly since 1977. Action:
Review statistical data re uniformity of concrete and review larger sample of concrete compression tests.
CPRRG RECOMMENDA110NS t
Co.anche Peak Actions I
ID RECOMMENDATION ORGANIZATIONS REFERENCES 49 Confirmatory NRC OSP pg 5-1, App A Table 2, action.
Issue: NAMCO recomenda IR switches IES 79-28 tien #1 85-16/13,Itee were not properly 8,p3-41,42: pg identified on 3-8 installation travelers. Action:
Monitor applicants' EQ cap. Note (3)
Applicant actions. list 50 Confirmatory NRC OSP pg 5-1 App A. Trble action: Issue:
recommenda 1, IR I
Insufficient evidence tion #1 85-16/13, Iter of successful testing 12 & pg 3-46 of 81500 fire seals.
filing of a false report by BISCO---validity.
Action: Reinspect seals and certification documentation.
51 If spool CVCS spool OSp pg 5-1, pg 3-10. Ap; B piece was not marked recomenda pg 15 at the time of tion #2 inspection, then additional review would be warrented.
Resolve uncertainty associated with when the spool piece was marked.
52 Inspections included OSP App C, in th6 1986 inspection Table 1, program, but not pp.10-12 completed at Unit 1,.
should be reviewed,
)
and those determined to be necessary to confirm plant Quality, should be j
accomplished.
CPRRG RECOMMENDATIONS Cemsw.he Peak Actions ID RECOMMENDATION ORGANIZATIONS REFERENCES 53 The status of the OSP inspection programs pg 5-F, pg 3-27/28, for Unit 2 should be recommenda App C pg 4 tion #3 monitored with respect to all NRC inspection activities to assure 1
that inspections keep pace with construction and " windows of opportunity" are not lost.
59 Further review of-OSP Operations Traveler -
App B pg 15 i
criteria, control and effectiveness is warrented if it has
(
not been done as a part of inspection i
activities completed to date.
60 A need to verify the OSP adecuacy of Level ! QC App B pg 15
. inspection of RPV installation may i
exist.
61 Further NRC review of OSP the completeness of QC App B pg 15 coverage and technical acceptability of the actual inspection criteria for the installation of all the major NSSS components is possibly warranted.
62 Inspection of other OSP J
installed App B pg i
15 field-fabricated spool pieces should be considered.
.,[ ', '
CPRRG REC 0tiENDATIONS Comanche Peak Actions.
ID RECOMMENDATION ORGANIZATIONS REFERENCES 63 Verify adequate OSP App B pg material 15 identification and traceability program for earlier work or review procurement and control program for the bulk piping stock at CPSES with furthr.r inspection directed to the checks and balances precluding install. wrong material 66 Determine if the-OSP App B pg Regulatory Guide 1.97 16 QA commitments heve been properly implemented at the CPSES and whether Region IV has monitored such implementation.
67 The adequacy of the OSP
' App.B pg licensee's program to 16 update permanent installation documentation when components are changed should or replaced should be reviewed, if 1
not already evaluated j
in inspections to date.
j The need to evaluate OSP App B pg I
safety significance 17 Rec. #
I and all pertinent 1.7.9 aspects of the i
licensee's QA Program l
may need to be emphasized.
i
CPRRG RECOMMENDATIONS j
Comanche Peak Actions l
ID RECOMMENDATION ORGANIZATIONS REFERENCES 72 Additional inspection OSP App B pg by NRC is recuired to 4.6-6' review engineering Items 28/33 efforts to close IEB 79-14.
73 Region IV selectively OSP App C pg 3 review records to see if specific inspection gaps were caused by non-performance. If so Task group recommends "the Region" (sic) take appropriate action to close those gaps where there remains a clear benefit to... plant quality.
l l
l 1
. - _ _ ~ _.,.... _,
1 3.
CPRRG RECO MENDATIONS 4,
General Programmatic Actions-2D RECOMMENDATION ORGANIZATIONS REFERENCES 04 ANSI N45.'2.9 is silent NRR RES pg 3-13 app B pp.
on shipping records. A definitive and 75-77, pg 3-14 two places.
documented regulatory position does not exist on controls during transfer between organizations.
05 Clarify agency NRR pg 5-1 pg 3-25, pg guidence: IE MC 9900 recomenda 3-18, App B pg guidence was tion 2 16 App B pg misinterpreted on 116 applicability of 10 CFR 50, Appendix 8 i
criteria to to the requirements of 10 CFR 50.55(e).
21 Clarify agency NRR NMSS OE pg 5-1, pg 3-24, pg guidence:
recomenda 3-22 Philosophical tion #2 App B p 10 differences... cn two issues: first, to what extent should inspectors focus on
hardware" vs QA
" records" second, to what extent should violations be developed prior to issuance.
64 The philosophical NRR ESS App B pg position as stated by 16 Region IV (that although a procedure required blade inspections, it did not require documentation of such inspections) requires careful consideration.
CPRRG RECO MENDATIONS
.}
General Progranrnatic Actions ID REC 0tEENDATION ORGANIZATIONS ~
REFERENCES 65 Consideration should NRR NMSS-RES App B pg be given to the TAT 16 position that "cermanent" records re.ooved from storage for c e or revision revert to an "in-process" status, which do not require application of the full ANSI N45.2.9 provisions.
75 NRC Headquarters NRR App C pg 9 should improve its regional assessment function to require more frequent and timely in-depth evaluations of the region's plant inspection performance and documentation practices.
.NMSS App B pp App B pg 17 discretionary guidence 6-11 Recommendation provided to
- 1.7.8 supervisors and management when dealing with non-escalated enforcement. When does a non-compliance become a violation?
Expand MC 0400 and 0610 accordingly. Also see Sequence number 68.
68 Consideration should OE NRR NMSS App B pg be given to amplifying 17 Rec. #
MC 0400 and MC 0610 1.7.9 regarding how to develop and document violations of 10 CFR 50, Appendix B Criteria. Alse $.ee Sti.uence number 57.
t m
CPRR3 RECOMMENDATIONS
~
General Programmatic Actions ID RECOMMENDATION ORGANIZATIONS REFERENCES j
07 No NRC guidance exists OE NRR NMSS pg 3-23 on the time permitted a licensee to retrieve a document which is required to be retrievable.
12 Clarify agency CE NRR NMSS pg 5-1, pg 3-25 guidance: Authority of recommenda inspectors and tion #2 supervisors to disposition violations involving isolated matters having minor safety significance and for which the licensee takes inmediate, effective corrective action.
14 Clarify agency CE NRR NMSS pg 5-1, pg 3-25 guidence: No recommenda definitive guidance tion #2 exists regarding the acceptability of multiple violations for the same underlying cause.
17 Clarify agency CE NRR pg 5-1, pg 3-25 guidence: The FSAR is recommenda part of the tion #2 application for an operating license and enforcement submitted to NRR for review. The role of the FSAR in the inspection process for facilities under construction is unclear (IE MC 9900).
z_
y J
CPRRG RECOMMENDATIONS Data Management Improve ents ID RECOMMENDATION ORGANIZATIONS REFERENCES 54 Develop a more NRR OIRM pg 5-1, pp 3 28-32, comprehensive, unified recomenda App C pg 9 766 System that meets tion #4 App D pg I 2I current agency needs, Consider the and pg VI!!
monitoring of site specific inspection programs, periodic regional monitoring of inspection program l
status, and Hg overview. Possibly
{
then do Sequ#s 76 and 77.
7C Establish inspection NRR OIRM App D pg App D pg VIII and enforcement data I-2 Rec. # Rec. #2 qua'lity assurance 2
policies ~and procedures as well as a training program to help assure a gensistent, reliable, and timely agency data source. This could be accomplished after Sequence' number $4.
J 77 Consider collecting NRR O!RM App D pg App D pg VIII all inspection and I-2 Rec. # Rec. #3 enforcement staff 3
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.
j.
_m_.__
m__
IMPLICATIONS FOR OTIIER REGION IV FACILITIES With respect to the issue of whether Region IV failed to conduct required setivities for Comanche Peah, the principal focus of OIA's investigation was on the inspection of the utility's Quality Assurance Program, mainly at the company's headquarters, pursuant to IE Manual Chapter 2512.
(OIA Report at 37-46)
The CPRRG, however, expanded this scope and examined the matter from the broader perspective of all required inspection activities called for by the current NRC inspection program.
The CPRRG concluded that "... broader implications for other facilities in Region IV cannot be ruled out and are likely to exist."
However, while no specific recommendations are made, a number of observations stated by the CPRRG do provide useful guidance.
For example, the CPRRG stated that:
... to the extent that limited resources were a factor at Comanche Peak [in terms of deficiencies in Region IV QA inspection activities), some evidence arists tha*. this factor may hrve affected other plants.
Construction programs at Waterford, Comanche Peak, South Texas, Wolf Creek, and River Bend were all under way at the same time.
This fact could have aggravated the situation, particularly since Region IV has a relatively small staff.
Testimony in the record - indicates that inspection activities at Comanche Peak and Waterford were adversely affected as a result of limited regional resources.
Further, some of the factors that apparently lead to the difficulties at Comanche Peak, and ultimately to the OIA investigation, appear to be rather fundamental in nature and may not be limited to one site.
In this regkrd, it is not at all clear that for Comanche Peak there was an established and understood philosophy for the conduct of the inspection pregram; a commonality of purpose on the p6rt of both inspectors and management; and good communications and interchange in the development and dispositioning of inspection findings....
!!owever, there are factors apparent from the CPRRG review that tend to m6ke it diff! cult to gauge or assess the significance of such implications.
The heart of the Comanche Peak conflict seems to be a dispute between an inspector and his management.
This dispute reficcted differences in inspection emphasis, enforcement policy.
and the role of the inspector in the inspection and enforcement program....
Additionally, despite much controversy over the issues reflecting this dispute, the record does not establish that any unsafe condition exfr,ts at Comanche Peak.
In fact, none of the 34 issues
g 2-raised by the inspectors and included in the OIA report have direct safety significance.
Further, the _ record I
contains considerable testimony that, for the most part,.
the Comanche Peak activities were being pursued by individuals attempting to properly discharge. their responsibilities as they understood them. These findings suggest that the controversy in this case involves a limited nurrber of individuals and a limited number of issues. (CPRRG Report at 3 3-4.).
The language quoted above is presented to provide a perspective on the approprista breadth of actions necessary to assess whether the situation as it existed in regard to Comanche Peak, existed - with respect to. other facilities within Redon IV. It is also necessary ' however, to undarotand.the evolution tsf the NRC's inspection program over the years in~ order to assess -
the significance of any gaps that might exist.
In fact, the findings of both the OIA an:' CPRRO Repcrts with respect to the NRC's inspection program are, in : general sense, consistent with the Commission's own ; findings, presented in "A Report to Congress, Improving Quality and the Assurance of Quality in the Design and Construction of _ Nuclear Power Plants,"
N UREG-1055, May 1984.
Through the late-1970's, the inspection. program was fundamentally oriented towards a review of a licensee's written quality assurance program and program documentation with little. emphasis on.
observation of work and inspection of hardware. The program, which has always been based _ on inspections / audits of cnly a fraction of ' all. such activities,
be they construction-related or operation-related,
exceedred manpower resources.
Such manpower constraints have been magnifled from '
time to time and from Region to negion because of specific Regional manpower ahortfalls and/or because of peculiarly heavy inspection' demands resulting from the number of facilities within a - Region requiring like, manpower-intensive efforts in the same timeframe.
In the 1980's, the focus -
of the program was reviced-somewhat to put increased emphasis on the inspection and obserystion of work and less on records review, and to better accommodate resource limitations.
At each stage of the evolution of the inspection program, the IE Manual and its inspection modules, which provides guidance to NRC inspectors, have been changed to ccrrespond to the then-current inspection: philosophy.
It should also be recognized that literal completion of each inspection module in not required.
Rather, as the
~
IE Manual makes clear, an inspector is obligated to give consideration to the inspection requirements of' each module whfeh, due to facility-specific considerations, may result in any given module not beir.g " completed".
Fforeover, as a practical matter, completion of all modules har gener911y not been achieved; completion of the inspection prograns has ranged fram _ about 60-70t to 90-100%.
The foregoing background is discussed at length in Appendix D to the above-menitoned Report to' Congress.
Also relevant to the question of broader implications is the implementation of augmented NMC inspection and audit activitics (such as CATS, PATS, ID!s and the like) at many sitec as well as the implementation of a variety of independent and utility-conducted design, construction and quality assurance verification programs prior to the !! censing of all recent plants.
While both
.--.____----__e-.---___..__x-_.___--._____---_
J; '
~
of these efforts have tended to focus on selected areas of a facility, they have taken into consideration applicable QA/QC requirements and have been sufficiently broad in scope, in terms of the spectrum of structures, systems and components of a plant under scrutiny, to provide a well-rounded retrospective picture of the adequacy and effectiveness of the respective QA program.
Both the OIA r.nd CPRRO Reports acknowledge the contribution of such efforts, in the case of Comanche Peak, to compensate for possible gaps in the NP.C routine inspection process.
The existence of similar undertakings elsewhere, therefore, is of significance in deciding whether measures are warranted to determine whether such gaps in the inspection program as were found at Comanche Peak are of concern at other facilities.-
In light of the foregoing, the CPRRO's conclusion regarding broader implications is addressed.
As noted by the CPRRG, a number of facilities in Region IV were under construction in generally the same timeframe.
- Thus, on the one hand, limitations on Region IV resources logically could have had an effect on inspection efforts related to all of them.
the Region was fully budgeted for these activities and a variety of special On the other hand, and augmented inspection and audit activities were condgeted at several of these facilities which provide confidence that any gaps 71n the Region IV program would not likely have resulted in the failure to detect deficiencies with safety signifleance.
For instance, as at Comanche Peak, extensive staff technical audits were undertaken at the hterford, South Texas - Wolf Creek and River Bend facilities in connection with the staff's operating license reviews.
These activities included detailed reviews of the applicants' site records on selected (but widely varied) fesues and team inspections on selected important safety systems.
As pcrt of these efforts, emphasis was placed on implementation of QA programs related to the matters under review.
Similarly, Fort St. Vrain has been subjected to detailed scrutiny in connection with factors surrounding the extended plant shutdown, compliance with the Commission's environmental qualification requirements and the staff's review of the Chernobyl implications.
Although these reviews focused principally on hardware end systems design, related QA elements were implicitly considered in the licensee's overall in)provement program.
In l
addition, Region IV conducted an surmented inspection of the licensee's quality programs as a result of a SALP category 3 finding.
The Cooper, Fort Calhoun end Arkansas lluclear One facilities have been in operation for many years, indeed, prior to the development of the NRC's increased emphasis on construction inspection activities and were not I
subjected to such detailed audits and inspections.-
Nonetheless, because their periods of construction preceded by some years some of the I
evolutionary changes in the inspection process, the uncertainty as to the proper inspection philosophy is likely less than was found to exist in later yeats when more changes occurred. Furthermore, e.!though the staff did not perform any special or augmented audits or inspections at these plants, their long operational histories strongly suggest thkt gr.ps that might be found are of little moment in terms of safety.
1 p
-f-
.A 6 noted above, the CPRRG also observed that the conflict regarding Comanche Peak appearc to have at its heart "a dispute bettreen an inspector and his management."
This factor, unquar.tifiable though it may be, could tend to limit the potential for far-reaching implications; we are not aware of similar disputes of such broad scope that have arisen in connection with any other facility in Region IV.
Moreover, the CPRRG's found that, in general, Region IV's disposition of each of the 34 items at issue in regard to Comanche Peak was appropriate and that none of these issues was of direct safety significance.
The CPRRG Report gives no reason to suspect that I
such disputes as etight have existed in connection with other facilities were i
mot also appropriately dispositioned or that issues of direct safety 1
significance are likely to have been discarded or ignored because of process-related conflicts.
I
)
l 1
I l
l 1
1 i
l 1
I EN CLOSURES 1
3 L 1,
lo l
DeceT.
l Information in this record was deleted I
in accordance with Uie F;esde:n cf Informblica Act, exempt;cr.s 6 F01A =37-MA i
I 1
l l
l l