ML20237K030
| ML20237K030 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/09/1987 |
| From: | Jennifer Davis NRC |
| To: | NRC |
| Shared Package | |
| ML20237J194 | List:
|
| References | |
| FOIA-87-87, FOIA-87-A-14 NUDOCS 8708270025 | |
| Download: ML20237K030 (84) | |
Text
A-w /
(
pQ RIGO
'g UNITED STATES o[
3W q
NUCLEAR REGULATORY COMMISSION E
WASHING TON. D. C. 20555 MEMORANDUM FOR:
FROM:
John G. Davis, Chairman Comanche Peak Report Review Group (CPRRG)
SUBJECT:
CPRRG MEETING, JANUARY 27, 1987 The Comanche Peak Report Review Group (CPRRG) met in the Willste Building, Silver Spring, at 1:30 PM on January 27, 1987.
Participants were: John Davis, j
NMSS; Bob Erickson, NMSS; Guy Arlotto, RES; Jack Heltemes, AEOD; James 4
Lieberman, OGC; Philip McKee, IE; Samuel Collins, RI; Richard Hartfield, IRM; Dennis Crutchfield, NRR (who participated by telephone).
HIGHLIGHTS i
Discussion with Task Group Leaders The CPRRG briefed Group Leaders (McKee, Task i
1; Collins, Task 2; and Crutchfield, Task 3) on the background and purpose of the CPRRG effort.
It was agreed that Task Groups would review and comment on their respective task statements within a few days, so they can be finalized.
Additional Matters to be Addressed The Chairman's memorandum of January 15, 1987 and the ED0's memorandum of January 21, 1987, require the CPRRG to review the purpose and significance of NRC Form 766 and also to offer a,iudgment based on its review of Region IV's activities related to Comanche Peak, whether it is l
likely that there are broader implications in Region IV. The Group discussed l
the NRC 766 question at length with Richard Hartfield, IRM, who is taking the lead in that office to assist in the review.
]
The CPRRG will be requesting OGC thoughts concerning broader implications for Region IV based upon 0GC's review of OIA Report 86-10 and the supporting record. The Task Groups might also be asked for comments in this regard.
Task Schedules The following were determined to be the earliest possible dates for respective Groups to complete their reports:
i Task 1, February 10, 1987 i
Task 2, February 10, 1987 i
l Task 3, February 17, 1987 I
4 8708270025 870819 PDR FOIA B AUMAN,87--A-14 PDR
\\
710 3 $97 During the'veek of February 2,:1987, the CPRRG' intends to submit an overall-schedule ~to the EDO for approval.
o I.
John G.
avis, Chairman Comanche Peak Report Review Group L
cc:
G. Arlotto. RES l
C. Heltemes, AE00 C. Paperiello, RIII J. Lieberman, OGC J. Goldberg, 0GC R. Erickson, NMSS P. McKee, IE L
S. Collins, RI' D. Crutchfield, NRR R Hartfield. IRM l
1 l
c m__________.__._________._
\\
REVISED PER ARLOTTO & HELTEMES CPRRG CHARTER DPAFT #5 RErickson/bc 02/13/87 MEMORANDUM FOR: Victor Stello, Jr.
Executive Director for Operations FROM:
Guy A. Arlotto, Chairman Comanche Peak Review Group (CPRRG)
SUBJECT:
COMANCHE PEAK OIA REPORT 86-10 REVIEW GROUP The purpose of this memorandum is to present the CPRRG's plan for accomplishing tasks outlined in your memorandem dated January 21, 1987.
In performing our review, we will rely principally on the OIA Report 86-10 and information submitted to the CPRRG. The CPRRG will not duplicate the 01A effort but will request information, review records and documentation, and interview as needed to perform its mission. We have organized four working groups as an aid in accomplishing the following assigned tasks:
1.
IDENTIFY THE SAFETY SIGNIFICANCE OF THE ISSUES IDENTIFIED IN OIA REPORT 86-10.
The CPRRG will specifically address the safety significance of the identi-fied issues and the need for additional action, if any.
2.
DETERMINE WHETHER THE ISSUES IDENTIFIED IN OIA REPORT 86-10 WERE APPROPRIATELY HANDLED AS TO PROCESS AND DISPOSITION The CPRRG will address this aspect as an integral part of its report. The CPRRG report will deal also with whether an item was appropriately categor-ired within the IE report system and how the item was dispositioned, as documented in the record.
3.
DETERMINE WHETHER THE CURRENT AUGMENTED REVIEW AND INSPECTION EFFORT AT COMANCHE PEAK IS SUFFICIENT TO COMPENSATE FOR ANY IDENTIFIED WEAKNESSES IN REGION IV'S QA INSPECTION PROGRAMS.
a.
The CPRRG will use the existing IE construction inspection program as the standard against which the efforts at Comanche Peak will be compared. Consequently, the CPRRG will not identify the IE inspec-tions requirements that existed at various times during.the' Comanche Peak process, b.
The inspections actually performed by Region IV of those activities and items at Comanche Peak will be compared against this inspection program in terms of inspection objectives or coverage.
L
_ _ _. _.--________----_--i
k.
CPRRG CHARTER DRAFT #5 l
RErickson/bc 02/13/87
)
J c.
The inspections'actually performed by the Comanche Peak Project Office and any other elements of NRC (such as inspections managed by IE Head-quarters, NRR, or other Regions) and the Comanche Peak Response Team will also be compared against this inspection program in terms of inspection objectives or coverage.
d.
The CPRRG will provide a judgment whether the inspections actually 1
performed result in an inspection coverage at Comanche Peak sufficient to compensate for any identified gaps in Region IV's inspection programs.
l e.
The CPRRG will not review the technical findings of the inspection program actually performed and thus will not coment upon the adeouacy of the IE construction inspection program or the quality of the plant.
4 REVIEW THE PURPOSE AND SIGNIFICANCE OF NRC FORM 766 The CPRRG will review the purpose and significance of NRC Form 766 and make appropriate rec; emendations concerning its use.
l In addition, the CPPPG will address the following:
5.
JUDGMENT ON BROADER IMPLICATIONS IN REGICN IV Without expanding the above four specific tasks, and based upon the record, the CPRRG will offer its judgment on whether it is likely that there are broader implications in Region IV, beyond the Comanche Peak plant.
Your memorandum of January 21, 1987 requested a report by February 20, 1987.
We expect to have the relevant information collected by then.
However, we request additional time, until March 13, 1987, to allow for adequate research i
and documentation of the issues and overall evaluation and integration of the i
findings into a suitable final report.
Unless I hear from you, I will proceed on the assumption that our proposed scope and course of action as stated above, is satisfactory.
l Guy A. Arlotto, Chairman Comanche Peak Review Group l
4 a
.c 7,
l-CPRRE CHARTER DPAFT #5 RErickson/bc 02/13/87 a.
Enclosure:
List of. Principal Participants and Schedule U.
cc:., T. Murley, RI J. Keppler, RIII R.. Martin,'RIV E. Beckjord, RES.
W. Mcdonald IRM
.J. Taylor, IE H. Denton, NRR R. Scroggins, IRM C. Paperiello, RIII C. Feltemes, AEOD J. Lieberman, OGC J.-Goldberg, OGC P. Erickson, NMSS P. McKee, IE
- S.. Collins, RIII
's D. Crutchfield, NRR 4
R. Hartfield, IRM l
1 l
/
---______.___________.______m__________,,___,_
f }'
. my 9
N. q I,\\
~
DRAFT #5 j
1 CPrjRG CHARTER.
RErickson/t'c j
02/13/87
{
l m
COPANCHE PEAK OIA REPORT 86-10 REVIEW GROUP (CPRRG) '
l Principal Participants i
Guy A. Arlotto, RES, Chairman i
4 i
Clemens J. Heltemes, AE00, Carl J. Paperiello, R-III James Lieberman, OGC Jack R. Goldberg, OGC 4
Legal Advisors-l l
Robert A. Erickson, NMSS.
Coordinator Phillip F. McKee, IE, Leader Inspection Assessment Task Group Samuel J. Collins, R-I, Leader Issue Pandling and Irocess Task Group
-Dennis M. Crutchfield, NRR, Leader Safety Significance Task Cropp Richard A. Hartfield, IRM, Leader 766 System Review Group Schedule Complete Issue Handling and Process Task February 10, 1987 Complete Inspection Assessment Task February 13, 1987 Complete Safety Significance Tcsk February 17, 1987 Complete 766 System Review Task February 17, 1987 Assemble and Integrate Information February 27, 1987 Vorify and Augment Information March 6, 1987
! Complete Final Report March 13, 1987 RJ ENCLOSURE
-- j-d 4,'
(
CPRRG CHARTER 1
DRAFT #4 RErickson/bc 02/12/87
)
l MEMORANDUM FOR: Victor Stello, Jr.
Executive Director for Operations FROM:
Guy A. Arlotto, Chairman i
Comanche Peak Review Group (CPRRG)
SUBJECT:
COMANCHE PEAK OIA REPORT 86-10 REVIEW GROUP The purpose of this memorandum is to present the CPRRG's plan for accomplishing tasks outlined in your memorandum dated January 21, 1987.
In performing our review, we will rely principally on the OIA Report 86-10 and information submitted to the CPRRG. The CPRRG will not duplicate the OIA effort but will recuest information, review records and documentation, and interview as needed to perform its mission. We have organized four working groups as an aid in accomplishing the :TG:~:T4 tasks u
j ag,.s 4
.I.
DETERMINE WHETHER THE CURRENT AUGMENTED REVIEW AND INSPECTION EFFORT AT COMANCHE PEAK IS SUFFICIENT TO COMPENSATE FOR ANY IDENTIFIED WEAKNESSES IN
' REGION IV'S QA INSPECTION PROGRAMS, a.
The CPRRG will use the existing IE construction inspection program as the standard against which the efforts at~ Comanche Peak will be compared.
Consequently, the CPRRG will not identify the IE inspections reouire-ments that existed at the ti ;c cn insggtior shpM bcVe beerrperfumd.
o ma ta se
, u.,.
.s b.
The inspections actually performed by Region IV of those activities and items at Comanche Peak will be compared against this inspection program in terms of inspection objectives or coverage.
c.
The inspections actually performed by the Comanche Peak Project Office and any other elements of NRC (such as inspections managed by IE Head-quarters, NRR, or other Regions) and the Comanche Peak Response Team will> be compared against this inspection program e4ee in terms of 1
fr' inspection objectives or coverage.
y d.
The CPRRG will provide a judgment whether the inspections actually performed result in an inspection coverage at Comanche Peak sufficient to compensate for any identified gaps in Region IV's inspection pro-
- grams, e.
The CPRRG will, o review the technical findings of the inspection
[]
f program actual y performed and thus will not comment upon the adecuacy I
of the IE_i f'..f program or the quality of the plant.
b a {., L J3ut]
l
P CPRRG CHARTER 2
DRAFT #4 PErickson/bc 02/12/87 2.
OETERMINE WHETHER THE ISSUES IDENTIFIED IN OIA REPORT 86-10 WERE APPROPRIATELY HANDLED AS TO PROCESS AND DISPOSITION The CPRRG will address this aspect as an integral part of its report. The CPRRG report will deal also with whether an item was appropriately categor-ized within the IE report system and how the item was eventually closed or resolved [oritscurrentstatusf,asd-en:tr:t-fintherecord.
< red >(
/
3'.
IDENTIFY THE SAFETY SIGNIFICANCE OF THE ISSUES IDENTIFIED IN OIA REPORT
/
86-10.
j;, nwya The CPRRG will specifically address the safety aspects of.4 ectr issuef as to 1
agion.- This.mey v a.eil en-sitc revin end-
{gnjf.m.m.,eand jggng<
g, y
j vi ut ivi e
4.
REVIEW THE PUPPOSE AND SIGNIFICANCE OF NRC FORM 766 The CPRRG will review the purpose and significance of NPC Form 766 and make appropriate recommendations concerning its use.
"e ho w uLLoined-assistanca-.frc-
!"" in Tvionog thi; rev 6. -
vs.
In addition, the CPRRG will address the following:
5.
JUDGMENT ON BROADER IMPLICATIONS IN REGION IV Without expanding the above four specific tasks, and based upon the record, the CPRRG will offer its judgment on whether it is likely that there are broader implications in Region IV, beyond the Comanche Peak plant.
Your memorandum of January 21, 1987 requested a report by February 20, 1987.
We expect to have the relevant information collected by then.
However, we request additional time, until March 13, 1987, to allow for adequate research and documentation of the issues and overall evaluation and integration of the findings The-CMM-e l s e n ea ds + h i s t 4 =^ + ^ -^^ t with-01 A,- Req +ow-IV-and-o the rs,
to-verify r infe-:thn :nd distil' jth a suitabTe fiiiaT~ report )
Unless I hear from you, I will proceed on the assumption that our proposed scope and course of action as stated above, is satisfactory.
Guy A. Arlotto, Chairman Comanche Peak Review Group i
(
l CPRRG CHARTER 2
DRAFT #4 P.Erickson/bc 02/12/87 2.
DETU31INE WHETHER THE ISSUES IDENTIFIED IN OIA REPORT 86-10 WERE APPROPRIATELY HANDLED AS TO PROCESS AND DISPOSITION
/
The CPRRG will address this aspect as an integral part of its report. The CPRRG report will deal also with whether an item was appropriately categor-ized within the IE report system and be" +'e 't: a;; evente:1?y cleted cr b'tk. & WWM'
- P" as '4 Q 3/
eniv a /n 4 +,.
-.---1
'^--- '--' L in the record *
/
3' IDENTIFY THE SAFETY SIGNIFICANCE OF THE ISSUES IDENTIFIED IN OIA REPORT l
/.
86-10.
~
p,,.2 w. l;,w. <
The CPRRG will specifically address the safet ::p :t: of -eettr issuef es to -
4,,i'f n= and,
.. _:,; actiongbi;,nej c, Jail ca-sit; revie end -
r l
- = ination b ut ivi C
y 4.
REVIEW THE PURPOSE AND SIGNIFICANCE OF NRC FORM 766 The CPRRG will rvview the purpose and significance of NP.C Form 766 and make appropriate recommendations concerning its use.
"e ha c ub6.acd-
- estictanca fee- !"" in m ivuu hiu tMc ev!=.
In addition, the CPRRG will address the following:
5.
JUDGMENT ON BROADER IMPLICATIONS IN REGION IV Without expanding the above four specific tasks, and based upon the record, the CPRRG will offer its judgment on whether it is likely that there are broader implications in Region IV, beyond the Comanche Peak plant.
Your memorandum of January 21, 1987 requester 4 a report by February 20, 1987.
We expect to have the relevant information collected by then. However, we request additional time, until March 13, 1987, to allow for adequate research and documentation of the issues and overall evaluation and integration of the t4-t: =ct aith OIA, "egion "! :nd eLo, findings g The C""99 s1re aeeds thie te va*4'y p-4 af-: tion :nd disti1' itfinto a suitable final report)
Unless I hear from you, I will proceed on the assumption that our proposed scope and course of action as stated above, is satisfactory.
Guy A. Arlotto, Chairman Comanche Peak Review Group i
CPRRG' CHARTER.
3 OPAFT,#4
'RErickson/bc 02/12/87
Enclosure:
List of Principal Participants and Schedule.
cc:- T. Murley, RI
.J. Keppler, RIII R. Martin, RIV E. Beckjord, RES W.-Mcdonald, IRM J..Tay1or, IE H. Denton, NRR R. Scroggins, IRM C. Paperiello, RIII C. Peltemes, AE00 J. Lieberman, OGC J. Goldbero,.0GC
-R. Erickson, NMSS P. McKee, IE S. Collins, RIII D. Crutchfield, NRR R. Hartfield, IRM
_.-~_..-.__.-.-_.__m.__
(.
e a.-_.
CPRRG CHARTER DRAFT fa RErickson/bc 02/12/67 COMANCHE PEAK OTA REPORT 86-10 REVIEW GROUP (CPRRG)
Principal Participants Guy A. Arlotto, RES, Chainnan Clemens J. Heltemes, AEOD Carl J. Paperiello, R-III I
James Liebennan, OGC-Jack R. Goldberg, OGC-Legal Advisors Robert A. Erickson,-NMSS Coordinator l
Phillip F. McKee, IE, Leader Inspection Assessment Task Group Samuel J. Collins, P-I, Leader Issue Handling and Process Task Group Dennis M. Crutchfield, NRR, Leader Safety Significance Task Group Richard A. Hartfield, IRM, Leader 766 System Review Group
- Schedule, Complete Issue Handling and Process Task February 10, 1987 Complete Inspection Assessment Task February 13, 1987 Complete Safety Significance Task February 17, 1987
~
Complete 766 System Review. Task February 17, 1987 Assemble and Integrate Information February 27, 1987 Verify and Augment Information -
March 6, 1987 f
1
. Complete Final Report March 13, 1987 ENCLOSURE
t 1
CPRRG CHARTER DRAFT #4 RErickson/bc 02/12/87 COMANGHE PEAK OIA REPORT 86-10 REVIEW GROUP (CPRRG)
Principal Participants Guy A. Arlotto, RES, Chainnan Clemens J. Heltemes, AEOD Carl J. Paperiello, R-III James Lieberman, OGC 1 -
Jack R. Goldberg, 0GC Legal Advisors Robert A. Erickson, NMSS Coordinator Phillip F. McKee, IE, Leader Inspection Assessment Task Group Samuel J. Collins, R-I, leader Issue Handling and Process Task Group Dennis M. Crutchfield, NRR, Leader Safety Significance Task Group q
Richard A. Hartfield, IRM, Leader 766 System Review Group Schedule Complete Issue Handling and Process Task February 10, 1987 Complete Inspection Assessment Task February 13, 1987 Complete Safety Significance Task February 17, 1987 Complete 766 System Review Task February 17, 1987 Assemble and Integrate Information February 27, 1987 Verify and Augment Infonnation March 6, 1987 Complete Final Report March 13, 1987
___.y ENCLOSURE i
1
- d
.(
CPRRG CHARTER 2
DRAFT 3 RErickson/bc 02/11/87 2.
DETERMINE WHETHER THE ISSUES IDENTIFIED IN OIA REPORT 86-10 WERE 1
APPROPRIATELY HANDLED AS TO PROCESS AND DISPOSITION
/ "th c?nd d b %i W U-L4i.
.. an integral part of 4he report,4:: ling - *
}
ith ::fet; i; i:::::.
f-n mea -.1.,stJAm i
"" di:;;;iti.... u J fy. d alt: J.;.ith the safety aspects of
{
each issue as to significance and corrective action. This may entail on-site review and examination by or for the CPRRG.
j
/.
- 3. dixxitir[TheE; fort will deal also with whether an item was 6ppropriateTy categorized within the IE report system and how the I
I item was eventually closed or resolved (or its current status), as (demonstratedintherecord.
3.
IDENTIFY THE SAFETY SIGNIFICANCE OF THE ISSUES IDENTIFIED IN OIA REPORT 86-10.
l L
m
' Review eacn of tne 34 1ssues identified in attachment MM to 0IA l
t 86-10.
j b.
Evaluate the est case consequence and safety 5 icance of each issue as presen n OIA Report 86-10, ass 9 that the condition existed without recog
. on or correct c.
Determine the disposition of sue.
t d.
Express an opinion on e adequacy of the ns that were taken or are planned to a ate the concerns associate h each issue.
e.
Provi rationale for the opinion.
f Evaluate the safety significance of new concerns identified by other I
14 cat 5 add in. -& y-7~ d9p*l^*2*** pC MC A*** 'W g Mg f f.
REVIEW THE PURPOSE AND SIGNIFICANCE OF NRC FORM 766 4
W b ": C"aac h;; obtained assistance from IRM in r::f rin; the p r;::: C.
th: 755 UM-:-
'h t Tri;^ aill eddie fell. ! +
. ;g:-
ine intenaeo purpose and use of the 766 System.
b.
Det e if the current use of the 766 S m by both H dquarters and Regioi Office management is cons ent with the int nded pur-pose. Does t ting 766 Syste t the stated purpos ? What reasonable use can be of 766 System?
c.
If the 766 system does fulfi intended purpose and f this l
purpose is necessa or an effective tion and Enfore nt i
program, how a hese objectives currently be accomplished
(
4 CPRRG CHARTER 3
DRAFT 3 RErickson/bc 4
02/11/87 1-,
I-alteniauva =d rem-endations for the continuation of thWV a.
System in order to utih:Q GC neaoquarters and Regional
\\
Wt.
l r
In addition, the CPRRG will address the following:
i g ]J 1
)
5.
JUDGMENT ON BROADER IMPLICATIONS IN REGION V.
HW d
Without expanding the specific tasks, ive the CPRRG will offer,fou.its.,
v judgment on whether it is likely ee+ there are broader implications in i
Region IV /s J 46. A r -6 8 cal, g 9,
f Your memorandum of January 21, 1987 requested a report by February 20, 1987.
We expect to have the relevant information collected by then. However, we request additional time, until March 13, 1987, to allow for adequate research and documentation of the issues and overall evaluation and integration of the findings. The CPRRG also needs this time to meet with OIA, Region IV and others, to verify our information and distill it into a suitable final report.
ep
& Jtf'- 4 Unless I hear from you, I will proceed on the assumption that Wt w:p"ntad te i
W de, as stated above, is satisfactory.
"/-
Guy A. Arlotto, Chairman Comanche Peak Review Group
Enclosure:
List of Principal Participants and Schedule cc:
T. Murley, RI J. Keppler, RIII R. Martin, RIV E. Beckjord, RES W. Mcdonald IRM J. Taylor, IE H. Denton, NRR R. Scroggins, IRM C. Paperiello, RIII C. Heltemes, AEOD J. Lieberman, OGC 1
J. Goldberg, OGC R. Erickson, NMSS P. McKee, IE S. Collins, RIII
{
t
(
CPRRG CHARTER 2
DRAFT RErickson/bc I
02/03/87 The CPRRG intends to accomplish its first three tasks as follows:
To rely principally on the OIA Report 86-10 and information to be
. submitted to the CPRRG to perform its tasks.- The CPRRG does not intend to perform an independent investigation but will request information, review records and documentation, and interview as needed to perform its mission. We have organized three task groups respectively dedicated to these tasks.
1.
IDENTIFY THE SAFETY SIGNIFICANCE OF THE ISSUES IDENTIFIED IN OIA REPORT 86 10.
a.
Review each issue and define it in specific terms.
b.
Evaluate the safety significance of the issue using NRC staff and consultants as appropriate.
c.
Determine the disposition of each issue.
d.
Express an opinion on each issue.
e.
Provide a rationale for its opinion.
2.
DETERMINE WHETHER THE ISSUES IDENTIFIED IN OIA REPORT 86 10 WERE APPROPRIATELY HANDLED AS TO PROCESS AND DISPOSITION a.
This determination will be an integral part of the report dealing with safety significance.
b.
By disposition, the report will deal with the safety aspects of the issue as to significance and corrective action. This may entail on-site review and examination by or for CPRRG.
OFC :
NAME :
DATE :02/03/87
(
9 W----
CPRRG CHARTER 3
DRAFT RErickson/bc 02/03/87 at.
By disposition, the report will deal also with whether an item was l
appropriately categorized within the IE report system and how the item was eventually closed or resolved (or its current status).
3.
DETERMINE WHETHER THE CURRENT AUGMENTED REVIEW AND INSPECTION EFFORT AT COMANCHE PEAK IS SUFFICIENT TO COMPENSATE FOR ANY IDENTIFIED WEAKNESSES l
IN REGION IV'S QA INSPECTION PROGRAMS.
a.
The CPRRG will accept the existing IE construction inspection program as the standard against which the efforts at Comenche Peak will be compared. The CPRRG does not intend to attempt to identify the IE inspections requirements that existed at the time an inspection should have been performed, b.
The inspections actually performed by Region IV of those activities and items at Comanche Peak will be compared against the current IE construction inspection program in terms of coverage of inspection obiectives or requirements.
c.
The inspections actually performed by the Comanche Peak Project Office and any other elements of NRC (such as inspections managed by IE Headquarters. XhR, or other Regions) will be compared against the current IE construction inspection program in terms of coverage of inspection objectives or requirements, d.
The report will identify whether the inspections actually performed result in an inspection effort at Comanche Peak which is equivalent to the current IE construction inspection program. The report will identify when the program falls short and when it exceeds the IE defined program.
e.
The CPRRG will not review the technical findings cf the inspection program actually performed as to demonstrating the adequecy of the OFC :
NAME :
DATE :02/03/87
..,,... ~
~.,,
-CPRRG CHARTER 4
DRAFT RErickson/bc 02/03/87 IE: defined program or demonstrating the quality of the plant.
4..
REVIEW THE PURPOSE AND. SIGNIFICANCE OF NRC FORM 766 The'CPRRG has obtained assistance from IRM in reviewing the purpose and
-significance of the 766 system. That review will address the fo'110 wing:
a.
The intended purpose and use of the 766 System.
b.
Determine if the current use of the 766 System by both Headquarters and Regional Office management is consistent with the intended purpose.
Does the existing 766 System meet the stated purpose?
If the 766 system does fulfill its intended purpose and if this
(
c.
purpose is necessary for an effective Inspection and Enforcement program, how are these obje'ctives currently being accomplished?
d.
Alternatives and recommendations for the continuation of the NRC 766 System in order to satisfy the needs of NRC Headquarters and Regional Office management.
Your memorandum of January 21, 1987 requested a report by February 20, 1987 We expect to have the relevant information collected by then. However, we request additional time, until March 13, 1987, to allow the CPRRG to meet with OIA, Region IV and others, to verify our information and distill it into a suitable final report.
ilohn G. Davis, Director Office of Nuclear Material Safety and Safeguards OFC :
NAME :
DATE :02/03/87.
1(
CPRRG CHARTER 5
DRAFT RErickson/bc 02/03/87
Enclosure:
List of Principal Participants and Schedule cc:
E. Beckjord, RES W.~ Mcdonald, IRM R. Martin, RIV G. Arlotto, RES R. Scroggins, IRM J. Taylor, IE H. Denton, NRR J. Keppler, RIII T. Murley, RI C. Paperiello, RIII C. Heltemes, AE00 4
I
.OFC NAME :
i
_____:-__.........:..____......:.__.........:.___________.r..___....:....________:. _______
DATE :02/03/87
- /
}
l l
COMANCHE PEAK OIA REPORT 86-10 REVIEW GROUP (CPRRG)
Principal Participants.
John G. Davis, NMSS Chairman Guy A. Arlotto, RES Clemens J. Heltemes, AE00 Carl J. Paperiello,_R-III James Liebennan, OGC l
Jack R. Goldberg, OGC Legal Advisors Robert A. Erickson, NMSS Coordinator Phillip F. McKee, IE, Leader Inspection Assessment Task Group Samuel J._ Collins, R-I, Leader j
Issue Handling and Process Task Group Dennis M. Crutchfield, NRR, Leader Safety Significance Task Group Richard A. Hartfield, IRM, leader 766 System Review Group Schedule Complete Issue Handling and Process Task February 10, 1987 Complete Inspection Assessment Task February 13, 1987 Complete Safety Significance Task February 17, 1987 Complete 766 System Review Task February 17, 1987 Assemble and Integrate Information February 27, 1987 Verify and Augment Infonnation March 6, 1987 Complete Final Report March 13, 1987 1
ORAFT 02/03/87 1
CPRRG CHARTER MEMO ENCLOSURE
~l JN t NITED STATES
/N
/
NUCLEAR REGULATORY COMMISSION j
$ ' I., t WASHINGTON, D. C. 20555
- N l/
?
o
%f..u ORAFT:01/30/87 MEMORANDUM FOR:
William G. Mcdonald, Acting Director Office of Information Resources Management l
FROM:
John G. Davis, Director Office of Nuclear Material Safety and Safeguards
SUBJECT:
COMANCHE PEAK REPORT REVIEW GROUP (CPRRG) TASK RG IRM-01 By a memorandum of January 21, 1987, entitled OIA REPORT REVIEW: OIA FILE 486-10-ESTABLISHMENT OF REVIEW GROUP the Executive Director for Operations assigned'to the CPRRG the task of reviewing the purpose and significance of the computer-based NRC 766 System and make appropriate recommendations concerning its use. A copy of the ED0's memorandum is attached.
In order to assist the CPRRG in the accomplishment of this task, we reauest that you assign appropriate personnel to examine the NRC 766 System purpose and use and provide the CPRRG with a report that includes the following:
1.
The intended purpose and use of the 766 System.
2.
Determine if the current use of the 766 System by both Headquarters and Regional Office management is consistent with the intended purpose. Does the existing 766 System meet the stated purpose?
3.
If the 766 System does not fulfill its intended purpose and if this purpose is necessary for an effective Inspection and Enforcement program, how are these objectives currently being accomplished?
(.
William G. Mcdonald 4.
Alternatives and recommendations for the continuation of.the NRC 766 System in order to satisfy the needs of NRC Headquarters and Regional Office management.
i In performing this task, please document the basis for your conclusions or opinions.
In developing this basis you should, as appropriate, interview members of the IE and Regional Office staffs.
Your draft report should be submitted to the CPRPG by February 17, 1987.
John G. Davis, Director Office of Nuclear Material Safety and Safeguards
Attachment:
As stated l
FEB 02 '87 14257 HRC KING OF PRUSSIA P02 i
Task G2-02 2-1 (2/02/87) l TASK GROUP 2 TASK FOR EXAMINATION OF ISSUES RELATING TO PROCESS AND DISPOSITION OF INSPECTION FINDINGS OF OIA REPORT 86-10 This task relates to exarnination of the 34 issues of Attachment 1 to Attachment i
MM of OIA Report 86-10 and any additional relative issues revealed by the q
activities of Task Group 1 as a result of activities under Item 5 (and docu-mented in Item 6e) of the Task 1 description.
The basic task is to review the processing and disposition of issues and
' nspections findings in the Region IV inspection of the Comanche Peak project i
and to compare the actual processing against the identified policy or practices of the NRC, IE, and Region IV.
3p. 1 l'
As a minimum, the Task Group will have available to it:
1.
CPRRG-7, the information from IE in response to CPPKU Letter HU 1h-U2.
This information establishes the basis from IE for inspection reporting; item identification, classification and disposition; and responsibilities for inspection performance and reporting.
l FEB.02 '87 14:57 NRC KING OF PRUSSIA P03
(
I Draft 2-2(2/02/87) 2.
CPARG-8, the information from Region IV in response to CPPRG Letter AG RIV-02.
This information establishes the basis from Region IV for inspection reporting; item identification, classification and disposition.
l and responsibilities for inspection performance and reporting.
p fj Z) f 8 M 3.
Information from grelative to NRC policy and practices for processing and disposition of issues and inspection findings, this shall be forwarded to Task 2 by CPRRG 1etter.
4.
The.information of specific process.ind disposition issues from OIA Report 86-10 (essentially the 34 issues in Attachment I to Attachment MM of OIA Report 86-10).
5.
Any process and disposition issues forwarded to Task Group 2 from the work of Task Group 1, this shall be forwarded to Task 2 by CPRRG 1etter.
Insofar as possible, the performance of this task should rely on the written record where that record provides sufficient information to support conclu-it is necessary to = Q= =ad this record, thiCh;. M L dvowy &A&M &m&.
d in stons. Wher r/ fit.**v4/
A M -A4
=diaeuen,,10. 000.
n"$lr1 4
FEB 02 f87.'14s57 NRC KING OF PRUSSIA P.04 S
NN f Ap MAsp4.
rex ro.- W s.
2-3 ( /
- 87) -
ThisTaskGroupshail:
1.
Review information provided by IE, Region IV, the Comanche Peak the primary or source documeh to Project Office or others st become familiar with the inyet cigation and CPRRG record. Where applicable, assess the accuraci and completeness of the records provided.
2.
Identify the specific process and disposition issues from OIA Report 86-10 (34 issues of Attachment 1 to Attachment 2 ).
3.
Analyze each issue, independent ssess and describe the process and 4 gg disposition by which the item should have been handled.
Identify the at process, guidance or practice that was used in making this indepen-dont determination.
4.
Analyze the actual process and disposition of each issue.
Describe the prncPss by which it actually was handled including where appli-cable, the identification and classification as a finding (with references) by the inspector, inclusion in the draf t reports, eval-uation by Region IV management and inclusion in the final report.
Particular attention and discussion will be provided to ' items where there is an absence of agreement on process or disposition. The basis for the disagreement and documentation there3f, including timeliness of review, signature, concurrences and report issuance will be described.
. ~
a
FEB 02 '87.14:58 NRC KING OF PRUSSIA P05
(
Draft I
2-4 (2/02/87) -
5.
In a itiontodescribingtheaboveprocesstheTask rt wili: M i
a M
d"--'7";.. ef how the task was performed.
a.
A b.
Identify where there are dif ferences between &gency guidance, IE guidance, and Region IV guidance and areas where guidance does not exist or is subject to wide interpretations.
Include i
where applicable.
Where and how this failure to follow guidance has occurred.
For items of disagreement, express an opinion on whether the guidance for process and disposition was, or was not, followed.
For disagreement for which no guidance exists, express an opinion or the appropriateness of the process and disposition actually performed in light of the signi-l ficance and implications of the disagreement.
Where guidance does not exist, express an opinion as to what guidance is needed.
Where guidance does exist, but there are differing inter-pretations, recomend a course of action.
i
m EB 02 '87 14:58-NRC KING OF PRUSSIA P06 Draft 2-5(2/02/87) l Schedule 1/20/87 Task Leader appointed 1/29/87-Membership, Organization & Approach established 1/31/87 Start work on example (ptiot effort) 6 2/0//87 Review pilot effort with CPRRG 2/05/87 Check for possible impact of Ta!.k I on Task 2 2/10/87 Task 2 report complete, provided to cPRRG i
l 4
l l
l
(
p i
TASK GROUP 1 TASK FOR DETERMINING WHETHER THE CURRENT AUGMENTED REVIEW AND INSPECTION EFFORT AT COMANCHE PEAK IS SUFFICIENT TO COMPENSATE FOR ANY IDENTIFIED WEAKNESSES IF l
REGION IV's INSPECTION PROGRAMS NOTE Performance of this task accepts as the baseline or standard the existing IE construction inspection program as identified by IE in response to the Comanche Peak Report Review Group (CPRRG) Letter RE IE-01.
It is against this baseline that the efforts at Comanche Peak will be compared.
The basic task is to identify and report whether the total 6gency review and inspection effort at Comanche Peak, meets or is equivalent to, the l
current IE construction inspection program.
1 l
The Task Group will have available to it:
l
- 1..
The information from IE (CPRRG-6 and 7) in response to CPPRG Letter
]
RG IE-01. This information establishes the data base to be evaluated and compared to the scope of inspection and review activities perfor-
\\
med at Comanche Peak.
l l
o
l l(
- 2.-
l l
l 2.
The information from Region IV in response to CPPRG Letter
.RG RIV-01 (CPRRG-8). This information provides the Region's view of the inspection performance by the Region against the IE construc-tion inspection requirements (MC 2512).
3.
The information from the Comanche Peak Letter RG-P0-01 (CRRRG-9).
f This information provides the Project Office's view of its perfor-4 mance against MC 2512.
4 Basic inspection documentation (reports and related documents) or input from individuals who performed or managed inspection or review activities at Comanche Peak.
The performance of this. task should rely on the written record where that record provides sufficient information to support conclusions. Where it is necessary l
to supplement this record, any additional information obtained should be clearly documented.
In addition to personnel resources available within the agency, Task Group 1 j
whenever necessary or desirable, may use contracted expertise to provide assis-tance as needed.
1 4
l
(
. This Task Group shall:
1.
Selectively audit information provided by IE, Region IV, the Comanche l
Peak project Office and others against the primary or source document or other information 'to assess the accuracy and completeness of the
[.
input provided.
l 2.
Compare the review and inspection efforts accomplished by'(a) l Pegion IV; (b) the Comanche Peak Project Office (CPP0); (c) any other elements of NRC (such as inspections managed by IE Head-quarters NRR, or other Regions) against the current construction inspection program of IE.
This comparison shall be in terms of coverage of inspection objectives or requirements.
3.
With respect to accomplishment of the inspection requirements or objectives of the current construction inspection program, identify:
(a) Whether or not inspections performed by Region IV inspectors covered the requirements of the current inspection program.
l (b) Whether inspections or reviews performed by any other elements of NRC covered the requirements or objectives of the current inspection program.
i I
mm -
mmm.
(
i I
l 1
The report should provide references to documents with information that provided the basis for the identification of inspection per-formance for iteins (a) and (b) above.
If in the judgement of the task group a requirement was only partially covered by inspections performed by Region IV, the report should, if available, state basis for the determination.
i 4.
Identify where inspection and reviews conducted as part of the CPRT' program demonstrate the accomplishment of the objectives or require-ments of MC 2512.
Particular attention should be given to those inspection program requirements found not to be covered or only partially covered by Region IV or other NRC inspections or reviews.
The report should provide references to document information that provided the basis for the identification of inspection performance.
5.
For selected inspection attributes, conduct a detailed evaluation and comparison of the records addressing completion of PC 2512.
This evaluation and comparison shall be in tenns of level of effort and timeliness of inspection or review.
6.
If the review of inspection program accomplishment (Items 2, 3, 4,-and 5) identifies inspection findings where questions are
)
4
i raised on the ' adequacy of closecut of the findings, these issues should immediately be brought to the attention of Task Group 2 and 3.
7.
Report on the task efforts:
a.
Describe how the task was performed.
b.
Identify the information on which the task group's conclu-sions are based. This should describe the results of activities to assure the accuracy of the information base, c.
Provide as complete as possible specific references to the information that served as the basis for the conclusions and findings.
d.
For inspection requirements and objectives of the current construction inspection program:
(1)
Identify where Region IV's inspection program did not cover or, in th.e judgment of the Task Group, only partially covered the inspection program j
requirements.
For areas identified as being I
only partiall'y covered, state the rationale for J
that determination.
j f
(2)
Identify those inspections or reviews performed
']
f
^
by other elements of the NRC that in the task groups judgement adeouately covered the reovire-ments or the objectives of the inspection program.
]
l (d)
Identify those efforts conducted as part of the CPRT program that in the task groups judgement demonstrate accomplishment of the objectives of the inspection program.
(4)
Identify the Task Group conclusion on the sufficiency of the efforts reported as part of (2) and (3) above to compensate for eny identified weaknesses in Region IV's inspection program.
l l
7 i v/
C/
U u
k ZD
}
O K SI /p PROCESSING INSPECTION FINDINGS gg,
~~
RErickson/hc A@
l
~
01/30/87 i
MEMORANDUM FOR:
' James H. Sniezek, Deputy Executive Director For Regional Operations l
FROM:
John G. Davis, Chairman.
j Comanche Peak Report Review Group (CPRRG)
]
SUBJECT:
NRC POLICY AND PROCEDURES FOR PROCESSING INSPECTION FINDINGS 1
.As you know, the CPRRG has been asked to review issues raised by OIA Report 86-10, x
including Region IV's handling of inspection findings pertaining to Comanche Peek.
IE has already provided the CPRRG information regarding means for resolv-l f
ing differences of opiniodh or positions arising from inspections and inspection i
reports.
l However, to assure that we consider all pertinent guidance in our review, we would appreciate assistance from your staff in identifying any DEDROGR directives or other NRC policy statements relevant to Regional Office processing of inspec.
tion findings.
l The staff contact person for the CPRRG is Bob Erickson (X-74194).
John G. Davis, Chairman Comanche Peak Report Review Group l
l DRAFT
,i d
it
)FC :
(AME :
) ATE :
e
^
e.C l Y."
,g_
V f
A U l yp;
-c
- t c.
y a._
., ~
t C DRAFT #1 i".
<dGDavis:bsp
'i1/27/87
?/ ~,. '
lh f
4 j.F.ENORANDUM FORi $1111am G. Mcdonald,3 /" A, et /, 4 - d, b re.
/k,,,.. p,. /
p
+
FROM:
- John G.
avis. /e'en"
+
~
y a 2
jCOMAtbHEPEAK'REPORTREVIEW00 [f7EE(CPRRO) TASK--P.CRM-Of
SUBJECT:
j
},
By c yemorandum of January 21, 1987, entitled OIA REPORT REVIEW: OIA FILE
- 86-10-ESTABhlSHMENT OF REVIEW GROUP the Executive Director for Operations 1
- ) - assigned to the CPRRC, the task of reviewing the purpcse imd significance of NRC Form 766 and mne appropriate recommendations dbE1certifog its use.
A @py'of the ED0's memorandum is attached.
i 1
In 6rder to assist the CPRRG in'thelaccomplishment 'ofJ hi5 task,'we request t
s
_ ~.
f n 7 that you assign appropriate personnel to examine the NRC Form 766 purpo'se and
- ~
a.44e g,1w-piirp d /a4 f~ h gh.. # port'that S-1;ddi-the. fol lo the CPRRG wi re 4
use and provi C
i ose o'f the NRC. Form 7f 6 program.
1.
T lher-u.t.LC O/
l nth:r ;. c.c'. the NRC Form 766 program currently meets 'ts "tr ^" -
d 2
u Ly M dso. /.d/hk/ib%t mee't this purpo3ej&::Le.,, Atphah l
c not,;djt=:
P t, r
? J pu pose.
Cml V
w i
est ate of. 2-relianceAtA#v cx b p! = # on the i,nf ation within 1
M, W M do FrNWtt r1 </4 y 4 "n g
the D7/ Grm %A />.f wm.
%;i a
3.
If the NRC Fom 766 program does not fulfill its 'ntxd:d purpose and if J
l
)'
its purpose is necessary to the functioning of the Office of Inspection l
c#d Enforcement arid of the Regional Office programs ow is this purpose currently being accomplished?
- 4. -I+-tM-Hnc icini 7F gegra dc= =t ful fill. b inihadcipurpase, should de lt the NRC Form 766 programrt;la, mcEf ted to perform its "trded purposej l
, tmd; if so, what modifications appear 4 appropriate?
ty in a s;.,..,,
1 1
,l
.r i
j
m
(
i William G. Mcdonald 700 prograiii dee5 net fulfill its }'r.tendid purp Mthe NK Ter ni (c
c-end ;i Jues not appear appropriate to mociry i-t, hat alternative a zz a vn:/a K v meansofaccomplishmentrppear;;;r;;ot:?fMw:f, a
In perfonning this task, please document the basis for your conclusions or opinions.
In developing this basis you should, as appropriate, interview members.
of the IE and Regional Office staffs.
Your report should be submitted to the CPRRG by February 9,1987.
John G. Davis
Enclosure:
As stated i
i l
w
(
p ys s j w
- J r[
a p
d, MEMORANDUM FOR:
Jack R. Goldberg Deputy Assistant General Cou el for Enforcement Group (CPMG')
FROM:
John G. Davis, Chairman Comanche Peak Report Revie 1
SUBJECT:
ISSUES RAISED BY OIA REPO T 86-10 HAVING BROADER IMPLICATIONS FOR GION IV' In the Chai rean's January 16, 1987, memo ndum to the EDO, the Commission requested the CPRRG to offer he EDO its judgement on whether the problems identified at Comanehe Peak are isolated or there are hroader implications in Region IV.
The CPRRG requests OGC's completed review of the OIA repord, Specifically, based on OGC assistance in addressing this issue.
what issues, if any, are raised /which the CFRRG abould consider as potentially having
" broader" implications for Region IV7 OGC's suggestions, as well 1
as those of others, will be valuable to the CPRRG in reaching its
'f have proad implications.
M E M. __,"IO w.4,t.4es4/rfw he judgement 4
The CPRRG appreciates your assistance on this matter.
j j
NOTE:
OGC's response will identify four issuest.
1.
Regional management's interaction with inspectors and j
management's role in reviewing, revising, and approving inspection reports.
2.
Any identified fmilures of Region IV to carry out e
inspection modules.
3.
Whether Region IV treated Comanche Peak differently from other plaatse 4.
The state of the NRC Forn 766 system at Region IV.
sevD/NG-snadR 06%F16Vn-7Mk i94so svGces7T
/yb ogg [cppG 077MRS Stc.W s4s..Z~E wy,,,, asx eiescr.r sseuw orisseee wiwrxee rier w(erez R 6tP O W 7"O fjgyg gwyyrfind SEM'wG w 7?M DuoWG 77/ eta? JeEV/W*
e e
4
l A
J 1-2 performance of the Region against the IE construction inspection' requirements.
3.
The information from the Comanche Peak Letter RG-P0-01. This i
information provides the Project Office's view of its perfomance against the IE construction inspection requirements.
4.
Basic inspection documentation and individuals who performed or reviewed inspections or supervised or managed the inspection program for Comanche Peak.
Insofar as possible, the performance of this task should rely on the written record where that record provides sufficient information to support conclusions. Where it is necessary to extend this record, this should be done in writing or by interview. Transcripts are to be made of interviews.
In addition to skills available within the agency, Task Group 1, whenever necessary or desirable, may use outside experts 'to provide needed skills and objectivity.
This Task Group shall:
1.
Audit information provided by IE, Region IV, the Comanche Peak Project Office and others against the primary or source document or
V
{
a 1-3 information to assess the accuracy and completeness of the input provided.
2.
Compare the scope, frequency and skill depth of inspections 'y (a) b Region IV; (b) the Comanche Peak Pro,iect Office (CPP0); (c) any other elements of'NRC (such as inspections managed by IE Headquarters, NRR, or other Regions) against the current construction inspection program of-IE. This comparison shall be in terms of specific items or l
activities, skill depth and timeliness.
3.
Identify where inspection performance:
(a) meets IE' program requirements (b) exceeds IE program requirements
]
(c) does not meet IE program requirements.
(
In the report of this task, complete and specific references should be provided to documented information that provided the basis for the identification of inspection performance.
If a requirement was only partially met, the report should so indicate and explain. For any
]
current program requirements not met through Region IV or CPPO activities, specify the requirements in effect at the time of the inspection if different from current requirements and describe the degree to which the then existing inspection requirement was' fulfilled.
1-4 4.
Describe specific inspection requirements which have not been
~
completely fulfilled by the agency's to::a1 inspection effort. This complete fulfillment is with regard to activity, skills, timeliness, and completeness. References are to be made to requirements in the IE defined program and to inspection reports (regardless of by whom performed and' reported) so that information on nature and degree of any incomplete status of any current inspection requirements can be identified.
5.
Identify inspection findings or results that showed "open" items, unresolved items, items of noncompliance, violation or any other finding or conclusion where the inspection activity is not " closed."
Track the documentation of these items from identification to current status.
Report on whether the significance or description of the item has been changed and whether the status and decision on items are documented.
(Particular emphasis should be placed on items identified which cannot be tracked to current status or closure.)
i 6.
Report on the task efforts:
a.
Describe how the task was performed.
b.
Identify the information base on which the task group's conclusions are based. This should describe the results of activities to assure the accuracy of the information base.
i 1-5 c.
Provide complete and specific references to the information that served as the basis for the conclusions and findings.
d, Where the conclusion is that inspection performance does not meet current IE program requirements, specify, in detail with references, where and how the performance 'is deficient.
e.
Where the inspection findings or results have been modified from initial identification to closure or current status, specify, in detail with references, where the modifications have occurred.
Schedule 1/20/87 Task Leader appointed 1/?2/87 Membership, Organization & Approach established 1/23/87 Stort work on example (pilot effort) 1/27/87 Resiew pilot effort with CPRRG 1/30/87 Check for possible impact of Task I on Task 2 10 l
2//'87 Submit final report to CPRRG
/
O
2-1 (1/20/87)
TASK GROUP 2 s
TASK FOR EXAMINATION OF ISSUES RELATING TO PROCESS AND DISPOSITION OF l
INSPECTION FINDINGS OF OIA REPORT 86-10 te :
This task relates to examination of the 34 issues of Attachment 1 to Attachment MM of OIA Report 86-10 and any additional process and disposition issues revealed by the activities of Task Group 1.
These Task Group 1 issues would be as a result of Task Group 1 activities under Item 5 (and documented in Item 6e) of the task description TASK GROUP 1-TASK FOR DETERMINING WHETHER THE CURRENT AUGMENTED REVIEW AND INSPECTION EFFORT AT COMANCHE PEAK IS SUFFICIENT TO COMPENSATE FOR ANY IDENTIFIED WEAKNESSES IN REGION IV's INSPECTION PROGRAM The basic task is to identify the processing and disposition of issues and inspections findings in the. Region IV inspection of Comanche Peak reactor and to compare the actual processing against policy or practices of the NRC, IE, and Region IV.
1 i
The Task Group will have available to it:
l l
I 2-2 l
\\l' 1.
The.information from IE in response to CPPRG Letter RG IE-02. This infomation establishes the basis from IE for inspection reporting; item identification, classification and disposition; and responsibilities for inspection performance and reporting.
2.
The infonnation from Region IV in response to CpPRG Letter RG RIV-02.
This information establishes the basis from Region IV for inspection i
reporting; item identification, classification and disposition, and responsibilities for inspection performance and reporting, j
3.
Any information from OGC relative to NRC policy and practices for processing and disposition of issues and inspection findings.
4.
The information of specific process and disposition issues from OIA i
Report 86-10 (essentially the 34 issues in Attachment I to Attachment MM of OIA Report 86-10).
5.
Any process and disposition issues from the work of Task Group 1.
l 6.
Basic inspection and enforcement documentation and individuals who are involved in the process of identifying, processing, and disposing of inspection findings and issues.
)
i l
l l
2-3 l
l Insofar as possible, the performance of this task should rely on the written record where that record provides sufficient information to support conclusions. Where it is necessary to extend this record, this should be done in writing or by interview, Transcripts are to be made of interviews.
This Task Group shall:
1.
Audit information rvovided by IE, Region IV, the Comanche Peak Project Office or others against the primary or source document or information to assess the accuracy and completeness of the input provided.
2.
Analyze each issue and describe the process by which it actually was handled. This relates to its identification as an inspection
" finding" (or other result of an inspection), classification as to analysis should show (with complete and specific references) the item from the point of identification by the. inspector, inclusion in field notes, and draft reports to the final report, any tracking or monitoring system used by the inspector, supervisors, or the Region to maintnin awareness of the item and its status.
For these items where there is an abserce of agreement on process or disposition, identify the basis for the disagreement and any record of disagreement and its processing.
Particular attention should be given to signatures and concurrences and timeliness of these l
l s
j 2-4 l
p l
signatures and concurrences in relationship to changes in documentation.
3.
Analyze each issue and independently describe the process and disposition by which the item should have been handled. Reference the guidance or practice th'at was used in making this independent determination.
Compare this independent determination with the handling and disposition that actually occurred. Where there are differences in the process and disposition between what independent determination describes and what actually occurred, explain the differences.
Reference reports, guidance, practices that provide the basis for these explanations.
'4.
Report on the task efforts:
a.
Describe how the task was performed.
b.
Identify the infomation base on which the task group's conclusions are based. This should describe the results of activities to assure the accuracy of the infomation base.
Provide complete and specific references to the information that c.
served as the basis for the conclusions and findings.
t.
^I
\\
t 2-5 i
I d.
Identify where there are differences between agency guidance, IE guidance, and Region IV guidance and areas where guidance does not exist or is subject to wide, interpretations.
4 e.
Where the conclusion is that identification, processing, and disposition have not followed expressed agency, IE, or Region IV guidance, specify, in detail and with references, where and how this failure to follow guidance has occurred.
f.
For items of disagreement involving disposition or the handling of changes in the report or records, describe the disagreement and_ express an opinion on whether the guidance for process and j
disposition was, or was not, followed.
For disagreement for which no guidance exists, express an opinion on the appropriateness of the process and disposition actually performed.in light of the significance and implications of the disagreement.
g.
Where guidance does not exist, express an opinion as to what guidance is needed, h.
Where guidance does exist, but there are differing interpretations, recommend a course ~o'f action.
-i 4
'.g 2-6 a.
Schedule '
1/20/87 Task Leader appointed 1/22/87 Membership, Organization & Approach estblished 1/23/87-Start work on example (pilot effort) 1/27/87 Review pilot effort with CPRRG 1/30/87 Check for possible impact of Task 1 on Task 2 2/ /87 Submit final report on CPRRG i
I
\\
3-1 (1/20/86)
TASK GROUP 3 TASK FOR EXAMINATION RELATIVE TO SAFETY SIGNIFICANCE OF ISSUES OF OIA REPORT 86-10 This task relates to examination for safety significance of the 34 issues of i to Attachment MM of OIA Report 86-10 and the safety significance of any additional issues revealed by the activities of Task Group 1 and Task Group 2.
The efforts relative to Task Group I would be to describe the safety significance of failure by.the agency to perform inspection requirements of the IE construction inspection program, particularly these requirements which cannot now be fully performed due to the extent of the plant completion. These items would be the result of Task Group 1 activities under Items 4 and 5 (and described in Item 6d) of the task descriptica TASK GROUP 1-TASK FOR DETERMINING WHETHER THE' CURRENT AUGMENTED REVIEW AND INSPECTION EFFORT AT COMANCHE PEAK IS SUFFICIENT TO COMPENSATE FOR ANY IDENTIFIED WEAKNESSES IN REGION IV's INSPECTION PROGRAMS.
In addition, the efforts relative to Task Group 2 would be the safety significance of process and disposition issues identified by Task Group 2.
These items would be the result of Task Group 2 activities under Items 1 and 2 (and described in Items 4e and f) of task performance in the task description TASK GROUP 2-TASK FOR EXAMINATION OF ISSUES RELATING TO PROCESS AND DISPOSITION OF INSPECTION FINDINGS OF OIA REPORT 86-10.
The Task Group will have available to it:
1.
The information of issues from OIA Report 86-10 (essentially the 34 issues in Attachment I to Attachment MM of OIA Report 86-10).
u 1
3-2 2.
Any other issues needing safety significance review from the work of Task Group 1.
I 3.
Any other issues' needing safety significance review from the work of Task Group 2.
4.
Basic inspection and ifcensing information and individuals knowledgeable of issues.
i Insofar as possible, the performance of this task should rely on the written record where that record provides sufficient information to support conclusions. When it is necessary to extend this record, this should be done in writing or by interview. Transcripts are to be made cf interviews.
In addition to skills available within the agency, Task Group 3, whenever necessary or desirable, should use outside experts to provide needed skills and objectivity.
This Task Group shall:
1.
Analyze each issue and describe its safety significance to the Comanche Peak reactor assuming that the condition of the issue is as stated in OIA Report 86-10. The purpose of this analys'is is to specify the " worst safety case" that may result assuming that the issue exists as stated without correction or recognition that the adverse situation exists, that.is, as if it existed and was undetected.
In this analysis, provide complete and specific i
references that serve as the basis for determination of safet) significance.
b
4 3-3 2.
Analyze the actions which were taken or which are planned to be taken to alleviate any safety significance asiociated with each of the 34 issues at Comanche Peak identified in 01A Report 86-10.
In this analysis, give references to reports and other documents that serve as the basis for determining'the actions taken or planned and their effect in alleviating concerns.
Evaluate the actions to determine the extent to which they alleviate _or resolve the safety concern.
If the actions taken or planned do not sufficiently alleviate the safety j
concerns, describe actions which, if taken, would alleviate the concerns.
Give. references in support of opinions or conclusions regarding corrective actions.
l 3.
Evaluate the safety significance of the failure to completely perform the inspection requirement in accordance with the IE construction inspection program.
(Note:
The input for this item will come from 1
Task Force 1.) The analysis should take into account all inspection j
1 activities associated with an incomplete or non-performed item.
Safety concerns should be described.
If agency actions alleviate concerns, these should be described.
If the actions taken or planned do not alleviate concerns, describe actions which, if taken, would
]
alleviate concerns.
4.
Evaluate the safety significance of items identified by Task Force 2 that were not processed according to guidance or which are in dispute as to correctness of processing and disposition. All safety concerns should be identified.
If actions have alleviated these concerns, these actions should be described.
If no action has been taken or if actions taken or planned do not alleviate the concern, describe actions which, if taken, would alleviate concerns.
k 3-4'
)
5.
Report on the task efforts:
l a.
Describe how the task was performed.
t b.
Identify the information base on which the task group's are j
based. This should describe any auditing to assure the accuracy of the information base.
1 Provide' complete and specific references to the information that c.
serves as the basis for conclusions and findings.
- d..
Highlight any safety significance issues where agency actions or plans may not alleviate safety concerns.
Schedule 1/20/87 Task Leader appointed 1/22/87 Membership, Organization & Approach established 1/23/87 Start work on example (pilot effort) 1/27/87 Review pilot effort with CPRRG 2/5/87 Analyze reports of Tasks 1 and 2.
Factor into Task 3 2/9/87 Submit final report to CPRRG
- _ _ _ _ _ _ _ - _ _ _ _ _. _ _ _ =.
(
gyg i
PEMOPANDUM FOR:
Robert D. Partin, Regional Administrator k,w 4
1 Region IV FPOM:
Jchn G. Davis, Chairman
)
Comanche Peak Report Review Group
SUBJECT:
INFORMATION FOR COMANCHE PEAK OIA REPORT 86-10 PEVIEW GROUP -- RG RIV-01 1
i In order that the Comanche Peak OIA Report 86-10 Review Group (CPRRG) can proceed with its review, the following information concerning the Comanche Peak project since its inception is requested of you:
1.
A report on the extent to which the activities of Region IV at Comanche Peak covered the scope and requirements of the current IE 42: lit; :::er
.enee construction inspection program (i.e., the IE inspection require-i ments).
It should be noted that this request covers the IE ;;P't;
)
.+eetreeeee construction inspection program as now defined, not the program as it may have been defined at the time the activity was inspected (or should have been inspected) at Comanche Peak. Also, the information relates to-t+e. inspection coverages by Region IV, m, u,orw o/Je; Ane /um all u ~,~
m e W. inspection activity = n11ad by 9:p;; p., ; g;;g ;;;
O,;;u ti;.."
2.
The regiiinal inspection activity described against each requirement of the
+ha e"' h -:;;' kd
+ha IE programe-i ^.. t,s opcu;ik.:.; : D epar+ad
-;;l,w uie or (nu :..;p :thn;, ;4 t; ;;ti'.iti-::; +h4 "d:pth" ei inspecuan, th; ;u; ;f "::r;1;;," :tc.
In sum, the CPRRG desires an expression of what inspections, and the extent, that Region IV actually performed, in all
~
mq erk
'its aspec.ts, against what the IE construction-q :lity :::
m program-requires or describes.
eM 4e 4
RIV 1 DUPLICATE DRAFT,[12/22/86),
[
ZlV- #l
(
2 A
./
~
a
., v '
h )(18 o
Page 2 Robert D.. Martin d
3.
For each IE ion requi provide a reference to the Region IV document Gany.., the requirement, including the page(s) where the requirement is addressed.
4.
A listing of the IE construction zuMt; u.....c; inspection requirements j
which were not covered (and why) by Region IV.
If a requirement was only partially met, the report should so indicate and explain.
For any current program requirements not met through Region IV activities, you are y
requested to determine whether the requirements in effect at the time of l
the inspection may have been different and, if so, please inform the CPRRG the degree to which the requirements in effect were met.
l 5.
A listing of the Region IV construction ~Wt; :nrxx inspection requirements or activities which are in addition to the IE program and why ti
'.tems were added by Region IV. A refe ence to the relevant Region IV document conveying the requirement [hYuN e provided including the relevant page number (s).
{
6.
A copy of the inspection reports and related correspondence concerning enforcement or management issues or the relevant pages for each of the j
items or activities which Region IV inspected which are a part of the IE construction ; =',it3 n s... m c inspection program.
If you have any questions concerning this request, please promptly contact the CPRRG.
)
Ed l
l Your reply should be received by the CPRRG by January g,1987.
l I
1 J
1 J
l John G. Davis, Director l
Office of-Nuclear Material f
~
Safety and Safeguards gy,o; f
nearT n 9 /99 /ad DTV 1 C11P1TCATF
1 I.
,4' I
MEMORANDUM FOR:
Robert B. Martin, Regional Administrator Region IV FROM:
John G. Davis, Director Office of Nuclear Material Safety and Safeguards
SUBJECT:
INFORMATION FOR COMANCHE PEAK OIA REPORT 86-10 REVIEW GROUP -- RG RIV-02 i
In order that the Comanche Peak OIA Report 86-10 Review Group (CPRRG) can proceed with its review, the following information is requested of you con-cerning Region IV inspection reporting; item identification, classification and disposition; and inspector responsibilities:
1.
Infomation--regardless by whom developed--which establishes the respon-sib 111 ties of the inspector, supervision, and management with regard to inspection perfomance, reporting, review and concurrence on reports and meaning and responsibilities of signatures and concurrences.
Jh6 [{fw;;;I b
_ -, C
- .
- Y which identifies means to resolve differ-2.
Information er:
ences of opinions or positions with regard to inspecM performance M'
~
cw...,~.-J; ;i v n a, and Cesi;; ?"
- p;rt :: t::t.
4 a#:;.; ;;un,f fnyrd an ors.
i Ir. formation that descrigthe possible classifications of findings or 3.
conclusions from M and the" meaning of the classifications in terms of safety significance, " attention" or Regional follow-up given to items because of classifications, conclusions regarding licensee performance, f
and enforcement. What the CPRRG seeks is information used by Region IV
.g sus. met-RIV 2 DUPLICATE DRAFT 112/22/86),
RIV _
-..____._m____
l 1
h A
Robert B. Martin Page 2 staff that identifies the significance of differences.in classiff-cation of items or findings from inspections. The CPRRG.is especially interested in distinguishing between differences based on procedural requirements from those based on. safety concerns and whether such differences result in different Regional handling and follow-up actions.
4.
Information that describes how Region IV intends that findings and items from inspections be " resolved" with regard to safety significance and significance to the licensees performance.
5.
The system or method used by Region IV to assure that appropriate Region IV staff members were aware and understood the information in Items 1-4, above.
6.
A copy of appropriate documents or relevant pages which address the above i
matters.
If you have any questions regarding this request, please promptly contact l
CPRRG.
7 Your reply should be received by CPRRG by January X 1987.
I John G. Davis, Director Office of Nuclear Material Safety and Safeguards i
l l
m
~
RIV 2 DUPLICATE
~
DRAFT 112/22/861 Rif-Ok l
6 MEMORANDUM FOR:
James M. Taylor, Director Office of Inspection and Enforcement FROM:
John G. Davis, Director f
Office of Nuclear Materi and Safeguards
SUBJECT:
INFORMATION FOR COMANCHE PEAK OIA REPORT 86-10 REVIEW GROUP RG IE-01 In order that the Comanche Peak OIA Report 86-10 Review Group (CPRRG) can pro-
-ceed with its review, it needs information on what constitutes the current IE
[ Quality A'ssurance] inspection program at a reactor under construction and what, if any, specific provisions or modifications were made for Comanche Peak.
Thus, the following information is requested:
1.
A description of the current scope and specific requirements of IE{ quality g assurance 3 inspection program that is to be accomplished by the NRC at a q
reactor under construction today.
Please identify any requirements that are not expected to be implemented or where there is flexibility i
regarding implementation under the control of the Regional Administrator and the rationale for such detenninations.
1 2.
Were any specific additions, deletions or modifications made to the IE
[
f
[ quality assurancejinspection program as it was to be applied at Comanche Peak?
3.
The description of the scope and requirements should be as definitive as j
practical in tenns of the required actions,- such as the items to be q
-j w
~
RIV 3
)
DRAFT 112/22/861 IE -- Of -
l
t l
L l
I
./.*\\
MEMORANDUM FOR:
James M. Taylor, Director
[ Q) f Office of Inspection and Enforcement p N
agG FROM:
John G. Davis, Director Office of Nuclear Material y and Safeguards I
SUBJECT:
INFORMATION FOR COMANCHE PEAK OIA REPORT 86-10 l
i In order that the Comanche Peak OIA Report 86-10 Review Group (CPRRG) can pro-ceed with its review, the following information is requested of you concerning inspection reporting; item identification, classification, and disposition; and, resident and regional inspector responsibilities:
1.
Information that IE has which establishes the responsibilities of the inspector, supervision, and management with regard to inspection perfonn-ance, reporting, review and concurrence on reports, and meaning and
~
responsibilities of signatures and concurrences.
l I
2.
Infonnation that IE has which identifier means to resolve. differences of opinions or positions with regard to inspection performance and report content.
'i 1
3.
The possible classifications of findings or conclusions from reports and 4
the meaning of the classifications in forms of safety significance, con --
formance to procedures, " attention" or follow-up given to items because of l
classifications, conclusions regarding licensee performance,.and enforce-
]
ment. What the CPRRG seeks is information that identifies the significance -
l of differenc.es in classification of items or findings from_ inspections sufficient to separate procedural _from safety concerns and whether such l
~
~
~
differences should result in different handling and follow-up actions.
DRAFT,{,12/22/86L RIV4 DUP (ICATE Z25~- 02.
I
c
(
?
. sh*.
James M. Taylor Page 2
.tx 4.
Informati.on that describes how that findings and items from inspections be " resolved" with %.
d to safe'ty and procedural signifi-4 cance and licensee's performance.
5.
A copy of relevant documents which address the above matters. The information provided in 1 through 4 above should include appropriate references to applicable documents.
6.
A copy of any headquarters directed team activities, such as an AIT report, involving Comanche Peak.
If you have any questions regarding this request, please promptly contact CPRRG.
i 4
1' Your reply should be received by the CPRRG by January f.1987.
John G. Davis, Director j
Office of Nuclear Material Safety and Safeguards l
i l
l f
s ee
~ 0 RAFT,(12[22/861
~
RIV 4 DUPLICATE
.fr-o2-
~
~
(
Page 2 Vince Noonan
+
[4provide a reference to a CPP0 4.
For each CPPO inspection re document con'veying the re including the relevant page number (s).
5.
A copy of appropriate reports or. relevant pages for each of the CPPO inspections.
1 If you have any questions concerning this request, please promptly contact the CPRRG.
1 Your reply should be received by CPRRG by January A, 1987.
1 I
John G. Davis, Director Office of Nuclear Material Safety and Safeguards I
l e"
y W-DRAFT 112/22/86}
~
~ ~ ~ " '
RIV 5 DUPLICATE
&-of
1 2
l i
i WORKIE NfB Victor Stello, EDO Page 2 i
2.
DETERMINE WHETHER THE ISSUES IDENTIFIED IN OIA REPORT 86-10 WERE APPROPRIATELY HANDLED AS TO PROCESS AND DISPOSITION This determination will be an integral part of the report dealing a.
with safety significance, b.
By disposition, the report will deal with the safety aspects of the I
issue as to significance and corrective action.
This may entail on-site review and examination by or for CPRRG.
)
By disposition, the report will deal also with whether an item was c.
appropriately categorized wi. thin the IE report system and how the item was eventually closed or resolved (or its current status).
3.
DETERMINE WHETHER THE CURRENT AUGMENTED REVIEW AND INSPECTION EFFORT AT COMANCHE PEAK IS SUFFICIENT TO COMPENSATE FOR ANY IDENTIFIED WEAKNESSES g
IN REGION IV's 3 INSPECTION PROGRAMS.
l The CPRRG will accept the existing IE construction quality assurAEr., /
a.
inspection program as the standard against which the efforts at Comanche Peak will be compared.
The CPRRG does not intend to attempt to identify the IE inspections requirements that existed at the time an inspection should have been performed.
b.
The inspections actually performed by Region IV of those activities and items at Comanche Peak will be compared against the IE inspection program requirements as to items, skills, and timeliness, The inspections actually performed by the Comanche Peak Project c.
Office will be compared against the IE inspection program requirements as to items and activities, skill, and timeliness, d.
The report will identify whether the inspections actually performed result in an inspection effort at Comanche Peak which is equivalent
/
to the current IE construction quality assurance inspection program.
The report will identify when the program falls short and when it exceeds the IE defined program, The CPRRG will not review the technical findings of the inspection e.
program actually performed as to demonstrating the adequacy of the IE defined program or demonstrating the quality of the plant.
The CPRRG currently is developing a schedule aimed at report submittal to you by January 30, 1987. We will inform you of the schedule.
John G. Davis, Director Office of Nuclear Material
- SafetyandSafeguards
~
yy ggw r ~
v 1
d e
1 1
f MEMORANDUM FOR: James M. Taylor, Director Office of Inspecticn and Enforcement Robert D. Martin, Regional Administrator Region IV Vincent A. Noonan Comanche Peak Project Office FROM:
John G. Davis, Chairman Comanche Peak Report Review Group
SUBJECT:
COMANCHE PEAK REVIEW GROUP The ECO has recommended to the Commission that a Review Group be established to address the issues raised in OIA Report 86-10. Although the Commission has not yet approved the E00 recommendations, in view of the extremely short time period, I am forwarding draft letters requesting certain information from Hopefully, this' draft will allow you to get an early start on developing you.
the information identified to date by the CPRRG. Related draft letters requesting other information are also being forwarded for your background.
We intend to have a conference call early in the week of December 29 to discuss these requests.
Specific questions can be addressed at that time.
John G. Davis, Chairman Comanche Peak Report Review Group i
Enclosures:
l Two letters to J. M. Taylor Two letter to R. D. Martin One letter to V. Noonan
I F.
o PEMORANDUM FOR:
Robert D.-Partin, Regional Administrator Region IV FPOM:
John'G. Davis, Chairman Comanche Peak Report Review Group
SUBJECT:
INFORMATION FOR COMANCHE PEAK OIA REPORT 86-10 PEVIEW GROUP -- RG RIV-01 1
In order that the Comanche Peak OIA Report 86-10 Review Group (CPRRG) can' l
proceed with its review, the following information concerning the Comanche Peak project since its inception is requested of you:
1.
A report on the extent to which the activities of Region IV at Comanche Peak covered the scope and requirements of the current IE quality assur-ance construction inspection program (i.e., the IE inspection require-ments).
It should be noted that this request covers the IE quality assurance construction inspection program as now defined, not the program as it may have been defined at the time the activity was inspected (or should have been inspected) at Comanche Peak. Also, the infonnation relates to the inspection coverages by Region IV, whether or not the inspection activity was called by Region IV a "ouality assurance
{
I inspection."
2.
The regional inspection activity described against each requirement of the IE program, i.e., the specific items inspected, the skills applied, the j
schedule of the inspections, site activities, the " depth" of inspection.
l l
the size of " samples," etc.
In sum, t.he CPRRG desires an expression of
- what inspections, and the extent, that Region IV actually ' performed, in all 4
itsaspects,againstwhattheIEconst;ructionqualityassuranceprogram
]
requires or describos.
j i
DRAFT 112/22/861 RIV 1 DUdLICATE j
(
llV~ fl J
(
2 4
~
lhl> 0 '
~(
Page 2 Robert D. Martin p
9 3.
For each IE inspection requi
?!t provide a reference to the Region IV document conveying the requirement, including the page(s) where the requirement is addressed.
4.
A listing of the IE construction quality assurance in:pection requirements which were not covered (and why) by Region IV.
If a requirement was only partially met.the report should so indicate and explain.
For any current program requirements not met through' Region IV activities, you are requested to determine whether the requirements in effect at the time of the inspection may have been different and, if so, please inform the CPRRG s
the degree to which the requirements in effect were met.
5.
A listing of the Region IV construction quality assurance inspection requirements or activities which are in addition to the IE program and why r
the items were added by Region IV. A reference to the relevant Region IV document conveying the requirement should be provided including the relevantpagenumber(s).
6.
A copy of the inspection reports and related correspondence concerning enforcement or management issues or the relevant pages for each of the
.si<.
itemC or activities which Region IV inspected which are a part of the IE
. construction quality assurance inspection program.
]
i i
If you have any questions concerning this request please promptly contact the CPRRG.
i
)
Your reply should be received by the CPRRG by January 5, 1987.
[
)
i <
1 John G. Davis, Director j:
Office of Nuclear Material Safety and Safeguards J(W-di nearT (1 p /pp /pr3 RTV 1 DilPITCATF
(
2 Robert B. Martin Page 2 staff that identifies the significance of differer:es in classifi-cation of items or findings from inspections. The CPRRG is especially
-interested in distinguishing between differences based on procedural requirements from those based on safety concerns and whether such differences result in different Regional handling and follow-up actions.
4.
Information that describes how Region IV intends that findings and items from inspections be " resolved" with regard to safety significance and significance to the licensees perfonnance.
5.
The system or method used by Region IV to assure that appropriate Region IV staff members were aware and understood the information in Items 1-4, above.
6.
A copy of appropriate documents or relevant pages which address the above matters.
If you have any questions regarding this request, please promptly contact CPRRG.
Your reply shonld be received by CPRRG by Januei,, 5,1987.
John G. Davis, Director Office of Nuclear Material Safety and Safeguards a
e
~
RIV 2 DUPLICATE DRAFT 112/22/86}
Qlf-Qk
(
~
2 6 p,$
. lames M. Tayle,r, IE Page 2 inspected,skillstobeapplie) d schedule for inspections,
" hold points," " readiness reviews," the " depth" of inspection, the size of
" samples," etc.
In sum, the requested information is that which will infortn the CPRRG of the quality assurance inspection program required and expected to be performed by the NRC at a reactor under construction.
If you have any questions concerning this request please promptly contact the CPRRG.
Your reply should be received by the CPRRG by January 5,1987.
i John G. Davis, Director Office of Nuclear Material Safety and Safeguards cc:
CPRRG Members Region IV Noonan PDR DRAFT 112/22/861 RIV 3 ZE-0/
I
(
MEMORANDUM FOR:
James M. Taylor, Director
~
[.' Q>
OfficeofInspectionandEnforcemenbo N
FROM:
John G. Davis, Director-Office of Nuclear Material y and Safeguards
SUBJECT:
INFORMATION FOR COMANCHE PEAK OIA REPORT 86-10 REVIEW GROUP -- RG IE 02 In order that the Comanche Peak OIA Report 86-10 Review Group (CPRRG) can pro-i ceed with its review, the following information is requested of you concerning inspection reporting; item identification, classification, and disposition; and, resident and regional inspector responsibilities:
1.
Information that IE has which establishes the responsibilities of the inspector, supervision, and management with regard to inspection perform-ance, reporting, review and concurrence on reports, and meaning and responsibilities of signatures and concurrences.
2.
Information that IE has which identifies means to resolve. differences of opinions or positions w'ith regard to inspection performance and report content.
3.
The possible classifications of findings or conclusions from reports and the meaning of the classifications in fanns of safety significance, con-formance to procedures, " attention" or follow-up given to items because of classifications, conclusions regarding licensee performance, and enforce-ment. What the CPRRG seeks is information that identifies the significance f
of diffe~renc.es in classification of items or findings from inspections sufficienttoseparateproceduraljfromsafetyconcernsandwhethersuch differences should result in different handling and follow-up actions.
RIV 4 DUPLICATE DRAFT 112/22/86,},
Z25'- 02.
p a
(
?
L g 6, Page 2 James M; Taylor R,-
4.
Information that describes how s that findings and items from inspections be resolved" with d to safety and procedural signifi-cance and licensee's perfonnance.
5.
A copy of relevant documents which address the above matters. The information provided in 1 through 4 above should include appropriate references to applicable documents.
6.
A copy of any headquarters directed team activities, such as an AIT report, involving Comanche Peak.
If you have any questions regarding this request, please promptly contact CPRRG.
Your reply should be received by the CPRRG by January 5, 1987.
John G. Davis, Director Office of Nuclear Material Safety and Safeguards i
a BM DRAFT 112/22/86}
JE-0*k{i RIV 4 00PLICATE j
l b.
MEMORANDUM FOR:
Vince Noonan Comanche Peak Project Office FROM:
John G. Davis, Director Office of Nuclear Material S' Safeguards
SUBJECT:
INFORMATION FOR COMANCHE PEAK OIA REPORT 86-10 REVIEW GROUP RG P0-01 In order that the Comanche Peak OIA Report 86-10 Review Group (CPRRG) can proceed with its review, the following information is requested of you:
1.
A report on the extent to which the activities of the Comanche Peak Project Office (CPP0) covered the scope and requirements of the current IE quality assurance construction inspection program. This report should identify that which the CPP0 has inspected and specify whether that which CPPO has inspected is required to be inspected as a part of the IE quality assurance construction inspection program.
2.
As a separate section of the report, an identification of items and activities of the program implemented by CPPO that are in addition to or different than those in IE program.
3.
The CPP0 inspection activities described against the requirements of the IE program, i.e., the specific item inspected, the skills applied, the schedule of the CPPO activities, the site activities, the " depth" of CPPO activities, the size of " samples," etc.
In sum, the CPRRG desires an expression by CPP0 of what inspections CPP0 actually performed, in all its aspects, and a coniparison with what the IE construction / quality assurance program requires or describes.
j DRAFT {12/22/861 RIV 5 DUPLICATE Po-of
k 2
i p>
Page 2 Vince Noonce:
v 4.
For each CPP0 inspection re provide a reference to a CPP0 including the relevant page number (s).
document conveying the re ya 5.
A copy of appropriate reports or relevant pages for each of the CPP0 inspections.
If you have any qccr.tions concerning this request, please promptly contact the CPRRG.
i Your reply should be received by CPRRG by January 5, 1987.
John G. Davis, Director
)
Office of Nuclear Material Safety and Safeguards i
d T
DRAFT 112/22/86}
~
~
RIV 5 DUPLICATE
&-of l
i I
l' Victor Stello, EDO Page 2 1
2.
DETERMINE WHETHER THE ISSUES IDENTIFIED IN OIA REPORT 86-10 WERE APPROPRIATELY HANDLED AS TO PROCESS AND DISPOSITION a.
This determination will be an integral part of the report dealing with safety significance.
b.
By disposition, the report will deal with the safety aspects of the issue as to significance and-corrective action.
This may entail on-site review and examination by or for CPRRG.
I c.
By disposition, the report will deal also with whether an item was appropriately categorized within the IE report system and how the item was eventually closed or resolved (or its current status).
3.
DETERMINE WHETHER THE CURRENT AUGMENTED REVIEW AND INSPECTION EFFORT AT COMANCHE PEAK IS SUFFICIENT TO COMPENSATE FOR ANY IDENTIFIED WEAKNESSES IN REGION IV's QA INSPECTION PROGRAMS.
a.
The CPRRG will accept the existing IE construction quality assurance inspection program as the standard against which the efforts at Comanche Peak will be compared.
The CPRRG does not intend to attempt to identify the IE inspections requirements that existed at the time an inspection should have been performed.
b.
The inspections actually performed by Region IV of those activities and items at Comanche Peak will be compared against the IE inspection program requirements as to items, skills, and timeliness.
c.
The inspections actually performed by the Comanche Peak Project Office will be compared against the IE inspection program requirements as to items and activities, skill, and timeliness.
d.
The report will identify whether the inspections actually performed result in an inspection effort at Comanche Peak which is equivalent to the current IE construction (qualliv assuraagC) inspection program.
}
I The report will identify when the program falls short and when it exceeds the IE defined progra.m.
e.
The CPRRG will not review the technical findings of the inspection program actually performed as to demonstrating the adequacy of the IE defined program or demo.1strating the quality of the plant.
The CPRRG currently is developing a schedule aimed at report submittal to you by January 30, 1987.
We will inform you of the schedule.
WORK NG PAPER John G. Davis, Director Office of Nuclear Material Safety and Safeguards
p
(
6 f
- a. l.
l-i i
l
~ MEMORANDUM FOR:
James M. Taylor, Director Office of Inspection and Enforcement FROM:
John G. Davis, Director Office of Nuclear Material Safety and Safeguards
SUBJECT:
INFORMATION FOR COMANCHE PEAK OIA REPORT 86-10 REVIEW GROUP RG IE-01 In order that the Comanche Peak OIA Report 86-10 Review Group (CPRRG) can l
proceed with its review, the following information is requested of you concerning the IE quality assurance inspection program:
1.
A description of that which constitutes the IE quality assurance inspection program that is expected to be accomplished by the NRC at a reactor.under construction.
2.
Any information that describes how the Quality Assurance Inspection Program is intended to be implemented including such information as skills to be applied to the inspection program, the expected schedule for inspections, " hold points," " readiness reviews," the " depth" of inspection, the size of " samples," etc.
That which is requested is information which IE has developed which will inform the CPRRG of that which constitutes the Quality Assurance inspection program required and expected to be performed by the NRC at a reactor under construction.
I If you have any questions concerning this request please promptly contact the CPRRG.
t fAYl.0R MEMO DRAFT 12/19/86 7
1;
(
(' y-g.
James M.' Taylor, IE Page 2
.Your reply should be received by the-CPRRG by January 5,- 1987.
L John G. Davis, Director Office of Nuclear Material Safety and Safeguards cc:
CPRRG Members Region IV Noonan
'POR DRAFT 12/19/86 TAYLOR MEMO
\\
1 i
(
I 8
1 i
~
1 MEMORANDUM FOR:
James M. Taylor, Director I
Office of Inspection and Enforcement FROM:
John G. Davis, Director l
Office of Nuclear Material Safety and Safeguards
SUBJECT:
INFORMATION FOR COMANCHE PEAK OIA REPORT 86-10 REVIEW GROUP -- RG IE 02 In order that the Comanche Peak OIA Report 86-10 Review Group (CPRRG) can proceed with its review, the following information is requested of you concerning inspection reporting; item identification, classification, and disposition; and, resident inspector responsibilities:
1.
Information that IE has which establishes the responsibilities of the inspector, supervision, and management with ragard to inspection performance, reporting, review and concurrence on reports, and meaning and responsibilities of signatures and concurrences.
2.
Information that IE has which identifies means to resolve differences of opinions or positions with regard to inspection performance and report content.
3.
The possible classifications of findings or conclusions from reports and the meaning of the classifications in forms of safety significance,
" attention" given to items because of classifications, conclusions regarding licensee performance, and enforcement.
What the CPRRG seeks is information that identifies the significance of differences in classification of items or findings from inspections.,
DRAFT 12/19/86 TAYLOR MEM0 2
.________m
b
(
l Lg t.
?
2 James M. Taylor ~
Page 2 4.
Information that describes how IE intends that findings and items from inspections be " resolved" with regard to safety significance and significance to the licensee's performance.
If you have any questions regarding this request, please promptly contact CPRRG.
Your reply should be received by.the CPRRG by January 5, 1987-1 l
' John G. Davis, Director Office of Nuclear Material Safety and Safeguards a
1 DRAFT 12/19/86 TAYLOR MEMO 2 l
,j
L j.
~
(
'4.
l l
MEMORANDUM FOR:
Robert D. Martin, Regional Administrator Region IV FROM:
John G. Davis, Director Office of Nuclear Material Safety and Safeguards
SUBJECT:
INFORMATION FOR COMANCHE PEAK OIA REPORT 86-10 REVIEW GROUP -- RG RIV-01 In order that the Comanche Peak OIA Report 86-10 Review Group (CPRRG) can proceed with its review, the following information is requested of you:
1.
A report of Region IV's performance at Comanche Peak against the activities and items identified in the IE quality assurance construction inspection program.
It should be noted that this request covers the IE quality assurance construction inspection program as now defined, not the program as it may have been defined at the time the activity was inspected or should have been inspected at Comanche Peak.
Also, the information relates to the inspection coverages by Region IV, not whether the inspection activity was
]
called by Region IV a " quality assurance inspection."
l 2.
The skills applied during the Item 1 inspections, the schedule of the inspection in comparison with the IE program schedule, and site activities, the " depth" of inspection, the size of " samples," etc.
That which the CPRRG desires is an expression of what Region IV actually performed, in all its aspects, against what the IE construc-tion quality assurance program requires or describes.
l DRAFT 12/19/86 MARTIN MEM0
\\
C l
2
\\
L Robert D. Martin Page 2 3.
Clear references in your report between.-the IE inspection require-ment and the Region IV report " covering" the requirement.
4.
A listing of the.IE construction quality _.tu urance inspection f
i requirements or guidance which were not covered by Region IV.
5.
The inspection findings by Region IV for each of the items or activities or requirements which Region IV inspected which are a j
part of the IE construction quality assurance inspection program.
I If you have any questions concerning this request, please promptly contact the CPRRG.
Your reply should be received by the CPRRG by January 5, 1987.
John G. Davis, Director Office of Nuclear. Material Safety and Safeguards DRAFT 12/19/86 MARTIN MEMO s
4 1
,a iG l..
t 1
MEMORANDUM FOR:
Robert B. Martin, Regional Administrator Region IV FROM:
John G. Davis, Director Office of Nuclear Material Safety and Safeguards
_q l
i
SUBJECT:
INFORMATION FOR COMANCHE PEAK OIA REPORT 86-10 j
REVIEW GROUP -- RG RIV-02 j
In order that the Comanche Peak OIA Report 86-10 Review Group (CPRRG) can proceed with its review, the following~information is requested of you
~
concerning Region IV inspection reporting; item identification, classification Land disposition; and inspector. responsibilities:
1.
Information--regardless by whom developed--which establishes the responsibilities of the inspector, supervision, and management with regard to inspection performance, reporting, review and concurrence on reports and meaning and responsibilities of signatures and concurrences.
2.
Information used by Region IV which identifies means to resolve differences of opinions or positions with regard to inspector performance and report content.
3.
Information that describes the possible classifications of findings or conclusions from reports and the meaning of the classifications in
. terms of safety significance, " attention" given to items because of classifications, conclusions regarding ifcensee performance, and enforcement. What the CPRRG seeks is information used,by Region IV ORAFT 12/19/86
--MARTIN MEMO 2
]
/
(
(
2 Robert 8. Martin Page 2 staff that identifies the significance of differences in classifi-cation of items or findings from inspections.
4.
Information that describes.how Region IV intends that findings and items from inspections be " resolved" with regard to safety significance and significance to the licensees performance.
5.
The system or method used by Region'IV to assure that appropriate Region IV staff members were aware and understood the information in Items 1-4, above.
If you have any questions regarding this request, please promptly contact CPRRG.
Your reply should be received by CPRRG by January 5, 1987.
John G. Davis, Director Office of Nuclear Material Safety and Safeguards.
4 i
DR. AFT 12/19/86 MARTIN MEMO 2
t Y.
'i l
i 1
MEMORANDUM FOR:
Vince Noonan Comanche Peak Project Office FROM:
John G. Davis, Director-Office of Nuclear Material Safety and Safeguards I
SUBJECT:
INFORMATION FOR COMANCHE PEAK OIA REPORT 86-10 REVIEW GROUP RG PO-01 i
In order that the Comanche Peak OIA Report 86-10 Review Group ~(CPRRG) can proceed with its review, the following information is requested of you:
)
1.
A report of the performance of the Comanche Peak Project Office (CPPO) in relationship to the items and activities identified in the IE quality assurance construction inspection program as now defined.
This report should identify that which the CPP0 has inspected and specify whether that which CPPO has inspected is required to be inspected as a part of the IE quality assurance construction inspection program.
2.
The skills applied during the Item 1 CPP0 activities, the schedule of the CPPO activities in comparison with the IE program schedules and site activities, the " depth" of CPPO activities, the size of
" samples," etc.
That which the CPRRG desires is an expression by CPP0 of what CPPO actua11.y performed, in all its aspects, in comparison with what the IE construction quality assurance program requires or describes.
i DRAFT 12/19/86 N0ONAN MEMO
r a
i 2
Vince Noonan-Page 2 3.
As'a separate section of the report, a description of those activities performed by the CPPO that are not included in the IE construction quality assurance program.
4.
The findings by the CPP0'for each of its activities described above.
If you have any questions concerning this request, please promptly contact the i
CPRRG.
Your reply should be received by CPRRG by January 5, 1987.
l John G. Davis, Director Office of Nuclear Material Safety and Safeguards 1
DRAFT 12/19/86 NOONAN MEMO
(
'/
Document Name:
NOONAN MEMO Requestor's ID:
WATTSH Author's Name:
JGDavis Document Comments:
OIA Report 86-10 RG FO-01 11 L
e 4
5
s.-
~___.
i
..t i
o MEMORANDUM F0l' Vince Noonan Comanche Peak Project Office l
FROM:
John G. Davis, Director Office of Nuclear Material' Safety and' Safeguards
SUBJECT:
INFORMATION FOR COMANCHE PEAK OIA RCPORT 86-10 REVIEW GROUP RG PO-01 In order that the Comanche Peak OIA Report 86-10 Review Group (CPRRG) can proceed with its review, the following information is requested of you:
1.
A report of the performance of the Comanche Peak Project Office (CPPO) in relationship to the items and activities identified in the IE quality assurance construction inspection program as now defined.
This report should identify that which the CPPO has irspected and specify whether that which CPPO has inspected is required to be inspected as a part of the IE quality assurance construction inspection program.
I 2.
The skills applied during the Item 1 CPPO activities, the schedule of the CPP0 activities in comparison with the IE program schedules and site activities, the ' depth" of CPP0 activities, the size of
" samples," etc.
That which the CPRRG desires is an expression by CPPO of what CPPO actually performed, in all its aspects, in i
comparison with what the IE construction quality assurance program requires or describes.
i DRAFT 12/19/86 NOONAN MEMO
.'l l
j
~
r i i p
PEAK
..l t
h(SkV I'
REtMW r
i SMdP f
S,,jy
,+
,Is e
J
\\
- y CORRESPC) b N E i
_..ux-m 6' Au17/oes ry
l o
l CPRRG ADMINISTRATIVE DOCUMENTS l
AUTHORITY 1.
Statement by Chairman Lando W. Zech, Jr., 12/12/86 2.
Memo, Stello-to-Zech, 12/17/86,
Subject:
DIA Report Review - OIA File
- 86-10 with enclosures (including Memo. Martin-to-Stello, 12/17/86,
Subject:
OIA Report Review: OIA File 86-10) 3.
Memo,2ech-to-Stello,1/15/87,
Subject:
01A Report Review - OIA File
- 86-10 4
Memo, Stello-to-Martin, 1/21/1987,
Subject:
OIA Report Review - OIA File f86-10 5.
Memo,Stello-to-Davis,1/21/87,
Subject:
01A Report Review: UIA File
- 86 Establishment of Review Group 6.
Memo,Stello-to-Zech,2/10/87,
Subject:
Comanche Peak Review Group 7.
/bA4tc,
3ll kt h - Ypek,98 d., ?//7/f7 A s,..+,
fe d /%A M-6/sq
i CPRRG CORRESPONDENCE 1.
Memo, Davis-to-File,2/9/87,
Subject:
'CPRRG Meeting, 1/27/87' 2.
Memo, Davis-to-Martin,2/9/87,
Subject:
Information for Comanche Peak ReportReviewGroup(CPRRG)
'3.
. Memo, Davis-to-Taylor,2/9/87,
Subject:
Information for Comanche Peak.
ReportReviewGroup(CPRRG) 4.
Memo,. Davis-to-Noonan,2/9/87,
Subject:
Information for Comano:e Peak l
I Report Review Group (CPRRG) 5.
Memo, Davis-to-Martin,2/9/87,
Subject:
Information for Comanche. Peak OIA Report 8610 Review Group 6.
Memo, Davis-to-Goldberg,2/9/87,
Subject:
Issues Raised by OIA Report l
86-10 Having Broader Implications for Region IV 7.
Memo, Davis-to-Sniezek,2/9/87,
Subject:
NRC Policy and Procedures for Processing Inspection Findings
}
8.
Memo, Arlotto-to-Mcdonald, 2/12/1987
Subject:
Comanche Peak Report 1
-Review Group (CPRRG) Task RG IRM-01 9.
Memo,Arlotto-to-Stello,2/13/87,
Subject:
Comanche Peak OIA Peport 66-10 Review Group.
/Q.
8 l24 + H, b l $ h b* ~ A st, 2ll/7llf 7 '
ChfdG-/
,2l5/El t
% t}ebM-??%Q 2/u/M M'ah ow~/ rr nr it, Ww PG"C cuya ? ' CVI FCW.~ M-n t
/2.
MCA M, A$$ k -S'D, 2 /25/' f f h/j.'eef: T-h * s'ht d' < 2l/>!IY
- a. /%c, ih6 M. A S&, 2 4 r/i v,4,1:o t'. (p., n.,, c.
.,i,q /i 7 m / u
% ac A sc,,s wi
-,,a co,;,,c,s :...,,,,,y ;\\
i f:i.. :( %/i t A.,,9pJ $l1'e,p/? Wi/ Efl& '
,4,;/
.i'; d,,L.
/%rr
/9 & fb 4,& lshN r s
i C.
.. 7 g / b,,.+ p'. m' do.. f'o 6 y
- . n,..
Ac< M g - p,5,,o, ct;.. + m J,. 3,.. J: n w r.'-;"'
-_ - _- -