ML20237K294
Text
.
[J.
ff
'4 [".p uag o
UNITED STATES
'i'8 Ig NUCLEAR REGULATORY COMMISSION w
n j_
., ~,E W ASHWGTON, D. C. 20555
..++
p-,
g..:
/
3/ 8(o PEMORANDUP T0:
Vincent S. Noonan, Director PWR Project Directorate No. 5 Division of PWP l.icensino-A.
FROM:
Annette Vietti-Cook, Project Manager PWR Proiect Directorate Po 5
. Division of PWR I.icensino-A SUPJFCT:
PEVIEW OF OIA REPORT
REFERENCES:
1.
OTA Report dated November P6, 1986 7.
Memoranda from T. G. Scarbrnuch dated July 8 July 15, November 5, and November 25,.19P6 3.
Technical Review of inspectors issues Contained in Comanche Peak Inspection Reports by Stephen Goldbero I have reviewed the above referenced documents and the following is my evaluation:
None of the technical. concerns (3?) reised seem to be of the nature to h've an adverse affect on plant safety.
In fact, I believe that the technical concerns raised are being addressed in some way by the applicants alreadv-either through the CnRT program plan or other efforts.
I would have to verify this through a review of the licensino documents.
(See recommendation 11.
Further it is evident from a review of the referenced documents that determining whethe'r a concern is a violation, unresolved item, etc.,
is judgemental. Just as inspectors and supervisors disagreed in the OIA investigation so did 01A consultants Scarbrouch and Goldberg in their-1 expert review of 16 of the concerns raised by the inspector. This may be a generic problem in the acency that needs to be resolved through instruction, etc. However, as far as Comanche Peak is concerned we need to assure ourselves that all concerns are identified and addressed, no matter which bin it goes into, i
The allecation regarding the ability and willingness of Region 4 inspectior, and enforcement staff to effectively inspect and audit problems at the Comanche Peak facilty is not new and was specifically raised in a March 19, 1984, petition pursuant to 10TFR ?.206 from B. P. Garde on behalf of CASE.
l.ater, special inspection efforts were conducted by the SRT (April 3-13, 19841 and the TRT JJuly-October 1984) and some oraanizetional and management chances took place within Reaion IV.
Following applicants procram plan submittal, Region TV personnel were assigned oversight responsibilities of the onsite activities for the 00C and 0A/0C prooram and review of construction and 0A/0C B708270131 870019
)
PDR-FOIA BAUMANB7-A-14 PDR j
1 7
allegations that were raised after 9/15/85. Region IV efforts in'the review of implementation of the CPRT procram plan were and have been coordinated closely with NRP. Concerns raised in the 01A report were raised throuah the regional routine inspection procram. Very little oversite by NRR was given in this area except to consider the inspection report findinas with regard to their affect on other licensing activities.
The problem I see here is primarily one of perception since the supervisor of the routine reoional inspection, where concerns of suppression of problems were raised, is also the supervisor of the recions CFRT proaram plan oversicht group. The auestion is raised do these inspectors have concerns that are not beine addressed. OIA did do some additional interviewing in this regard.
From the results of this interviewing, it did not appear that concerns were raised with the intearity of the regional CPRT oversicht group although this may be an area we may want to confirm.
(See Recommendation Pl.
I Recommendations 1.
Prepare a matrix to verify all technical issues raised in the CIA investigation are beino addressed.
If thev are not, the staff should take action to verify the concern is resoTv~ed, This can be done by requestina an action plan from the applicants with NRC oversicht or independent action by the NRC, 2.
Confirm NRC Comanche Peak inspectors do not have concerns with the plant that are not being addressed.
Possibly round table meeting of all CP inspectors to voice concerns to appropriate individuals.
3.
Receive OGC assistence in determining need for Board Notification.
/ %%a
\\
~
Annette Vietti-Cook, Pro.iect Manager PWR Project Directorate No. 5 Division of PWR I.icensing-t cc:
P. Vollmer T. Novak l
l i
)
i l
l
1
-0 a
e GGH6 M"vLag s
LTu
-Gr-w/n h
q3 R/T W 7 qqa hwr MEz@ (U[Q'y Qy&
?5kL
( m q gG,,gh QE (SAfl% Ed% /7,I t L 4?
TvGGa Poab 1
C P -& ?- IP. y' k ST4-302. N N (r%,%.dw) i i
i i
)
4 W
y CPSESIFSAR witnessing. Additionally, these' areas are identified for audit'
{
purposes.
Theeffectivenessofthevebdor'scorrectiveactionprogramis
. assessed during audits by th'e vendor, the pr'ime contractor, subcontractor, and by.TUGCO.
Stop work authority is exercised as required.
,(/
17.1.17-QUALITY ASSURANCE. RECORDS af 50 The TUGCO, Quality Assurance program establishes procedures and practices to assure that TUCQO and its contractors have a quality records system which provides documentary evidence of the performance of activities.affecting quality. Procedures assure or shall require:
1.
That records that are required to be' maintained show evidence of performance of activities affecting quality. Typical. records maintained include quality assurance programs and plans, design data'and studies, design review reports, speci.fications.
{
l procurement documents, procedures, inspection and test reports, material certifications, personnel certification and test reports, audit reports, reports of nonconformances and corrective actions, as-built drawings, o ng lo
, calibration records, maintenancedata,anYTrt1Vreand'incidentreports.
7 2.
That inspection and test records, as a minimum, identify the date of the inspection or test, the inspector or data recorder, the type of observation, the results, the acceptability, and the 50 action taken in connection'with any deficiencies noted. -~
3.
That records are protected against deterioration ar.d damage.
4.
The criteria for determining the classification of the record as well as the length of theiretention period.
E.KHIBIT 43 AMENDMENT 50.
i ilVLY 13, 1984
! 17.1-40
]'
w.
CPSES/FSAR 1>
=^
5.
The method of identification and indexing of records for ease of retrievability.
^
6.
Responsibility for record keeping during. design, fabrication, construction, preoperational testing and commercial operation.
7.
The method of transfer of records between organizations.
TUGC0 verifies conformance to the record requirements by reviewing contractors' quality assurance methods for record keeping, by auditing contractors' systems when functional, and by selective review of quality records for completeness and accuracy.
The permanent on-site record storage facility is constructed of reinforced concrete, concrete block, masonry, or equal construction.
A concrete floor and roof with sufficient slope for drainage is provided. A sealant is applied to walls, floor, and foundation. All
(
entrance and exit doors are fire retardant type. Aclosedloopforcedl50 air circulation system to control temperature and humidity is provided.
Dry chemical or gas fire extinguishers are provided.
Standard steel cabinets and metal shelving are used inside the storage facility to contain records and files. Access to the records facility is kept controlled so that only authorized personnel have access to
._the records area.
i 4
>17.1.18 AUDITS m
TUGC0 r quires that lanned and periodic audits be per ormed to yerify
'h cen) 6nce with all as ects of the quality assurance r
-f q
4 rogram at/ 1 0
.dete ine the effective. ss of the program. TUGC0 A performs suc.h audits on Westinghouse, G bs & Hill, Brown & Ra, other 70600 50
- orgar izations, and others a necessary to prov de an objective evaluation of the effectivene of their pr grams; to determine that 1
t l
l t
l 17.1-41 AMENDMENT 50 Jul.Y 13, 1984
~.
______O
n.
1 j
]
CAUIION NOTICC - This standard is being prepared
}
b-or reviewed and has not been approved by ANSI. It is subject to revision or withdrawal before lssue.
i l
~
hierican National Standard 4
Reactor h'lants and Their Maintenance Requirernents for Cellection Storage, and H'aintenance off Quality Assurance Records for Nucicar Power Plants i
1
(
ANSI M45.2.9 Sponsor The American Society of Hechanical Engineers lith Draft - Rev O' 1/17/73~
~
l ' ""
EXHIBIT 44a' I
l
3 1.2. Applicability.. Tbc requirements of this Lt. ndar ppi to the vorP.
2 of any individus1 or organization that participates in co11cetion, storage, 3
or maintenance of quality assurance records associated with t,
'nucicar power plants,-
O The extent to which the
' k.C 5
individual requirements of thio standard apply will depend upon the nature 6
and scope 'of the work to be perforced and the importance of'the item or ser--
7 vice involved. The requirements are intended to assure that records are 8
availabic when needed for their intended purpose.
9 10 1.3 Res pons ibility. The organization or organizations responsible for 11 establishing the applicable requirements for the activities covered by 12 this standard shall be identified and that scope of their responsibility'ics 13 shall be documented. The work of establishing practices and prgcedures 14 and providing the resources in terms of personnel, facilities, and ser, 15
. vices necessary to implement the requirements of this standard may be 16 delegated to othe; organizations and such delegation shall also be docu-17 nented.
It is the responsibility of each organization performing vork 18 covered by this standard to comply with the procedures and instructions 19 issued for the project and to confom to the requirements of this standard 20 applicabic to its work.
{
21 I
(
i l
22
1.4 Defini
ions.
The following definitions are provided to assure a uni-23 form understanding of select terms as they are used in this. standard.
j 24 l'
25 Oualitv Assurance Records. Those records which furnish documentary l
26 evidenceofthequalityofitectsandofactivitiesaffectingquaN.ty.
For i
27 the purposes of this standard a document is considered a quality assurance 28 ccord when the document has'been completedl
,/
30 Other terms and their definitions are contained in ANSI N45.2.10.
31Property "ANSI code" (as page type) with input value "ANSI N45.2.10.</br></br>31" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. 32 1.5 Referenced Docume.nts. Other documents that are required'to be included
'33 as a part of this standard are *either identified at the point of reference 34 or described in Section 8 of this standard. The issue or edition of the re-l 35 ferenced document that is required vill be specified either at the point of 36 reference or in Section 8 of this standard.
//
\\
gehDraft-Rev0 i'd.". -3 1
, ' /-/7 75
_____._______._______-O
1-2.
CEllEPAL 'REQUE REKEN75 I
2 3
This section sets forth ' general requirements for the control of quality -
4 assurance records.
..b.
The requirements include collection, filing, storing,
'5 maintenance and disposition of records as required by ~ other codes, 6
. standards,'~ specifications, or regulatory requirements.
The procedures _to 7-be employed 'to perform the reauired activities shall be planned and docu-
.8
.mented.'
9 2.1 Quality Assurance Record System.
A quality assurance records system 10 shall be established by the organization responsible at the earliest prac-
)
11 ticable time, consistent with the schedule for accomplishing vork activities 12 and in compliance with the general requirements of this standard.
i The 13 quality assurance records system shall be defined, implemented and enforced -
{
14 in accordance with written procedures, instructions and other documentation.
15 16 2.2 Categories.' Tuo categories of quality assurance records are established -
17 lifetime and nonpermanent.
18 19 2.2.1 Lifetime Quality Assurance Records.
I Lifetime records are those'vhich 20 meet one or more of the following criteris:
'.1 22 (1) Those which would be of si;;nificant value in demonstrating l
capability for proper functioning of sa.fety-related items.
']
23 24 25 (2)
Those which would be of significant value in maintaining, rework-26 ing, repairing, replacing, cr modifying the itern.
l 37 j
28 (3)
Those which would be of signi.ficant value in determining the cause 29 of an accident or un1 function of an item.
//
18th Draft - Rev 0 m
-w g s as
/-17-73 '
)
I B
i
1 32 Records Administrations
" ~~
~~
~ '~
g.
3 3.2.l' Ceneration of Quality Assurance Recordc..It is not the intent of i
k this standard to specify the preparation of the quality assurance records 5
to be generated.
The applicable desi n specifications, procurement docu.
6 6
tients, construction, maintenance, in::pection and test procedures or other "f
documents. shall specify the quality assurance records to be Benerated by, 8
supplied to, or held for the evnery '5ea uri'fthassuranc erriec o rgsysqb'!$@3 9
5 hic 5N MTgEbicsciapretMEAedsmibaartib6 10 Regit$fgililmtTgtiWDitrearenvp1VedM 11 l.
6 i
12 The' app'licabic ' quality assurance records shall be considered valid oniv 13, if stamped or initialed or signed or othervise i
14 L'aXtTornYdEpftgl1 These records may be either th'e M or a @
15 g {d @ epy.
16 l
t 27 3.2.2 rI. tid 6{ The quality assurance records shall be listed in an index.
1 18 The index shall indicste, as a minimum, record retention times, where the 19 records are to be stored and the location of the records vic'hin the storage 20 area. The index should be established prior to receipt of the records.
21 22 3.2.3
_ Dis tribu t io n.
The quality assurance records shall be distributed 23 and handled 'in accordance with written procedures.
24
,j 25 E M ddIdentification.
Quality assurance records shall pr' ovide sufficient 26 information to permit identification ba:an the record and the item or 27 items or activity to which it applies.
28 29 N classification.
Quality as surance records shall be classified $s 30
- Lif e c itee or Nonpermanent.
r 1
e i
//
s 26th Draf t - Rev 0
-14 !
/-/7 7.5 i
C V ~
~l
\\
\\
L' f/(l 1
4.2' Timeliness.
T'o assure their availability, a specific submittal plan shall be established for quality assurance records by agreenent between I
the purchaser and supplier.
i l
4-i
{
5 Receipt Control. Each organization responsible for the receipt of f
6 quality assurance records shall designate a person or agency responsible 7
fot receiving the records. The designated authority shall-be responsib,le
~
8 for organizing and implementing a systen of receipt 'contro1 of quality 9
assurance records. 'Ihis system shall apply to the receipt of records into 10 a temporary working file and the permanent storage file'.
p.
i 11 L.
12 As. a minimum, a receipt control system shall include:
13
'4 (1) i A records check list design.iting the rer;uired quality assurance 1
15 records.
16 r.
17
-(2) A record of Quality Assurance records received.
k 9
(
(3) Procedures for reccipt and inspection f incoming recprds.
20
~
21 4.4 Status.
Each receipt control system shall be structured to permit I
{
22 a current and securate assessment of the status of qu.ality assurance 1-23 re, cords during the receiving proc'ess.
_F 25 5.
STORACE, PRESERVATION AND SAFEKEEPING 26 27 5.1 Cen era l.
This scetion establishes storage requirements for the
.~
28 maintenance, preservation and protection of quality assurance record lI 29 files from the time of receipt until their ultir: ate disposal.
I' Y
~
..L ff *
.Mfth yraf t - Rev 0 it"?!"
~16-f /7 73 T
F d
b-'
5.2 Location of Facilitter.. The quality ' assurance record files shall bc
^
stored in predetermined locations as necessary to meet ithe requirements of l
_ 2
' 3' applicabic standards,. codes, and regulatory agencies. l
~
4 g-age. ~ Prior to storage of records in a quality assurance record 5
5.3 file, a vritten storage procedure shall.be prepared and a c.ustodian shall.
6 7
be desigt.ated with the responsibility to enforce the' proc'edure., This pro-8 cedure shall include the following as a mininum:
g 9
. 10 (1) A. description of the storage area. '
r 11 12-(2) The ffling system to be used.
13 14-(3) A method.for verifying that the records received are,in agree-15 ment with the transmittal document and that the records are in 16 good condition.
17
(
i8 (4) A method of verifying that the records agree with the pre-19 established records check list (see ' Subsection 4.3 of this 9
30 standard).
21 22
'( 5) The rules governing access to and contro'1 of the files.
23 24 (6) A method for maintaining control of and accountability for 25 records removed from the storage facility.
26 27 (7) A method for filing supplemental information (see paragraph 28 3.2.6) and disposins of superseded rec'ords.
//
38th Draft - Rev 0
-t.
- i4'd5 '-R
- i
/-Jf.7)
~17-
.__m_____ _ _ _. ____. _ _ _ __ _ _ _ _ _ _ _. _ _.
,:t l}
l 4
N Preservation. Records shall be stored in a manner approved by the f
t organization or organizations responsibic for the files.
In. order to 3
preclude deterioration of the records the 'following requirements shall
,[.
4-app 19:
i' 5
6 (1) Containers. Within a permanent storage ' facility (see Subsection 7-5.6 of this Standard) containers or shelving shall be used; stan- -
8 dard steel file cabinets are preferred. ThoseVriii@diisnesdM 9
within:.a temporary storage facility shall beraffo'rdedi M ote.cti,9
~
by dse%f fire resistant cabinets with a ~eneshi:i6E@dride6rit'efsh i
10 11 rating.. A satisf actory alternative is maintenance of duplicate
)
12 records stored in a separate remote location.
4 13 14'
-(2) Condensation. Provisions shall be made in the storage arrange-15 ment to prevent damage from condensation.
16 17 e Loose Documents.
Loose documents shall not be stored, on open surfaces such as tables or on top of cabinets. Records shall 7
be firmly attached in binders dr placed' in folders or envelopes 20 for storage in containers or on shelving.
j
~
t 21 l
22 Special Processed Records. Special processed records (such as 23 radiographs, photographs, negative.3, and microfilm) which are 24 light-sensitive, pressure sensitive or temperature sensitive 25 shell be packaged and stored as recomended by the manufacturer 26 of these materials.
l me i
I
//
(.
3#th Draft - Rev 0 1t#4,7AM j /./7-73
[.
,p a
- 1 %.Safekeenina:.
Provisions chall be established to preclude the V2 entry or unauthorized personnel into the storage area 'and to guard 3 against larceny and vandalism.
4 5
5.6 Facility. Record storage facilities shall be so constructed and located 6
as to protect contents from possible destruction by causes such as fiie, flooding, tornadoes, insects, rodents and from possible Ick;erioration by a 7
8 combination of extreme variations in temperature and humidity conditiens, 9
10' At least the following features shall be considered'in th' design of e
l 11 the permanent storege racility:
12 15 (1) Reinforced concrete, concrete block, nasonry, or equal construc-14 tion.
15 16 (2) Concrete floor and roof with sufficient slope for drainage; if a 7
floor drain is provided, a non-return check valve (or equal)
~ 18 chall be included.
19 20 (3) Fire retardant door (two-hour Underwriters' rating minimur:;).
21 22 (4) Sealant applied over walls as a noisture or condensation barrier.
{
23 I
24 (5) Surface sealant on floor providing a hard-wear surface t'o nini-25 mize concrete dusting.
26 27 (6) Foundation sealant and provision for drainage.
28 29 (7) Forced-air circulation with filter system.
30 31 (B) Dry chemical or gas fire protection system.
//
JEth Drafe - Rev 0 Y1*?tM
, '/-/7-73
'(9)' Ho pipe other than those providing fire protection to the storage 1
/
facility is to be located within the facility.
s J 4
Tor storage of film and other special processed records, humidity and h l
5 temperature controls shall be provided to maintain an environment as;recom-l 6
nended by the manufacturer.
7 fhAudits. An audit system shall be established to assure that the 8
9 quality assurance records' storage system is effective.
The following.
10 shall be performed as a minimum:
11 12 (1) Periodic surveys to assure that records logged in are avail-13 able and have been placed in their proper? location within the 14 files, and to assure that the control. system is adequate.
j' i
15 16 (2) Periodie audits to assure that the facilitics are in ' good con-I 17 dicion and that the temperature / humidity controls and protective J
18 devices are functioning properly.
t I
i 20 (3) Periodic audits of the records to assure that the documents are 21 not deteriorating due to improper storage practices or rough 22 handling.
23
\\
24
- 6. -RETRIEVAL I
25 I
26 6.1 Ceneral.
This section is intended to establish requirements for the I
27 retrieval of documents that are stored within the quality assurance re*-
28 cord files.
i
//
- 46th Draf t - Rev 77 / ' 7 /7 2-j
/-/7-73
\\.
l
. ~...
1, 612T.AAcessibiliev. Storage systems chall provide for the accurate 2
retrieval of information vithoutn ndormdelay.
u J
3 c
q i
4 gg'K list shall be generated designating those personnel who shall l
5 have access to the files.
)
6 7
Quality assurance records maintained by a ucnufacturer at his 8 facility or other location shall be accessible to the Buyer or 0.rner l
j s
i 9 in the case cir lifetime records for the life of the items involved of I
10 for the designated retention periods for nonpermanent records.
11 12 7.
DISPOSITION
~
13 14 7.1 General. This section is intended to provide requirements for the 15 transfer of quality-assurance. records to the Owner, who has ultinate 16 responsibility for these documents, and their disposition.
17 18 7.2 Accumulation e.4 Transfer of Record s. Quality assurance records accumu-19 lated at various locations prior to final transfer to the Owner shall q
20 be made accessible to the Owner directly, or through the procuring organi-21 ration. Examples of such records are vendor r. manufacturing records, con-22 struction documentation, and startup data.
Upon final transfer, the Owner 23 sha2.1 inventory the submittals, acknowledge receipt and process these ree-24 ords in accordanco v.th this Standard.
25 26 7.3 Disposition of Nonpermanent Records.
Records classified as nonpermanent 27 should be retained for at least the minimum period of tine as recommended in 28 Appendix A.
After this time, these records may be disposed of by or vith con-29 currence of the 0.mer.
W
.Mfth Drafe - Rev 0
-t#7Me.
V-/7-73
-2i-l
CPSES/FSAR
-Mscussion
(
The termrn tion of the operating license and'subgent decommissioning of the Comanch eak Steam Electric Station,wH'l address the regulations in ef ct at that time.
N.
\\,N i
Guidance for Constructi If lass omponents in Elevated-Temperature Reactors (Supplement SME Section III de Cases 1592, 1593, 159.4, 1595, and 1596)
Discussion Th regulatory guide is not apnlicable to the CPSES.
Regulatory Guide 1.88 Collection, Storage, and Maintenance of Nuclear Power Plant Quality
(
Assurance Records Discussion The quality assurance program for design and construction at CPSES 8
incorporates the intended objectives of ANSI N45.2.9 (Draft 11 QE.19 Revision 0, 1/73). During the operations phase, the quality assuran$
methods and administrative controls utilized for controlling and storing QA records, as described in Section 17.2, will comply with the applicable guidance provided in ANSI N45.2.9 - 1974, as endorsed.by Revision 2 (10/76) of this regulatory guide; except for paragraph 3 of section 5.6.
For this exception, CPSES will comply with paragraph 3 of 42 section 5.6.1 of ANSI N45.2.9-1979, which requires a minimum two hour rating for the structure, doors, frames and hardware of the storage facility. Application of the requirements of: Revision 2 (10/76) of this regulatory guide will be in accordance with the guidance provided in ANSI N18.7 - 1976.
(
EXHIBIT 44b AMENDMENT 42 SEPTEMBER 12, 1983 1A(B)-36
-M'"*
2-o y
- wt e.ne nts.+a.
em.4.wem-
~,
p'r, *f *'O7i4 I " ( " T I, h +
l'
,...dll.6
.., {] r
'/ gy't, ;'iy..m3h g./ -
,,9Q,,8**
l*', I, f ff"
.g
' % (,,
,P '.A
'f *l
- *l "l ',_
, d..w ' : O r#- ')
jy e.,
', <, 4.p; n : ' ' ggQ
_Q _y.
w
,v y},
vg y ( y q 4 p, a..
x,; ~
- n,,,,,,% g,7 y
,7 s 3 yr
.s
~.
/;.,4..w
.s. y
.F
- m. w. >.*
1 n
n
,a s
M
..s. ~.
...a..c yx y,s,.,$z a a -.
4 no,,.
. <. - e,. *} wy.. t y,.,. n. ;
<..>..., t ;g 4*v r~
a w.
w,
,4, y 9, ? y,..
. o.,.-..,, n,.
g c -,
1
- Q gg%,y / Kg;g{4,(e*%
g
,.,L sa gt,..
,e
- ' s -
.m y',9. %. c g M.Q,g y y g*h u y r%
6
,c
-A.
3,.
, W,$ M,....
- s. y 4 3
w f
g; 2, p4h '
e+
g,.,1,s i
i 4 -,
s, u m.w
,y a y Am
-s y,
- r a...
w g m.. q% q.c
.w y 4 e &h&f?WWWWA,. g% pw %Nlgld@g,,,%
y s,.
w, n.e Yk p.m,%m..
s,u
.%. q> u Ly 9 a,gs,,.
+ > :y:w(/) r.p.q%.
.g g
- eWs y+ 9 imJ tmvi - 3. j ;, f.. m
&u
@@g %.g.+ c rn wea.1,MWGKSMOe,/
g ysy gW5'ke s p
+, e o.c 4
o ty teg 3
W'
%L N '$i, g)4 y' aid.,9[ 4 DN 4-m dap.h e
. t%' [N
, j, p. p.
Ah etM I
+,MN' el.
s-f'-
s
'I
- h. #
. Y 4
k'#h '
r S n Q ~ t,n,'.'[, u 4
2 q4M.n,L M,&c.gp *[:p$c y l.f.f M p<s q$x yQA ' ' &s yp.; n n&w w*4 L, w w'.
~ m y g:j f;@my, x W
. ?
i,.. ag s,.
. ff M
)i?Q.
w, m yx%" 4q:; *:q gh.f, Q:49 J.
b
.V4y
. ?.gy.id
' %.W 3,
p.w 4pS%:w.,a'D_
%pf
.. & c a; pI M w
J < ;p;.w.km d@'ylW:.r N w.e i
.a.yg.yk %n j.) AfpepT,@q
.g 3 g. m2 gg
- .n L
-.n:y-u 1Ji, R 1 W.;m..y5y nw gmW y
s w W Ax,&m% w 1 y 4.;.=
e Du m %o t.
n.
ngt.
4 E.,
kVI,c
..m o
qa (ma:: ?.7%s M i n,g,4 b pg. y > y,
~
1 cgim h Ay Wg * %;@g.gaw u,7,44 wgM) A ny spo.
wjde A W vf a.gg. 4.ghynpt$w% gg.p? m:. 3.;. y,i u m x. w,w;; n..
.na
,f. 4 u
g q g.w,
~p w
+
une,w n w, w wown w w %a %m.mm.w,aummawu
, x a, w wu ws.nm.;seommean ammMmeoww amkM,4 _
2 seuwesanon m m s,a s.xx m w.
tag,p g.(yQ @ yMg %)g.M $x@ _$.%.~,w. m g,$,ww,.a.. ~yfh.[,.g,,
hwh%$.
gg dMffy6..
~
+.. me.f4 /4. *
,as;.m._ _
7-
.,- [
M#.tJ4 '7 pits.fgglW*egygjg 4,p.gj g g.put.et
%, m,,,,,%,...,m.g
,,w.u rr - _..
.,s-e.,r%- %u -
c.
~ ; _ 4 ypsy.i s egn
.pq #.se gang f*fk.CW
, ",y.& 'B'", E *'*"FW1.# M""*q.N ' fn44. K.,,4, 5 7.,._.7,
' 3*IhnstfygWi '[f.ty'. g%. F9,%,* 'y
'd #"74WO
- 7H8#7754edd%f4,id. #.5e@la,$JN5My,APhd#rpt
.,.,h, 3 ren$
g K h44 8px e
,., e, u w,,
..,.3
..e.~
. J -g[=#W% *'le v F
- h G2,;4,uw5:,:,4%p4#'f aM***Vf W'P hl%f........
hap k
@M g**M l'.
p 8 WM,x.Gr2 G.aGCMM ej%:nu 4%.p:&,f ty4g. Aw g%.,;sL;
-s.,.rw a.s.a1,4 % g e s,J M.:".,*.C. s '
u:G.
V z, c.,ad
,aw gg
...p..
ga d
.+ uw.. -,
- ggt,.m:f% $ym$4+yggr Q t*a. w p,%. k: u.3.,r W ). 4 uQtho.
. i.Nh3ND,, Mb 5 N/[%{h. 7 4.o #.u m.,%.w q::m MwrA:wW mQe
- g ge,w r.
- q t ummswwwwge26%m[M:wgM
.s O b t /N tii fNY TTNY# iN,4.'
.NNUl.i@.NMMMP$ M,S, Mc.
M an
. w,,,,,
a,. n.~a.gic a m.., m w w w.w
.?
-mrm
-. u.,. _n e
.i.,n. w,, p n:4 k.,n..,,
n..- c,
...- ymna,. n.mm,Jn~. e..,n..a w..m mm.
n.
, +
.n y
n.-
n
.+
[I hl5(.$N}. E iwN$nn t[,x [4pd '.s,d;i,/,I4g Mydh.YmN j,
'hd,NID/oh.d.Y,, Qi,ii h.'f, s n.ffm.Ih$y#M73m, e.u h
47
.[S.TEQ.k.
hM M M h
w,y w u
.wa a m m o...,,,
r,v.n.wnmuruews ry m x, w.u w.mu e< g 1 m W,y^n.g.9l;Ly m.m ~' yd N sW h f*k. pN g% y},iM9,w < L 1:
LyXf.D 'O y Q' 'Q,.sW&.'2T;h h ;
t W
~
Q e*. m,m.s 4.ms: a WWw &.'
- gqimier linpshw u: -
e,e,pe qg..;.; _,..m4 uh
.w.+=4.m,.
. v.
W E..,
tp y
4 s
hy e yni.se.G y
~'
3 9
. e f, i ax. t,g
- -.,,.., w e s., s.,
s.,
gm
, Y.e
.o e
w
, o ls,a
~
sep s w,w y a s.
- +.
9 b;
- v. a..
i> "
(
.$ h j*
,&. a u, k,
' j &m$:ly.%,hp**
- f.. kTN,A,*
,m, e
M I
ms s..
u
.c s,ws e w w w,,m
,o n.w L e m + mad wy. W. * ;..
f _
E
g,g
)*
- ,, I
't A
V
,r v
w w w. m
. h...
s' we%m+g., g.
e m
.x
..wf6 v#p y@,g, n y.
.w
'.,whw j
9-m' Nm. sg%
ewe
.c
@$$;YLb;44:k.D &e
,%laa 1
'. H pt s
.w ;,
y ws c
,s.,
i % v,ns m.
. Mc=~C gs (&:...)h,&y:
J 4.NW'*'1 N??.~
r, 24 % 4.4
~h$
- V t
. W.J. - ' y +f
- o.,
t Lf. *%..f i
~.
m
_ teW % gg#
m.T. r ed.
4 s, y+.'.
, f i. r,,.e - ! y, L,.y.s p ric%mQ.,,,
- i'. g Wu -
4
[a,y]<k t.
- s. g.-
s
.A, 9t W&%QOfQ,
?.@ W)[, J C
w
.y g
g
&"Q.. $ WE
--A MU N' y[
s <.
y g
Ay f ) '
My sNpwre.m?%b.,,w s r,.
3g wAqvu 's.n nm m,.,. ac m
2 hr WW y
,( :
p
.v
... :&n, &f" 's i -
auyw.. W *% 1;%we 3
S y 9. w;.m %v W b q &~Q. >f@ f f % %.pg@V.4. %..=, 3%Q
- Q,_ y%g. f.f $) ? y W" " x '.7 n n ' -%%%g
.4 ).
,,,y..
m-i wQ 7
d.
-v t
M:
J H p.. y 4q< A.;./.%.i N
if t..%.,. 4MW
-n
- V
~g<
g..v.
'" V Y,
v s
, '}
t, l%n.ema.ma,n WAm +n w m w
us a
2 m.ya.wwwsx
+wwwun m n
nw -m.e ~w.-
sr w.a.. g,w.<
e w
. n -. m' m m m m m a, n -. ~
Ie u, n a ~ 4nb+n.
.n,wm*
m-nw-n.
a
~
s 9n wssA 3 y:r g y p rVMwtMs.M % QeM M b 4 M a'.Y.1: sst s g
.&jg O4v Ahs ki% es.c.o.e.up*h p,.-_
o 4ym s ga-++, e g.ud.,
-n e 6 1 4.
e gggW," -'--.,
.+r4
.R V6 7a hwic.<3%.+dt@ y,Mt A
"-T
_e
&. mwr ~.c spe.s i9,,;
Wd,.. -. a e.,.mv
.m.a. m4 ekmy,W m-a m =y~c ~.+ 4
_ g'm.g ' i$.p }a.,,,,4,w
s V 4. *?eh e nr-5w v.m~,t.'hf,. f,,m.,n #
w.
,u ys
+
f*3 Mf.,..,
e h
- 9...g p wu.a. Br*V a f 'w 4.*
hadJt
,a,%,m' Weu %i
. n'e9
,g p.
c,
'A e$'" 8/g. m" M.,
341*
P8 8) w p.i
'. Fp,7
- a < g"r..
g.
- W g, 4 y t o y y a&q.:@w,Q QQ]'
. ; s pp.,9
.v 4, g 4, 3y- [Ag am-s y,, 9c
.p*h'+? m'w 4M M y#.yS.m~c
~ w v.
.-q
- s..e
, w by l7 F,.e
.)g W*
> '~
68th h k*.pw'&n ph:n&
W s
gy eryk.
M', Y.qh., %g$ x.
m u e. w y %w N..Y.Mi? y M, p D h h y [ w% N (% c@ m Qm a c m (% y & e h $
.Qh r
s t
T
%,h lfhQ yM.Q %M
- ( 4 yk;a mo
% kpy[MkMWW @w(y A'kN hhM#94
/ENi lY
'h pp sp? ?;",Wt M,
n m p& ; &a &+ & y l y t
~
&m -, _ OO m y y _f,f ff e
,N
.h.
Q f
9,. g e
u.j b g M,M y epm 9 $e w %nd~aw g a sAA *MM$ @
e
,,C vig925
- jupw E
Q Q %;C'A wm s
va run M M #s u.s. e(W +h $nM,p g wffy,, g n=
G VN..y*. u
%w y -
ao g W~ y~
synmyu
'a m n mmm t w 1.
q u : M u g %,w j Lm T
w 4
M,kx nmy.e.f ttGb.:
F mA a% m iMS 4
~
1,o M a QWMm p
f 4
,t ibN
. w r e.$ m p.fp6nm4 g
%w'm@o(ghQ J Qkb@$% @yp&rv %oM A-a g n.tc.
qw. %
d c ' - N A.' M.
kp7n%m@;n'_W'p4,.
wm e n y#
. ~
4 0 M4 o ip 4N M#
- 94.
,0jd"MGRhM c. @p..m,5Dq s.M '
My yw@ym,y k ;S hddM T
Rg MM d
Q w n y g;p _M M & Mg $.,sg@- m@M) s !g RM WWM. k
$mgs.n;m m
m m -
w M y @+$ %e g y @:
4my.; y
+
n [n DN
@M pd MON M
g w g a~. a n. u..w w,w m m e ne u n wm
& ; R%-
' w x % w ; m. sJ % :, & x x v g g -
dh L l h wg n lr m y ' Q Q. w -
w:t f g~w g a.G.
h %
rinr g
e e
uws.
a
'l A
m K3 11.
u LF.h A b % O S O yesih,}
W
.y 4,A A h w/c. PRS 4 **"$pt M
~ ~ ~
w MIf"J."
u r A. ba. Og Jg January 9, 1987 g
, m
- m. < a A+..
m&1 k=
, ^
.w...
--A...x
--y
- - - s. u n.,
_t_
i MEMORANDUM FOR: Guy A. Arlotto, RES l'g Clemens, J. Heltemes, Jr., AE00 Carl J. Paperiello, R-III If FROM:
John G. Davis
SUBJECT:
TASK GROUPS FOR COMANCHE PEAK REVIEW GROUP Subsequent to our meeting of 1/7/87, the " task" work in support of the CPRRG has been revised. Drafts are attached.
As we discussed three Task Groups have been identified--a group that deals primarily with sufficiency of the inspection activities; a group that deals with process and disposition; and a group that deals with safety significance.
It is the output from these three groups upon which we--the CPRRG--will mainly base our conclusions and recommendations. Hence, it is essential that the tasks be sufficient to fully support our activities.
I ask that you critically review the draft task statements to assure that, if performed, the results would provide us a basis for performance of our assignment.
You should recognize two p Wific;tione are included in these drafts:
P 1.
As we agreed, :n r;r..i:n Of the reference IE program Ad include y
the construction inspection program and not be limited to the construction quality assurance 2.
AbreedeningofthcNasksttorecognizethatissuesarenotlimited @#[
to those identified in 0IA Report 86-10 but will include additicnal s
issues that may be identified by the Task Groufas they perform,,$jc. #$
their work wintin 71 w s-(7?nk l'718e)
The concept embedded in these tasks is that:
Information first will be received from IE, Region IV, and the o
Project Office, o
The three tasks can proceed in parallel fashion. However, Task r
GroLp 3 (safety significance) must include in its review any issues identified by the other groups.
I will appreciate connents (to Erickson) by 1/12.
~
John G. Davis f
" BM=n C P R g 6-N#h'P
_=
u-
...,H C
C l
1-1 1
01/09/87 TASK GROUP 1 l
TASK FOR. DETERMINING WHETHER THE CURPENT AUGMENTED REVIEW AND INSPECTION EFFORT AT COMANCHE. PEAK'IS SUFFICIENT TO COMPENSATE FOR ANY IDENTIFIED WEAKNESSES IN I
LREGIONIV's_INSPECTIONPROGRAMS
]
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 RG 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 agency inspection l
effort at. Comanche Peak, regardless of by whom performed, meets or is 1
equivalent to, the existing IE construction inspection program.
' The Task Group will have available to it:
1.
The information from IE in response to CPPRG Letter RG IE-01. This L-information establishes the base against which inspection activities perfonned are to be compared.
2.
The infonnation from Region IV in response to CPPRG Letter RG RIV-01. This information _provides the Region's view of the inspection performance of the Region against the IE construction inspection requirements.
H 3.
The information from the Comanche Peak Letter RG-P0-01. This infonnation provides the Project Office's view of its performance 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.
1 Insofar as possible, the performance of this task should rely on the written E
' record where that record provides sufficient information to support-conclusions. Where it is necessary to extend this record, this should be done (<oenty-in writing or.by interview. Trgnjcripts are to be made of. interviews.
werWw p i
our;rmr trtP b k
= l' c " # n :t b h M i l,;; h::: stacdO'C N M
M M n th t d re-'^
g O _ Audit e64h4e intonnatioW~~ ':on IV. t1e Comanche Peak Pro.iect ' Office or otherD as r rm:dndGy IE, Reci
- 5 atainst the primary or source.
document or' information to assess the ;;.;;Mr.; ?:x1 :f accuracy and
- ecee 4me+,e q R& h e: 4N pg, u
e a
~
~
} _
e,
c c
c~
l-2 01/09/87 a
Th& Teels, h --
" rf:W,m z = 0' th:*t d shall:
el c JV saa p" _'
,,,,.,_,,,,j h _- *aby(a)RegionIV;(b)-the Compare the _
" " + " + " -
Comanche Peak Project Office; (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.3 g Qhis comparison shall idxtify items or activities, skills n
k w4y$
timeliness.
3, Identify where inspection performance:
a meets IE program requirements
/ cR CPPC @
b exceeds IE program requirements
/
c does not meet IE program requirements.
J t..,
es.x.*1 l
q a-J.'
faces that providad the basrefere'nc#s'shoul In the report of thestask.
be provided to Me
' u-j is for the identification of. inspection performance.
If a' requirement was only p'artially met, the report should so indicate and explain.
For any current program requirements not met through Region IVPactivities, specify the requirements in effect at the time of the inspection if different from current requirements and describe the degree to which the then i
exi, sting inspection requirement was fulfilled.
l I
$,r V O Specific 403 inspectitumrequirements which have not been completely fulfilled by the agency's total 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 ene% perfonned and reported) so that infonnation on status of y'M requirements pe,4eemenos can be identified.
Aa 4
_,,4 (M) M
[
Identify inspection findings or results t t showed "open" items, unresolved items, items of noncompliance,is not " closed."r any other finding or conclusion where the inspection activity 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 +sa4L documented.
(Particular emphasis should be placed on items identified which cannot be tracked to current status or closure.)
I, 31se(eportM the task efforts'ohour Describe how the task was performed.
a.
b.
[dentify the infonnation base on which the task group's conclusions are basec'.
assure the accuracy of}he information base,This should descr a to
- x ditt g
M e
- WUp
.(
(-
1-3 01/09/87 4 aW i
Provide e4eer,referencesto the infonnation that served as the i
c.
basis for the conclusions and findings.
f d.
Where the conclusion is that inspection perfonnance does not meet IE program requirements, specify, in detail with refer t
p rmance 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,
- t_he modifications have occurred.
Schedule Y&
S ee
- l ew O"
bM qu
g
-=
C C
'1,
,4-
~
L
~
i l
2-1 01/09/87 TASK GROUP 2' l
t TASK FOR EXAMINATION OF ISSUES RELATING TO PROCESS AND DISPOSITION OF
. INSPECTION FINDINGS OF OIA REPORT 86-10'-
f ekem t'k S e
This task relates to examination of the 34 issues of Attachment I - 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 G oup 1 issues would be as a result of Task Group 1 activities under Item 5(and Item 6ehf 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 PROGRAMS.
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, sJoTr and Region IV.
$ usue
- 4. twa.
, pGrJ. %pitaa e J',.
The Task Group will have available to it:
on M W**trad*W m F ' !*tf="'g ;
ta 1.
The information from IE in response to CPPRG Letter RG IE-02. This *
~
l information establishes the basis from IE for inspection reporting; NM item identification, classification and disposition; and ana.
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 reporting; item identification, classification and disposition, and responsibilities for inspection performance and reporting.
3.
The infonnation of specific process and disposition issues from OIA Report 86-10 (essentially the 34 issues in Attachment I to Attachment PN of OIA Report 86-10).
4.
Any process and disposition issues from the work of Task Group 1.
S '.
Basic inspection and enforcement documentation and individuals who are
~
~
involved in the process of identifying, processing, and disposing of inspectiort. findings and issues.
~
Insofar as possible, the perfonnance of this task should rely on the writter record where lhat record provides sufficient; infonnation to support "
conclusions. Where it-is necessary to extend this record, this should be done in writing or by ihterview. Transcripts are to be made 'of interviews.
46 O
~'
g(q'r g 18, y[9, N: t A b4. y g.
A o
- pv N. q-
.e
-'w--
g m tu, eq e J *:: g'P 3 a6 % V q = ='y A-e.
4 2-2 01/09/87 N g(m...
F;rf;.-=j:f&t;:2shall:
ga 7@
2.
Analyze each issue and descr e the process by which it actually was handled. This relates to it identification as an inspection
~
" finding" (or other result of an inspection), classification as to i
significance or non-complian y status,.and ultimate resolution. This f
analysisshouldshow(with:;:r;;-f:t: 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 insoector, supervisors, or the Region to maintain awareness of the item i.nd its status For these items where there is an absence of agreement on process aN disposition, identify the basis for the disagreement and any record of disagreement and its processing. Particular attention should be given to signatures and f
concurrences and timeliness of these 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 that was used in making this independent detennination. 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 Me Feport@ the task efforts,'sha.1.k a.
Dascribe how the task was performed.
b.
Identify the infonnation base on which the task group's j
conclusions are based. This should describe 73 n ftf ; to assure the accurart of the infonnation base.,9 % 4 aWJea, j _. _ m. h, y...,1 Provide okler referelceV to the information that servpA as the l
c.
~
l basis for the conclusions and findings.
d.
Identify where there are differences between agency guidance, IE
}
guidance, and Region IV guidance and areas where guidance does not exist r A ^- 'j+ E A +3*ap-M * :.
)
Where the conclusion is that identification, processing, and l
e.
disposition have not followed expressed agency..IE, or Region IV
^
~ guidance, specify, in detail and with references, wheee this fa.ilure to follow guidance has occurred.
df g
~
h l
f'
(
(
.l 2-3 01/09/87
._..u_-,_
f 0,s55_, N b ">. 6 f.
For items of disagreement e changevin the report or records, describe the disagreement-..:
and express an opinion on
_c whether the guidance for process and disposition was, or was not, followed. For disagreement for which no guidance exists, express an opinion on the c t " #': ~^
^# +ba
<H"r^^ : t ;nd the ;ggRof the process and disposition actually,per, forme M,-
Ath rp-C r-g ea0-
-~
g.
Where guidance does not exist, express an opinion as to what 4 N !"
Grt guidance &u'd 5:.
As M.
Schedule N f dY M
aa &p 9 2.tcy as,www
- W f '&
M AM) l I
N O
O 6
4 es g
~
(
(
e 3-1 01/09/87 TASK GROUP 3 TASK FOR EXAMINATION RELATIVE TO SAFETY SIGNIFICANCE OF ISSUES OF OIA REPORT
- 86-10
, T% u%&es % q P *4 = j'" '
- L y
V 'o This tas relates to examination fo safety significance of the 34 issues of-Attachme t I to Attachment MM of O! Report'86-10 and the safety significance of any a dditional issues revealed t y the activities of Task Group 1 and Task Group 2, The efforts relative ta 1 ask Group I would be to describe the safety i
signific ance of failure by the ager icy to perform inspection. requirements of the IE 3
cannotjbe fully performed due to _.::!':::: construction inspection projram, particularly thes d'" h ".
.l f th: ' :;;;ti; :":rt.
ese items would be the result of Task Group 1 activities under Item 4(pnd tem 6d) p y P 3 ~
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 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 (pn se and f)of task performance in the task description. TASK GROUP 2-TASK F9 EXAMINATION OF ISSUES RELATING TO PROCESS AND DISPOSITION OF INSPECTION FI INGS OF OIA REPORT 86-10.
h P 43%e The Task Group will have availab?e 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).
2.
Any other issues needing safety significance review from the work of Task Group 1.
1 3.
Any other issues needing safety significance review from the work of Task Group 2.
4.
Basic inspection and licensing information and individuals knowledgeable of issues.
Insofar as possible, the performance of this task should rely on the written record where that record provides sufficient infortnation 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 of interviews.
Qwfaan,n&JN g
)
e Inadditiontoskillsavailablewithintheagency,TaskGroup3fshoulduse outside experts to provide needed skills and objectivity.
~
~
- tMk shall:
=
1.
Analyze each issue.and describe its safety significance to the Comanche Peak reactor assuming that the condition of the issue is as f
stated in CIA Report 86-10. The purpose of this analysis is to l
specify the " worst safety case" that may result assuming that 'the
~
t
-. ~
(
(
a s.
3-2
~
01/09/87 f y g 4 J ~..* L *.
n yv issue exists as stated without correctio t or recognition that the adverse situation exists, that is, a{if it existed and was undetected.
In this analysis, provide =,,r:;ritte references that serve as the basis for. determination of safety significance.
2.
Analyze the actions which were taken or which are planned to be taken to alleviate any safety significance associated with each of the 34 issues at Comanche Peak identified in 0IA Report 86-10.. In this analysis, give references to reports and other documents that serve as the basis for detemining the actions taken or planned and-their effect in alleviating concerns. Eta,luate the actions to d'l' 3 NW t wkA ;;;.r; h;th;r they alleviate or resolve,Tafety concerng.
If the actions taken or planned do not alleviate,the safety concerns, describe actions which, if take, would alleviate the concerns, Give references in support of inions or conclusions regarding corrective actions.
,.m._._'-
- 3. q{ "e,i Tr %g 1 c , :r h:= ' S = itca, the;..
..;t c r;1:t:ly i= ?= t;d ;;,;q.ir;d by th; :: ovm. us u e. i=;=t h; p. ;;r;.r.
'Ti: =;1.7......A.
u,;., ;.. L i., ta fvaluate the safety significance cf the failure to completely perfom the inspection requirement in g
accordance with the IE construction inspection program. Re(dA:Ng.
analysis should take into account all inspection activities b
M 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.
T4 be D
- a. _ n u e__T_.
..,,,.... C id itekthatVft t processed I
4, a
(Tccording to guicance or wnicn it in dispute as to correctness of J nd disposition f.'h;3;t:'. ; 1,, ; ' ;.., J.,
,,..... 4 -
\\orocess safety significance th::: fr =s. M,ety concerni stvaluate t id;...;T.d.
th;;; should be identified.
If amp actions have alleviated these concerns, these actions should be described.
If no action has been taken or ;'....;f, th: i;;.. g... d h it-t!' fed
/f actions taken or planned do not alleviate concerni, describe actions which, if taken, would alleviate concerns.
i DM l
~
9 l
r,
(
(
1 l
1 3-3 01/09/87 -
L n
m l
5.
Me FeportW the task efforts',:h:1?n l
L
.a.
Describe how the task was perfonned.
l
-b.
Identify the information base on which the task group's are based. This should describe any auditing to assure the accuracy of the information base, r-yt, a a
c.
Provide obr refer nc s to the information that serves as the basis for conclusions and findings.
d.
Highlight any i::::: :f safety significance re agency actions or plans may not alleviate safety concerns."
b ee e9 e
m
~
~
~
m 1
l DRAFT 12/17/86-A MEMORANDUM FOR:
John G. Davis, Director Office of Nuclear Material Safety and Safeguards FROM:
Victor Stello, Jr.
c;c, Executive Director for Operations l
SUBJECT:
OIA REPORT REVIEW: OIA FILE #86 ESTABLISHME OF REVIEW GROUP I
In order to resolve issues which OIA Report 86-10 has raised, I taking the following action:
1.
You are assigned as Chairman of a Review Group to resolve issues as described below.
G. Arlotto, J. Heltemes and C. Paperiel o are assigned as members of the Group.
2.
The task of the Review Group is to review the technical ssues identified in OIA report 86-10 and to determine and document in a r port to me (1) the satety significance of those issues for Comanch Peak, i. e.,
whether actions should be taken to rectify any Nnsafe conditions;
, 2) whether the issues when identified were appropriately handled as to process and disposition; and, (3) determine whether the* current augmented review and inspection effort at Comanche Peak hsufficient +n enmpensate
[4 fer any identified weakness in jegin IV's Q/A inspection programs.
+ q M M
<1,f M e %
6y -
-4 [gj YoumaytaskotherNRCstafforutilizecontractorsasrequired,afthough
/
I recommend that you keep your requirements to the minimum possible.
Necessary funds will be made available at your request by RM.
T. Westerman y
and H. Phillips will be detailed to support your independent review on a full-time basis; other members of RIV are at your full disposal as you may require.
Similarly, IE and NRR staff working on Comanche Peak are available to assist.
4.
Copies of the report and enclosures will be provided to you by separate cover.
5.
I would like to have your report in my hands by January 30, 1987.
Victor Stello, Jr.
Executive Director 9 /4,,,,,
- a.
for Operations t
cc:
E. Beckjord R. Martin 72 # - U # '
G. Arlotto
~ '/ /',I R. Scroggins J. Taylor H. Denton J. Keppler C. Paperiello :is 0FC :A0/EDO
- ED0 NAME :TRehm
,4VStello
................p ?y................................................................---........
~
02/13/87 1
Y O
'm, f e
> 1 p,' '
h r'\\
)
I T0:
G. Arlotto, RES N
C. Heltemes, RES C. Paperiello, RIII J. Lieberman, 0GC J. Goldberg, 0GC P. McKee, IE S. Collins, RI D. Crutchfield, NRR R. Hartfield, IRM CPRRG MEETING NOTICE DATE & TIME:
Wednesday, 2/18/87 0 8:45 AM PLACE:
AEOD CONFEREhCE ROOM hp 2nd Floor - EWS - Bethesda 4lf Y
4 lg/
A_GENDA ITEMS b
Y.
gb OGCBriefingonF0IAProcedures'}gtW[ d I'
Receive reports from:
Inspection Task Group Safety Significance Task Group 766 Task Group Discuss Process Task Group draft report Plan CPRRG Report Production i
.N c O/M kA)CH C f O tx k u 68;A rt M l'
C P/2Pf 7htK Grou f 2
-i
/
ia s
l:a> :::, T hocpLr~s we :,a;c -
l&ccca caDhs euikeu l 5eoh 3
Tssu :cd7 A. t B yroww/
DVt.tbuwim,u 2 Tan 1
I'5
? 2{'(91 C 65
~
ga
9 3
2 34bcu ksk+n& (As if (cn(b2tc& wa hcevacww eA o
3 A4a/2Azlua0haaDJ)up4(Zb!&{
u
x 3.
_l lf I
f i ' - ^E (kl Q
j.
gg s
a i
.. i
'l
(
- 4,,
'\\
p I,,"
- \\ 4 '
6
,4.
f uw Q
G
.f) y s
3
! 1 l
\\
i a
p, it 4
\\*
'\\
(
l y
,s.
Mk
^-
.g pg'
,.gg j
[g Ne c.1
E x - 4t.
~
~
s
.. +
y Document.Name:-
E3 COMANCHE PEAX/4 Requestor's ID:
MILLER:
I Author's Name:
W JGDavis l
'$ (
l' Document Comments:
f M
Destination Name:
MILLER Distribution Nane:
IT NRCADMW BEVERLYC 0015
(
Addressee; I
Lois Miller, P404, x27726 Data Sent:
/
01/L /87 1
Tinie Sent:
15:31 L
Message:
Pls deliver to Vollmer, and Rossi, NRR.
As discussed w/ Davis; C.E.Rossi proposed to organize and lead Comanche P k Gp.-3 Task statement attached. R.Erickson (74194), Review Gp.
Coordinator, can answer questions if needed.
bcsr M
CDosn-u a 4 % am 3 3g %
1
+
f lbsl$nA, & AU
@ p e>-cn w 3 -
3 se a u-Oz n~ px L DQ-u&%w&) CaPL"p Om&.
1%s/s sp f@4%=rA @
.>..sn o
rk h tbNHH Yd'f
i I-1(1/20/87)
TASK GROUP 1 l
l TASK FOR DETERMINING WHETHER THE CURRENT AUGMENTED REVIEW AND INSPECTION EFFORT 1
AT COMANCHE PEAK IS SUFFICIENT TO COMPENSATE FOR ANY IDENTIFIED WEAKNESSES IN 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 RG 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 agency inspection effort at Comanche Peak, regardless of by whom performed, meets or is equivalent.to, the existing IE construction inspection program.
The Task Group will have available to it:
i 1.
The information from IE in response to CPPRG Letter RG IE.01. This
]
information establishes the base against which inspection activities performed are to be compared.
-2.
The information from Region IV in response to CPPRG Letter RG RIV-01.
This information provides the Region's view of the inspection
1-2 performance of the Region against the IE construction inspection requirements.
1 i
3.
The information from the Comanche Peak letter RG-PO-01. This information provides the Project Office's view of its performance 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 im writing or by interview. Transcripts are to be made of intetviews.
In addition to skills available within t,ie agency. Task Group 1, whenever necessary or desirable, may use outside experts to provide needed skilli and objectivity.
This Tack Group shall:
1.
Audit information provided by IE, Region IV, the Comanche Peak Project Office and others against the primary or source document or
c 1:
.1 1-3 L,'
information to assess'the' accuracy and completeness of the input I
provided.
2.
Compare de scope, frequency and skill depth of inspections by (a)
Region IV; (b) the Comanche Peak Project Office (CPP0);-(c) any other
.j 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 activities, skill depth and timeliness.
i q
3.
Identify where inspection performance:
1 (a) meets IE program requirements (b) exceeds IE program requirements l
~
(c) does. not meet IE program requirements.
i 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 CPP0 activities, specify the requirements in effect at the time of the I
inspection if different from current requirements and describe the degree to which the then existing inspection requirement was fulfilled.
1
e 1-4 l
t.
i 4.
Describe specific inspection requirements which -have 'not been completely. fulfilled by the ' agency's. total inspection effort. This complete fulfillment is with regard to activity, skills, timeliness, 1
and completeness.
References are to be made to requirements in the IE defined program and to inspection reports (regardless of by whom 1
performed and reported) so that information on nature and degree of l
any incomplete status of any current inspection requirements can be identified.
)
5.
Identify inspection findings or results that showed "open" items, I
h unresolved items, items of noncompliance, violation or^any other f*
finding or conclusion where the i..spection 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.)
6.
Report on the task efforts:
i l
1 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.
l f-i
1 l
5 1-5 l
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 1/22/87 Membership, Organization & Approach established 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 Test 1 on Task 2 2/4/87 Submit final report to CPRRG l
1 i
i 1
l j
I i
~
~
1 i-,
2-1(1/20/87)-
1 q
TASK GROUP 2 l
1 i
TASK FOR EXAMINATION OF ISSUES RELATING TO PROCESS AND DISPOSITION OF INSPECTION FINDINGS OF OIA REPORT 86-10 This task relates to examination of the 34 issues of Attachment i to Attachment MM of OIA Repcrt 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 COMPENSATEFORANYIDENTIFIEDWEAKNESSESINREGIONIV'sINSPECTIONPROGRAMS.
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, j
and Region IV.
The Task Group will have available to it:
l
.)
I l
A
2-2 i
.1.
The information from IE in response to CPPRG Letter RG IE-02. This i
information establishes the basis from IE for inspection reporting; item identification, classification and disposition; and responsibilities for inspection performance and reporting.
2.
The information from Region IV in response to'CPPRG Letter RG RIV-02.
'i This information establishes the basis from Region IV for inspection reporting; item identification, classifications and disposition, and responsibilities for inspection performance and reporting.
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 Report 86-10 (essentially the 34 issues in Attachment 1 to' Attachment MM of OIA Report 86-10),
i 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, processins, and disposing
)
of inspection findings and'inues.
x 2-3 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.
l This Task' Group shall:
1.
Audit information provided by IE, Region IV, the Comanche Peak Project Office or others against.the primary or source document or i
information to assess the accuracy and completeness of the input
.provided.
t 2.
Analyze each issue and describe the process by which it actually was handled. This relates to its identification es an inspection
" finding" (or other' result of en 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 maintain awareness of the item and its status.
For these items where there is an absence of agreement on process or disposition, identify the basis for the disagreement and any record of L
disagreement and its processing. Particular attention should be given to signatures and concurrences and timeliness of these t.
ai.
24 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 that 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 i
basis for these explanations.
~4.
Report on the task efforts:
a.
Describe how the task was performed.
i l
b.
Identify the information base nn which the task group's conclusions are based. This should describe the results of i
i activities to assure the accuracy of the information base.
c.
Provide complete and specific referencas to the information that served as the basis for the conclusions and f,'ndings.
l l
_______-____L
(
y
'.L' 2-5 s.
[..
'd.
-Identify where there are differences between agency guidance, IE l
l guidance, and-Region IV guidance and areas where guidance does
.not exist or is subject to wide interpretations, g
e.
Where'the conclusion is that identification, processing,-and i
. 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 d
of changes in the report or records, describe the ' disagreement and 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 on the appropriateness of the process and disposition actually performed.in light of the significance and implications ~ of the disagreement.
I 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 of action.
l 7
i D
2-6 Schedule 1/20/87 Task Leader appointed 1/22/87 Membership, Organization & Approach estblished 1/23/87 Start work on example (pilet effort) 1/27/87 Review pilot effort with CPPRG 1/30/87 Check for possible impact of Task 1 on vask 2 2/4/87 Submit final report on CPRRG I
3-1(1/20/86)
TASK GROUP 3-TASK FOR EXAMINATION RELATIVE TO SAFETY SIGNIFICANCE OF ISSUES OF DIA REPORT 86-10 This task relates to examination for safety significance of the 34 issues of
~
Attachment 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 i
Group 2.
The efforts relative to Task Group 1 would be to describe the safety significance of failure by the agency to perform Mpection 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 S (and described in Item 6d) of the task description TASK GROUP 1-TASK FOR DETERMINING WHETHER THE CURRENT AUGMENTED REVIEW AND INSPECTION EFFORT AT CO.MANCHE 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'01A REPORT 86-10.
~
I The Task Group will have available to it:
j l
l 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).
a
.c 3-2 l
2.
Any other issues needing safety significance review from the work of j
Task Group 1.
3.
Any other issues needing safety significance review from the work of Task Group 2.
I 1
4.
Basic inspection and licer. sing information and individuals knowledgeable of issues, insofar as possit.le, the performance of this task should rely on the written record rhere 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 of 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.
&jn })y ( Q ( [sR W & M f !i ? a ".
"{.L.Y $
-., q.
The purpose of this analysis is to specify the '.,.. g
.Q..
..7
- 4. i
}&}Kff
' f W.'.
l
- .[
=,
l (MIMENIN%T?M 1;1;i.e_i_ - )..,i. 83 (g{gQd.
In this analysis, provide complete and specific references that serve as the basis for determination of safety significance.
3-3 2.
(Analyze ;the actionsiwMC(%if n,
(to-' alleviate'any safetf3JMjfidh)nifyggggg34 (issgat Comanche;Peaklide~niffiEd2RRRiggg077 In this analysis, give references to reports and other documents that serve as the basis for determining the actions taken or planned and their e#fect 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 sufficier.tly alleviate the safety concerns, describe actions which, if taken, would alleviate the concerns. Give references in support of opinions or conclusions regardir.; corrective actions.
[Eva106tsMhe safetylsignif1Magd"g%)MistgT(Myg~
D 3.
Othey nspection re'quj % 35 3 @ Tag M M g g ginspection program.' 1(NoteQThe3puffhEBiO5[tiiin$$$flFom (Task 7 Force 1.) The analysis should take into account all inspection g' [
c ities associated with an incomplete or non-performed item.
Safety concerns should be described.
If agency actions alleviate h
concerns, these should be described.
If the actions taken or planned
)
kb do not alleviate concerns, describe actions which, if taken, would alleviate concerns.
4.
Evaluate the safety significance of items identified by Tcsk Force 2 q
that were not processed according to guidance or which are in dispute as to correctness of processing and disposition. All safecy 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.
.--_____________D
~.
n H,
3-4 5.
Report on.the task efforts:
' Describe how the task was performed.
a.
b.
Identify the information base' on which the' task group's are based. This should describe any auditing to assure the accuracy.
of the information base, c.
Provide complete and specific references to the information that serves as the basis fcr conclusions-and findings.-
d..
Highlight'any safety significance issues where agency actions or p1ans may-not al_leviate safety concerns.
Schedule l
1 1/20/87-Task Leader appointed i
l 1/22/87 Membership, Organization & Approach established
)
1 1/23/87 Start work on example (pilot effort) l 1/27/87 Review pilot effort with CPRRG 2 /87 Analyze reports of Tasks 1 and 2.
Factor into Task 3 2 /87 Submit final report to CPRRG
/
1 f
h4 0 s
9
.s l
F~'-~-~'~
~ ~'~ - -~' ~~ -
'~
~
'~'-
~
~
o fl 'e' g
4 j
- /.
6dllJJuh Aub
] 19 /
G A S a...
- t.
as z uv sta d (AM ss-ovfor
- t as z eev m,.a.wa a a
% g
- v-ap j
i L&
br
- O'%lsl 5k As o
L.uA sc-s)a
- s pass >
4 mu w m)+st-op
'@. _q g _S4 y
85 m,j,1
"(g)
A
$ A L w% G rg-kW6 v..L puQ
- +
sc-62 os
- g ag,h 4ed A.p.0 x!n.
luk. Lgf 55-aps
- b Lt wLL y
bS ~ l'llIl
- (l) f5AC wn6's a,ue.mb-6 sc iv/or (2) n,,+. h - m.ds j
1 (ptQ s 5 I'lj'11 cu%L of.uesJ> -%,. A i
s 9
.'4/n
- 4 xkvs/cau.
ojuwAs 1
es.duS ol Alcovko
% 4~ 14lH S
8 4 -11l11 (o
6sdd ol As4 i
( M L u.)
- 94}i+]iu 7
call
>}ximb
S l
hk% ' E h~h h
MM ol4A El-14ll1 4%
4 il ol A A
% {- 14ly
- 1 i
%f - l1)r a fo eaLL.j.aJ k$
- lY ll f
O U b
i sc - 19),
t 12. eMfd (p ff )
L n.,$,
s,3 o~-u.p a tN ss -ia ),,
e 19 a t o p a - ca s h +
att.;.oua t 4.p 4 e
sr - >+
s 1
9 f-1LfI'b w
e
~M
~.11/
ss-ium
+2 49 ea sc - u.)a
- 4 s % % L 'A
- T Am a
ss-K,jia m
~
l
y A
i Q*z as &c 1
E-
..k Ateg,v) 6 - l' / S 6
%Q h 4,a.E 8 5 - l<./ a.
- T wfug 4
xJ (deLDwdl.j w
sq a af~gtL,,0 ss - sqa
's
-q~
k w - 14,2
'n
-wfn w -,q,3
- il
-q-g h
,..h'M:
4 Gnx3 LO r
v h
O AlA o
W - Mll3
)~l, deads mi
,9 %
Guw s - ALD i
0&
" & hb 7
4
)
l j
l t
i l
i
'/f,i - 800 %
h COMANCHE PEAK OIA REPORT 86-10; REVIEW GR0llP (CPRRG) 5520 Local NAME TELEPHONE MAIL 3 TOP Node Name Address John G. Davis, NMSS, Chainnan 42-74063 SS-958 NRCADMW BONNIEP Guy A. Arlotto, RES 44-37995 NL-005 NRCRES MCCAUSLA Clemens J. Heltemes, Jr., AE0D 49-24484 EWS-263 NRCIE AEOD Carl J. Paperiello, R-III FTS-388-5517 R-III NRCRIII LEAD 0P James Lieberman, OGC 49-28679 MNBB-9604 NRCELD CONNIET Jack R. Goldberg, OGC 49-2.7619 MNBB-9604 NRCELD CONNIET Legal Advisors
'YC Phillip F. McKee, IE 49-29650 EWS-346 NRCIE LEADOP Task Group 1, Leader Samuel J. Collins, R-I FTS-488-1126 R-I NRCRI LEAD 0P Task Group 2. Leader Dennis M. Crutchfield, NRR 49-27733 P-500 NRCDPLB SHEA Task Group 3, Leader PRINCIPAL CONTACTS Robert D. Martin, R-IV FTS-728-8225 R-IV NRCRIV LEADOP Vince Noonan, NRR 49-27a25 110 NRCDPLA SIMS James M. Taylor, IE 49-27397 EWW-322 NRCIE IEDIR OTHER CONTACTS AND INTERESTED PERSONS lan Barnes, R-IV FTS-728-8176 R-IV NRCRIV LEADOP Eric Beckjord, RES 44-74341 NL-005 Lawrence J. Chandler, OGC 49-28658 MNBB-9604 NRCELD ANNIEB Paul 5. Check, R-IV FTS-728-8222 R-IV NRCRIV LEAD 0P Harold Denton, NRR 49-27691 P-433 Alexander W. Dromerick, IE 49-24784 EWW-507 Ramon E. Hall, R-IV FTS-728-8182 R-IV NRCRIV LEAD 0P Richard A. Hartfield, IRM 49-28258 MNBB-7602 Eric H. Johnson, R-IV FTS-728-8106 R-IV NRCRIV LEAD 0P James G. Keppler, R-III FTS-388-5181 R-III NRCRIII LEAD 0P James E. Konk11n, IE 49-29656 EWS-312 NRCIE VI George A. Mulley, Jr., OI A 49-24451 EWS-461 Thomas E. Murley, R-I FTS-488-1299 R-I NRCRI LEADOP Delmer E. Norman, R-IV FTS-728-8257 R-IV NRCRIV LEADOP James G. Partlow, IE 49-24614 EWS-360 NRCIE EILEEN H. Shannon Phillips,'R-IV (817) 897-2201 R-IV NRCRIV LEAD 0P Thomas A. Rehm EDO 49-27781 HNBB-6209. NRCRM EDO Ronald M. Scroggins, IRM 49-24750 MNBB-12109 R. Lee Spessard. IE 49-28833 EWS-350 NRCIE EILEEN Charles M. Traunell, NRR 49-27317 110 NRCDPLA SIMS Stuart A. Treby, ELD 49-28661 MNBB-9604 NRCELD LEAD 0P Annette Vietta-Cook, NRR 49-28525 110 NRCDPLA SIMS l
Richard H. Vollmer, NRR 49-27726 P-428 NRCNRR MILLER Thomas F. Westerman, P-IV FTS-728-8145 R-IV NRCRIV LEADOP (REVIEWGROUPMAILINGLIST) 01/27/87 l
I.
o l
DRAFT #1 l
I JGDavis:bsp 1/27/87 MEMORANDUM FOR: William G. Mcdonald,3"M n d M~k 7ar
&g FROM:
John G. Davis. Mov'*'
e 1H ^
m,,,
j
SUBJECT:
. COMANCHE PEAK REPORT REVIEW CC ZI, TEE (CPRRG) TASK--RG RM-01 By a memorandum of January 21, 1987, entitled 0IA REPORT REVIEW: OIA FILE
- 86-10-ESTABLISHMENT OF REVIEW GROUP the Executive Director for Operations assigned to the CPRRC2the task of reviewing the. purpose and significance of NRC Fonn 766 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 request that you assign appropriate personnel to examine the NRC Fonn 766 purpose and use and provide the CPRRG with a report that includes the following:
1.
The purpose of the NRC Form 766 program.
2.
Whether or not the NRC Form 766 program currently meets its intended purpose.
If not, why does it not meet this purpose? If not, an estimate of the reliance that can be placed en the information within the
- /// Zerm % 4 fryrom.
j 3.
If the NRC Form 766 program does not fulfill its intended purpose and if its purpose is necessary to the functioning of the Office of Inspection and Enforcement and of the Regional Office programs, how is this purpose l
currently being accomplished?
4.
If the NRC Fonn 766 program does not fulfill its intended purpose, should de the NRC Form 766 programpy>p. modified to perform its intended purpose and, if so, what modifications appear appropriate?
2 l
r;, _
(
,7 William G. Mcdonald 5.
If the NRC Form 766 program does not fulfill its intended purpose and it does not appear appropriate to modify it, what alternative means of accomplishment appear appropriate?
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 report should be submitted to the CPRRG by February 9,1987.
John G. Davis
Enclosure:
As stated 1
I I-1.(1/20/87)
TASK GROUP 1 L
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 NOTE Performance of this task accepts as the baseline or stendard the existing IE construction inspection program as identified by IE in response to the Comanche Peak Report Review Group (CPRRG) Letter RG 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 agency inspection effort at Comanche Peak, regardless of by whom performed, meets or is equivalent to, the existing IE construction inspection program.
The Task Group will have available to it:
i l
1.
The information from IE in response to CPPRG Letter RG IE-01. This l
information establishes the base against which inspection activities performed are to be compared.
2.
The information from Region IV in response to CPPRG Letter RG RIV-01.
l 1
i' This information provides the Region's view of the inspection l
l l
l 1
1
e[' '
1
(
+-
12 performance of the Region against the IE construction inspection y
requirements.
d 3.-
The information from the Comanche Peak Letter RG-P0-01. Thfs 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
.c
" reviewed inspections or supervised or managed the inspection program for Comanche Peak.
i 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 l
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 s, kills 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 a.
^
l k
1-3 infonnation to assess the accuracy and completeness of the input I
I provided.
1 l
2.
Compare the scope, frequency and skill depth of inspections by (a)
Region IV; (b) the Comanche Peak Project 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 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.
1-4 1
l i
1 4.
Describe specific inspection requirements which have not been j
completely fulfilled by the agency's total 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 performad and reported) so that infonnation 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 l
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 ideri.ified which cannot be tracked to current status or closure.)
6.
Report on the task efforts:
I Describe how the task was performed.
a.
b.
Identify the information base on which the task group's I
conclusions are based. This should describe the results of activities to assure the accuracy of the information base.
I 1
1-5 c.
Provide complete and specific references to the information taat served as the basis for the conclusions and findings.
d.
Where the conclusion is that inspection performance does not me?t current IE program requirements, specify, in detail with references, where and how the performance is deficient, Where the inspection findings or results have been modified from e.
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 liembership, Organization & Approach established 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 2/4/87 Submit final report to CPRRG b
i 2-1 (1/20/87) risk GROUP 2 TASK FOR EXAMINATION OF ISSUES RELATING TO PROCESS AND DISPOSITION OF INSPECTION FINDINGS OF OIA REPORT 86-10 l
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 PROGRAMS.
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.
The Task Group will have available to it:
t 2-2 1.
The information from IE in response to CPPRG Letter R6 IE-02. This l
information establishes the basis from IE for inspection reporting; item identification, classification and disposition; and responsibilities for inspection performance and reporting.
2.
The information from Region IV in response to CPPRG Letter RG RIV-02.
This information establishes the basis from Region IV for inspection l
reporting; item identification, classification and disposition, and responsibilities for inspection performance and reporting.
1 3.
Any information from OGC relative to NRC policy and practices for processing and disposition of issues and inspection findings, i
4 The information of specific process and disposition issues from OIA Report 86-10 (essentially the 34 issues in Attachment I tc Attachment MM of OIA Report 86-10).
5.
Any process and disposition issues from the work of Task Group 1.
6.
Basic inspection and enforcement documentation and individuals who are involved in the process of' identifying, processing, and disposing 1
l of inspection findings and issues.
l l
l i
l
l 2-3 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 rece
.1, this should be done in writing or by interview. Transcripts are to be made of interviews.
This Task Group shall:
1.
Audit information provided 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 maintain awareness of the item and its status.
For these items where there is an absence 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
I
\\
~
2-4 signatures and concurrences in relationship to changes in
' documentation.
3.
Analyze each issue and independently describe the process and l
disposition by which the item should have been handled. Reference l
1 the guidance or practice that was used in making this independent
.l l
determination. Compare this independent determination with the i
)
I handling and disposition that actually occurred. Where there are differences in the process and disposition between what independent I
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 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, c.
Provide complete and specific references to the information that served as the basis for the conclusions and findings.
(
l
~2-5 l
s 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.
i c.
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 i
this' failure to follow guidance has occurred.
f.
For items of 'sagreenent 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 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.
I h.
Where guidance does exist, but there are differing' interpretations, recommend a course of action.
l f
)-
t t
r l
lL
(
l 2 A
-' Schedule.
l/20/87 Task Leader appointed.-
1/22/87 Membership, Organization & Approach estblished 1/23/87 Start work on example (pilot effort)'
I
- 1/27/87 Review pilot effort with CPRRG
-1/30/87. Check for possible impact of Task I on Task' 2 2/ 87 Submit final report on CPRRG i
i i
i e
-.'f, k
ci '
g 7,
'N 3-1 (1/20/86)
TASK GROUP 3 i
i 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 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 6
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 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 1
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 perfomance 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 i
issues in Attachment I to Attachment MM of OIA Report 86-10).
(
~
y.___ __
3-2 2.
Any other issues needing safety significance review from the work of Task Group 1.
3.
Any other issues needing safety significance review from the work of Task Group 2.
4 Basic inspection and licensing information and individuals knowledgeable of issues.
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 of 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, i
This Task Group shall:
1.
Analyze each issue and describe its safety significance to the 1
Comanche Peak reactor assuming that the condition of the issue is as stated in OIA Report 86-10.
The purpose of this analysis is to specify the " worst safety case" that may result assuming that the issue exists as stated without correction or reco,gnition that the adverse situation exists, that is, as if it existed and was undetected.
In this analysis, provide complete and specific references that serve as the basis for determination of safety significance.
o
(
3-3 t
2.
Analyze the actions which were taken or which are planned to be taken to alleviate any safety significance associated with each of the 34 issues at Comanche Peak identified in OIA Report 86-10.
In this analysis, give references to reports and other dncuments 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 clieviate the safety concerns, describe actions which, if taken, would alleviate the concerns. Give references in support of opinions or conclusions regarding corrective actions.
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 Task Force 1.) The analysis should take into account all inspection activities associated with an incomplete or non-performed item.
f Safety concerns should be described.
If agency actions alleviate
{
concerns, these should be described.
If the actions taken or planned j
do not alleviate concerns, describe actions which, if taken, would alleviate concerns.
l l
4.
Evaluate the safety significance of items identified by Task Force 2 l
that were not processed according to guidance or which are in dispute I
I as to correctness of processing and disposition. All safety concerns f
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.
l.
i
t, i.~
(
g 3-4 i
S, u
5.
-Report on the task efforts:
a.
Describe how the task was performed.
l b.
Identify.the information base on which the task group's are based. This should describe any auditing to assure the accuracy of the information base.
Provide complete and specific references to the information that c.
serves as the basis for conclusions and findings.
I d.
Highlight any safety significance issues where agency actions or i
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 I and 2.
Factor into Task 3 17
- 2/5'/87 Submit final report to CPRRG 4
a
(,
,f
(
.h
,e
)h*
' MEMORANDUM FOR:
Robert B. Martin, Reg 1'onal_ Administrator j
Region IV l
f t
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 In order that the Comanche Peak OIA Report 86-10 Review Group (CPRRG) can
~
e 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:
?i 1.
Information--regardless by whom developed--which establishes the respon-y, sibilities 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.
Information re ${KM $ N_,. ;O., ".' which identifies means to resolve Ak 2.
ences of opinions or positions with regard to inspec M performance
,(
4 ': 2. ;. ;..,. w_ :..i ;....,..d ^ ;;;; "' c; ;rt ;;:t::t.
WW Mhnf.
Information that descri ble classifications of findings or conclusionsfromYU:gthepossi I~
3.
s and the meaning of the classifications in tenns of safety significance, " attention" or Regional follow-up given to items because of classifications, conclusions regardi g licensee performance, n
and enforcement. What the CPRRG-seeks is infonnation used by Region IV L
^
' ~ -~
~
~
'IV 2 DUPLICATE R
DRAFT,(,12/22/861 RIV -0L
-