ML20237K413
Text
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March 23, 1987 Note.to:
Robert Erickson From:-
Lawrence J. Chandler
SUBJECT:
DOCUMENTS RESPONSIVE TO GAP FOIA REQUEST 87-87 I
In accordance' with Guy Arlotto's memorandum dated February 25, 1987 and our conversation of this date, attached are copies of.
the following documents in my files which appear to be responsive to the referenced FOIA request and which are not listed in your catalogue of documents collected'or prepared by the CPRRG:
1.
Review Group Mailing List 1/13/87 2.
Listing of Documents Received by-CPRRG, dated.1/15/87 3.
Comanche Peak OIA Report 86-10 Review. Group (CPRRG) and Principal Contact
- Persons, dated 12/19/80 4
Memorandum, Davis to OGC, undated
- draft, subject: Issues Raised by OIA Report 86-10 Having Broader Implications For' Region IV In addition,. it is not clear from your catalogue whether the
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following documents are included among the enclosures attached to item 2 of CPRRG ADMINISTRATIVE DOCUMENTS:
5, Memorandum, Stello to Martin, subject:
OIA REPORT REVIEW OIA FILE
- 86-10, DRAFT 12/17/86-A j
6.
Memorandum, Stello to Davis, subject:
OIA REPORT REVIEW:
OIA FILE
- 86-10 ESTABLISHMENT OF REVIEW
- GROUP, DRAFT 12/17/86-A 7.
Draft Press
- Release, NRC'S EXECUTIVE DIRECTOR APPROVES ACTIONS AT REGION IV OFFICE IN COMANCHE PEAK MATTER, undated Copies of documents 5 - 7 are attached for your records.
d4WAth awrence Chandler Attachments: As stated I
$N14, PDR J
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j COMANCHE PEAK OIA REPORT 86-10 REVIEW GROUP,(CPRRG) 5520 Local 1
NAME TELEPHONE -
MAIL STOP ~
Node Name Address John G. Davis, NMSS, Chairman 42-74063 958-SS ~
NRCADMW BONNIEP Guy A. Arlotto, RES 44-37995 NL-005 NRCRES MCCAUSLA Clemens J. Heltemes, Jr., AE0D 49-24484 EWS-263 NRCIE AE00 Carl J. Paperiello, R-III FTS-388-5517 R-III NRCRIII LEAD 0P
- James Lieberman, OGC Legal Advisor 49-28679 9604 NRCELD CONNIET Robert A. Erickson, NMSS Coordinator 42-74194 881-SS NRCADMW B.EVERLYC-PRINCIPAL CONTACTS Robert D. Martin, R-IV FTS-728-8225 R-IV NRCRIV LEAD 0P Vince loonan, NRR 49-27425 110 NRCDPLA SIMS o
James in. Taylor, IE 49-27397 EWW-322 NRCIE IEDIR OTHER CONTACTS AND INTERESTED PERSONS Eric Beckjord, RES 44-74341 NL-005 Lawrence J. Chandler, OGC 49-28658 9604 NRCELD ANNIEB 1
Paul S. 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 Jack R. Goldberg, OGC 49-27619 9604 NRCELD CONNIET Ramon E. Hall, R-IV FTS-728-8182 R-IV NRCRIV LEA 00P 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. Konklin, IE 49-29656 EWS-312 NRCIE VI George A. Mulley, Jr., OIA 49-24451 EWS-461 James G. Partlow, IE 49-24614 EWS-360 NRCIE EILEEN H. Shannon Phillips, R-IV (817)897-2201 R-IV NRCRIV LEAR 0P Thomas A. Rehm EDO 49-27781 6209 NRCRM EDO Ronald M. Scroggins, IRM 49-24750 12109 R. Lee Spessard IE 49-28833 EWS-350 NRCIE EILEEN Annette Vietta-Cook, NRR 49-28525 110 NRCDPLA SIMS Thomas F. Westennan, R-IV FTS-728-8145 R-IV NRCRIV LEAD 0P REVIEW GROUP MAILING LIST 01/13/87
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NUCLEAR REGULATORY COMMISSION L(
OFFICE OF INSPECTION AND ENFORCEMENT
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INSPECTION AND ENFORCEMENT MANUAL DEPER INSPECTION PROCEDURE 92703 IE BULLETIN, CONFIRMATORY ACTION LETTER, AND GENERIC LETTER FOLLOWUP R
PROGRAM APPLICABILITY:
2512, 2513, 2515 92703-01 INSPECTION OBJECTIVES 01.01 To ascertain whether the informaQ n_,4pb;Q$tebby a licensee in to anwjE rgkiq$1styjentL. Mattien Qfollowup of IE response u
a bulletins sent Tor information is addressed in procedure 92717) is technically adeouate, satisfies the requirements established c see.
01.02 To ascertain whether the information discussed in a confirma-tory actior letter (CAL) represents the action taken by the licensee.
01.03 To ascertain whether the information discussed in a generic letter (GL) has been addressed by the licensee.
92703-02 INSPECTION REQUIREMENTS 02.01 FptregtUlkM 3 determine whether the following actions taken by the licensee meet the bulletin requirements and licensee commitments:
a.
Document Review.
Review every requested action to assure the following:
1.
gwas within the time period stated in 2.
64 includes the information required to be reported.
3.
Mft9tPWW999Mff*Tficludes adequate corrective action commitments based on information presented in the bulletin and licensee's response,
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i Issue Date:
2/15/85
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'L, IE RULLETIN, CONFIP.MATORY ACTION-E 92703-02.01b.1 LETTER AND GENERIC LETTER FOLLOWUP 1.
Licensee management has forwarded copies of the written response to appropriate onsite management representatives.
2.
Information discussed in the licensee's-written response was accurate.
3.
Corrective action taken by the licensee was_ as described in the written response.
02.02 For each confirmatory action letter sent to the licensee, determine by selected sample onsite whether the following actions taken by the licensee meet CAL requirements and licensee commitments:
a.
Licensee management has forwarded copies of the let-ter and any needed instructions to appropriate onsite maragement representatives.
b.
Corrective actions were taken as described in the CAL.
02.03 For each generic letter sent to the licensee for action, de-termine by selected sample onsite that the following actions were taken by the licensee:
a.
Licensee management has fo'rwarded copies of the written response to appropriate onsite management representatives.
b.
Picnt-specific actions were taken as described in the licensee's written response.
The response is clear and i
consistent with the understanding of onsite management reoarding any statements or commitments.
If a significant inspection effort is anticipated, tem-porary instructions (tis) will be written.
Nn inspection of plant-specific actions is needed, if the generic letter nerely requested information for possible licensing ac-tions.
If a discrepancy or potential problem is found, notify the regional office and the appropriate project manager in NPR's Division of Licensing.
92703-03 INSPECTION GUIDANCE 03.01 A bulletin normally requires a written response from the li-censee to the regional office within a specified period. When a written response is received at the regional office, the as-signed regional office personnel review and evaluate the licen-see's response for adequacy.
An inadeouate response should be Issue Date:
2/15/85 _
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IE BULLETIN CONFIRMATION ACT10N LETTER AND GENERIC LETTER FOLLOWUP 92703-03.01a i
resolved under the provisions of IE Manual Chapter (MC) 0720 (formerly MC 1125) IE has the responsibility for compiling regional findings and closing'out the overall issue.
i a.
Whenever a bulletin or licensee response specifies ac-l tions that alter.an existing license condition, the-4 evaluation of the-licensee's written response is coordinated by IE with NRR or NMSS in accordance with' the' NRR/IE/AE0D/ Regional /NMSS Interface Agreement (IE MC 0720).
b.
The Regional. Inspection Report' of site inspecti_on
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activityJ associated with a.
bulletin should include the inoffice review of the written. response.
- Also, inspection hours. for direct inspection efforts docu-mented on NRC Form 766 should include both the site and inoffice inspection hours.
q Temporary. instructions, if
- required, provide guidance for any unique handling, evaluation, or processing of licensee replies and onsite inspection of licensee l
actions.
The TI may be issued concurrently with. a bulletin, or shortly afterwards.
03.02 The confirmatory action letter is issued by the regional office as a means for confirming a licensee's agreement to take certain actions to.. resolve significant concerns about.
health and safety, safeguards, or ' the environment.
Unless instructed otherwise by regional management, CALs sent to a licensee should be inspected on a' sampling-basis in accor-dance with this procedure ~ and closed out in an inspection report.
Responsibilities, criteria, and guidance regarding the issuance of CAls are delineated in 10 CFR 2, Appendix C.
03.03 NRR periodically promulgates information, interpretations, and requirements to licensees via generic letters.
The gen-eric letter sometimes necessitates that the licensee per-forn certain actions or provide a written response to NRR's Division of Licensing or. both.
While NRR normally has the responsibility (unless specifically delegated to the regions) of evaluating generic letter responses for technical adequacy, it is important to utilize any plant-specific knowledge of the resident or regional inspectors to clarify or help in the technical evaluation of the response.
On e sampling i
basis, the licensee's response should be reviewed to ensure
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that site management's understanding of commitments are consistent with the written response.
This review should concentrate on
- policy, operational or procedural
- changes, j
scFedules, prcposed facility modifications and/or existence of present procedures or equipment.
I l Issue Date:
2/15/85
e IE BULLETIN, CONFIRMATORY ACTION 92703-03.03 LETTER AND GENERIC LETTER FOLLOWUP If aiere is no specific formal request from NRR for postimple-mentaticn followup inspections, changes to procedures or plant modifications should be reviewed to verify that the licensees are meeting their accepted commitments.
Any reviews or followup inspections should be documented in an inspection report and on the NRC Form 766.
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END I
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i Issue Date:
2/15/05 _ _ _ - _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ - _ -
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UNITED STATES t
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OFFICE OF INSPECTION AND ENFORCEMENT
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Washington, D.C. 20555
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i INSPECTION AND ENFORCEMENT MANUAL i
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INSPECTION PROCEDURE 92703 IE BULLETIN, CONFIRMATORY ACTION LETTER, AND GENERIC LETTER FOLLOWUP R
PROGRAM APPLICABILITY:
2515 92703-01 INSPECTION OBJECTIVES 01.01 To ascertain whether the information submitted by a licensee in response to an IE bulletin is technically adequate, satisfies the requirements established in the IE bulletin, and represents the action taken by the licensee.
01.02 To ascertain whether the information discussed in a confirma-R tory action letter (CAL) represents the action taken by the licensee.
01.03 To ascertain whether the information discussed in a generic R
letter (GL) has been addressed by the licensee.
92703-02 INSPECTION REQUIREMENTS 02.01 For each IE bulletin sent to the licensee for action, determine whether the following actions taken by the licensee meet the bulletin requirements and licensee commitments:
1 a.
Document Review.
Review every requested action to assure l
that:
1.
Written response was within the time period stated in the bulletin.
2.
Written response includes the information requi*ed to be reported.
3.
Written response includes adequate corrective action commitments based on information presented in the bulletin and licensee's response.
b.
Independent On-Site Verification.
Review a selected R
sample of actions.
Issue Date:
09/25/84
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.f IE BULLETIN, CONFIRMATORY ACTION
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92703-02.01b.2 LETTER AND GENERIC LETTER FOLLOWUP 1.-
Licensee management has forwarded copies of the r
written. response to ' appropriate on-site management representatives.
2.
Information discussed in the licensee's written response was accurate.
3.
Corrective action taken by the licensee was -as described in the written response.
02.02 For each confirmatory action letter sent to the licensee, R-determine by selected sample on-site whether the following actions taken by the licensee meet CAL requirements and licensee commitments:
a.
. Licensee management has forwarded copies of the let-
-ter.
and any needed instructions to appropriate on-site management representatives.
b.
Corrective actions were taken as described in the CAL.
02.03 For each generic letter sent to the licensee for action, de-R ter mine by selected sample.on-site that.the following actions R were taken by the licensee:
R a.
Licensee management has forwarded copies of the written R
response to appropriate on-site management representa-R tives.
R b.
Plant-specific actions were taken as described in the R
licensee's written response.
The response is clear and R
consistent with the understanding of on-site management R
1 regarding any statements or commitments.
R If a significant inspection effort is anticipated, tem-R porary instructions (TI) will be written.
No inspection R J
of plant-specific actions is needed if the generic letter R merely requested information for possible licensing ac R
tions.
R If a discrepancy or potential problem is found, notify R
the regional office and the appropriate project manager R
j in NRR's Division of Licensing.
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'92703-03 INSPECTION GUIDANCE
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03.01 A bulletin normally requires a written response from the li-censee to the regional office within a specified period.
When a written response is received at the regional office, the as-signed regional of fice personnel review and evaluate the licen-I see's response for adequacy.
An inadequate response should be Issue Date:
09/25/84,..j
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IE BULLETIN, CONFIRMATION ACTION y'g.
LETTER AND GENERIC LETTER FOLLOWUP 92703-03.01a resolved under the pro-visions of IE Manual ' Chapter (MC) 1125.
IE has the responsibility for compiling regional findings and R closing out the overall issue.
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a.
Whenever a bulletin or licensee response specifies ac-R l
tions that alter an existing license condition, the R
i evaluation of the licensee's written response is R
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l coordinated by IE with NRR or NMSS in accordance R
with the NRR/IE/AE00/ Regional /NMSS Interface R
R b.
The Regional Inspection Report of site inspection R
j activity associated with a bulletin should include R
J the-in-office review of the written response.
- Also, R
inspection hours for direct inspection efforts docu-R
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mented on NRC Form 766 should include both the site R
l and in-office inspection hours.
R 1
1 Temporary instructions, if required, provide guidance R
I for any unique handling, evaluation, or processing of R
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licensee replies and on-site inspection of licensee R
l actions.
The TI may be issued concurrently with a R
bulletin, or shortly afterwards.
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03.02
'The confirmatory action letter is issued by the regional R
office as a means for confirming a licensee's agreement to R
take certain actions to resolve significant concerns about R
j health and safety, safeguards, or the environment. Unless R
instructed otherwise by regional management, CALs sent to R
a licensee should be inspected on a sampling basis in accor-R i
dance with this procedure and closed out in an inspection R
report.
Responsibilities, criteria, and guidance regarding R
the issuance of CALs are delineated in IE MC 0800.
R 03.03 NRR periodically promulgates information, interpretations, R
and requirements to licensees via generic letters.
The gen-R eric letter sometimes necessitates that the licensee per-R form certain actions or provide a written response to NRR's R
Division of Licensing or both.
While NRR normally has the R
responsibility (unless specifically delegated to the regions) R of evaluating generic letter responses for technical adequacy, R it is important to utilize any plant-specific knowledge of R
the resident or regional inspectors to clarify or help in R
3 the technical evaluation of the response. On a sampling R
basis, the licensee's response should be reviewed to ensure R
that site management's understanding of commitments are R
l consistent with the written response.
This review should R
concentrate on policy, operational or procedural changes, R
schedules, proposed facility modifications and/or existence R
of present procedures or equipment.
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1 Issue Date:
09/25/84 1
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-4 II IE BULLETIN, CONFIRMATORY ACTION 92703-02. 0lb. 2 LETTER AND GENERIC LETTER FOLLOWUP 1
If there is no specific formal request from NRR for postimple-R mentation followup inspections, changes to procedures or plant R modifications should be reviewed to verify that the licensees R are meeting their accepted commitments.
R Any reviews or followup inspections should be documented in R
an inspection report and on the NRC Form 766.
R i
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09ns/84 I..-
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E NUCLEAR REGULATORY COMMISSION 3J OFFICE OF INSPECTION AND ENFORCEMENT
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Washington, D.C. 20555 INSPECTION AND ENFORCEMENT MANUAL DI INSPECTION PROCEDURE 94300 STATUS OF PLANT READINESS FOR AN OPERATING LICENSEE PROGRAM APPLICABILITY:
2512, 2513, and 2514 94300-01 OBJECTIVES 01.01 Provide a status of the inspection program and findings.
01.02 Provide a summary status of preoperational testing and identify incomplete system acceptance and testing by the licensee.
01.03 Provide a summary status of the construction of the facility and identify areas where construction is incomplete.
01.04 Provide an evaluation of the licensee's management readiness to perform QA activities during operation of the plant (reference Exhibit 2),
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milestones).
94300-02 REQUIREMENTS 02.01 90-Day Status Report.
Approximately 90 days before the scheduled issuance of the operating license, the regional office will prepare a sta-tus report using the format of Exhibit 1.
The status report will be trans-mitted by memorandum to the responsible Licensing Division Director in the Of fice of Nuclear Reactor Regulation (NRR) with a copy to the Director, Of fice of Inspection and Enforcement (IE).
This memorandum will include j
the region's evaluation as to whether or not the published fuel loading date is realistic in term.s of the work remaining to be completed by the licensee.
The status report will address the following areas, as appro-priate:
a.
Inspection Program.
Review the status an
'ns ctions required b(~MC r WM 4
insbecti tion.
6+emue b.
Enforcement Items.
Identify any violation for which corrective action has not been completed and all unresolved items and their status.
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Issue Date:
02/14/86
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b.
Status Report Update 02.02.. Past experience has indicated that the licensee's scheduled fuel ' loading date is generally optimistic.
When there is a large variance in the scheduled fuel loading date and the region's estimated fuel loading date, it may be preferable to update the status report on a 6-week basis or. longer, depending on the variance.
As the licensee gets closer to the fuel loading date,. the issue frequency of the. report should increase and it should become more specific with emphasis.placed on impact assess-ment.
If appropriate, the listing of open items also should be discussed with the licensee on a continuing basis.
c.
30-Day Status Report 02.03..The 30-day report should categorize the remaining open items by the milestone at which they must be comple-ted.
To arrive at this milestone categorization, the proposed tech-nical specifications may be used as guidance.
Open items must be i
resolved for any system or component, prior to the time the facility
)
technical specifications requires it to be operable.
Categories of I
open items are to be considered only as regional recommendations until they are endorsed by the operating license.
In those situa-tions where the list of open items is long and/or the fuel loading date is delayed after the the 30-day report is issued, the region should consider issuing a final memorandum a few days before the anticipated issuance of. the operating license.
If the region be-lieves that issuance of the 30-day report is premature based on plant circumstances, the report can be delayed; however, status report updates should continue as stated in section 02.02.
END 1
94300 Issue Date:
02/14/06 1
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EXHIBIT 1 EXAMPLE FORMAT FOR 90-DAY STATUS REPORT l
MEMORANDUM FOR: Robert Bernero, Director BWR Licensing Division, NRR l
FROM:
Charles C. Norelius, Director Division of Reactor Projects, Region III
SUBJECT:
CLEVELAND ELECTRIC ILLUMINATING, PERRY UNIT 1 l
DOCKET NO. 50-440, STATUS OF FACILITY COMPLETION t
This memorandum is forwarded to provide you information on the preparedness for licensing of Perry Unit 1.
Enclosures 1 through 4 include items re-quiring inspection and resolution before a finding of readiness for opera-tion can be endorsed by Region III.
The categories used are consistent with those used by the applicant.
Cleveland Electric Illuminating esti-mates a fuel load date of early November 1985.
Region III considers December 1985 as a realistic, yet optimistic, time frame for a licensing decision, contingent upon satisf actory resolution of the issues presented in the enclosures to this memo.
If you have any questions concerning this matter, please contact me or Mr. R. C. Knop of my staff.
Charles C. Norelius, Director Division of Reactor Projects cc:
J. Taylor, IE
Enclosures:
1.
Open Items Including Enforcement and Unresolved Items 2.
Preoperational and Acceptance Testing Status 3.
Construction Status 4.
Status of Inspections Required by MC 2512, MC 2513 and MC 2514 (Summary)
(For each item in the above enclosures, the expected or required completion date and an assessment of the significance, should be included.)
1 c
STATUS OF PLANT READINESS EXHIBIT 2 94300 EXAMPLE FORMAT FOR 30-DAY STATUS REPORT MEMORANDUM FOR:
Harold R. Denton, Director Office of Nuclear Reactor Regulation FROM:
J. Nelson Grace, Regional Administrator y
SUBJECT:
DUKE POWER COMPANY, CATAWBA UNIT 1, DOCKET NO. 50-413, STATUS OF FACILITY COMPLETION Based on the results of our inspection efforts in implementing the pre-scribed NRC inspection program and other related inspection activities, we have determined that construction and preoperational testing of Catawba Unit 1 Nuclear Station have been completed in accordance with the FSAR, other docketed commitments, and regulatory requirements, with the excep-tion of items indicated in the enclosures.
Remaining construction, testing, and inspection items identified in the enclosures have been categorized by recommended completion milestones.
As part of our inspection efforts, we have reviewed the licensee's prepara-tions for implementation of the Quality Assurance Program for Operations.
We have found that an organization and procedures are in place to give reasonable assurance that the licensee's Quality Assurance Program (Chapter 17 of the FSAR), which was reviewed by the Office of Inspection and Enforcement, can be adequately implemented.
We recommend a full power license be issued, as conditioned by the items listed in the attached enclosures.
J. Nelson Grace Regional Administrator cc: J. Taylor, IE
Enclosures:
(A separate enclosure should be included for each of the following comple-tion milestones.
An assesanent of significance should be included for each item.)
1.
Items to be Completed Before Fuel Loading 2.
Items to be U mpleted Before Initial Criticality 3.
Items to be Comoleted Prior to Exceeding 5% Rated Thermal Power 4.
Items to be Completed Prior to Achieving Full Power Operation Issue D' ate: 02/14/86 E2-1
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Operating License.. Issuance
- t Procedure No.:
'94300B Issue Date:
4/1/76 SECTION II 1
< INSPECTION REQUIREMENTS l
Inspection items 1-4 below shall be. completed as a portion of the routine inspection plan.
Items 5 and 6 shall be completed as indicated.
1.
Inspection Program a.
Review the status of inspections required by MC-2512, 2513 and 2514.
b.
Identify all outstanding inspection areas and the reasons for incompletion.
-l 2.
Enforcement Items i
a.
Identify all uncorrected items of noncompliance and their l
status.
i b.
Identify all unresolved items and their status.
3.
Testing Program a.
Identify all Category I-III preoperational testing committed to in the FSAR which is incomplete, b.- List those startup tests not yet developed and their status, c.
List system performance deficiencies and plans for correction.
1 4.
Construction Status a.
Define systems for which construction is not completed.
b.
List any system or significant components not formally accepted by the licensee.
c.
List all items from the construction punchlist which could l
l affect the safe startup and operation of the plant.
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Operating License Issuance Procedure No.: 94300B Issue Date:
'l/1/79 5.
Ninety; days before scheduled issuance of the operating license, prepare an initial memorandum to Headquarters using the format of Enclosure 1,- identifying remaining completion items. in each of the' above areas and their impact on the proposed issuance of the operating license.. Do not utilize inspection procedures as
~
references or include the list of open modules in the letter since the LPM does not have access to these on a continuing basis.
The letter.should be addressed to the Director, Division of Reactor Operations Inspection, with copy coverage to the Directors of the otherLIE Headquarters Divisions. Update this letter approximately.
every 30 days until one month before scheduled fuel loading.
6.
Approximately 30 days before scheduled issuance of the operating license, prepare a memorandum to Headquarters using the format.of, identifying all remaining completion items and their impact on the. proposed issuance of the operating license. By
. enclosure, categorize each item by the Region's recommendation regarding completion milestone. Each item should be stated in terminology suitable for direct insertion as a license condition.
Sufficient detail should be provided to support the rationale for incorporation into the license. This memorandum should be addressed to the Director, Division of Reactor Operations Inspection, with copy coverage as indicated in paragraph 5 above.
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Operating License Issuance
~
Procedure No.: 94300B Issue Date:
1T1/1/77 j
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When ' delays ~ in the ilicensing process are. experience status of.the' outstanding items of paragraph'5 above undergo.
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rapid' or extensive changes, it may be necessary to prepare a'
. final memorandum approximately two days before anticipated issuance of an operating license.
The Division of Reactor Operations Inspection, in conjunction with the Regional Office and NRR, vill determine when this final memorandum is necessary.
This memorandum should be submitted in the format of Enclosure 2.
'Each item should be stated in terminology suitable for direct insertion as a licensa condition as sta'ted in paragraph 6 above.
11-3 e
6
[,i i-e Operating _ License Issuance Procedure No.: 94300B Issue Date:
1/1/79 l
SECTION III 1
l INSPECTION GUIDANCE l
9 i
i Conditions for issuance of an operating license are defined in 1
'10 CFR 50.57. Any items which could affect positive findings regarding license issuance must be identified to IE Headquarters, who will communicate to NRR any outstanding items.
l In preparation for this ' finding, a list of open itens will be main-tained by the inspector (s) and transmitted to IE Headquarters 90 days before scheduled license issuance for information. Of necessity, this initial transmittal may be fairly general in topic identification; but, y
l as fuel loading nears, it should become' more specific and-greater emphasis should be placed on impact assessment. A typical open item transmittal letter is appended.
It should be periodically updated at approximately 30-day intervals. All items potentially impacting the license issuance date should be promptly discussed with Regional super ~
vision and with the inspection specialist in the Division of Reactor Operations Inspection who is responsible for the preoperational testing program. If appropriate, the listing of open items should also be dis-cussed with the licensee on a continuing basis.
The formal letter should be transmitted approximately 30 days prior to license issuance along with sufficient information to permit tech-III-1
Operating License Issuance Procedure No.: 94300B Issue Date:
1/1/79 nical review by other organizations to support a conclusion regarding license issuance. A final memorandum may be required approximately two days before anticipated issuance of the operating license.
The Division of Reactor Operations Inspection will determine when this final memorandum is necessary on a case-by-case basis. Any remaining open items following submittal of the final memorandum (30 days or two days before license issuance) may be subsequently closed by telephone or facsimile, as appropriate.
In the formal msmorandum submitted 30 days before anticipated license l
i issuance (and the subsequent menorandum, if applicable), the remaining outstanding items should be categorized by the milestone at which they must be comp 1.eted. To arrive at this milestone categorization, the proposed technical specifications may be used as guidance. Outstanding items must be resolved for any system or component, prior to the time et which the system is required to be operable as defined by the facility technical specifications.
Categorizations of open items are to be con-sidered only as Regional recommendations until theylare' endorsed by the operating license.
The licensee should be encouraged to assure that his
{
requests for licensing conditioning are consistent with the Regional l
recommendations.
For purposes of completion categorization, the following milestones may be used as necessary at the option of the inspector:
t i
t III-2
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9
J 1
Operating License Issuance Procedure No.:
94300B Issue Date:
4/1/78 Beginning of Fuel Loading Entry Into Colv s..utdown (Mode 5)
Entry Into Hot Shutdown (Mode 4)
Entry Into Hot Standby (Mode 3) f Initial Criticality (Mode 2)
Pcwer Operation (Mode 1)
For assistance in categorization, it may be appropriate for the Region to consult with IE Headquarters Divisions.
If necessary, NER positions relative to plant completion will be obtained by IE:HQ from tha appropriate NRR Division.
The memoranda and enclosures tc IE:HQ should be transmitted by Mag Card initially, since material received by facsimile is not suitable for formal inter-office correspondence.
The Mag Card copy of the memoranda and enclosures i
should be directed, for action, to the Reactor Inspection Specialist responsible for the preoperational test prograr.
Tae NRC mail system is satisfactory for submittal of the signed
- copy, i
1 i
l l
i l
1 III-3
. _ _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ ~
o
' a0 L
l' l to Procedure No.: 94300B j
Issue Date:
1/1/78
~
l FORMAT FOR DEN ITEM TRANSMITTAL LETTER
. MEMORANDUM FOR:
, Director Division of Reactor Operations Inspection, IE FROM:
, Director, Region
SUBJECT:
LICENSEE, FACILITY, DOCKET NUMBER In accordance with Inspection Procedure No. 945308, the attached enclosures list the remainino open items that require resolution before finding of readiness for operation may be endorsed by Reaion The significance of each identified item, relative to the planned issuance
. of the operatinn license, is discussed:
____, Director Region _
cc: _
, RCI/IE
, FFMSI/IE
,SI/IE
Enclosures:
(A separate enclosure should btincluded for each of the following topics.
For each item, the ex should be included.) pected or required completion, and its significance, A.
Outstanding Items including Enforcement and Unresolved Items B.
Preoperational Testing Status C.
Construction Status j
D.
Status.of Inspections Required by MC 2512, MC 2513 and MC 2514 (Suninary)
~
III-4
+o 1
, to Procedure No.: 94300B Issue Date: 1/1//8 FORMAT FOR FINAL OPEN ITEM TRANSMITTAL LETTER MEMORANDUM FOR:
,Di rector Division of Reactor Operations Inspection, IE FROM:
Director, Region
SUBJECT:
LICENSEE, FACILITY, DOCKET NUMBER Based on the results of our inspection efforts, we have detennined that Construction and Preoperational Testing of the subject facility have been l
completed in substantial agreement with docketed commitments and regulatory requirements, with the exception of items indicated in the enclosures. With the exception of noted items, we have completed our inspections in accord-ance with the requirements contained in MC 2500.
Remaining construction, testing and inspection items identified in the enclosures have been cate-gorized by our recommended mandatory completion milestone.
As a part of our inspection efforts, we have reviewed the licensee's preparations for implementation of the Quality Assurance Program for Operations, and have found that they meet the requirements of 10 CFR 50, Appendix B, as specified in the licensea's Quality Assurance Program (Chapter 17 of the FSAR), which was reviewed by the Office of Nuclear Reactor Regulation.
We have also enclosed a proposed letter of facility readiness for your consideration. All items on the enclosures will be fonnally closed out in future inspection reports, and, if necessary, by appropriate rapid communication techniques.
j
\\
)
, Director Region i
cc:
, RCI/IE
, FFMSI/IE
,SI/IE l
Enclosures:
(A separate enclosure should be included for each of the following comple-j l
tion milestones. An assessment of significance should be included for each
(
item.)
A.
Items to be Completed Before Fuel Loading j
B.
Items to be Completed Before Initial Criticality l
C.
Items to be Completed Before (other milestones as appropriate)
D.
Proposed Letter to NRR (sample included as Enclosure 3) l III-5
7-
< 1 q..
. Enclosure 3 to Procedure No.:
943008 Issue Date:
7/l/77 t '
FORMAT FOR TRANSMITTAL OF OpEN ITEMS TO NRR MEMORANDUM FOR:
, Director Division of Project Management, NRR FROM:
, Director
, Division of Reactor Operations Inspection, IE
SUBJECT:
LICENSEE, FACILITY, DOCKET NUMBER We have been infonned by our Region Office, based on their inspection. findings, that construction and preoperational testing of the subject facility have been completed in substantial agreement with docketed comitments and regulatory requirements, with the exceptions listed in the enclosures. The Office of Inspection and Enforcement has no further items which would preclude issuance of an Operating License to permit facility operation up to its full design rating (or alternateoperatinglimitationsasappropriate).
It is recomended that the operating license be conditioned with the information contained in the enclosures.
We have reviewed the licensee's preparations for implementation of the Quality Assurance Program for Operations, and have found that they meet the requirements of 10 CFR 50, Appendix B, as specified in.the licensee's Quality Assurance Program (Chapter 17 of the FSAR), which was reviewed by the Office of Nuclear Reactor Regulation.
, Director Division of Reactor Operations Inspe.ction Office of Inspection and Enforcement
Enclosures:
Items Lists (categorized by completionmilestones) cc: AD/NRR BC/NRR PM/NRR l
Director, Region ADFC Files IE Files III4 4
l.
's'.i;-
h,/.
1-i' f
Ins'pection Report 50-445/85-16; 50-446/85-13 Item 7 1.
OIA' Statement of the' Issue (See Attachment MM) g.
Issue Resolution in Final Report 7.
TUGCo's IEB record files were.
Unresolved item downgraded incomplete.
to open' item (445/8516-0-05; 446/8513-0-05).
2,
. Expanded Description of the Issue and Related Background Information i
L The OIA statement of resolution in the final report should be changed to
~
l state that the completeness of record issue was lef t as an unresolved l
item.
l l
.The basic issue as understood by Region IV management is as follows:
The inspector (H..Phillips) believed that the "IE Bulletin File" maintained in accordance with Nuclear Operations Engineering Manual,
" Licensing Procedure N0E-205", Revision 1 was incomplete in that neither the 1982 nor 1985 files contained sufficient records or reference to records which would show that IE Bulletin action items were completed.
I s,
m j,; ()T
./.
T 22 i
. The "IE Bulletin File" was not in the QA Records Center and the inspector.
believed that support documentation of engineering evalu_ations either a
resided with specific individuals or were unknown.
i i
This issue was identified in draft la, page 4-3 (Attachment 2), as an unresolved item.
It was identified in draft 3,. paragraph 6 (Attachment 4),
as an unresolved item. The issue is considered open with regard to location of -the IE Bulletin file in the final report, paragraph 5, and an unresolved item with regard to the completeness of records is included in paragraph 4a of the final report (Attachment 8a).
3.
Safety Significance of the Issue There is no safety significance to this issue.
Verification of corrective action will be inspected r~ior to licensing.
The closecut inspection of IE Bulletins will be tracked in the IE Manaual Chapter 94300 letter. Corrective action committed to in a Bulletin reply J
is inspected using the OA records. The reply provided by the licensee to
]
a Bulletin is complete within itself and can be inspected directly using the associated QA records. A licensee may choose to track all IE Bulletin 1
corrective action in one location until completion but such " single file" tracking is not a regulatory requirement. As has been discussed previously, files do not have to be established for the convenience of the inspector.
1 I
I
C n.
- T;V 7o j,
\\e, 23 The '.'IE' Bulletin File" referred to by the inspector is an administrative
,- file assigned to'the Nuclear Operations Department by the Nuclear ;
'.icensing Supervisor. The file is intended to control ' licensing correspondence assigned to Nuclear Operations. The file is maintained in f
l:
accordance with Nuclear Operations Engineering Manual, N0E-205
( Attachment 15) and is termed the licensing' correspondence log (LCR).
The purpose of'the LCR log is to' track incoming and outgoing licensing correspondence to. assure response:to all licensing correspondence, including IE Bulletins. All internal memoranda necessary to prepare a Bulle' tin response to the NRC is required be included in this file.
The file is closed upon final reply the NRC.
The inspector indicat'ed that there was support documentation of engineering evaluations which he believed were in the possession of individuals or whose existent.e was unknown.
Regional management was unable to assess the significance of this item since the inspector was not specific; i.e., were they required QA records or did he have specific l
1 examples of corrective actions for which necessary support documentation
- was apparently missing.
4.
Region IV Management Handling of the Issue
. The location of the "IE Bulletin File" issue was properly carried as an l
open item since TUGCo had committed to review the issue.
i t
t
!i
- 6.. '
24
~
With regards to the other issue, the inspector, at the time'of the report, had not identified any specific QA record which not was not[being maintained as required by regulations.
The matter was appropriately handled as an unresolved item as it had been initially categorized.
i l
I l
l l
I l
l 1
I l
y
,./
I 6
I Fitting Locations," and Cp-i? '?, " Auxiliary Feedwater Pressure Control "
stated that corrective action was scheduled to be completed for Unit 1 by Hay 1985. The open items list indicated that they were not completed on November 30, 1985.
TUGCo management has assembled a task force consisting of four to five engineers or specialists to evaluate and take action on the matters described above. Thisitemisunresolved(445/8516-U-01,446/8513-U-01).
No violations or deviations were identified.
4.
Applicant Action on IE Bulletins (IEBs) d 4, O t
o ces. Reg 1 to '
t will perform a review of re o determine the adequacy o teness of associated records.
The in rt will f th k review of the ss.
This item is unresolved (445/8516-U-02, 446/8513-U-02).
b.
The TUGCo actions on two IEBs (i.e., Nos. 79-14 and 79-28) were selected to review hardware evaluations or repair / replacements. TUGCo 10ER Log Sheet, page 10, dated April 9. 1984, was reviewed to determine the status of the IEBs.
I
_(1) ICB 79-14 was evaluated by TUGCo in 1983 and was statused as closed. The NRC inspector indicated that the closure of IEB 79-14 was premature since Stone & Webster is currently analyzing Unit I seismic analysis versus as-built drawings, which directly relates to this IEB. Unit 2 as-built work has also not been completed.
TUGCo stated that the IEB 79-14 file will be reopened and a supplemental report will be submitted upon completion of the ongoing project engineering work.
The above item (IEB No. 79-14) status is considered an open item I
(445/8516-0-03,446/8513-0-03).
(2) IEB 79-28 identified deficiencies with certain manufactured lots of NAMCO EA 180 limit switches. The gasket material of the faulty lots, when exposed to temperatures above 175"F vaporized and emitted a yellow-brown crystal like resin that can cause these switches to fail. The NRC inspector found the TUGCo documentation l
to be complete with respect to the specified corrective action of i
replacing these switches with switches manufactured in acceptable lots.
Field verification of replacement of 14 switches identified, however, that the identity of 2 switches could not be traced to existing travelers. Specifically, the replacement NAMCO limit l
I j
Y b
l' w-m/glk e.
7 switches on residual heat removal valves 1-HCV-606 and 1-FCV-618 4
were identified on travelers EE 82-1415-5801 and EE 83-0373-5801 as EA 180-32302 and EA 170-31302, respectively. The switches actually installed in the field were identified as EA 180-31302 and EA 180-31302, respectively. TUGCo is evaluating this inconsistency to determine if there is other documentation to account for this.
This item is unresolved (445/8516-U-04, 446/8513-U-04).
j 5.
QA Records Retention
- % e - b,y I
^
Kot stored in the QA records vaults.
deposited in a central loc ncountered in l
cord file issue.
retrieval.
g Y
M J
j I
6.
Electrical Penetrations l
In NRC Inspection Report 50-445/84-22 dated October 11, 1984, the
]
certification of 8ISCO electrical penetration seals (fire barriers) was J
questioned with respect to the testing of the seals. During the followup I
of this item, which'is discussed in paragraph 2.h above, the NRC inspector
]
identified related but different findings.
The NRC inspector reviewed the records to determine if the documentation for eight 815C0 seals support the certification statement. The eight penetrations inspected were; AB-790-174-1022A, EC-854-150A-1018A and-10188, l
EC-854-151A-2003A and-2004A, EC-854-1518-2025A and-2026A, and TB-803-010A-100BA.
l The following documents contained apparent conflicting information that the NRC inspector Ms identified for further followup:
k BISCO letter to TUGCo dated November 13, 1984, answered the NRC certification inquiry and stated that the subject fire barrier seal (Test No. PCA-76, ANI No. 5-26, 24"x42", floor / wall, material 6548, 9 inches depth, t.AD or SLD tray, all cables, 40% loaded) met all test j
requirements of TUGCo Contract No. CP-0707, Gibbs & Hill i
l Specification 2323-MS-38F ASTM E-119, and IEEE 634.
American Nuclear Insurers (ANI) letter to 81500 dated August 20, 1985, withdrew its acceptance of 815C0 SF-20 (1977) Silicone or Dow Corning 3-6548 RTV Silicone foam for 2-and 3-hour rating without a damning board left in place. The NRC inspectors ascertained that this withdrawal was based on 815C0 not having complete documentation of
.l the test rssults and the recent failure of a 815C0 sample tested at j
an independent laboratory employed by the ANI.
)
l
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l' e*
i 6
s 1
1 s:
C i
)
1 FILE NAME: FEp0FT.4 LATE 8 11/13/65
$Uhr4#. OF 1 E l'_U ETIN EEU1EW Two IE lulletanJ wer+ chosen fc reviewI 79-14 8. 79-28.
Using t h.r Inspe::t ion ano E nt o rcen.ent Menuni Inspection Procedure 92703 ar,a suic+. the TUGCo IE Iulletin files were reviewed.
The files are under t he cont rol od M.L.
(Lean) Palmer, Industry Operating Emerience Coordinator ( ICEC ),
ext. 5313.
As expl ained tn F e l ine r.
- ie as responsible, for IE Bulletins that do not require m rezconse to the NRC.
Harold Che,is t he am.
Operat1ons Support, evt 5310.
la rerpensible for maintaina ns IE Eulletin files o>hich require a respons+ from the utility to the NkC.
Ther+
are the " official filer" for the IE Bulletins n.alntained ov TUGCo.
IE Eulletin 79 Erie +1y.
the status of this file is that it
. [s.c been cloz+c ty Pa l n+ r :<. #.:. i d anc it as not co:un+nted su1ticient1; t o nie+t the intent of the bulletin.
FF.OM THE pFOCEDUEE - 9270!-02.01 m.
1.
Written rerponse wmr witnan the tin + perloc stet +c in the bulletin.
Tr +
bul1+ tin w&E d ht ec'
~ '2 7 9 and dat e stamped received on 7 /5/7 3'.
Fevised bulletin to 11 ns i t work ccope was sent on 7/1su?9.
F a rrt s u ppl et.nent sent on 6/15/79 and dbte st aruc.ed r+
ed on i. /17
.'9.
$+cond s upp l enient was sent on 9/7/79 and c r.
.s t ains+c received en 9-10 79.
All suppleu.ents referenc+c + %
rew i rernent s of th+
bulletin.
F rorn the bulletin a written r+spons+ war rewi e s e in:
- 1. 20 dws - no evidence of required response within 30 days
- 2. d-O caos - no evidence of required response within 60 dtvs
".. 120 deus - no evicence of r ef gui red response within 120 dnas 4
If nonconfortannces are identified 1
- a. p r or.c t report er c+ fined by Tech Spec - no evider C+
of requir+d response as cefined The ut111ty firrt responre wbs TR.;
3062. dat ed 10/25/79 and the s ecor.c respons+
whi T'
- 3597.
det+d 12/3/82.
The first respon2+ umr mitt.in 110 cars and was int end+d t o meet the 30 dav response in content. enc requ+sts a waiv+r on the 129 day report ins re :. s i rernent.
FROM THE FROCE*.t.dE - 92701-02.01 a.
- 2. W rit t en response includes the infornhtton r+2vir+1 tc or repor.ed.
The 7/2M9 IE lulletin required the following inf o rru at i on for the S t.
d as responr+s 1.
Icenti+v Inpsection E l +n.+n t s
- a. List of Lertgn Docun.+nt s (Title. ID no..,
Revis1on chte' b.
3ggcription 3.+ 1 Ern 1 C Anal,'si r input I nf o rtu tt 1 Cn I
,a d
~
k' ll L s '. 5 4 g
i-i
-p:
\\
c.
Identify svst+ ras or port ions of systern.to be Anspected' The 7/2/79 IE Eulletin required the followtng infe rrnat i on for the 60 day response; j
- 2. Submit a description of the results of the
}
. inspection i
The 7/2/79 IE Eulletin requi red the following information for the 120 day responset
- 3.. Submit a description of the results of the second j
inspection The 7/2/79 IE Eulletin required the'following information Tor the If non confortuences were foundl 4
If nonconformances are identified i
a.
prompt report as defined by Tech Spec b.
submit an evaluat ion of identified nonconfortnances submit schedule fors
- 1) cornpl et ing the reanalysis
-j
- 2) cornparisons of the results to FSAR, etc.
$) subrnitting descriptions of results c.
In 11+u of b, submit a schedule for correcting nonconfortnances and description of necessary wo rk The' TXX
- 3062 letter states that construction is not sufficiently along to perform requested scope of work.
Letter also stetes that a procedure is-being finaliced to address the requirements of IE Eulletin 79-14 and it
- .11 be re&dy for irnpleneentat s on by 12/15/79.
The TXX - 3597 letter states that the program required by the IE Lulletin is beins iruplernented, and all systems are included. The letter aodresses sterns 1.b and 1.c above.
The remaining items 2,
- 3. and 4 are not addressed.
FROM THE PROCEDURE - 92703-02.01 a.
3.
Written response includes adequate corrective action coror is t ment s based on information presented in the bulletin and licensee's response.
Based on the letters TXX - 3062 and - 3597, the answer would be no.
The procedure referenced in TXX
-3062 is not identified nor included with the IE Bulletin folder.
There is insufficient 4
info rm at i on in the folder to answer this question.
OTHER NOTES i
See REPORT.3, 10/30/85, for discussion of current TUCCo 79-14 activities.
I Foy Cisneros.
Special Project Group Coordinator.
ext 5563, l
report ing t o H.
Che a t he arn, called on 11/13/65 and indicated that t
the 79-14 file will be und+r his control.
l 1
l ee
- j
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.g.
l-
..RECOr1MENLED STATUS:-
1.
This file war closed af t +r work was completed in Unit 1.
.The file-document ed a part 2 41 responte by the Utility with respect to the responses requested by th+ bulletin.
2.'
The..CPRT reinspection of the AS BUILT quertion is a result of the Utility reopening certian areas for investigation.
O.
The NRC has and is. invest igat ing the piping and hangers -f rom many different directions.
4 The Utility and Consultant AE rework with the piping and hangers it being performed according to 79-14.
- 5. The - paper work is a probl+m. The files are being maintained by.
~
Utility. Personnel who are not directly involved with the rework effort.
The' adeninist rat ive error here is that the official'IE Eulletin onsite record is not being kept current with the present CFpT investigation.
6.
With respect to this IE Eulletin file, it has not been-rnmantain+c ee cocunient ec zuTT 2 c1ent a y to show compiiance te Ae t
requirements of the Bulletan.
This includes the time pe e'i od_'
prior to the CPpT.
m
~m i IE EULLETIN 79 Briefly, the st atus of this file is that it ir closed and it ir documented sufficiently to meet the intent ot' the bulletin.
[i k d M - h4 fd tA 3 g
g FROM THE PROCEDURE - 92703-02.01 a.-
1.
Uritten response was within the time period stated in the bulletin.
The bulletin was dated 12/7/79 and date stamped received on 12/10/79. From the bulletin a written response was required ins 4 60 days - no evidence of required response within 60 days The utility 13rst rerponte war TMX - 3112,'
dated 3/24/80 (134 davs> and the second response was TXX - 3375, detec 7/30/81 (1.5 years).
FROM THE PROCEDURE - 92703-02.01 a.
2.
Written response includes the inforraat ion requi red to be report ed.
The 12/7/79 IE Eulletin required the following information for the 60 day rerponset 2.
Submit your piens t programs including schedules The TXM
- 3112 letter identifies the plans and schodule for completing the required work.
3
.6 I
l 5
cv.
6 5
.EI The TXX - 0375 letter states that all items will be replaced, 1
which meets the intent of 79-28.
FROf1'THE PROCEDUFE
.92703-02.01 a.
- 3. Written response includes adequate corrective action corprnit tnent s based on information presented in the bulletin and licensee's response.
Yer the Utility response does meet the intent of 79-28.
FROM THE PROCEDURE - 92703-02.01 b.1. Yes the dist ribution of the
+
bulletin was acceptable and documented.
- 92703-02.01 b.2.
Yes.the di st ribut ed information was accurate.
- 92703-02.01 b.3. Yes corrective action was taken.
OTHER NOTES:
This work was completed and closed out under NRC's E 81 107s
( closed cn 5/4/83 ) and E S1 113r ( closed on 5/23/t'2 ).
FIELD SURVEY A field survey was performed to determine whether or not the site document at ion presented an accurate pictLre of the as built equipment.
The audit trail follows:
f 1.
NCR E-81-0113r R. 3 Uni t 1 identifies 91 valves.
The position J
or limit travel switenes for these valves were replaced.
From the NCR the following valves were chosen without prejudice, along with identifying information.
No VALVE SYS LOCATION TRAVELER No 1
1-FCV-0110E CS 810 AUX EE82-1407-4901 2
1-FCV-0520 FW 856 SG1 EES2-1419-2802 3
1-FCV-618 RH 789 SFGD EE82-0373-5801 4
1-PCV-0456 RC 914 RXEL 3EES2-1413-5501 5
1-HCV-606 RH 793 SFGD EE82-1415-5801
- 6 1-07136 UP SOS RXEL EE82-2025-4105 7
1-08145 CS 808 RXEL EES2-1878-4901
- On NCR E-81-0113r, this Traveler No is EES2-1413-5801.
When
-~
r_emue s t ed f rom the const ruct ion vault, that record was not found.
The computer data bare has the number correctly recorded.
,j The Traveler's identify the NAMCO Limit Switches that were used to replace the questioned switcher on the va16 es.
They aret 4
1 l,
r AUDIT TFAIL IN FIELD.
No VALVE LOCATION SWITCH MODEL NUMBERS VERIFIED DATE 1
1-FCV-0110B 810 AUX EA1SO-15302 11/15/85
- ~
EA180-14302 11/15/85 0
1-FCV-0520 856 SG1 EA180-12302 11/18/85 EA180-11302 11/18/85 3
1-FCV-618 789 SFCD EA170-31302 not verified EA170-31302 11/18/85'
~
4 1-PCV-0456 914 RXBL EA180-11302 11/14/85 EA180-12302 11/14/85 5
1-HCV-606 793 SFGD EA180-32302 11/18/85 EA180-32302 not verified 6
1-07136 803 RXEL EA180-14303 11/15/85 EA180-15303 11/15/85 7
1-03145 GOS RXBL EA160-11303 11/19/85 EA180-12303 11/15/85 Two of th+
limit swit ches could not be matched to the Doc.ent et s on a n t he v a u a r..
i r eez+ switches were checked asaan 2_n tre field and the paper trati was rechecked in the vault.
They aret FRQM THE FIELD VAULT PAPER TRAIL No VALVE LOCATION SWITCH MODEL No SWITCH MODEL No
==.__
3 1-7CV-618
.789 SFGD EA180-31302 EA170-31302 5
1-HCV-606 793 SFGD EA1SO-31302 EA180-32302 The date codes for the installed switches ares.
Ho VALVE LOCATION SWITCH MODEL NUMBERS DATE CODE 1
1-FCV-0110F 810 AUX EA1SO-15302 2482L30330 EA180-14302 2682L30330 2
1-FCV-0520 856 SG1 EA180-12302 3782K31638 EA180-11302 2382K31634 3
1-FCV-618 759 SFGD EA180-31302 1882K29188 j
EA170-31302 2082M29486 l
4 1-PCV-0456 914 RXBL EA180-11302 2382K31634 EA100-12302 3782K31638 5
1-HCV-606 793 SFCD EA180-31302 1882K29188 EA180-32302 2382K31651 6
1-07136 808 PXBL EA180-14303 2482A31714 EA180-15303 2482A31716 7
1-03145 808 RXBL EA180-11303 2682A30837 EA180-12303 2682A30837 Also from the Const ruct ion vaul t,
the switch model numbers were tracec to a pee 2evin, Inspect 2on peport urino the vault comput e_r data base.
The Equ a prt.ent Qualification Report number was located h erattons Vault using the FC Humber f rom the RIR files.
mmep-
i l
SWITCH MODEL EQUIPMENT No VALVE LOCATION t4UMIERS RIR QUAL REPORT
=
1 1-FCV-0110B 810 AU';:
EA180-15302 19143 QTR-105 EA180-14301 19143 QTR-105 2
1-FCV-0520 856 SG1 EA160-12302 19143 QTR-105 EA180-11302 19143 QTR-105 3
1-FCV-613 789 SFGD EA180-31302 19143 QTR-105 EA170-31302 19143 QTR-105 1
4 1-PCV-0456 914 RXBL EA180-11302 19143 QTR-105 EA180-12302 19143 QTR-105 5
1-HCV-606 793 SFCD EA180-31302 19143 QTR-105 EA180-32302 19143 QTR-105 6
1-07136 808 RXIL EA180-14303 19820 EA180-15303 19820 7
1-03145 808 RXBL EA1SO-11303 19820 EA180-12303 21762 A review of there PIP's was performed using the const ruct ion vault records.
RIR 19143 - PO No. CPF-1163-5.
MR No. 124224 Identifies the following switch model numberrt EA170-31302 EA1SO-11302 i
EA170-32302 EA180-12302 EA180-31302 EA180-14302 EA180-15302 EA180-34302 The RIR stater "There switches qualified to IEEE 323< 1974 ),
344(1975),
t< 382< 1972 > per QTR-111.
RIR 21762 - PO No. CPF 1210. MR No. 1357-01 Ident ifies the fo11owing switch model number; EA180-12303 serial Nos. 1340 1336 1605 1362 1602
)
1593 1391 1349 1584 162f 1623 1405 1607 1348 13?J 1351 1328 1506 1317 1(16 j
The RIR states "There switches qualified to IEEE 323< 1974 ).
344< 1975 ).
4 3e2<1972> oer QTu-111.
q l
FIR 22900 - PO No. CPF-1163-5. MR No. 143,333
]
Identif ter the fo11owing switch modei numbert
{
EA180-32302 The RIR states "These switches qualified to IEEE 333(1974), 344(1975/. 4 382(1972) per DTP-105, l
6
t-s.
'o l
F rorn the ' conrt ruct ion. vault, t he-t reveler docurnent at i on
. identified the followings Traveler EE 63-0373-5301 valve installed sw rernoved sw
=_
==
=-=_ - - - - - - - -
1-FCV-618 EA170-31302 EA170-32302 EA170-31302 EA170-32302 1
1-HCy-606 EA160-32302 EA170-32302 EA1BO-32302-EA170-32302 1-8145 EA160-11303 EA170-11302 EA160-12303 EA170-11302 The PO numbers identified in the RIR's are used to locate t he - EQ documentation.
In-the operations vault, only one of t he PO numbers was found.
'The recommendation was that the remaining records are located in Warehouse A.
TUCCo PO No. CPF-1163 Report No. OTR 105. August 20, 1981 Rev 3, copy No.
1506. " Qualification of EA180 Series Limit Switches for use in Nucione Power Plants in Compliance with IEEE l
Standards 323-1974, 382-1974, b'344-1975.".
STATED PUPPOSE OF TESTS "The tests verify the limit switch perforrnance and includel Aging Simulation, wear aging, Rndsation exposure, seismic Qualification and Design Iarar Event Env i ronr<.ent a l Conditions."
PEPORT IDENTIFIES:
EA1$0-11302 EA1BO-12302 EA130-21302 EA160-22302 EA180-31302-EA160-32302 EA180-14302 EA1SO-15302 EA1GO-24302 EA180-25302 EA1SO-34302 EA100-35302 Date code is week and year, 1630 x 00000 16 t h week SO 1930 year Feport Identifies norraal service environmental conditionsi 90 C / Arnbient press / O to 100*1 R. H. / 204 (10E6) Rads Seismic OEE 1-4 H: 0.6 - 9.52 s's, 4 - 35 H: 9.52 s's Plant Induced vibration 1 (10E6) Cycles at 100 H=
0.75 s's Lesign Easis Envi ronn.ent Transient Conditions j
340 F e 50 - 105 psig'/ 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 45 min L 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> hoornent a ry Spike Conditions 391 F,
119 psig Cherni c a l Spray first 4 devs Na2$2O3, H3E03, NaOH, H2O 1)
-- a
/'4 d
~
Lesign Lasis Envi ronh+nt Long Tern Soak Conditions 200 F / 10 prig / 100?. Humidit/ / 26 Days / Unter spray Service Life 100 300 Cycles l
100.200 Cycles plus greater than 100 cycles durant other tests Periodic Testing - Randorn Switch selected will be heat aged
- for 400 hrs. at 120 C then operated for 100,000 cycles.
Estimated Qualified Life Analysis Use of Arrhenius Law to mathematically ext rapolate the thermal aging time / temperature to service conditions.
Qualified Life estlanated to be 5.0 years at 55 C t.400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br /> at 120 C, page 4-12, Figure 8.
Statement made that this is extended considerably by preventative maintenance.
Fecorded one switching failure on page 7-1, a t ern I
i Us Actual test report is attached,' TR 3613-PP, 2/15/80 Rev. O I
by Research Cent er of Acme-Cleveland Corp., Signed L y
dated
. 3' Test Plan is attached) No. LP10767-3, 7/26/77, NAMCO
./
jj;-
Also under TUGCo PO CFF-1163 in the file werel
(,
QTR 110 Rev 0 EA750 series QTR 111 Rev 0 EA740 series (j
J OTR 107 Rev 0 EA170 series E4170-11302
{
EA170-12302 EA170-21302 d' '
EA170-22302
- t EAl?O-31302-
. [
EA170-32302
},
EA170-13302
(",
l EA170-23302 EA170-33302
/
3 COMMENTS 8
'a The limit switches in the field, EA180-31302, not identified for s.
the indicated location by an audit paper t rail are documented in js g
RIR 19143 as being quellfied.
During the recheck, the model j ',
nurnbe rs of four of the suitches removed from two of the three q
above valves ( EA170-32-302 ),
observed to be qualified in RIR
- f w+re l
19143.
1 l
' All date codes on the switches VI 1.
' code identified in the 1E Lulletin 79-28, as being suspect.
One
?
are beyond the 0279 to 0379 date q
date code for 1-PCV-0456 does not look correct (3782).
- However, I
that date code in t he audit trail matched the date code in the field.
(later found that the first two digits represent the week g
of the year)
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i PEMAIH!tG OUESTI Or45 :
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Whv were the,two quilifted switches replace?
Since all the i
swatches thkt were snspect+c in the 12 eld have date coder. which I
l are not an,ons those ident:11ed in 79-2S as being in question, l!.
this quest ion is not risn1T2chnt.
i,'dl 2.
Why were the two NAMCC linet t switch locations recorded
.')
incorrectly? Tha r rneans that anv tirne a NAMCO switch is suspects all NAMCO switchez in the plant toust'be checked.
C On 11/22/85, had exit intervaew with Roy Cisneros, covered the I8 following pointza v
-1.
IE.Lulletin file 79-14 is incomplete.
,su a.
No evidence of responding to bulletin within required t irne period.
,h b.
With respect to response contents, of four response lJ,,
requi rernent s.
a response roe t two of three items in one (the Tarsi.) response
- c. The file war closed. ~ requi rernent.
h*f i
however, work is currently in
[.
progress thst was r+4utred by the Bulletin.
'f.,
- d. The required coeurnent s *or 79-14-were not ret rievable.
I"
/
/
- 2. IE Eulletin.Wie 79-23 i s cornp l et e,. howeve *, the following
'n problerns w+re observed.
b
- a. A field audit of the NANCO switches revealed that two
['
switched identif34.d a n the docurnent ation could not be p'
traced to the field.
9
- b. An audit of *- Eevipment Qualification docurnentation f,E for the NAMCO switcher revealed that EQ tests for four of j%
the NAMCO switcher were not retrievable.
ll RECOMMENDED ?.TA1UI.:
).
1-q 1.
All currently installed L1rnit Switches on the seven inspected
- }
valver are t racab.. to en EO test report number.
j) x 2.
Two rwatch nurucers are not recorded correc i$
I 3.
Of th+ *1+;d audsted zwatcher, one is not t raceable to en EO report nurnbe ".
p.
4 EO report; could not b+ found for four of the fourteen NAMCO 4
switcher.
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CP16 50-445/DS-16/13 155UE AS UNDERSTOOD BY THE REVIEW GROUP 1.
TUGCO's procedure to process Construction Deficiency Reports (CDR) failed to require file information which would give evidence of issue closure.
2.
TUGC0 f ailed to revise subtier implementing procedures before corporate NEO Procedure CS-1 was issued, resulting in conf 13ct with five other procedures.
3.
TUGCO failed to maintain CDR files that were retrievable.
4.
TUGCD failed to report to the NRC the corrective actione actually taken and changes to commitments.
D.
TUGCO CDR files were not auditable with respect to corrective actions.
DISCUGSIUN:
The reporting r requirements under j oCFR50. 55 (e), Constr ucti on Deficiency Reports (CDR), were insti tuted to provi de the NRC w i -L h prompt notification o+
significant construction deficiencies. This would give the NRC timely information on which to base an evaluation of the potential safety consequences of the deficiency and determine if further regulatory action is required. [1] CDR's are normally i
identified by the licensee's quality assurance program through nonconformance reports, design deficiency reports, q
vendor 10CFR21 reports or other similar systems.
I l
SAFETY SIGNIFICANCE The issues that were identified by the inspector all relate j
to the interface between the NRC and the licensee. There is H
no indication that the identification mechanism for CDR's was deficient and, therefore, the sources of input to the j
process were functioning satisfactorily. This means that the l
deficient equipment or controlling systems were being I
corrected through other established mechanisms such as the nonconformance corrective action process prescribed by 10CFR 50, Appendix B.
Criterion XVI, Corrective Actions. Thus, there is no safety significance relative to the plant equ3pment.
Any breakdown in the CDR reporting and tracking system would impact on the notification, evaluation and final closure as it relates to the NRC. The NRC requires that selected construction deficiency reports be closed through
(
f inspections.[2] I4 detailed tracking files are not mai ntai ned, closure becomes more difficult;however, the primary corrective action tracking document for the identafed deficiency would be the original quality assurence report.
The procedure identified in item No.1 does not require certain information to be retained in the licensee's tracking file which would permit the inspector to readily determine if the item had been properly closed. This makes the f il e unaudi table f or the inspector unless there are cross references to the corrective actions programs.
The failure to revise subtier procedures, item No.2, results in nonuniformity in the processing of CDR's, but does not necessaril y af f ect reporting to the NRC. This also affects the interface between the NRC and the licensee, and internal pr oa. eing within the licensee's organization.
~f h e 4ailure to maintain CDR files that were retrievable, item No.
3, stems from the inspectors inablility to cross ref er ence tmtween the CDR files and corrective action prcgram tlles. This is similar to item Nos.1 and 5 in that f i l et that are not retrievable are also not auditable.
The failure to report corrective actions actually taker and any changes to commitments, item No.4,directly affects the NRC / l i c ensee interface. This impacts the NRC's ability to perf or m a meaningful evaluation and any decision to take f urther regulatory action.
CORRECTIVE ACTIONS:
The issues discussed above were all either unresolved items or not transmitted to the licensee in the Region IV inspection report. Accordingly, there is no formal response to the issues in the correspondence to the NRC. Because of this, 2nformation concerning planned or actual corrective action coul d not be evaluated by the review team.
However, the r evi ew group bel i eves that the licensee's construction deficiency reporting system should be structured such that they can determine when all NRC reporting requirements have been completed. Further, it should have a loop closing feature built-in to assure that all commi tted corrective actions have been completed as st ated. [ 3] This can be accomplished by reference to the appropriate formal corrective action tracking documents without mei nta) nanc e of duplicate fi1es.
It was noted by the review group that TUGCO PROCEDURE NEO CS-1. " Eval uati on of and Reporting of items / Events Under 10CF R21 and 10CFR50.55(e)." does not specify that all items
t g
.f reported under the procedure should be first recorded in the esteb]i shed corrective action systems. The procedure states that inputs can be received from any source. Where the source is other than an established quality tracking system, it is possible that a reported deficiency would not be properly processed under a formal corrective action system.
References:
1.
10 CFR50.55(e) Statement of Considerations, 37FR6459 2.
Inspection and Enforcement Manual, Inspection Procedure 92700, 8/13/84 3.
Inspection and Enforcement Manual, Interpretations 10CFR50.55(e), 4/1/80 IE9UE A5 UNDERSTOOD BY REVIEW GROUP 6 and 11.
All reporting requirements of Inspection and Enforcement Bulletin 79-14 wer e not met. The reporting requirement for nonconformances, paragraph 4,
were not sat i sf i ed by TUGCO.
DiscuFsion:
Quality Assur ance Aspects Inspection and Enf orcement Bulletin (IEB) 79-14 was issued because several operating facilities had been identified in which the as-built configuration of the piping systems did not agree wi th the seismic analysis design inputs. The bulletin discussed several actions requested of the licensees including the identification and reporting of nonconforming conditions noted during inspections that would cause safety systems to be inoperable.
It is obvious by the wording of the bulletin that it was primarily directed to plants that held an operating license at the time the bulletin was issued. Examples of this can be found in paragraph 2 of the bulletin," Where nonconformances are found which affect oper abi l i t y of any system..."
Operability considerations are normally associated with with operating plants with Technical Specifications wherein the term is defined. Paragraph 2 also discusses
"... systems thet ar e normall y accessi bl e... " These are defined in the bulletin as areas of the p] ant that can be entered during reactor operation. Lastly, the bulletin directs that,"
Facilities holding a construction permit shall inspect saf ety-rel ated systems in accor dante with Items 2 and 3 and report the results within 120 days." This very explicitly I
l l
i
s 5'
f excl uch s construction f acilities from Item 4 of the bulletin deal i nkg with nonconformances.
BAFET Y SIGNIF ICANCE:
There i s no saf ety significance to this issue based on the fact that facilities under construction were not intended to report nonconformances to the NRC to comply with IEB 79-14.
This is further supported by a discussion with a cognizant Inspection and Enforcement staff member who confirmed that the intent of reporting nonconformances was to assure that operating plants took appropri ate corrective actions.
CORRECTIVE ACTIONS:
This item was initially discussed as an unresolved item in the draft inspection report and subsequently dropped from ihe final inspection report. The issue was never formal 1y t r ansmi t t ed to
- t. h e 11censee and,thus, no corrective actions would have been initiated. No further actions are warranted concern 2ng this matter.
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l 17
'l Inspection Report 50-445/85-16; 50-446/85-13 Item 6 and 11
' 1.
DIA Statement of the Issue (See Attachment MM)
Issue Resolution in Final Report 6.
TUGCo never responded to.all Unresolved item downgraded i
I
.of IEB 79-14.
to open item (445/8516-0-3; 446/8513-0-03).
11.
TUGCo internal letter stated that Paragraph dropped.in final TUGCo not identify'non-conformance report.
on IEB 79-14 to NRC.
2.
Expanded Description of the Issue and Related Backaround Information i
)
The basic issue as understood by Region'IV management is as follows:
i I
I The inspector (H. Phillips believed, based on his determination from his
]
(
review of the TUGCo responses to IE Bulletin 79-14 (Attachment 12), that j
TUGCo did not respond to all aspects'of the IE Bulletin 79-14, i.e., the 3
l TUGCo response did not indicate that all seismic Category I piping 1
(regardless of size) would be evaluated to the action items in the IE-1.
Bulletin'if it was dynamically analyzed by computer.
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7 I
18 The inspector (H. Phillips) believed that TUGCo was not reporting nonconformancesasrequiredbyIEBulletin79-14basedo,nahTUSCo internal letter CP8#24.163, dated October 22, 1982, that he had reviewed.
This issue' was first identified in draf t la, unnumbered paragraph, page 4-2 (Attachment 2).
It is not assigned any category, i.e., open, unresolved, or violation.
Page 4-3 addresses an unresolved item related to further review of TUGCo policies and procedures.
In draft 3, paragraph 6 (Attachment 4), the issue is deleted.
3.
Safety Significance of the Issue j
There is no safety significance to either issue.
At the outset, while the following paragraphs will discuss the details of the technical issue, it should be noted that since " unresolved items" are reserved to identify those items which may be violations of requirements upon further review, the requests made in an IE Bulletin are not regulatory requirements unless further imposed by NRC Order. Thus, a Bulletin related issue for further review as an open item does not represent a " downgrading" but rather an appropriate classification.
I The inspector has improperly interpreted IE Bulletin 79-14 with regard to i
seismic Category I piping to be evaluated as discussed in Addenda 2 in j
the testimony of T. F. Westerman (5ttachment 13).
Safety Class 2 and 3 l
l small bore (2" an'd smaller) non-high energy lines were stated in the TUGCo I
s1
)
1 j,t '.
' q.
l1 19
~
December 3, 1982, response to IE Bulletin to have been excluded from the TUGCo formal 79-14 verification program, since the TUGCo program" already in place satisfied Bulletin 79-14 verification requirements.
In addition, TUGCo had excluded high energy line of 1-inch and under as allowed by.the Bulletin, since these lines were not computer analyzed.
The inspector had incorrectly drawn the conclusion that based on an internal TUGCo letter, TUGCo had not reported nonconformances foun'd during the followup of IEB 79-14.
For a facility under construction, the I
requirements'for reporting-to the NRC were satisfied by filing reports in accordance with:10 CFR 50.55(e) as discussed in Addenda.4 to T. F.
Westerman, 01A testimony (Attachment 14).
The inspector (H. Phillips) assigned his const.1 tant (J. McKluskey) to inspect IE Bulletin 79-14 without Regional management direction or concurrence. He apparently considered that Region IV had, in most cases, inadequately inspected hardware associated with IE Bulletin corrective actions (draft la, page 4 [ Attachment 2]). The hardware associated with IE Bulletin 79-14 has been thoroughly inspected, and the present Stone and Webster redesign of pipe supports is receiving direct oversight by NRR, as discussed in Addenda 1 to T. F. Westerman OIA Testimony
( Attau.. <nt 14a).
J 4.
Region IV Management Handling of the Issue Region IV management has concluded that'there is no substance to the two i
i items. The issue was properly left open for followup on the TUGCo I
al 9
]
1
/1 it
'I 20
( ~ Y, i
ys commitment t.o prqvide a reviced respanse to IE Bulletin 79-14 to reflect l
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the new S&W pipe support effort.
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Fitting Locations," and CP-85-12. " Auxiliary Feedwater Pressure Control "
stated that corrective action was scheduled to be completed for Unit 1 by May 1985. The open items list indicated that they were not completed on November 30, 1985.
_j i
TUGCo management has assembled a task force consisting of four to five engineers or specialists to evaluate and take action on the matters described above. Thisitemisunresolved(445/8516-U-01,446/8513-U-01).
No violations or deviations were identified.
4.
Applicant Action on IE Bulletins (IEBs) a.
In response to discussions regarding the TUGCo program concerning IEBs, Circulars, and Information Notices Region IV was informed that TUGCo will perform a review of related procedures and records to detemine -
the adequacy of procedures and the completeness of associated records.
The initiation of this effort will follow the task review of the 10 CFR Part 50.55(e) program which is presently in progress.
Thisitemisunresolved(445/8516-U-02,446/8513-U-02).
b.
TheTUGCoactionsontwoIEBs'(i.e.,Nos.79-14and79-28)were selected to review hardware evaluations or repair / replacements. TUGCo 10ER Log ;,heet, page 10. dated April 9,1984, was reviewed to i
detennine the status of the IEBs.
(1) IEB 79-14 was evaluated by TUGCo in 1983 and was statused as closed. The NRC inspector indicated that the closure of IEB 79-14 was premature since Stone & Webster is currently analyzing Unit I seismic analysis versus' as-built drawings, which directly relates u
to this IEB. Unit 2 as-built work has also not been completed.
i TUGCo stated that the IES 79-14 file will be reopened and a supplemental report will be submitted upon completion of the ongoing project engineering work.
The above item (IEB No. 79-14) status is considered an open item f445/8516-0-03,446/8513-0-03).
(2) IEB 79-28 identified deficiencies with certain manufactured lots of NAMCO EA 180 limit switches. The gasket material of the faulty lots, when exposed to temperatures-above 175'F vaporized and emitted a yellow-brown crystal like resin that can cause these
]
switches to fail. The NRC inspector found the TUGCo documentation to be complete with respect to the specified corrective action of replacing these switches with switches manufactured in acceptable lots.
1 l
Field verification of replacement of 14 switches identified, however, that the identity of 2 switches could not be traced to existing travelers. Specifically, the replacement NAMCO limit 1
)
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TELECON i
M AUTHOR:
DATE:
f/9/f7 TIME s, J'.*/f#
CONVERSATION WITH:
8dt<N, Id~
SUBJECT:
M
[#8 79 BRIEF DESCRIPTION
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g MEMORANDUM FOR:
Vince Noonan Comanche Peak Project Office
'FROM:
John G. Davis, Director Office of Nuclear Material Safety and 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 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 inspected and specify whether that which CPP0 has inspected is required to be inspected as a part of the IE quality assurance construction inspection program.
2.
Similarly an identification of CPP0 action regarding items and activities I
of the program implemented by Region IV that are different than those in IE
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program.
3.
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 CPPO 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 comparison with what the IE construction quality assurance program requires or describes.
DRAFT 12/19/86 DUP /N0ONAN MEMO
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4.
As a separate section of the report, a description of those activities performed by the CPP0 that are not included in the
'IE construction quality assurance program or Region IV implementation program.
5.
The findings by the CPP0 for each of its activities described above.
' If you have any cuestions concerning this request, please promptly contact the CPRRG.
.Your reply should b-eceived by CPRRG by January 5, 1987.
John G. Davis, Director Office of Nuclear Material Safety and Safeguards i
4 4
DRAFT 12/19/86 DUP /NOONAN McM0 fL-t.
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. Document Name:
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. DUP /NOONAN MEMO f -
Requestor.'s ID:
MCCAUSLA j
Author's Name:
JGDavis' Document Comments:
OIA Report 86-10 RG PO-01 t
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1 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 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 regard 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, confomance to procedures, " 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 sufficient to separate procedural from safety concerns.
DRAFT 12/19/86 DUP /
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Information that describes how IE intends'that findings and items from inspections be " resolved" with regard to' safety and procedural.
significance and-licensee's performance.
If you have any questions regarding this. request, please promptly contact CPRRG.
I Your reply should be received by the CPRRG by January 5, 1987.
John G. Davis, Director Office of Nuclear Material Safety and Safeguards i
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DRAFT 12/19/86 DUP / TAYLOR MEMO ?
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DUP / TAYLOR MEMO 2
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MCCAUSLA Author's-Name:
. JGDavis Document Commentsi OIA Report 86-10 RG IE 02 s
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OIA report 86-10 RG ED-01
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MEMORANDUM FOR:
Victor Stello, Jr.
Executive Director for Operations 1
FROM:
John G. Davis, Director Office of Nuclear Material Safety and Safeguards
SUBJECT:
COMANCHE PEAK OIA REPORT 86-10 REVIEW GROUP RG ED 01 This is in reply to your memorandum of establishing the Comanche Peak OIA Report 86-10 Review Group (CPRRG).
The purpose of this memorandum is to describe for you the charter of the CPRRG I
and identify, in broad terms, the report that the CPRRG will provide you upon completion of its efforts.
The CPRRG has three specific tasks:
1.
Identify the safety significance of the thirty-two issues identified in J
OIA report 86-10.
(Attachment 1 to Attachment MM to OIA Report 86-10).
j 2.
Whether the issues referenced in Item 1, above, were appropriately handled as to' process and disposition.
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3.
Whether the current augmented review and inspection effort at Comanche Peak is sufficient to compensate for any identified weakness in Region IV's QA inspection programs.
1 The CPRRG intends to accomplish its 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
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IDENTIFY THE SAFETY SIGNIFICANCE OF THE ISSUES IDENTIFIED IN OIA REPORT
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86-10.
s' 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, t
c.
Determine the disp acn i%
d.
Express an opinion on each issue.
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Provide a rationale for its opinion.
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- 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.
l 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.
By disposition.the report will deal also with whether an item was c.
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 i
IN REGION IV's QA INSPECTION PROGRAMS.
a.
The CPRRG w I 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 l
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 i
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 i
you by January 30, 1987.
We will inform you of the schedule.
John G. Davis, Director Office of Nuclear Material Safety and Safeguards 4
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t 12/19/86' COMMANCHE PEAK OIA REPORT 86-10 REVIEW GROUP (CPRRG)
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EXTENSION MAIL STOP John G. Davis,-NMSS,: Chairman 74063 958-SS Guy A. Arlotto, RES 37995 NL-005
.Clemens J. Heltemes, Jr., AE0D 24484 EWS-263
., Carl J. Paperiello, R-III 38-85517 R-III-James Lieberman, OGC, legal Advisor 27486 9604 Robert A. Erickson, NMSS, Coordinator 74194 881-SS PRINCIPAL CONTACT PERSONS Eric Beckjord, RES 74341 NL-005 Paul S. Check, R-IV 728-8222 R-IV Harold Denton, NRR-27691 P-433 Eric H. Johnson, R-IV 728-8106 R-IV i
James G. Keppler, R-III 388-5181 R-III Robert D. Martin, R-IV 728-8225 R-IV George A. Mulley, Jr.,0!A 24451 EWS461 Vince Noonan, NRR 27425 110 Harry Phillips, R-IV (817)897-2201 R-IV Ronald M. Scroggins, IRM 24750 12109 James M. Taylor, IE 27397 EWW-322 Thomas F. Westerman, R-IV 728-8145 R-IV 2
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MEMORANDUM FOR:
OGC FROM:
John G. Davis, Chairman Comanche Peak Report Review Group
SUBJECT:
ISSUES RAISED BY OIA REPORT 86-10 HAVING BROADER IMPLICATIONS FOR REGION IV
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In the Chairman's January 15, 1987, memorandum to the EDO, the Commission requested the CPRRG to offer the EDO its judgement on whether the problems identified at Comanche Peak are isolated or there are broader implications in. Region IV.
The CPRRG requests OGC assistance in addressing this issue.
Specifically, based on OGC's completed review of the OIA report, what issues, if any, are raised which the'CPRRG should consider as potentially having
" broader" implications.for Region IV7 OGC's suggestions, as well as those of others, will be valuable to the CPRRG in reaching its judgement.on which. issues, if-any, have broader implications.
l The CPRRG appreciates your assistance on this matter.
)
NOTE:
OGC's response will identify four issues:
- I 1.
Regional management's interaction with inspectors and management's role in' reviewing, revising,' and approving inspection reports.
2.
Any identified failures of Region IV to carry out inspection modules.
3.
Whether Region IV treated Comanche Peak differently from other plants; if not, then broader implications are likely.
4.
The state of the NRC Form 766 system at Region IV.
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wash NGTON, D C,20655 DRAFT 12/17/86-A MEMORANDUM FOR: Robert Martin Regional Administrator, RIV
-FROM:
Victor Stello, Jr.
Executive Director for Operations l
SUBJECT:
OIA REPORT REVIEW - OIA FILE #86-10 I have reviewed your memo to me of December 17, 1986, which outlines your proposals for dealing with actions necessary to respond to the points raised l
in the subject report.
By separate memo (see Enclosure 1) I have established a Review Group, with j
John Davis, Director, Office of Nuclear Material Safety and Safeguards as Chainnan to conduct the review of technical issues as you reconsnended.
I approve your suggestion to detail T. Westerman and H. Phillips full-time to i
be at the disposal of the Review Group until their work is complete on or about January 30, 1987.
I approve the actions you recommend in regard to initiating remedial action within Region IV staff to assure a proper understanding of regional policies in regard to resolution of staff / supervisor problems, supervisory responsibilities and to develop an improved inspection report tracking You will advise me separately of specifics of implementation of I
system.
these actions.
i I agree with your comments in regard to the OIA conclusions on Allegation III (Data documented in Inspectors Reports).
I am withholding a decision on l
Allegation I (Management issues) and Allegation II (the adequacy of the inspection program at CPES) until the completion of the Review Group's efforts.
I l
Victor Stello, Jr.
Executive Director for Operations As stated i
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ENCLOSURE 2 c
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NUCLEAR REGULATORY COMMISSION n
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wAssmorow.o.c. nous DPAFT 12/17/86-A
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MEMORANDUM FOR: John G. Davis, Director -
i Office of Nuclear Material Safety and Safeguards l
FROM:
Victor Stello, Jr.
I Executive Director for Operations
SUBJECT:
OIA REPORT REVIEW: OIA FILE #86 ESTABLISHMENT OF REVIEW GROUP i
In order to resolve issues which OIA Report 86-10 has raised, I am 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. Paperiello are assigned as members of the Group.
2.
The task of the Review Group is to review the technical issues identified in OIA report 86-10 and to determine and document in a report to me (1) the safety significance of those issues for Comanche Peak, i.e.,
whether actions should be taken to rectify any unsafe 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 is sufficient to compensate for any identified weakness in Region IV's Q/A inspection programs.
3.
You may task other NRC staff or utilize contractors as required, although I recommend that you keep your requirements to the minimum possible.
Necessary funds will be made available at your request by RM.
T. Westerman 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.
S.
I would like to have your report in say hands by January 30, 1987.
Victor Stello, Jr.
Executive Director for Operations cc:.E. Beckjord R. Martin G. Arlotto
. R. Scroggins i
J. Taylor F
H. Denton
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ENCLOSURE 3
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-DRAFT PRESS RELEASE-
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I NRC'S EXECUTIVE DIRECTOR APPROVES ACTIONS-AT REGION IV 0FFICE IN COMANCHE PEAK MATTER Victor Stello, Jr., Executive Director for Operations of the Nuclear
, Regulatory Commission, has approved a series of actions to deal with the findings of a report from the NRC's Office of Inspector and Auditor on the performance of officials at the agency's Region IV Office at Arlington, Texas, concerning the handling of safety issues involving the Comanche Peak Nuclear PoweF Plant'at Glen Rose, Texas. The Commission has approved these actions, and is continuing its review of the matter.
The Office of Inspector and Auditor completed its report on November 26.
3 It deals with allegations made by an NRC inspector at the Region IV office. A summary of this report, with deletions, was made puFlic on December 11.
Mr. Stello has formed a special review group headed by John Davis, Director of NRC's Office of Nuclear Materials Safety and Safeguards, to review the technical details of the OIA report to determine (1) the safety significance of the issues for Comanche Peak and whether actions should be
~
taken to rectify any unsafe conditions; (2) whether the issues when identified by Region IV were appropriately handled; (3) whether the current augmented NRC review and inspection effort at Comanche Peak is sufficient to make a finding of reasonable assurance on the safety of construction without relying on Region IV's previous inspection program.
The NRC inspector at Region IV and his supervisor have been detailed temporarily from their present duties to be at the disposal of the review group until the work of the group is complete.
"I have appointed this special review group, headed by a senior NRC official, to get an independent view of the matters covered by the OIA re' port. I have requested a report to sne by January.30,1987," Mr. Stello I
j said.
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I In. addition, Mr Stello has approved' recommendations from Robert Martin, t
Region IV Administrator, that regional technical staff and~ supervisors be ret ~ rained 'concerning regional policies which set out the obligation of both the staff and supervisors and management to escalate disagreements promptly so that they can'be resolved. Mr. Martin also has directed that an improved
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i inspection report tracking system be developed to identify those reports that
,are unacceptably delayed in the various stages of preparation, reviev, approval and distribution. This new system is to be in operation by February 15, and will alert senior regional management of possible instances of protracted review of reports. Training will be conducted for all Region IV supervisors to remind them of their proper supervisory responsibility (s, including the need to give adequate direction and guidance, and to identify and document weaknesses they discern in their subordinates. Supervisors will be held accountable for developing suitable individual development plans to address any problems.
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