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NUCLEAR REGULATORY COMMISSION W ASHINGTON, D. C. 20555
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NOTE T0:
Richard H. Vollmer Deputy Director FROM:
Vincent S. Noonan, Director PWR Project Directorate No. 5 Division of PWR I.icensino-A SUBJECT
- NpR PRELIMINARY REVIEW 0F OIA REPORT (REGION IVI I received a copy of the Summary OIA Report on Thursday (1?/04/86) and the Attachments on Friday (12/05/86).
Since' receipts of these documents, I have taken the following actions:
a)
Assembled a group of NRR personnel. to assist in the review of the sub.iect document. (Calvo.
Vietti-Cook, Terao and Jeno);
b)
Reouested assistance from OGC and I&E. Would like Gilray for 0A and Kalman for inspection; c)
Reviewed the OIA summary document, both OIA consultant's memoranda and transcripts of Denise and Region IV secretary.
My comments are included in this note. Other reviewer comments will be submitted to vou individually; d)
Requested that OGC provide a listino of all inspection reports that have been submitted to the board; el Project Manaaer (Vietti-Cook) will provide matrix of insoector allegations versus documents where allegation has been previously addressed.
Any allegations not previously addressed will be noted.
11 I believe that most, if not all, of the inspections allegations are. concerns that have been previously identified and are included in the CPRT ' program plan. When paragraph (e) is finished, we will know exactly.
If I am correct, then from strictly a technical viewpoint, the inspection reports have been sent to the Board either as Board Notifications or by staff memoranda.
8708270240 870019 PDR FOIA BAUMANB7-A-14 _PDR
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7 The inspector's allegations are primarily focused on the fact that Region IV Management suppressed making their findings into violations and is not alledging that the findings were suppressed.
Region IV's manaoement attitudes are not issues before the Board however, credibility of staff (Reofon IVI witnesses are an issue.
In addition,_the majority of the inspectors at-the site did not. feel they.were harassed, intimidated or pressured.
Recommendations:
1.i' Our original thinking was to set up a team to 90 to the site and talk to all inspectors at Region IV.
I-believe we should still do this; 2.) Prepare a joint memorandum (NRR/IE/0GC) giving our comments on the OIA report; 3.1 Release to the Board the summarv OTA report, the two 01A consultant reports and the memorandum in paragraph ($1 above.
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't Mn, Director WR Project Directorate No. 5 Division of PWR I.icensing-A i
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s UNITED STATES y' Sw Ih NUCLEAR REGULATORY COMMISSION
- de ? [/ t WASHINGTON, D. C,20555 i u!5 December 8,1986 g '.o /
Docket Nos:
50-445 and 50-446 NOTE T0:
Vincent 5. Noonan l
FROM:
Jose A. Calvo
SUBJECT:
01A REPORT REVIEW As requested I have perfortned a cursory review of the subject report and selected accompanying attachments documenting the Office of Inspe: tor and Auditor's (01A's) investigation into allegations of misconduct by Region IV management with respect to Comanche Peak Steam Electric Station (CPSES).
The report makes a strong case against the adequacy of Region IV normal inspec-tion program at CPSES since the beginning of construction until recently.
It raises questions about the credibility of Region IV inspection and enforcement efforts. The contents of the report and the people involved are such that it could cast doubt on the validity of the inspection results from the Region IV Comanche Pe.'ik Inspection Group, which is responsible for verifying the imple-mentation of the applicant's program plan for demonstrating the adequacy of construction at CPSES.
Furthennore, it was ' alleged that proposed findings in draft inspection reports were deleted or downgraded by Region IV management.
The OIA report identifies 34 technical issues, all of them related to quality assurance (QA) and quality control (QC) matters pertaining to the construction of CPSES.
These issues were alleged to be improperly disposed by Region IV managemen',. The disposition of these issues was reviewed by 01A's technical advisors who noted disagreement in the manner that certain issues have been disposed by Region IV management.
My initial assessment of these issues indicates that any possible generic implications raised by them appear to have been already addressed in the sup-plemental safety evaluation reports (SSERs) prepared by the NRC Comanche Peak Technical Review Team and covered by the applicant's Comamche Peak Response Team (CPRT) program plan for demonstrating the adequacy of CPSES construction, except for three issues discussed below.
However, further review is needed to confirm the abuve. The specific implications of each issue as related to the installed hardware were aesessed and only three cases were identified that may require further evaluatioa. These are related to structural matters per-taining to the reactor vessel, welding rods improperly identified, and certi-fication of BISCO electrical penetration seals (fire barriers).
There is also an issue addressed in one of the 01A's technical advisor reports which is not mentioned in the 01A's report.
This issue concerns the failure to take corrective action on audit deficiencies by TUGC0 from 1980 to 1986.
I believe that this problem should have been corrected prior to 1986 and thus it merits further evaluation.
I am suggesting that the following actions be taken with regard to the techni-cal issues:
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2 Obtain the assistance of NRC personnel (excluding Region IV) familiar with o
the -implementation of QA/QC program for construction of nuclear facilities and with NRC QA Inspection Program to do the following:
Verify that all the QA/QC issues pertaining to the construction of oo CPSES which have been identified in the OIA report have been satis-factorily resolved, Confirm the adequacy of the evaluations performed by the 01A's techni-oo cal advisors as related to those issues pertaining to CPSES QA/QC construction matters.
(NRC personnel with QA/QC expertise is available at the Regions and IE) o Confirm that possible generic implications raised by these issues have been previously covered by the NRC Comanche Peak Technical Review Team and have also been addressed by the CPRT Program Plan.
(This review can be performed by previous or current Comanche Peak project managers who are familar with the subject matter.)
Assess the significance of the issue concerning structural and nnechanical o
(This assessment can be per-matters pertaining)to the reactor vessel.
formed by EB/DPLA.
Assess tt a significance of the issue pertaining to the improper identifi-o cation o', welding rods.
(This assessment can be performed by EB/DPLA.)
Determine whether the BISCO electrical penetration seals (fire barriers) o are qualified for the intended services.
(This determination can be made by the EICSB/DPLA with the possible assistance of a fire protection engineer.)
With regard to the issues concerning the adequacy of Region IV Inspection Pro-gram, I believe that immediate management attention should be given to correct the problems stated in the OIA Report.
Concerning the release of this 01A Report to the public, I believe that only those pages of the report containing technical information and accompanying evaluations from the OIA's technical advisors could be made available to the public at this time.
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[, h b' Jose A. Calvo
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