ML20237L221

Discusses Concerns Re Region IV Insp Program Per .Believes That Past Region IV QA Insp Effort Does Not Provide Strong Support for Safe Const of Facility

ML20237L221
Person / Time
Site:	Comanche Peak
Issue date:	07/15/1986
From:	Thomas Scarbrough NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
To:	Mulley G NRC OFFICE OF INSPECTOR & AUDITOR (OIA)
Shared Package
ML20237F760	List: IR 05000445/1980026 IR 05000445/1985018 IR 05000445/1986010 ML20237F757 ML20237K977 ML20237L009 ML20237L052 ML20237L058 ML20237L073 ML20237L183 ML20237L187 ML20237L193 ML20237L212 ML20237L221 ML20237L240 ML20237L244 ML20237L264 ML20237L285 ML20237L293 ML20237L327 ML20237L341 ML20237L352 ML20237L358 ML20237L369 ML20237L386 ML20237L409 ML20237L426 ML20237L431 ML20237L478 ML20237L496 ML20237L507 ML20237L519 ML20237L554 ML20237L564 ML20237L594 ML20237L616 ML20237L623 ML20237L628 ML20237L642 ML20237L652 ML20237L656 ML20237L679 ML20237L705 ML20237L711 ML20237L718 ML20237L754 ML20237L767 ML20237L814 ML20238A011 ML20238A033 ... further results
References
NUDOCS 8708200126
Download: ML20237L221 (5)

Text

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July 15, 1986

. MEMORANDUM' FOR: George A. Mulley, Jr., OIA FROM: 72ECi ' Thomas G. Scarbrough, ASLAP

SUBJECT:

COMANCHE PEAK q

In a July 8, 1986 memorandum to you, I discussed my review of the concerns expressed by H.S. Phillips regarding' ,

the Region IV inspection program for Comanche Peak. With respect to the adequacy of the Region IV QA inspection effort, I stated my opinion that the Region IV QA effort had been weak for that plant. One of the bases for my opinion was the review of various QA inspection reports by Region IV and a comparison of the content of those reports with the insp%ction procedure guidance provided in IE Manual Chapter' 2512. Because of time constraints, I used a March 1984 I

version of Chapter 2512 as an example of the recommended frequency for the performance of the QA inspection e

procedures. Since preparing my July 8 memo, I have had an l

l opportunity to backtrack through the IE Manual change notices to determine the past. inspection frequency l recommendations. In this memo, I discuss the results of my l 4 l search regarding each QA construction inspection procedure.

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Ins'pection Procedure.35020 Audit of Applicant's Surveillance of Contractor QA/QC Activities

• In a January 1, 1977 change, the IE Manual recommends 1

that this inspection be performed between 5 months after docketing and construction completion. As indicated in my July 8 memo, while a minor inspe,ction was documented in report 78-07, a thorough inspection in accordance with this procedure was not performed until 1984 as-described in report 84-32. Thus, this procedure was not satisfied until the plant was nearing completion.

Inspection Procedure 35060 Licensee Management of QA Activities In a July 1, 1980 change, the IE, Manual recomme.nds that this inspection be performed every 18 months. As indicated in my July 8 memo, this inspection procedur'e was not satisfied until the inspection documented in report 84-32.

Therefore, at least two inspections in this area were not performed as recommended by Chapter 2512.

Inspection Procedure 35061 In-Depth QA Inspection of Performance In an April 1, 1980 change, the IE Manual recommends.

that this inspection be performed annually. In my July 8 memo, I stated that only report 84-22 documented an inspection in accordance with this procedure but also that '

other reports had described'some inspection effort in this area. Therefore, I expressed my opinion that the Region IV '

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3 effort in meeting this procedure had been weak. My opinion remains unchanged as the history of the IE' Manual indicates that at.least 3 ins'pections in accordance with this procedure were not performed'as recommended.

' Inspection Procedure 35065 Procurement, Receiving, and Storage In a July'1, 1980 change,'the IE. Manual recommends that this inspection be performed annually. .In my July 8 memo, I indicated that report 84-26 was the only report that documented the performance of this inspection procedure.

While other reports document inspections in this. area,, they were not as extensive as required by this procedure. Thus, at least 3 inspections that were to have satisfied this procedure were not performed.

l Inspection Procedure 35100 Review of QA Manual In an April 1, 1976 change, the IE Manual recommends ..

that this~ inspection be performed as required. As indicated in my July 8 memo, while the 766 data only listed report 84-22 as documenting this inspection, other reports

, described the review of QA manuals. My concern in this area ,

remains with respect to the recent indication that the ~

applicant saw a need to revise its QA Manual so late in the construction process.

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.4 In'spection Procedure 35200 Mid-term Construction Permit QA Inspection In an April 1, 1976 change, the IE Manual recommends that this inspection be performed between 18 to 30 months after the beginning of construction..

In my July 8 memo, I indicated that I considered the inspection performed in thic area (and documented in report 78-23) to have been inadequate. i Therefore, this inspection procedure was not 1 satisfied as recommended by the April 1976 version of Chapter 2512.

Following my: review of the Chapter 2512 history of

• recommended frequencies for the performance of,the QA  ;

construction inspection procedures, I. remain of the view that the Region IV'QA inspection effort for Comanche. Peak was weak. As discussed, a significant number of the QA inspections recommended by Chapter 2512 were not performed j l in a timely manner.

l The fact that the Region IV QA inspection effort was weak is not the major concern at Comanche Peak by itself, 1 because the applicant's QA program could have been satisfactory despite the weaknesses in the Region IV effort.

However, the Technical Review Team in Supplement 11-to NUREG-0797 identified numerous deficiencies in the implementation of the applicant's OA program. In, particulars the Technical Review Team concluded that I

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failures by QA and QC personnel to detect deficiencies suggested an ineffective Brown & Root and TUGCO inspection system. It therefore. appears that the weaknesses in the Region IV QA inspection effort may:have contributed to-inadequacies in.the applicant's QA program.

As a result, I do not believe that the past Region IV l QA inspection effort.provides strong support for the safe construction of Comanche Peak. Other efforts, such as'the Construction Assessment Team Inspection 83-18/12, Region IV Special Inspection 84-26, the Technical Review Team ..

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, activities, and inspections of technical work by Region IV over the years, should be relied upon to determine the adequacy of plant construction. l t-t b

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