ML20237L367

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Forwards Partially Withheld Background Info Re Insp Repts 50-445/85-07,50-446/85-05,50-445/85-14,50-446/85-11, 50-445/85-16 & 50-446/85-13
ML20237L367
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 01/28/1987
From: Martin R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Jennifer Davis
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
Shared Package
ML20237K807 List: ... further results
References
NUDOCS 8708200192
Download: ML20237L367 (6)
v • d • e


See also: IR 05000445/1985007

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UNITED STATES

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  • ( . ,5 NUCLEAR REGULATORY COMMISSION ,,1 /

D REGION IV

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, 611 RYAN PLAZA oRIVE, SUITE 1000 ,

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ARLINGTON, TEXAS 76011

JAN 2 ' 1987

MEMORANDUM FOR:

John G. Davis, Director,

Office of Nuclear Material Safety & Safeguards

FROM:

SUBJECT:

Robert D. Martin, Regional Administrator, Region IV

BACKGROUND INFORMATION ON CPSES INSPEC

1 have prepared the attached general notes in order to pro id l

v e the CPRRG i

with some additional background on the overall Comanche Peak P

roject and how the

reports of interest relate to that project.  ; \

I trust you will find it useful.

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Robert D. Martin-

Regional Administrator

Attachment:

As stated

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Attachment

BACKGROUND INFORMATION ON

COMANCHE PEAK INSPECTION REPORTS

General

The Comanche Peak Project was formed by EDO in his memoranda of March 12, 1984

and June 12, 1984. The Project was to be under the direction of the Comanche

Peak Project Director. The first Project Director, T. Ippolito, was succeeded

by V. Noonan.in October 1984. When Region IV resumed responsibility for

implementation of field inspection activities, the region formed the Region IV

Comanche Peak Group (July 1985) under the direction of T. Westerman. Westerman

was succeeded by I. Barnes in June 1986. Prior to the formation of the

Region IV Comanche Peak Group in July 1985, the limitec' inspection activities l

of Region IV were conducted under the management of the Chief of Reactor

Projects Branch 2 in Region IV.

After formation of the group, it was found that only a few inspection reports

had been issued up to that point in 1985. There were inspection reports and

inspection-related correspondence that had been prepared, but not signed out by

the Division Director (that Division Director left NRC in November 1985). I

Westerman was given the assignment to get all outstanding inspection-related

correspondence through the Project Director (Noonan) and ELD review chain.  !

Because of the complex hearing in process for Comanche Peak and the extensive

inspections, reviews, and evaluations r nducted by the Technical Review Team

during the period from the summer of 15d4, it was decided that all Region IV

inspection reports reports would receive review by the Comanche Peak Project i

Director and ELD (now OGC) to assure consistency of NRC positions with TRT

actions and prior hearing testimony.

Initially, upon formation of the Region IV Comanche Peak Group it was believed

that a joint report for all Region IV inspection activities would be most

useful. Therefore, the reports of inspections of preoperational testing,

readiness for operation, construction, and oversight activities for the

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licensee's Comanche Peak Response Team program were synthesized into a common

document. In February 1986, this practice was discontinued becaue of the

varying preparation, review, and issue resolution time required for each of the

report segments. Since that date, each unit of the task group issues

individual reports. (It should be noted that report 85-07/85-05 was prepared

prior to formation of the Region IV Comanche Peak Group, but was one that had {

not been processed out of the region when the prior Division Director left.) 1

The Regional Administrator, by memo dated June 12, 1986, requested IE to

provide the review function for inspection reports prepared by Region IV for

! Comanche Peak. This was done when the region became aware of the OIA

investigation and the Regional Administrator was asked to suspend his review of

the issues in contention for the duration of the investigation.

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Inspection Report 85-07/85-05

Period of Inspection: April 1 - June 1, 1985

First Draft Produced: August 28, 1985

Sent to NRR and ELD for Review: Early October 1985

Revised Version: November 26, 1985

Sent to Licensee: February 3, 1986

Two prior versions and the final report are in the p6ssession of Region IV.

There is the initial draft which was provided to Region IV management in late

August 1985, by the inspectors. There is the second version which represents a

signed revision of the first version by H. Phillips and N based on

comments provided by T. F. Westerman and reviews done by 1. Barnes. This

second version, which had been signed, was sent to NRR and ELD for review and

comment in early October 1985. This was the first report to be handled by the

Region IV Comanche Peak Group. Further revisions to the report were made to be

responsive to the review comments made by NRR and ELD. Those revisions were

made by November 26, 1985 and returned to NRR for concurrence on December 3,

1986.

Prior to issuing the revised report to the licensee, the revisions were

discussed with the SRI-construction (H. Phillips) who was the team leader for

the inspection and who signed the report for himself and for who was

not available at that time. After the report was issued, Mr. questioned

why the report had been changed and a meeting was held on February 5, 1986,

with C T. Westerman, I. Barnes, E. Johnson, and R. Hall to

discuss this repor .

On March 12,1986,M met with R. Hall and E. Johnson to continue l

discussion of the report. Althou M apparently had no further j

questions on the report was still questioning why the report had J

been changed to drop unresolved tems. 6 said he understood the I

reasons for deleting the violations since they were clear items. E. Johnson

said that management must ensure that technically accurate reports are written

and since the apparent unresolved items were clear items, we were not required i

to write a report that basically said that the inspector saw an item which was

believed to be unresolved but then was determined not to be unresolved.

Inspection reports did not have to be a diary of inspector activities. 1

On or about March 12 T. Westerman and E. Johnson briefed R. Martin on this i

issue since he had been called by V. Noonan to report that he (Noonan) had i

received calls from Phillips and Q (who was at the site) to express l

concerns about report handling. ]

R. Martin directed T. Westerman to interview all the NRC inspectors and

consultants at the Comanche Peak site to determine if they had concerns over

the handling of reports or inspection issues. These interviews were conducted

on March 13 and 14, 1986. The results of the interviews are contained in an

April 3,1986 memo from T. Westerman to E. Johnson.

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T. Westerman infonned E. Johnson that H. Phillips andM still had

apparent problems. As a result E. Johnson issued a memo, dated March 25,

1986, to each of these people directing them to put their concerns in writing

so they could be dealt with. A similar memo was sent to to give him

the opportunity to express any remaining concerss. .

On March 14. E. Johnson talked to J. Partlow to ask if IE would be available to -

provide a person to assist Region IV in reviewing inspector findings when the .

inspector had an issue that could not be resolved by regional management.

J. Partlow agreed to do so. This was discussed with Y. Noonan on March 17, and

he also agreed to provide a consulting expart if one was required. This was to

be an ad hoc arrangement.

As a result of the difficulties encountered in addressing the HQ comments on

this report after it had been signed by the inspectors, signatures were not

obtained on any further reports until all regional and HQ comments had been

resolved.

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Inspection Report 50-445/85-14; 50-446/85-11

  • Period of Inspection: October 1 - October 31, 1985

7 drafts produced over period of

First Draft Produced:

' 11/1-12/23/85.

  • Sent to NRR and ELD for Review: January 22, 1986
  • March 6, 1986

Sent to Licensee:

This inspection combined the construction report, operations inspection, and

the Comanche Peak Region IV inspection of the Comanche Peak Response Team

activities into one common report.

There was a continuing interface between Regional management and the inspector.

These discussions dealt largely with the handling of issues in the inspection

report drafts. The inspector expressed disagreement; however, as the drafts of

the inspection report evolved, it was Regional management's understanding that

resolution had been reached on all issues. The inspector signed and concurred

in the report.

Regional management considers that an inspector, when concurring in and signing

an inspection report, is stating that he or she is in agreement with the report

in those areas for which the employee has knowledge, expertise, or

responsibility. Due to issues which developed from this report, Region IV

issued Policy Guide No. 0220, Revision 1, " Meaning of Concurrence" to

communicate this understanding to all of the staff.

The statement in the OIA Investigation Report, that " Westerman and Johnson were

also aware that Phillips andMdid not concur with changes made in

inspection reports and signed the reports only because management wanted them

to" is not correct and is misleading. It is true that Mr. Phillips and

did express disagreements; however, it was not until Mr. Phillips'

CApril ~ 1986, a, memo, which was received after the report was issued, that

Regional management was aware that the inspector (Mr. Phillips) was only

signing and concurring in inspection reports to acknowledge that "My signature

means I recognized that supervisors and managers have the authority to make

such changes."

The OIA Report conclusion states that " Westerman and Johnson accepted thisThat

situation and took no action to address the inspector's disagreements."

statement is incorrect. A number of initiatives were taken byThese Regional

initiatives

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management once it was identified that there were concerns. commenced in

discussed previously.

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Inspection Report 50-445/85-16; 50-446/85-13

Period of Inspection: November 1-30 1985

First Draft Produced: 7 drafts produced over period

12/9/85 - 2/14/80

Sent to NRR and ELD far Review': March 8, 1986

Sent to Licensee: April 4, 1986

In order to follow all the management actions relative to this report, the

following documents would have to be examined:

Phillips Memorandum of May 12, 1986 " Matrix of Drafts for Report

85-16/13"

Report Drafts la and Ib

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Report Drafts 2a and 2b

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Report Drafts 4

Report Drafts 5a and Eb

Final Report Draft 6.a

The drafts of this report were, in Regional management's judgement, poorly

written, organized, and difficult to read. This certainly compounded the

difficulties of review of this report.

Mr. Phillips' memorandum, mentioned previously, stating that his signature only

indicated that he acknowledged management had the right to make changes to the

report, was dated April 4, 1986, and was received after issuance of this

report. Regional Management would not have issued the report had Mr. Phillips'

memorandum been timely.

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