ML20238A609
| ML20238A609 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/11/1987 |
| From: | Beckman D, Cerne A, Eugene Kelly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20237K807 | List:
|
| References | |
| NUDOCS 8708210024 | |
| Download: ML20238A609 (174) | |
Text
{{#Wiki_filter:_ _ _ _ _ h 'N 10 19g~ 1 EV 0 U.S. NUCLEAR REGULATORY COMMISSION l Report No. Comanche Peak Report Review Group - Task 2 ! Conducted At: U.S. Nuclear Regulatory Commission, Region I Period: January 20 - Februsfy 10, 1987
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Task Group Members: v _24 87
!Lvild A. Be'cKman, Consultant, cate Pr su a-Beckman Associates e CL Antone C. Cerne, Senior Resident eMe7 date Inspector for Construction and Operations, Seabrook Station S&.W nt a? -/G-F7 cate Eugene Mgelly, Inspecto'r Senior Res@imerick for Operations, L Statior ' nit 1 er o .: I '
Thomas C. Elsasse p sf, Reactor Projects cate Section, No. 3C Leade f Il 05 Samuel J. Collins, Ueputy Director, cate Division of Reactor Projects I Rw LS7 8708210024 870312 5 PDR ADOCK 0500 G
hh FEB 101987 TABLE OF CONTENTS Page 1 -. 0 EXECUTIVE
SUMMARY
1.1 Background.... ............................................ ... 1 l 1.2 Task Group...................................................... 2 l.3 Task Group Review Method........................................ 3 t 1.4 S umma ry a n d C o n c l u s i o n . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-2.1 Persons Contacted.............. ............. .. ........ .. . 7
. 2.2 Report Organization.... . ........... .................. ....... 8 3.0 ISSUES No. Subject' Page 3.1 and 3.2 Control of Design Criteria and Design Changes. . . . . . . . 10 S.3 Audit of RPV Installation Activities... .............. 15 3.4 CVCS Spool Piece Traceability... . .............. . 20 3.5 Hydrostatic Test for the Cold Leg Piping Subassembly.. 24 3.6 Concrete Truck Mixing Blade Inspection Records. .. .. 27 3.7 Failure of FSAR to Describe TUGC0 Records System. .... 31 3.8 CA Manual Dot: 9t Address ANSI N45.2.9 Requirements and Commitments............... ... . ...... ... ...... 35 3.9 Procedure Control of Offsite Shipment of Original Engineering Design Records................ ........... 39 3.10 Original Design Records Shipped in Cardboard Boxes to (
S.iEC..... .. ...... ... ......... ................... 42 3.11 No Backup Copy of Records Shipped in Cardboard Boxes ' to SWEC.................................. .......... . 42 3.12 Failure to Control and Account for Records Shi to SWEC....... ........ ... .....................pped ... .. 42 i k.b V wiu ; 1
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'3.13 Site Records of Chicago Bridge and Iron Shipped to Houston, Texas in Cardboard Boxes..................... 45 3.14 No Backup Copy of Records Shipped to Chicago Bridge and Iron.............................................. 45 3.35 Failure to Inventory Records Sent to Chicago Bridge and Iron.... ..................... .................... 45' 3.16 TUGC0 Did Not Document Audit of CBI Records..... ..... 49 3.17 Failure to Preclude Rain from Entering QA Intermediate Records Vault........................... ............. 53 3.18 Failure to Preclude Food and Cof fee Pot from.QA Intermediate Records Vault..... ....... .... ........ 53 3.19 Failure to Install Fire Suppression System, Drains, and a Sloped Floor at Records Center. . . . . . . . . . . . . . . . . . .
.. 57 3.20 . Plant Records Stored in Folders or Binders in Open Cabinets at Records Center........... ................ 57 3.21 Failure to Provide Temporary or Permanent Storage for Records Co-Mingled with In-Process Documents in Paper Flow Group....... ....................... ............. 61 3.22 Veld Rod Identification............... . .............. 66 3.23 and 3.24 Governing Procedures on Deportability and Corrective Action Associated with Significant Deficiencies (10 CFR 50.55(e)). . ........... .... ... ..... .. 70 3-.25 and 3.27 Failure to Maintain Retrievable 10 CFR 50.55(e) Files, and TUGC0 10 CFR 50.55(e) files Not Available.. ...... 77
- 3.26 Corrective Action Commitments in 10 CFR 50.55(e)
Reports.. . . ......... .......... ................ 83 3.28 and 3.33 IE Bulletin (IEB) 79-14 Concerns...................... 88 3.29 Incomplete IE Bulletin Files.......................... 92 3.30 NAMC0' Switches (IEB 79-28) Identification Problem..... 96 3.31 and 3.32 Inadequate Procedures for Processing NRC:IE Pulletins and No Focal Point in TUGC0 Construction for Tracking.100 3.34 BISCO Fire Barrier Seal Certification.... ..... ..... 104 11 '
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j@.T U nlef d TEB 1 0 1987 4.0 OVERALL
SUMMARY
AND CONCLUSIONS NA Subject Pace 4.1 Task Assignment - Review Informat' ion. . . . . . .... .. .. 116 4.2 Task Assignment - Identi fy Issues. . . . . . . . . . . . . . . . . 118 4.3 Task Assignment - Independent Disposition of issues.. 119 4.4 Task Assignment - Analysis of Region IV Disposition.. .120 4.5 Task Assignment - Describe Task Performance - Analysis of Agency Guidance.. . .. .. . . 122 4.o Task Group Findings and Opinions for Consideration by the CPRRG ir Assessing the Potential for " Broader" . Implications.. . .. . .. ... . .. . 124 5.0 APPENDICES 5.1 Task Grouc 2 Resumes 5.2 Task Group 2 Charter 5.3 Criteria for Analy:ing RIV Disposition 5.4 Documents Reviewed 5.5 CPRRG Task Group 2 Results Matrix 5.6 Inspectors Apparent Safety Concern and Task Group 2 Evaluation xu- - I iii
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1.0 EXECUTIVE
SUMMARY
1.1 Background
On March 19, 1956, an NRC Commissioner met with the Acting Direct 6', Of-fice of Inspector and Auditor (OIA), to refer to OIA a number of allega-tions of wrongdoing concerning the handling of safety issues at COMANCHE PEAK STEAM ELECTRIC STATION (CPSES). These allegations had been brought to the Commissioner's attention by current and former NRC employees and NRC contractors. DIA was concurrently informed of the allegations from sources outside NRC. s On March 19, 1986, OIA interviewed the Senior Resident Inspector at CPSES, regarding concerns about the way Region IV was regulating the construc-tien of CPSES. Allegations were received that Region IV inspectors were being pressured, harassed and intimidated by Region IV management to delete or downgrade proposed findings in draft inspection reports to make the TEXAS UTILITIES GENERATING COMPANY (TUGCO), the applicant for CPSES, look better. - Speci'ic instances were discussed which allegedly resulted in viclations proposed by inspectors in draft inspection reports being unjustifiably downgraded in final reports. After reviewing the information provided, OIA combined the specific instances of alleged wrongdoing into a general allegation that: Region IV management harassed and intimidated inspectors to pressure them to downgrade or delete proposed inspection findings at CPSES. Additionally, DIA identified other issues that will be handled by OIA in separate reports. During the interview, two other issues involving CPSES were raised wnich OIA determined warranted review in conjunction with the investigation: The Region IV Quality Assurance (QA) Inspection Program at CPSES was inadequate; anc Data documented in Region IV's NRC Form 766, Inspector's Report, was inaccurate. In response to these concerns the Office of Inspector and Auditor con-ducted an investigation, issued in November 1986 as the Report of Inves-tigation File No. 86-10. On January 15, 1987, the Commission approved the formulation of the Comanche Peak Report Review Group (CPRRG) re-sulting in the memorandum dated January 21, 1987 from V. Stello, Jr. to J. G. Davis assigning CPRRG task responsibilities and a preliminary schedule. The task of the CPRRG is to review the technical issues iden-tified in OIA 86-10, and to determine and document in a report: la rA n r=e n b r
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FEB 101987 Executive Summary 2 Task 1: 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. Task 2: Whether the issues when identified were appropriately handled as to process and disposition.
- Task 3: The ' safety' significance of the thirty-four issues identi-fied in OIA Report 86-10.
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Task 4: A review of the purpose and significance of NRC Form 766 and appropriate recommendations concerning its use. Task 5: Without expanding the specific tasks above, to office to the Executive Director for Operations (EDO) any judgement on whether it is likely that there are broader implica-tions in Region IV. In order to facilitate the timely accomplishment of CPRRG goals, Task Groups were established with appointed leaders and Group Charters were proposed to address the specifics of Tasks 1 thru 4 above, and provide input to the CPRRG rel'tivea to Task 5. Each Task Group was provided reference material (Appendix 5.4) and the opportunit3 to finalize the proposed Group Charters. CPRRG meetings were held on January 27 and February 5, 1987 to confer with the Task Groups anc approve the charters. During the course of the Task Group reviews, discussions were held between the CPRRG members and Task Groups in order to coordinate activities and address the needs of the CPRRG final report. 1.2 Task Grouc An interdisciplinary Task Group team was established by the Group Leacer to review the process and disposition of the thirty-four items using the methodology described in Report Section 1.3. The team members were appointed based on backgrounc, engineering discipline, and experience which correlated directly with the technical and programmatic issues identified in the OIA 86-10 report. Each team member has extensive ex-perience in the NRC field inspection program, experience on the team in-clude construction senior resident inspector (1), operations senior resident inspector (3), reactor projects inspection program supervision on a section chief level (3), inspection program management on a branch chief and division level (1), and naticnal 19dJstS i*sce: tion experience on an NRC consultant level (1) (see Appendix 5.1 for Task Group Resumes). Team members were authorized to expend whatever resources were required , to resolve the issues. The review group activities were conducted from l January 20 - February 10, 1987 and resulted in 585 hours task effort. k (B
L,! 5 Executive Summary mmfl m n ;". , ' 3 1.3 Task Group Review Method The technical and philosophical. approach taken by the members of Task Group 2 in reaching an independent consensus on the thirty-four. items in Attachment 1 to Attachment MM of OIA, Report 86-10 is pertinent in achieving an understanding of the groups findings and conclusions. In order to achieve the mandate of the Task Group 2 Charter (Appendix 5.2) the following were established:
- 1. A record was compiled consisting of the references in Appendix 5.4
- 2. The task group supervisor reviewed the record and established' files
_ .containing information or documentation pertinent to each of the thirty-four issues.
- 3. Standardized criteria were developed to' insure consistency in the l review approach and documentation of each item (Appendix.5.3).
- 4. Based on discipline expertise, experience and interest, items were assigned to the task group members with the item file.as a work package, the compiled records as. reference material and the criteria as work method guidance. ,
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Each draft item package was reviewed by the task force supervisor, { technical and editorial comments were resolved to insure consistency, j technical accuracy and a common focal point to appreciate tne
" broader issue" implications. {
- 6. Upon completion of the technical reviews, the task force supervisor ,
and task group leader reviewed the results of the item dispositions and conducted discussions with task group members to provide for the analysis, summary and conclusions mandated by the Task Group 2 charter. In order to provide consistency and to enable the task group cojectives to be accomplished, basic assumptions were made as noted below:
- 1. The independent assessment of each item was conducted as if the issue arose in the daily inspection effort at a new construction facility. The issue was approached utilizing the assigned task group reviewer as the inspector who presents his findings to the Projects Section Chief (task group supervisor) and the findings are ultimately approved as an agency position by the Branch Chief (task group leader) by sign-out of the inspection report.
- 2. Although an attempt was made to provide a complete record of Task Group 2 activities, it is assumed that the reader is familiar with the OIA Report 86-10 record and able to appreciate the basic tech-nical significance of the thirty-four items.
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Executive Summary 4 l , FEB 10 %l
- 3. The task group utilized the available information in the record to-perform an independent assessment and an analysis of the Region IV disposition. Where appropriate, consideration was given to the development of information and the sequence of events which could have affected the Region IV disposition of the issue (s).
It is important to note that on several issues, considerable debate. occurred within the group in order to arrive at the "best" technical resolution, as with most inspection findings various options are avail-able to qualify the concerns and effect the appropriate corrective action. On every issue a consensus was reached utilizing the task group method-ology depicted in item 1. above. G
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Executive Summary 5 h.(da u .. . TEB 101987 1 l l 1.4 Summary and Conclusion To the maximum extent possible, the Task Group attempted to focus its effort on the two major tasks defined in its charter. First, perform a rigorous independent assessment of the technical aspects of the 34 items presented. Second, trace and evaluate the development of the issues by Region IV from the initial finding by the inspectors to their ultimate disposition in the issued final report. The^ approach taken by the Task Group was based on common sense field experience, and an as-sessment of safety significance and inspection program goals, rather than a concentration on compliance with existing NRC procedural guidance. The executive summary is limited to discussion of these issues. During the course of its efforts, the Task Group did develop findings and opinions that bear en the overall issue of what went wrong with NRC's internal processes in dealing with the issues at question here. These broader implications are more appropriately addressed in Section 4.6 of this report. The Task Group found that there was reasonable basis f'or management action in the dispositioning of each of the 34 items as they were origin-ally presented in the draft inspection reports. In all cases, the items were not sufficiently developed by the inspectors to support the proposed enforcement action. Inere were no instances where violations were im-properly downgraded by management based on the information available at the time the Inspection Report was issued. In several instances, later information developed by the inspectors supports the issuance of viola-tions, but in these instances, a definitive safety concern is still not apparent. In the opinion of all members of the Task Group, no major safety signi-ficance can be attached to any of the 34 items. There is basis for fur-ther inspection or analysis of Items 1-4, but it is unlikely that signi-fic:nt findings will be developed. The lack of safety significance of the items, particularly as initially presented by the inspectors, appears to be a major contributor to the inspector / management interface problems that developed. The inspectors consistently took an overly aggressive enforcement posture on items of minor or negligible safety significance. It was apparent to the Task Group that in several instances, an attempt was made to propose an inordinate number of violations which dealt with the same programmatic licensee deficiency. The most apparent application of this philosophy was in dealing with the licensee's program for 10 CFR 50.55(e) reporting. I Management did not ceal effe:tively with redirecting the enforcement { i posture adopted by the inspectors or addressing and correcting the in-sufficient development of inspection findings. As a result, a philo-sophical gap developed between the inspectors and management which ap- I parently widened as this entire matter unfolded. Region IV upper man-agement, who could have provided an objective overview of the situation, apparently did not recognize the seriousness of this problem. In re- l \ ! iF ? ?" bf$[
f Executive Summary 6 viewing the body of information provided to the Task Group, no instance was found where either Region IV management or the inspectors attempted to meet with a goal to effectively resolve these fundamental differences. As a result, protracted debate continued between the inspectors and their immediate supervision over issues with negligible bonafide technical concern, causing the overall goal of the inspection program to become secondary, j In the opinion of the Task Group, no amount of procedural guidance could have prevented the problems that developed. The Task Group has some minor recommendations for further review of NRC internal guidance or procedures, but these are not central to the issues. In summary, the inspectors presented poorly developed _ inspection findings and proposed inappropriate enfo-:r ..- 'on. Management recognized this, but was ineffective at refvt 31n; tr.: i.:spectors efforts. No significant tech-nical concerns persist as a result of the Task Group's analysis of the individual issues; newever, Items 1-4 should be further evaluated to determine, as a minimum, if additional review ef fort needs to be expended in this areas to insure that the goal of the inspection program has been met.
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2.0 INTRODUCTION
2.1 Persons Contacted U.S. Nuclear Regulatory Commission A. Krasopoulos, Reactor Engineer, Plant Systems Section, Region I K. Manoly, Lead Reactor Engineer, Materials and Process Section, Region I H. Miller,-Quality Assurance, IE G. Napuda, Lead Quality Assurance Engineer, Region I J. Petrosino, QA Specialist, DQAVT/IE J. Spraul, Quality Assurance, IE A. Vietti-Cook, Project Manager, NRR , 1 i
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(2.0 Continued) 8 W 10 1.987 { 2.2 Report Organization The thirty-four items contained in Attachment I to Attachment MM of CIA Report 86-10 were researched using the methodology depicted in Report Section 1.3. Base docunents and NRC resources used to conduct the as-sessment are referenced in Appendix 5.4 and Report Section 2.1. The technical issues were reviewed using Appendix 5.4 standardized criteria to insure consistency in the assessment approach and documentation of Task Group efforts. The Report Section 3.0, ISSUES, is structured as follows: Detail Detail Number Title Purpose 3._ Item Title Item number, where there are dupli-cates or similar concerns they are grouped together. 3 . _, .1 Background Describes origin of item in OIA 86-10. 3._ .1.1 Summary of Issue How the item was originally presented by the reporting inspectors through disposition of the issue by Region IV management. Where appropriate additional information made known subsequent to inspection report is-suance is also described. 3._.1.2 References Applicable documents used in develop-ing, researching, and analyzing the issue (s). 3._. 2 Independent Assessment Disposition of item by Task Group 2 performed on the basis of assessing the item, determining independently the regulatory concern identified by the issue regardless of the Region IV approach and disposition. 3._. 3 Analyzing RIV Disposi- RIV inspector finding as originally tion presented either verbally or in Draf t 3.1 Statement of Inspector's Inspection Report with Task Group Finding and Regulatory presentation of the intended primary Concern regulatory concern. 3.-.3.2 Characterization of Characterization of the safety intent Finding of the RIV inspection by the Task Group. '
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(2.0 Continued) 9 FEB 101987 Detail Detail Number Title Purpose 3._.3.2 (CONTINUED) Task Group evaluation of the develop-ment of the inspection finding in-cluding assessment of programmatic consideration. 3._.3.3 Nature of Downgrade of Narrative description of RIV manage-Inspection Finding as ment disposition of the inspection it Appeared in Final finding based on the OIA report. Draf t with Brief State- record. ment of Hanagement's ~~ Reasoning 3._ .3.4 Management's Role in Task Group analysis of the appropri- -- Achieving Final Dispo- ateness of the RIV management dispo-sition sition of the inspection finding in-cluding, where appropriate, recommen-dations for further action. 3._.3.5 If Item was Determined Task Group analysis of whether appro-to be Unresolved, was priate focus or commitments were made there Sufficient Infor- to insure eventual resolution of the mation in the Inspection issue. Report to Focus Activi-ties of the Licensee / Inspector to Effective Resolution 3._ . 4 Conclusions Narrative discussion of RIV disposi-tion as compared to Task Group find-ings; including, where appropriate, potential safety significance, acdi-tional actions warranted, and broader implications. Section 4.0 of this report provides the Task Group 2 Overall Summary and Conclusions based on the Task Charter goals. . 1
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10 FEB 101987 3.0 ISSUES
- 1. and 2. Control of Design Criteria and Desion Chances for RPV Installation 1/2.1 Backoround These items were identified in OI 86-10 as 85-07/05, Issues 1&2. These were " highlighted" items in Attachment 1, Attachment MM to OI 86-10.
They are combined for analysis and assessment because of their similarity
- and their joint review in AM achment MM.
1/2.1.1 Summary of Issue During the conduct of inspect 4en E5-C7/C5, c is;':n IV inspector toenti-fied two findings which were ir.i.ially documentec as violations of 10 CFR 50, Appendix 8, Criterion III and XV respectively. The first con-cern involved the questionable licensee processing of the Unit 2 reactor pressure vessel (RPV) installation design criteria and the second issue concerned the failure to document a deviation from these RPV design cri-teria as a nonconforming condition. Both of these findings were ccm-mented upon by tne NRR consultant assigned to review Region IV draft re-port: on CPSES. Ease- dn part w " thn e comments, and further Region IV management review, Doth violations were finally documented as unre-solved items in the final inspection report. 1/2.1.2 References
.1 CPSES Combined IR 85-07/05 (two draf t versions and final report)
.2 OI 86-10, pp. 9-10 and Attachment MM ,
.3 CPRRG-15, Enclosures 1&2 4 CPRRG-16, pp. 1-27 and Exhibits 2-6
.5 CPRRG-17, 85-07/05 Inspection Report (Items 1&2) and Attachments 1, 2, 6 and 6a.
.6 American National Standards, ANSI N45.2.8 and N45.2.11 1/2.2 Inceoendent Assessment With additional inspection review, a violation could have been developed and supported concerning the failure to control the design information conveyed by the Westinghouse Procedure for Setting of Major NSSS Compon-ents (CPRRG-17, Attachment 2) in accordance with 10 CFR 50, Appendix B, Criterion III. The existing controls provided by the Brown & Root Pro-cedure for the Preparation, Approval and Control of Operation Travelers, CP-CPM-63 (CPRRG-17, Attachment G) were adequate to control changes to the traveler which altered performance of work. The operations travelers, in of themselves, did not constitute records which would be subject to 10 CFR 50, Appendix B controls for design documents. However, common industry and A/E practice would dictate control of certain installation ,
tolerances as cesign information, for which changes must be treatec more
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W?[!i ' (3.0 Continued) 11 RB 101o87 rigorously than is directed by CP-CPM-6.3. The Westinghouse procedure l which provided the installation tolerances should have been controlled as a design document. 1/2.3 Analyzing RIV Disposition 1/2.3.1 Statement of Inspector's Finding and Regulatory Concern ; With regard to the RPV installation, the inspector documented two viola-tions of 10 CFR 50, Appendix 8, Criteria III & XV respectively. (1) Failure to translate design criteria into installation specifica-tions ~ and failure to control deviation from these criteria. (2) Failure to maintain tolerances and report deviations on a noncon-formance' report. The inspector's primary regulatory concern involved design and design change control and its programmatic application in the handling of tolerance changes for the RPV installation. 1/2.3.2 Characterization of Finding Inspector's apparent safety concern and Task Group's evaluation. Design information must be properly controlled, otherwise installa-tion of safety related components may occur outside parameters of the design envelope. The Task Group considers this item it. have moderate potential safety impact in that the inspector and his management did not ensure that the licensee's program for control of design information in the RPV installation instructions was rigorously controlled. This had the potential to result in actual hardware quality defects; however, with the evidence that the operations traveler system was fully functioning at the time of the installation, any concern of acverse hardware impact is diminished. Should it have been pursued for more examples of programmatic sig-nificance; was it? Programmatic impact of the Operations Traveler program and usage, with res]ect to the adequacy of design control, should have been pursued further, particularly as it pertained to more recent work activity. bh E :.N 3
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(3.0 Continued) 12 ~ ~ FES ; , se7 Was it reasonable to' expect further undirected action by the i e-porting inspectors? If yes, what action should have been taken? Expansion of the inspection sample (regarding design control for Operations Traveler usage) to cover more recent activities was war-ranted. 1/2.3.3 Nature of Downgrading of Inspection Finding as it Appeared in Final Report with Brief Statement of Management's Reasoning Region IV management concluded that the operations traveler procedure adequately controlled reactor vessel installation, that the procedures were followed, and that GA criteria were complied with and no additional controls were required. Reportedly the review of these issues by NRR consultant precipitated the belief that viola-ions ere inappr:;riate classifications for these concerns. Unresolved items were created in the inspection report to permit additional review by the inspectors. 1/2.3.4 Management's Role in Achieving Final Disposition Were management's actions sufficient to warrant downgrade? If yes, explain. Yes, downgrade was correct at the time because of the way findings were developed by the inspector. However, Region IV management in-dicated that no additional controls or checks of the operational traveler program were reauired because the subject controlling pro-cedure (Cp-CPM-6.3) professed compliance with the required CA cri-te ri a . This appears to be an incorrect interpretation of how design changes should be controlled. What further action should have been directed to proper resolution. Direction snould nave been proviced the inspector to expand the in-spection of operations traveler usage to more recent work activities. A Westinghouse position as to how their installation tolerances should be perceived as design information should have been sought at the time (i.e. which information on the traveler should have been treated as design information). The NRR consultant's comments on the violation should have been clarified. The consultant indicated he was asking a question, wnile Region IV management perceived his comments to mean he disagreed with the violation. l V ;n '
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li m M T (3.0 Continued) 13 FES 1 0 isa/ 1/2.3.5 If Item was Determined to be Unresolved, was there Sufficient In-formation in the Inspection Report to Focus Activities of the Licensee /Insoector to Effective Resolution No specific guidance was provided to direct the subject of these concerns to effective follow up inspection. The inspection report write-ups re-mained the same as that which supported the violations, but the findings were changed to unresolved items. Without further inspection into the underlying concern for control o.f design changes in operation travelers, the validity of the findings remains in question. The item, as expressed in the final report, did not meet the criterion for an unresolved item. 1/2.4 Conclusions These two concerns represent a sample of inspection points which merited additional attention to determine whether the CPSES QA Program commitment on Design Control (CPRRG-16, Exhibit 2) and therefore 10 CFR 50, Appendix B, Criterion III had been violated. In determining whether such inspec-tion findings now require the expenditure of additional inspection re-sources, the time frame of the activities (i .e. : RPV installation in 1979 versus record inspection in 1985) must be considered. As developed, CP-CPM-6.3 and the associated operation travelers appear to represent ade-quate controls to have assured proper RPV installation. The downgrade of Items 1&2 was correct at the time because the issues had not been fully developed by the inspector to support violations. However, Region IV management's justification for the downgrade indicates a lack of understanding of certain QA principles, particularly those discussed in ANSI N45.2.11 for design change control. Neither the in-spector, nor management sought to follow-up the central question raised by these two concerns whicn was whether the Westinghouse technical in-formation (tolerances and clearances provided in its Reactor Vessel Set-ting Procedure) was in fact design information. Since, in the Task Group's opinion the Westinghouse procedure (CPRRG-17, Attachment 2) should have been controlled as design documentation to meet the full in-tent of 10 CFR 50, Appendix B, Criterion III a violation for failure to do so should have been written. However, the RPV installation took place six years prior to this subject inspection activity. Also, the operations traveler program, while ques-tionably meeting design change control standards, did exhibit enough control to confirm the adequacy of the RPV installation itself. With regard to the cold gap concern, a Westinghouse letter (CPRRG-17, Attach-ment.6a) indicates the existence of no adverse design or hardware impact. The very f act such a cold gap deviation had to be analyzed, however, provides after-tne-fact evidence that design information was in question. The inspectors never fully developed the issue as to whether the oues-tiened tolerances did or did not represent design information. They assumed that it cic, and wrote the violation. The importance of such lit A 9 ' *7
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-(3.0 Continued) 14 j) FEB : 0 1987 inspection to activities which occurred six years earlier and for which no hardware problems were identified minimized the finding. While Region IV management properly dismissed the violations based on the information provided by the inspectors, it appears they did so for an incorrect rea-son and thus negatively impacted future inspection of these valid con-cerns.
Handling of the Unresolved Item i The unresolved item, as issued in the final inspection report-was impro-per. Management stated the item was unresolved to allow the inspectors i~ to determine if the information changed violated Westinghouse'e's design criteria. (OI 86-10, ATT. D, p. 179). However, it was not stated or
-impliec in tae inspection -encrt unat needed to be resolved and by whom.
It woulc nave oeen proper tc make tne item unresolved (with guidance as indicated above) pending a determination of whether the information changed was considered Westinghouse design information, not whether it violated Westinghouse design criteria as opined by management. Actual violation of design criteria gives rise to an entirely separate issue than is being considered here. It is the Task Group's view that the Westinghouse Reactor Vessel Setting procedure was design information and i should have been controlled (changed) as such. If this determir.ation was made by tne inspectors., the unresolved item would then have become the violation the Task Group considers could have been writt an. I l 4 m m n .m. c l _ ___-_--__--_-------__-----_-.--_-------_-J
W (3.0 Continued) 15 . l IEE 10193/
- 3. Audit of RPV Installation Activities
3.1 Background
This item was identified in OI 86-10 as 85-07/05,' Issue 3. This was a
" highlighted" item in Attachment 1, Attachment MM to OI 86-10.
3.1.1 Summary of Issue Ouring the conduct of inspection 85-07/05, a Region IV inspector identi-fied as a finding the failure of the licensee to perform audits of the Unit 2.RPV installation activities, procedures and records. This was initially documented in the draft inspection report as a violation of 10 CFR 50, Appe dix B, Criterion XVIII. Since the licensee did not make available to the inspector any audit or surveillance reports on the RPV work, the lack of evidence to support these QA activities was taken to represent a failure to perform the audits or surveillance. Region IV management's review of this finding resulted in its being down-graded to an unresolved item in the second draft and issued unchanged as an unresolved item in the final inspection report. 3.1.2 References
.1 CPSES Combined IR 85-07/05
.2 OI 86-10, page 8 and Attachment MM
.3 CPRRG-15, Enclosure 3
.4 CPRRG-16, pp 27-42 and Exhibits 10, 17-19, & 40
.5 CPRRG-17, 85-07/05 Inspection Report (Item 3) and Attachments 3, 4, 5, 7, 8, & 9
.6 ANSI Standard N45.2.12 3.2 Independent Assessment With reference to the initial draft inspection report (CPRRG-17, Attach-ment 3), it is stated that the licensee "did not make available any audit or surveillance reports of specifications for placement criteria, place-ment procedures, hardware placement, or as-built records" relative to the Unit 2 RPV installation. This in and of itself does not constitute a violation of 10 CFR 50, Appendix B, Criterion XVIII.
In CPRRG-16 (p. 29) reference is made to the Brown & Root (B&R) QAM Sec-tion 19.0 and implementing procedure CAP-19.1. This reference implies that B&R had QA Program and procedural responsibility to audit the in-stallation of major NSSS components. If this were not accomplished (and the lack of records.of such activity is evidence that it was not accomo-lished), a valid violation against 10 CFR 50, Appendix B, Criterion XVIII could have been cited. It should be noted that this information was un-covered by the inspectors after final issuance of the report in an effort to respond to the findings in 01 86-10. I?A]V"
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s' l (3.0 Continued) 16 fg y g g 3.3 Analyzing RIV Disposition 3.3.1 Statement of Insoector's Finding and Regulatory Concern The inspector was concerned that QA audits or surveillance of the Unit 2 RPV installation had not been performed because objective evidence of L such QA activity was not available for review. His initial finding documented this failure to perform audits or surveillance as a violation of 10 CFR 50, Appendix B, Criterion XVIII. .
'3.3.2 Development of Finding The development of this finding by the inspector utilizes IE Inspection Module Guidance (CPRRG-16. Exhibit 10) as partial ju3ti":Sti:r for the position that audits of the RPV installation were requirec. Mc ever, IE Inspection Modules are not regulatory requirements.
It appears that in the development cf the original finding, the inspector did not review the audit plan or the licensee's audit program to deter-mine if audit of this activity was programmatically required. Thus, the violation was technically supported, as initially documented, only by the inspector's belief that Appendix B requires an audit of the RPV in-stallation because it is an activity of safety significance. This development of the violation was incomplete and Region IV management's downgrade of this item to an unresolved item was appropriate. As dis-cussed below, however, Region IV appears to have not recognized the valid concern raised by the inspector regarding audit conduct for critical activities. 3.3.3 Characterization of Finding Inspector's apparent safety concern and Task Group's evaluation. On the broad scale the failure to implement a meaningful audit pro-gram (if this were the case), represents a failure of an important part of the licensee's QA program. The Task Group believes that, for this specific case, the failure to audit the RPV installation, when coupled with the design control issues documented by Concerns 1 & 2, represents over reliance on the contractor procedure and program to assure quality work. This has moderat3 potential to impact safety but is sufficiently removed from the actual quality related equipment activities to have not had direct safety impact, particularly since Level 1 QC activities for this activity were in evidence. Iif
l (3.0 Continued) 17 D FEB ' 0 1987 - ; Should it have been pursued for more examples of programmatic sig-nificance; was it? The generic implications of audit problems at the CPSES were already being addressed by Inspection Specific Action Plan VII.a.4 (CPRRG-17, Attachment B). Therefore, expanding the inspection sample beyond NSSS component installation was probably inappropriate. Was it reasonable to expect further undirected action by the re-porting inspectors? If yes, what action should have been taken? Yes; the inspectors could have developed the finding originally to include review of the audit plan requirements. Had this been ex-tended , the B&R responsibilities under QAM, Section 19.0 and QAP-19.1, a valid violation could have been cited. 3.3.4 Nature of Downeradino of Inspection Findino as it Acceared in Final Report witn Brief Statement of Management's Reasoning Based upon the facts as documented in the initial draft inspection report, downgrading this concern to an unresolved item was appropriate. As re-lated by Region IV management, their belief that the ISAP VII.a.4 program had already initiated actions to assess and correct the known problems with the licensee's audit program tended to support this position. 3.3.5 Management's Role in Achievine Final Disposition Were management's actions sufficient to warrant downgrade? If yes, explain. Yes, because the initial violation as developed by the inspectors was insufficient to support the violation. What further action should have been directed to proper resolution. The inspectors should have been directed to review the audit plan, particularly with respect to NSSS components, to determine the scope of audit implementation. Based upon the three concerns (Items 1, 2 & 3) all related to RPV installation, further evidence that the licensee had assurances of adequate controls by their contractors for this activity could have been sought. { 3.3.6 If Item was Determined to be Unresolved, was There Sufficiant In- } i formation in the Inspection Report to Focus Actiricies of the ' Licensee /Insoector to Effectiv_e Resolution No; in fact documented in Attachment MM (OI 86-10), p, 6, Region IV man-agement did not appear to understand the basis of the concern since it was suggested that " surveillance for the installation of the vessel"
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hS7 L; .; D i (3 0 Continued) 18 FEB 101c37 could have substituted for audits. In fact the inspection report itself indicated that neither audits nor surveillance were conducted. This lack of understanding of this issue indicates that the unresolved item was not cocumented for meaningful follow-up inspection, but merely to j demonstrate the issue had not been avoided by management. 3.4 Conclusion Region IV management's downgrade of this issue appears appropriate, based upon insufficient development of the finding by the inspector. However, documentation of an unresolved item without clear understanding or direc-tion of what was needed to resolve the concern was misuse of this cate-gorization. l A valid unresolved item could have been generated to pursue audit plan requirements or to followup the lack of audit / surveillance of NSSS com-ponents in general. Such direction would probably have led to the de-termination, as documented in CPRRG-16 by another inspector, that B&R audits of the major NSSS components were required. Further review then would have led to the issuance of a valid violation of 10 CFR 50, Appen-dix B, Criterion XVIII. While it is trae that the regulatory requirements for audits and the pertinent guidance (e.g. , ANSI N45.2.12) do not prescribe what specific activities must be audited, it does not necessarily follow that important activities (sucn as installing the NSSS components) should not have been audited. In fact, the inspectors document the fact that surveillance activities were not conducted for this work. This results in a situation wnere Level I OA controls (i.e., QC inspection) 1s totally relied upon to provide the requisite quality assurance. The existence of tne ISAP VII.a.4 program and regional management's in-tent to evaluate licensee corrective action in response to the ISAP pro-vided some justification for minimizing the inspector's initial finding, since a broacer generic concern with resoect to audits was already being pursued. However, other inspector concerns (Nos. 1 & 2) were noted in the same inspection report about the RPV installation and that tne re-gional MC2512 program had apparently not been fully implemented to in-spect this activity at the tinie it was in progress. Therefore, Region IV's lack of recognition of the weak or nonexistent audit program in tne area of NSSS comoonent installation represents a potential problem in regional perception of tne acequacy of QA controls at the CPSES. i Handlino of the Unresolved Item There was justification for making this an unresolved item; however, ne way it was addressed in the final inspection report and the lack of mana-gerial guidance given to the inspectors did not result in effective re-solution. It is clear that the vessel installation was not audited; P% d,..]3p=9= 13 e e ad
37 Mid 1 (3.0 Continued) 19 IEB:: 53~ . however, this in of itself was not a violation. The larger concern should have been on whether there were already existing requirements in the audit plan or the Brown and Root (B&R) quality assurance procedures which were not raet. As previously stated, further review by the inspec-tors in response to 01 86-10 did identify a B&R requirement to audit the vessel installation. If this had been properly developed by the inspec- I tors at the time, a violation could have been written. However, the adequacy of the audit plan with respect to major NSSS has apparently never been resolved. Management's belief that this need not be pursued by the inspectors because of ongoing ISAP or CPRT activities was short sighted. There was no guarantee this specific area would have been reviewed adequately by those ongoing efforts. Management should have directed the inspectors to conduct an indepth review of the audit plan, particularly as it pertained to major NSSS mechanical components. This direction should have been documented in the final inspection report as the means to pursue the unresolved item. A less satisfactory resolu-tion would have been for management to contact the personnel involved with the ISAP effort to ensure this issue was addressed, with appropriate documentation in the inspection report. There were valid concerns regarding the adequacy of the audit and sur-veillance program. However, neither the inspectors or management set upon a course of action to resolve this concern for the specific activity in question (RPV installation). The categorization of this as an un-resolved item provided tne mechanism to do this, but it was not properly employed. l l I 4 t
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- 4. CVCS Scool Piece Traceability
4.1 Background
This item was identified in 01 86-10 as 85-07/05, Issue 4. This was a
" highlighted" item in Attachment 1, Attachment MM to 01 86-10.
4.1.1 Summary of Issue During the conduct of inspection 85-07/05, a Region IV inspector identi- , fied a finding which was initially documented as a violation of 10 CFR l 50, Appendix B, Criterion VIII. An installed piping spool piece was in-spected for marking and traceability. Although the spool piece number and the B&R drawing number were found on the subject spool piece (3;'.), other markings as required by subsection NA-3766.6 of Section III of the ASME Boiler & Pressure Vessel Code (S74 adaenda) were not noted; hence the apcarent violation. Subsequent review of this issue by Region IV management indicated that tne requisite traceability was provided by the existing markings (e.g. , 301) as noted. Therefore, management dropped ' the violation and no discussion of a traceability problem was included in the final 85-07/05 inspection report. 4.1.2 References l
.1 OI 86-10, page 12 and Attachment MM
.2 CPRRG-01
.3 CPRRG-15, Enclosure 4 4 CPRRG-16, pp. 43-51 and Exhibits 32 through 37
.5 CPRRG-17, 85-07/05 Inspection Report (Item 4) & Attachments 3, 4
&5
.6 ASME B&PV Code, 1974 edition (S74 Addenda); Section III, Articles NA-3000 and NB-4000 4.2 Indecencent Assessment The markings noted on the subject piping spool piece (e.g. 3Q1) meets the intent of tne ASME B&PV Code with respect to material identification.
The requisite traceability was provided and the finding documented in the draft 85-07/05 inspection report (CPRRG-15, Exhibit 32) did not con-stitute a violation of 10 CFR 50, Appendix B, Criterion VIII. However, further review by the Task Group indicated that a violation of 10 CFR 50, Appendix B, Criterion V did indeed exist in the failure of the licensee to follow approved procedures with regard to material iden-tification and marking (CPPRG-15, Exhibit 37). This failure to follow l procecures had no direct hardware or adverse safety impact since the Brown and Root procedure for marking of field fabricated material went beyond the code requirements. 1
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1 re s) l (3.0 Continued) 21 FEB 1 3 1987 l l 4.3 Analyzing RIV Disposition l 4.3.1 Statement of Inspector's Finding and Regulatory Concern l A piping spool piece fabricated on-site from bulk piping material was identified to be in noncompliance with the ASME B&PV Code, Secticn III l (NA-3766.6). Marking with the material specification, grade and heat I number had not been accomplished. Even though traceability could later I be established through the piping spool piece number, the inspector's ! concern remained that a violation of 10 CFR 50, Appendix B, Criterion VIII had been identified. The inspector considered the marking of. the spool piece insufficient to meet tha requirement of the ASME code and a violation was written. 4.3.2 Characterization of Fi dinc Inspector's apparent safety concern and Task Group's evaluatter. Without proper traceability, the potential existed for the instal-lation of non-code controlled material in safety related systems. The Task Group considers this to be an apparently isolated instance whicn has no direct safety significance. Further examples or evi-dence that the licensee's programs had failed to provide the requi-site traceability would provide a safety concern of generic apolic-ability to the site. However, further inspection for aeditional examples was not accomplished and therefore, no evidence of safety imoact existed. Should it have been pursued for more examples of programmatic sig-nificance; was it? Expanded inspection would have further evaluated the adequacy of tne licensee's overall material identification and traceability orogram. Inspection of additional on-site fabricated spool pieces for proper marking was appropriate. Was it reasonable to expect further undirected action by the re-porting inspectors? If yes, what action should have been taken? Yes; the violation as originally documented in the draft inspection report attempted to connect the perceived lack of adequate markings directly to an ASME Code violation. Had the development of this issue proceeded through review of the licensee's program and ap-plicable orocedures, a valid violation could have been justified. CD.P[$ L.
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N 9 P, s" i ; (3.0 Continued) 22 9U , , A 0 1987 4.3.3 Timeliness Was communication between inspectors and RIV Management on final resolution timely? No, in addition to the seven month delay in the inspection report issuance, it appears that the Region IV technical expert was not aware of the pertinent fact that the subject spool piece was fabri-cated from bulk material. Conversely, the original inspector did not learn until he later reviewed OIA testimony of the specifics of the code interpretation made by the technical expert. Was lack of timeliness a detriment to effective resolution? Yes, since the semantics of code interpretation were oeing argued for a spool piece wnich inceed was traceable. 4.3.4 Nature of Downgrading of Insoection Findino as it Appe,ared in Final Recort with Brief Statement of Management's Reasoning Management dropped the violation because acceptable traceability could be established for the spool piece. Ultimately, Region IV's interpre-tation of the Code (subse-tion NS-4122) was correct and the violation, as provided by the inspector, was not valid. 4.3.5 Manacement's Role in Achieving Final Disposition Were management's actions sufficient to warrant downgrace? If yes, explain. Yes, as the f acts were provided to them, their interp. etation of the code was correct ano a violation did not exist. 4.4 Conclusion Material traceability was available, therefore there is no safety signi-ficance of this finding with respect to the inspected spool piece. The fact that a procedural violation did exist was not identified until later because of the apparent focus on coce question, rather than the adequacy of the overall licensee program for material identification. The late timing of the report, and apparent lack of communication among all con-cerned individuals, contributed to the problems in dispositioning the inspection finding. .The original violation, as documented, was not valid. Region IV management reasoning for dropping the violation., wnile ulti-mately correct, appeared to be based upon certain incomplete :nformation. l l A violation of the licensee's own internal procedures did exist, as later identified by the reporting inspector in his response to OI EHO, (CPRRG-16, Exhibit 37). While the safety significance of th)i is mini-mi::ed by the f act that traceability was indeed established, the proolem l l ry l
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Nlf _- ....s (3.0 Continued) 23 FEs ; . ; 7
-in the processing and disposition of this issue probably contributed to the fact that this violation was not identified sooner. Also, the intent of safety inspection in this area (to determine the adequacy of the licensee material identification program) appears to have lost its sig-nificance to the prolonged discussion on differences in code interpre-tations.
There is evidence in the OI 86-10 testimony that a question existed as to when the "301" marking was placed on the pipe. The task group con-sidered the resolution of this question to be beyond the scope of its task. However this question, coupled with the inspector's initial con-cern that a material traceability problem existed, should have been suf-ficient cause for increasing the sample size of the inspection. Neither the inspectors or regional management :aused this to happen. The per-tinent issue should have been whether tne licer:++ '- --cg-am to provide traceability of field fabricated material was ace:;wate. If an examina-tion,of this program has not been adequately addressed in other NRC in-spection directed activities, consideration should be given to coing so. If the spool piece initially did not have the required marking when
, . viewed by the inspector, this could raise larger issues of potential safety impact related to traceability of on site fabricated material.
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FES 1 : 1967 24 . (3.'O Continued) Subassembly 5. Hydrostatic Test for the Cold Leg Piping This was not 5.1 Bactqround 07/05, Issue 5.01 86-10. 01 86-10 as 85-Attachment MM to This item was identified ina " highlighted" item in Attac Summary of Issue Region IV inspector ques-5.1.1 85-07/05, a During the conduct of inspection i test on Loop 3 RC Cold Leg pipin tiened the deferral of hydrostat c d item subassembly until the issue This systemwas hydrostatic documented tes as an un tion was completed. quirements by NRC headquarter
- r pending clarification of the code re h Af ter review by regional management, t e.spector's using tne cuest.;,The final rep section of the inspection report discussecond draft report.
this sybject was removed from thef this item. was issued wich no mention o t References 5.1.2 i 85-07/05 (Attachment 1)
.1
.2 CPSES Comb ned IROI 86-10, pp. 5) &B-9 & 12, and Attachments 3, 4,5,Attach
.3 CPRRG-15, Enclosure 5 Inspection Report (Item 4
CPRRG-17, 85-07/05 Section III, General 11, 14, 15, 16, 17 & 18 d) ASME B&PV Code, 1974 edition d(S74 6000. Adden a ;
.5 Requirements (NA) anc Articles NS-4000 an 5.2 Independent Assesstent j t piping subassembly was ASME Code, but con-Deferral of tne hydrostatic test on the i ing sub systems ecTh proper.
stitutes the normal practice he forhydrostatic hydrostaSince test for thepiping l assemblies. i test for all of the included isted as sub and piping systems system serves themselves as the requis te are components, tN l assemblies and parts.a result of this inspection activity. 4 l 5.3 Analyzine RIV Disposition Concern Statement of Inspector's Finding the and_ Regulatory hydrostati: testing i 5.3.1 l bassembly, the inspector be-Based upon the inspection of records relative to of one ASME Section III, Class He1 documented piping su this conce f rmec on the lieved the code had been violated. resolved
" serious question..
piping" (CPRRG-15, Enclosure 5).
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N.[t*. n (3.0 Continued) 25
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5.3.2 Development of Finding How issue was researched and analyzed, including supportive bases; applicable documents consulted and by whom. Discuss appropriateness of documents reviewed. Region IV review of this unresolved item, which included major input by the technical specialist and ASME Code expert, determined that the code had not been violated and the issue was resolved. Region IV management was correct in their technical position and apparently further attempted to convince the inspector of this by seeking a
" third party" opinion from an NRR Code expert. The inspector had documented the original concern as unresolved pending " clarification of code requirements by NRC headquarters". Since the expert tech-nical opinion of both Region IV and NRR had been sought with respect to this coce interpretation, it is r.* clear what additional infor-mation the inspector felt was pertiu.nt to resolve this issue.
5.3.3 Characterization of Finoing Inspector's apparent safety concern and Task Group's evaluation. The inspector's only concern was that an ASME Code requirement had been violated and it then followed that the ASME Code stamp for the subject piping subsequently had been improperly applied. The Task Group considers this item to have no direct safety signi-ficance in that the technical concern was not valid for the identi-fied example, i.e., the spoolpiece would be subjected to a system level hydro and this fully complied with the ASME Coce requirements. Shouic it have been pursued for more examples of programtnatic sia-nificance; was it? No programmatic significance was identified. 5.3.4 Timeliness Was communication betweer inspectors and RIV Management on final resolution timely? It appeers that offerts were made by RIV Management to address the inspector's concerns by seeking an NRR technical position on this matter. The decision making process on tnis item seems to take this into timely consideration. 1 k 7L u .un[ d
f8@M (3.0 Continued) 26 LMiG j rue u w 5.3.5 Nature of Downgrading of Inspection Finding as it Appeared in the Final Report with Brief Statement of Management's Reasoning Since the technical concern was invalid, no unresolved item existed and removal from tne inspection report was proper. However, the entire paragraph documenting the inspector's review of this issue was deleted. Since valid inspection of this area had actually taken placs, considera-tion should have been given to document the inspector's inspection and explain how the issue was ultimately resolved. } 5.3.6 Management's Role in Achieving Final Disposition Were management's actions sufficient to warrant downgrade? If yes, explain. Yes; the coce itself was u.ilizec to resolve the question and tech-nical expertise both inside and,outside Region IV was solicited to confirm this position. 5.4 Conclusion , Region IV management was correct for deleting this unresolved item from the inspection report. The issue had been resolved by proper code in-terpretation which allowed deferral of the subject hydrostatic test. The correctness of this interpretation was confirmed with NRR. It is customary practice for inspectors to documeni. in inspection reports their inspection activities and questions in certain ar u s to track how the inspection effort was ceveloped and the time that was expenced. If the particular auestion is resolved, the inspection report can document how questions were acceptably resolved. With management's removal of the entire section of the report on this item, the recor of the inspection effort is lost. While it is recog-nized as a management prerogative to do so, the resolution of the in-spector's question should have been provided to the licensee in the final report. This is particularly important if the item was presented as unresolved at the exit meeting, which the Task Group assumes was the case. l
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i hb (3.0 Continued) 27
'I FEB 10 se7
- 6. Concrete Truck Mixiao Blade Inspection Records
6.1 Background
This item was identified in OI 86-10 as 85-07/05, Issue 6. This was a
" highlighted' item in Attc shment 1, Attachment MM to 01 86-10.
6.1.1 Summary cf Issue During the conduct of inspection 85-07/05, the Region IV inspector iden-tified that a procedural requirement for concrete truck mixer blades to be checked quarterly was violateo in that no licensea records were available to document such inspections. The initial draf t inspection report documented this finding as a viciation of 10 CFR 50, Appendin B, Criterion V. The pertin:nt details of the inspection report did recog-nize that "the mixing blades were periodically inspected" and that
" strength and uniformity tests have consistently been within the accept-able range .. even though mixing blade inspection was not documented."
Region IV management, in their review, did not cause substantial altera-tion to eitner the violation or pertinent inspection report section (e.g. reference to an ACI 304 standard commitment in the FSAR was added to the final report). However, the transmittal letter, dated February 3, 1986, transmitting tne final inspection report to TUGCo required no response to the violation and stated the reasons behind this position. 6.1.2 References
.1 CPSES Comoined IR 85-07/05
.2 OI 86-10, pp.5 and 11 and Attachment Ky
.3 CFRRG-16, pp. 51-55 4 CPRRG-17, 35-07/05 Inspection Report (Item G) and Attachment 19
.5 American Concrete Institute Standards, ACI-301 and ACI-304 6.2 Indecercent Assessment A violation of 10 CFR 50, Appendix B, Criterion V was correctly identi-fied and documented. Corrective action and mitigating reasons why lic-ensee response to this violation was not required were also documented.
This was appropriately placed in the cover letter transmitting the final inspection report, since the violation was valid and remained as written. 6.3 Analyzino RIV Disposition 6.3.1 Statement of Inscector's cinding and Reculatory Concern s While the inspector acknowledged no evidence of a significant technical concern, he objected to the decision to not require a licensee response to the violation. He inferred that other inspection procedures could similarly have problems witn their implementation and documentation. F '. 1, *y
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M4Q (3.0 Continued) 28 FD 1 C sa7 6.3.2 Development of Finding How issue w.s researched and analyzed, including supportive bases; applicable documents consulted and by whom. Discuss appropriateness of documents reviewed. Essentially, the report and violation did not change as a result of Region IV review. Management required the inspector to provide a reference to the standard (ACI-304) requiring mixer blade main-tenance. Input received from the NRR consultant kpparently ques-tiened the need for such e citation, but this did not affect the decision to issue.a violation. It may have affected the decision to not require a licensee response. In evaluating their analysis of this issue. a#m t e fact (CFRRG-17, 85-07/05 1R, Item 6), Region IV implies tnat documentation of the mixer blade inspections was not in fact required by the B&R proce-dure (35-1195-CCP-10) in question (reference CPRRG-17, Attachment 19). Also discussed at length is the fact that ACI-304 does not require blade inspection. However, ACI 301-72 which additionally is a valid reference document requires in Chapter 7-.2.2.6 that
" mixer blades shall be replaced when they , ave lost 10 percent of their original height." This standard then, and not ACI-304, pro-vides.the basis for the procedural requirement to inspect mixer blades. When such an inspection requirement has its origin in a national' standard, the Region IV position that actual documentation of this inspection was not required does not appear to be correct.
Notwithstanding such problems encountered in the Region IV after-tne-fact analysis of thic issue, their issuance of the violation was correct. 6.3.3 Characterization of Findino Inspector's apparent safety concern and Task Group's evaluation. The implied safety concern was that the absence of the periodic mixer blade inspections could permit blade degradation which would produce defective concrete for pit. cement in safety related structures.
-Since this was not apparent from the concrete test results, the in-spector assumed this issue represented a failure to document re-quired inspections.
Given the report statement that the m1xing blades had been oeriodic-ally inspected and that strength and uniformity tests of the re-sulting concrete were consistently acceptable, the 7ask Group be-lieves that the lack of required documentation is of negligible I safety significance.
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- Should it have been pursued for more examples of programmatic sig-nificance; was it?
\
No; it is unreasonable to assume that this one example of failure to follow procedures, in and of itself, represents an example of a major problem that procedurally required inspections were not being accomplished or documented. 6.3.4 Nature of Downgrading of Inspection Finding as it Appeared in the Final Report with Brief Statement of Management's Reasoning l The violation was issued, basically as originally documented. Because corrective action had already been implemented prior to report issuance, the response to the violation was not required and reasoning for this cecision was documented in the cover letter of the re: ort. 6.3.5 Manacement's Role in Achievine Final Disposition .
- Were managemont's actions sufficient to warrant decision not to require a licensee response to the violation? ,
Yes; corrective action on a records violation with little safety significance had been completed. Licensee response to the violation would have acded nottirg of import to resolution of the problem. 6.4 Conclusion A violation of minor safety significance (correctly classified as Severity Level '/) was issued. The decision not to require licensee response was soundly cased with the reasoning documented in the cover letter trans-mitting the inspection #2 port to the licensee. The significance of this violation was minimized by the lack of evidence that construction itself or safety-related work was adversely affected. Lack of the documentation for the required inspection activity was not, of itself, incicative of a larger generic problem that a licensee re-sponse would have been expected to address. If, as expressed, the in-spector believed this broader issue of inspection conduct and documenta-tion to be of concern, he should have documented this position in his l inspection findings to support that position. This was not the case. ( l On the other hand, while Region IV management's action on this issue l appears to have been entirely correct, their response to this item in CPRRG-17 creates additional questions. Region IV stated that while the B&R procedure required quarterly blade checks, it df d not procedurally specify that documentation of such inspection was required. Such a pesition is not consistent with 10 CFR 50, Appendix B, Criterion XVII which implies that if the activity itself (eg., a blade inspection) affects quality, sufficient records shall be maintained to furnish evi-dence of such an activity. The philosophical arguments with regarc to
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ti .- (3.0 Continued) 30 Utd FEB 10 'syy the ACI-304 requirements, while having merit in determining the minor safety significance of this issue, do not reflect Region IV knowledge that ACI-301 provided the technical basis for the procedural requirement. Research of this issue from the standpoint of both the inspector and management appears to have some technical shortcomings. As posited in CPRRG-17, regional management viewed this issue as a weak violation. While they were technically and managerially correct, their logic in defending the correctness of their position subsequent to the issuance of OI 86-10 indicates a defensiveness with philosophical? weak-nesses. l i (, JI 3j;
j i l (3.0 Continued) 31 pgp y g 1
- 7. Failure of FSAR to Describe TUGC0 Records System
7.1 Background
The item was identified in 01 86-10 as 85-14/11, Issue 1. It was not a " highlighted" item in Attachment 1, Attachment MM to 01 86-10. 7.1.1 Summary of Issue The licensee's records management system uses several " interim" or tem- ) porary storage and processing facilities for handling records prior to their transfer to permanent (life of plant) storage facilities. The inspector asserted that the interim facilities: a) did not meet the li- l { censee's FSAR commitment to ANSI N45.2.9 and, b) were not otherwise ad-dre: sed oy the FSAR as exceptiens to commitments. The ir.spector relievec the above to cor stitute a failure of the licensee to revise the FSAR to describe current practices as required by 10 CFR 50.34(a)(7). The pro- , posed violation in Draft 1 of the report was downgraded by management to an unresolved item in Draft 2(a) of the report. 7.1.2 References
.1 CPSES Comoined IR 50-445/85-14/11
.E CPRRG-17, RIV Management Positions on Attachment MM, IR 85-14/11
,3 O! File 86-10
.4 CPSES FSAR, Section 17.1
.5 NUREG 0800, Standard Review Plan, Section 17
.6 Transcript, Investigative Interview, T Westerman, July 10-12, 1986
.7 Transcript, Investigative Interview, H. S. Phillips, March 19, 1986
.8 Mcmo, B. K. Grimes, DIE, to V. S. Noonan, NRR, January 15, 1985 0A Review, Commanche Peak (Att. 6 to CPRRG-17)
.9 TRT Results, Allegation AQ-45, Permanent Records Not Stored in a Fireproof Vault.
7.2 Independent Assessment of Insoettiori Fincina The review of reference .8 above established that tne FSAR met current standards of acceptability for licensing. Although some differences existed between tne FSAR description and licensee practice, the lack of specific ~ regulatory guidance and criteria appropriate to these observa-tions permits tne licensee substantial latitLde in the development of detailed procedures and practices. The lack cf available guidance /cri-teria also makes enforcement undesirable if not untenable in that the substance of the issues identified is not addressed by either the regu-lations or the SRP (reference .5). In this case, the questions of lic-encee program adequacy and specific requests / recommendation for reguia-tory guidance should have been appropriately forwarded to NRC HQ for action. Typically such an item would be carried as an open item for
?? O F E, i i' .
me - .J d d e
TA n p w
~ ~ ~ i (3.0 Continued)- 32 D 10 '9g tracking purposes. The item does not strictly meet the definition of an unresolved item in that the responses from NRC HQ would not likely result in enforcement action.
7.3 Analysis of RIV Otsposition 7.3.1 Statement of Inspector's Findings and Regulatory Concern The violation as initially written stated: " contrary to 10 CFR 50.34, FSAR Section 17 was not revised to describe and reflect aspects of the current GA record system, including satellite storage areas, the Interim Record Vault, Permanent Plant Record Vault, and the Procurement Records Storage Area." The inspector apparently believed that the level of pro-tection afforded records being processed through the temporary facilities to be inadequate aad cutsice the latitude permitted by CSAR 17.1.1.17, 7.3.2 Deveicoment of Finding How issue was researched and analyzed, including supportive bases; applicable documents con:ulted and by whom. Discuss appropriateness of documents reviewed. Development of this finding appeared inadequate, with respect to both the inspector and first line management. The inspector appears to contend that the interim facilities do not meet the commitment to ANSI N45.2.9. but provides no specific examples or evidence of same to support this item. Inspection hfstory per reference .9 in-dicates that this subject had been reviewed in depth and found ac-ceptable. In the absence of hard examples in the inspection report, no enforcement was appropriate. Investigative Interviews (reference
.6 and .7) indicate that much discussion revolved around the re-quirements for reference .4 provided by reference .5. At no time did any of the principals state affirmatively that they had reviewed the references and uncategorically knew what the requiremen'.s and guidance were. Further, while the investigative interviews indi-cate a general knowledge of the TRT findings (reference .9), none of tne parties appear to have specifically reviewed these findings o'. had a first hand knowledge of the basis of acceptance applied by the TRT. Additionally, the inspector's draft citation referenced the incorrect 10 CFR 50 section as noted by reference .2.
7.3.3 Characterization of Finding Inseector's apparent safety concern and Task Group's evaluation. No direct safety concern is apparent on the part of the inspector. He apparently believes the licensee did not meet minimum standards for recoru storage facilities which could.jeopardi:e quality records which could prevent substantiation of performancehharacteristics of quality activities and hardware. 7, 3 ~, ~r,.: I
' ' }
'(3.0 Continued) 33 %" -
RB 10198f . The Task Group concludes that essentially no safety significance can be attached to this item; however, potential major economic significance would occur should record reconstruction be necessary. The only element of safety significance would involve both the lic-ensee and NRC accepting less than optimum data / records due to the inability to reconstruct lost records to original quality. Should it have been pursued for more examples of programmatic sig-nificance; was it? The major potential programmatic significance is the acceptability of both the FSAR and the licensee's practices in light of the lic-ensing requirements with the IE QAB and NRR but this activity was interrupted by the ongoing investigation. Was it reasonable to ex;e:t farther undirec;=:. a: tion by tne re-porting inspectcrs? If yes, what action should have been taken? Yes. Neither the draft fnspection report nor the references provide specific examples which demonstrate noncompliance with the existin'g FSAR commitments or requirements, Although the report draft text i implies that the facilities do not comply with the FSAR commitments, apparently no evicence of substance was developed. 7.3.4 Timeliness l Was communication between inspectors. and RIV Management on final resolutions (in so far as an effective exchange of ideas) timely? Initial di:cussions between tne inspector and immediate supervision apparently occurred while the inspection was in progress (references
.6 and .7). This appears appropriate but was ineffective. The references, however, incicate that escalation through the Region IV management chain was handled routinely, with no highlighting of the contentious nature of the findings.
7.3.5 Nature of Downeradino of Insoection Findino as it aopeared ir Final Report with a Brief Statement of Manacement's Reasoning The proposed violation was downgraded to an unresolved item in tne final report. Management found tne downgrading appropriate (refer-ence .2) based upon the current NRC practice of not citing a licen-see for an inspector's perception that there was a failure to pre-vide an adequate description in the FSAR when that description had been previously reviewed by the NRC Staff and foend acceptable in an SSER. Management had, however, intended to refer the matter to NRC HQ for further review. Wm
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.a l
*=.s a) )
\ . (3.0 Continued) 34 .i bY i ,' ' a, , OB 0 f)g7 7.3.6 Management's Role in Achieving Final Disposition l Were management's actions sufficient to warrant downgrade? If yes, explain. Yes. Downgrade and proposed handling was consistent with past practices at Region IV and other Regional Offices. The inspector apparently accepted this position based on his personal revision (Report Draft la) and omission of this item from the inspector's listing of " highlighted" concerns. What further action should have been directed to proper resolution. The inspector implied inadequacy in the licensee's practices without specifyirg exam les. 3 <-cer to completely resolved the 2:cect-aoility, acciucnal insce:. tion should have been perf ormec .e assure that, at least, the level of records management documented in the TRT findings ws: maintained. 7.3.7 If Item was Determined to be Unresolved, was there Sufficient In-formation in the Insoection Report to Focus Activities of tne Licensee / Inspector t' Effective Resolution The final report ties resolution of this item to resolution of Item 8 below (regarding TUGC0 rewrite of QA procedures) but does not provide sufficient guidance as to the applicant's committed actions, those de-sired by Region IV, or the existence of the proposed regional referral to NRC HQ. From the Task Group's perspective, tnis item was erroneously classified as unresolved, since it is unlikely that any enforcement action would eventually result from HQ resolution. 7.4 Conclusions The finding as presented by the inspector was not supportec by eitner his development of specific examples Or sufficiently prescriptive regu- 4 latory criteria. The inspector also failed to recognize or acknowledge 4 the need for resolution of the licensing issues separately from any com-pliance issues. From a technical and enforcement perspective, regional management's down-grading of the item was appropriate. Issuance of the unresolved item was inappropriate because there was no potential for enforcement. As indicated in the OI investigative interviews, inspector-management interaction during tne development of this item was abrasive and con-tentious with neither party providing sufficient justification for their respective positions. Available options for management escalation were not exercised. W *\ T y?- f*e u'
. .a
19 !,l :14' (3.0 Continued) 35 h; 10 Iggy ' ~ -
- 8. 0A Manual Does Not Address ANSI N45.2.9 Requirements and Commitments 8.1 Background '
This item was identified in OI 86-10 as 85-14/11, issue 2. It was not a " highlighted" item in Attachment 1, Attachment MM to OI 86-10. 8.1.1 Summary of Issue i A violation was proposed by the inspector in the draft report (85-14/11) citing that the QA manual did not address certain provisions of ANSI N45.2.9 as committed by the FSAR. The violation was downgraded by man-agement in the final report to an unresolved item. 1 8.1.2 References
.I' CPSES Comoined IR-50-445/85-14/11
.2 CPRRG-17, RIV Management Positions on Attachment MM
.3 OI File 86-10, Page 14 4- CPSES FSAR, Section 17.1
.5 NUREG 0800, Standard Review Plan, Section 17
.6 Transcript, Investigative Interview, T. Westerman, July 10-12, 1986
.7 Transcript, Investigative Interview, H.S. Phillips, March 19, 1986
.8 Memo, ~B. K. Grimes, OIE, to V. S. Noonan, NRR, January 15, 1986, CA Review, Commanche Peak (Att. 6 to CPRRG-17)
.9 TRT Results, Allegation AQ-45, Permanent Records Not Stored in a Fireproof Vault
.10 CPPRG-16. Notes of H. Phillips
.11 TUGC0 Procedure CP-QP-18.4, Quality Assurance Record Receipt Control and Storage 8.2 Independent Assessment of Inspection Finding The finding identifies an omission of regulatory criteria (ANSI N45.2.9) from the facility QA Program procedures. The inspection, as documented, did not establisn with specific evidence or examples'whether the omis-sion(s) actually resultec in defects in program procedures and implemen-tation. Although seven topics of omission are documented, the inspection data identifies only one case which appears to have resulted in actual violation of functional records management requirements (failure to con-trol.offsite shipment of QA records). In that one case, the licensee had previously had an acceptabit: lower tier procedure but it had in-advertently been rescinded.
If equivalent lower tier procedures exist for the other omissions cited, enforcement action would be' inappropriate in that the NRC typically does not issue violations for editorial (non-functional) errors in procedures and programs. Reference .9 indicates that a substantial body of other _ _ _ _ _ _ _ - _ _ - _ _ _ _ - _ _ - - _ _ i
~(3.0 Continued) 36 'h. gj[7 f j R I O ?g7 , Records Management Manual (RMM) procedures exist and were found responsive to FSAR commitments. This inspection (85-14/11) is silent on review or adequacy of t:c RMM procedures. Without an assessment of those proce- ; dures, the apparat contradiction'of this findings with the acceptable ' findings of reference .9. cannot be resolved and the functional accept-ability of the licer see's prog am cannot be determined. J Therefore, the item it appropriately categorized as unresolved pending completion of an evaluation of the overall licensee procedures program to determine whether at editorial error existed or whether procedures failed to address the o .her six " missing" regulatory criteria. The Task Group arrived at this cenclusion as if they were in the supervisors position at the time the item was presented by the inspector. In reality, this item would never have become a point of discussion between inspector and managerert if the inspector Fad reviewed lower tier procedures to determine wnetner tne ragu'. ry criteria were accressed. If tney were, then an inspection finding . dressing the need for the licensee to ad-dress the editorial error would have been appropriate. 8.3 Analysis of RIV Disposition 8.3.1 Statement of Inspector's Finding and Reculatory Concern The inspector found that reference .11. did not include specific provi-sions of ANSI N45.2.9 committed by the FSAR. The provisions are related to other violations proposed by the inspector (Items 9-15 below). The inspector apparently viewed this item as a central issue to the licen-see's overall performance. 8.3.2 Development of Finding
- How was issue researched and analyzed, including supportive bases; apolicable documents consulted and by whom. Discuss appropriateness of documents reviewed.
The inspector's development of the finding appears to be a result of other related findings regarding the shipment and control of records and records facilities. Evidence exists that a substantial portion of the licensee's program represented by a Records Manage- , ment Manual (RMM, reviewed in Reference .9.) was not involved in I the research. Regional supervision appears to have relied on the precedent inspection by TRT as a primary basis for their decision. Neither party appears to have expanded the scope of the inspector's initial review to determine if the procedural omissions were func-tionally significant'or whether lower tier procedures provided equivalent guidance.
. e.
ehe l
T1 C' " (3.0 Continued) 37 Q(,kg ,j3j' 3 FEB 10 ngy 8.3.3 Characterization of Finding Inspector's apparent safety concern and Task Group's evaluation. No direct safety concern is apparent on the part of the inspector. He apparently believes the licensee did not address all committed minimum standards for record storage facilities which could jeopard-ize quality records which could prevent substantiation of perform-ance/ characteristics of quality activities and hardware. The Task Group concludes that there was negligible direct safety impact. This item is an editorial problem with no evidence of a programmatic implication. Should it have pursued for more examples of programmatic signifi-cance; was it? See Item 8.2 above. 8.3.4 Nature of Downgrading of Inspection Finding as it Acceared in Final Report witn Brief Statement of Management's Reasoning The proposed violation was downgraded to an unresolved item in the final report. Management's (reference 2.) basis was: 1) the inspector's find-ings were subjective and 2) were in conflict with the findings of refer-ente .9. The justification steted in the final inspection report was that the licensee was rewriting all of their QA manuals to improve their l written program and that the item would be reviewed as part of that activity. S.3.5 Manacement's Role in Achievino Final Disposition What further action should have been directed to ensure proper resolution. The documentation provided by the insp- tor did not evicence rigorous evaluation of both upper and lower ti<r procedures. As discussed above, regional management should have required either additional inspection or documentation of inspection already performed. Fur-ther, management's position did not acknowledge the relationship between this item, tne lower tier licensee procedures, and the other findings related to the omitted provisions of N45.2.9. Specific direction was warranted for further development of the issues. (Note that the related findings also cid not reference or discuss detailed implementing p'ocedures. ' _ _ _ _ - - - - - - - - - - - _ _ , _ _ _ _ _ _ _ _ _ _ _ _ _ - - - - - - - - - - " " - - - - - - - ~ - - - - - - - ' - - - - -
(3.0 Continued) 38 %P 1 p 8.3.6 If Item was Determined to be_ Unresolved, was there Sufficient In-formation in the Inspection Report to Focus Activities of tne Licensee /Insoector to Effective Resolution No. The inspection report does not reflect the actions considered necessary to resolve the item on the part of either the licensee or the NRC (i.e. at.the conclusion of the ongoing licensee QA manual re-write, that a determination would be made with respect to adequacy of the re-vised manuals and the overall program). 8.4 Conclusions i Downgrading of the item by management was appropriate based on the in-
. sufficient staff research and development with regard to the availability of related, lower tier crocedures/ implementation and relevant potential violations (Items 9-15 ceiow). The issue had potential for being tne
" root cause" of the several related implementation problems; however, this significance was apparently either ignored or missed with little evidence of either inspector or supervisor motivation to fully develop l the issues.
The on going effort by TUGC0 to revise the QA Manual bears significantly on this issue. Since there were no identified issues which suggested
. existing significant programmatic deficiencies, prudence would dictate that further in-depth inspection effort be delayed until the. review of the OA Manuals was completed. This was handled through the use of the unresolved item, although not effectively documented in the final in-spection report as-to what specifically was-required to resolve the item.
As noted in the independent assessment (8.2), the Task Group considers that this should never have become a point of contention. The inspectors
-were at fault for insufficiently developing the specifics of this issue; su;:ervision erred in not properly directing the inspectors to focus their attention to resolve the issue before final issuance of the report.
1
.a.
(3.0 Continued) 39 ,1 jf; ,j 49 y 9 9.0 Procedure Control of Offsite Shipment of Original Engineering /Derion Records-
'9.1 Background.
This item was identified in OI 86-10 as 85-14/11, Issue 3. -It was a highlighted item in Attachment 1, Attachment MM to 01 86-10.
'9.1.1- Summary of Issue A violation was issued in final Report 85-14/11 for failure to have/use procedures and Webster,to control shipment of single copy, original records to Stone N.Y. A prior procedure existed wMch controlled those activities,.but when an organizational re-alignment occurred, the prior procedure responsiblewas cancelled and never reissued with pertine.nce to the newly organization. This matter was the subject of erotracted ciscussion cetween inspector and management. In the final analysis, the violation was lef t to stand, but impacted on subsequent management de-cisions regarding issues 10 through 15 discussed below. It has continued-to be carried as a contested item, apparently because of its overall
~
pertinence to the records control issue. 9.1. :. Re' ferences
.1 CPSES Combined IR 50-445/85-14/11
.2
.3 CPRRG-17, RIV Management Positions on Attachment MM, IR 85-14/11-OI~ File 86-10 4
.5 Transcript, Investigative Interview, T Westerman, July 10-12, 1986
'. 6 Transcript, Investigative Interview, H.S. Phillies, March 19, 1986 TRT Results,
'Firsproof Allegation AQ-45, Permanent Records Not Stored in a Vault
.7 CPPRG-16, Notes of H. Phillips 9.2 Independent Assessment of Insoection Finding The violation is valid as written. The. fact that ANSI'N45.2.9 is silent on shioping records is pertinent only in that a formal regulatory posi-tion needs to oe formulated by NRC staff. The spirit of N45.2.9 is such that licensee prudence is dictated for undefined or ambiguous situations (i.e., controls to be exercised during transfer of records among organi-zations is addressed as a general line item).
9.3 Analysis of RIV Disposition 9.3.1 Statement of Insoector's Finding and Regulatory Concern TUGC0 failed to have/use procedures to control shipment of original records to SWEC. The inspector's regulatory concerns appeared to be ad-dressed by the immediate and followup Region IV action. However, the I OI interview results indicate that substantial effort was expended by his supervision to " talk him out" of this item. (Note that Phillip's I 4 rm - _ _
~.
(3.0 Continued) 40 h uhl )J 1 ATp , g %
- i
" matrix of draf ts", Attachment K to Reference .2, incorrectly indicates this item was downgraded to unresolved). The inspector further objected to editing the report narrative of statements regarding the licensee's desire to avoid costs by not copying / safeguarding the in transit records.
The record is inconclusive as to what TUGCO's management's actual posi-tion was on the cost issue. 9.3.2 Development of Finding This finding appears to have been developed via licensee interviews and the inspectr/'s procedure reviews and is reasonably founded. The in-spector determined that the absence of procedure was due to inadvertent deletion of the previously available procedure as a result of a licensee reorganization. The report implies but does not state that the former procedure was adequate. 9.3.3 Characterization of Finding Inspector's apparent safety concern and Task Group's evaluation. Original single copy design records were being shippea from Texas to New York to support a major reanalysis effort. Loss of records would have substantially recucec tne confidence level in the cata available for reanalysis. The Task Group conclude. that essentially no safety significance can be attached to this item: however, potential major economic significance would occur should record reconstruction be necessary. The only element of safety significance would involve both the licensee and NRC accepting less than optimum data / records due to the inability to reconstruct lost records to original quality. Should it have been pursued for more examples of programmatic sig-nificance; was it? Development of related issues are discussed separately in Items 10-15 herein. 9.3.4 Timeliness Was communication between inspectors and RI V Management on final resolu-tions. Although it appears that some contenticas remained active between the inspector and his management following the end of the inspection, it appears that Region IV took effective, immediate action to terminate record shipments and obtain licensee action to correct the identified situation. The remaining contentions (Items 10 to 15) involve the de-tailed content of the issues, not the overall validity of the issues, e.g. , the licensee's motivation for <ot dupli:ating shipped recorcs, the cefinition of a final vs. in pror ?ss Pecord, etc. M ?~m
-?.J
_ _ _ _ _ _ _ - _ _ - - _ _ - _ _ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ---- ~--~----~--~-~ ~ ~ ~
'(3.0 Continued) 41 ') L d FG-16 g q
, 1 9.3.5 Nature of Downgrading of Insoection Finding as it Aopeared in Final Report with a Brief Statement of Management's Reasoning This enforcement item was not downgraded. However, it does appear that management. issued this violation as the essence of the various issues identified in Items 10-15, thereby supporting their position for down-grading the other items. -
9.4 Conclusions The violation as written, was issued in the final report. There is no safety significance or unresolved concerns that remain outstanding. However, this item is indicative of the considerable interface diffi-culties that existed between inspectors and regional me a;e ent. mn o l c _ - - - - - - - _ - - . - -
l (3.0 Continued) 42 T.:h:N
.n; i g ',
567 10.0 Original Oesign Records Shipped in Cardboard Boxes to SWEC. 11.0 No Backup Copy of Records Shipped in Cardboard Bcxes to SWEC. 12.0 Failure to Control and Account for Records Shipped to SWEC. i l 10/11/12.1 Background These items were identified in OI 86-10, as Issues 4, 5, and 6. They were " highlighted" items in Attachment 1, Attachment MM to 01 86-10. Items 10,11,12 have been grouped together due to their similarities. I 10/11/12.1.1 Summary of Issue These three issues as stated above, are the purported implementation failures resulting from Issue 9 above (Inspection Report 85-14/11). They represent the specific aspects of the licensee's failure to safeguard to records highlighted by the inspectors. The inspector (and a consult-ant) asserted that the records in transit required protection and ac- I 3 countability commensurate with the requirements of ANSI N45.2.9 and, based on statements attributed to licensee staff members, considered the
'icensee to have overtly pe-mitted shipment of the records without proper safeguarcs to avoic tne costs involved with providing such safeguards.
The inspector further asserts during the OI 86-10 testimony that his direct supervisor deleted enforcement actions and pertinent detail from the inspection report and protractedly harassed and badgered the inspec-tor in an attempt to suppress the inspection findings, . j 10/11/12.1.2 References i
.1 CPSES Combined IR 50-445/85-14/11
.2 CPRRG-17, RI V Management Dositions on Attachment MM,
.3 OI File 86-10 !
i
.4 Transcript, Investigative Interview, 7 Westerman, July 10-12, 1986
.5 l Transcript, Investigative Interview, H.S. Phillips, March 19, 1986 !
.6 Transcript, Investigative Interview, J. Gilray, July 17, 1986 l 10/11/12.2 Independent Assessment of Inspection Fincing These potential enforcement items are resultants of the licensee's fail- !
ure to have/use a procedure for control of the shipments as cited in the l violation discussed in Item 9 above. On the basis that Item 9 was the ! subject of an issued violation, issuance of a separate violation for l these items is inappropriate and contrary to normal practice. ine cause- I effect relationship of the failure to apply a control procedure resulting in the above deficiencies should have been incorporated, by citation of these examples, in the violation for Itsm 9 to ensure that the licensee understands and responds to the entire problem. 1 I 5 una
(3.0 Continued) 43 h3M j$Lj
% 2 0 1987 10/11/12.3 Analysis of RIV Disposition 10/11/12.3.1 Statement of Inspector's Finding and Regulatory Concern The inspector found that the licensee had not applied sufficient controls to the shipment of records to SWEC to safeguard the information' from loss or damage. The cause of insuffi.cient control was the absence of~a lic-ensee procedure discussed in Item 9 above. The specific shortcomings identified by Items 10-12 were failure to provide for inventory / account-ability, shipment in containers which afforded minimal protection, and failure to provide duplicate copies to act as replacements if the shipped records were lost. Note that the findings represent the inspector's opinion of the deficient conditions; no specific regulatory criteria exist. The underlying inspector concerns, which became inspector / man-agement contentions, involved the inspector's perception that the licen-see-intentionally failed to safeguard the records and assumed the risk of their loss as an' acceptable alternative to the costs associated with ,
providing the safeguards. Relevant draft narrative on these subjects was deleted from the final report. 10/11/12.3.2 Development of Finding The research and analysis of this issue during the inspection and report preparati_on appears to be erratic. The inspector's report draft provides a reasonable presentation of the problem notwithstanding the potentially volatile and possibly hearsay statements attributed to licensee personnel regarding the licensee's actions ud motivation for not safeguarding the records. However, the draft violations proposed in the report narrative lack specific citation of regulatory requirements, applicable licensee program requirements, and licensee procedures. Further, no acknowledge-ment is made of the cause-effect relationship with Issue 9 above. Followup of the finding by the inspector's supervisor also appears er-ratic and directed at synthesizing his position regarding the ANSI standard which was aimed at suppressing the enforcement'value of these issues and Issue 9 above. Reference 4 provides substantial discussion of supervision's rationale and actions. The espoused positions appear both superficial and specious. Although additional NRC:HQ support was sought by telephone (Reference .6), available evidence indicates that the consultation was quite informal and generalized. 10/11/12.3.3 Characterization of Finding Inspector's apparent safety concern and Task Group's evaluation. No direct safety concern is apparent on the part of the inspector. He apparently believes the licensee (and a contractor) did not meet , minimum standards for record shipments could jeopardize quality ' records which could prevent substantiation of performance /charac-teristics of quality activities and hardware. ; i e
1 p (3.0 Continued) 44 .
.sj y;[ .;
rTF 101987 The Task Group concludes that essentially no safety significance can be attached to this item; however, potential major economic significance would occur should record reconstruction be necessary. The only element of safety significance would involve both the licensee and NRC accepting less than optimum data / records due to the inability to reconstruct lost records to original quality. Should it have been pursued for more examples of programmatic sig-nificance; was it? Additional development of the issues appears unnecessary except to the extent to incorporate the issues by example into the violation of' Issue 9 above as stated in the Independent Assessment. 10/11/12.3.4 Nature of Downgrading of Inspection Finding as it Apoeared in Final Report with a Brief Statement of Management's Reasoning All of the items were dropped frem the report (sequence provided in reference .2). Region IV management considered the violation issued per Item 9 bounded each of the issues 10-12. Further, management's position in reference .2 implied that the absence of' specific regulatory require-ments/ guidance also bore on their position. 10/11/12.3.5 Management's Role in Achieving Final Disposition Were management's actions sufficient to warrant downgrade? If yes, explain. Althougn some of the regional management positions presented in references .2 and .4 are rather shallow, the underlying principles discussed above (lack of regulatory guidance / specific requirements, root cause identification, etc.) remain valid. It appears that middle management struggled to elaborate on a basically sound posi-tion when it was unnecessary. , 10/11/12.4 Conclusions Regional management handling of the technical and enforcement issues was consistent with the Task Group assessment except that these items were not sufficiently linked to the root cause finding (Item 9) to ensure comprehensive corrective and preventive action by the licensce. Incor-poration of these issues as examples of the violation issued under Item 9 would have accomplished this. The more significant issues are again the interaction between the inspector and his management. The Task Group found the amount of time spent by all parties concerned debating the issues discussed here to be disproportionate when viewed from the per-spective of-the low potential safety significance of the issues involved.
% .h[P ALh l !
L
/
-(3.0 Continued) 45 L'a D D L 13.
EP ! i @ Site Records of Chicago Bridge and Iron Shipoed to Houston, Texas in Cardboard Boxes
'14. No Backuo Copy of Records Shipped to Chicago Bridge and Iron
- 15. Failure to Inventory Records Sent to Chicago Bridge and Iron 13/14/15.1 Background l
l These items were identified in 01 86-10 as Issues 7-9. They were "high-lighted" items in Attachment 1, Attachment MM to 0I 86-10. Items 13, 14, and 15 have been combined because of their similarity. 13/14/15.1.1 F --=-" of Issue As documented in inspection Re;,cr . 65-14. H, Cn cago E 1cge anc Iron (CBI) erected the CP Unit 2 containment liner as a subcontractor to the construction manager, Brown & Root (B&R). As a result of an inspection several months earlier, the inspectors became aware of an offsite ship-ment of records similar to those discussed in Items 9-12. The original CSI containment construction records were shipped from the site to the CBI Houston offices in accordance with CBI's nuclear records precedures. The inspectors asserted that the records should have been handled in accordance with TUGC0 procedures, inventoried and afforded protection in transit equal to temporary storage requirements of the TUGC0 QA pro-gram or that backup, duplicate records be maintained (at the site). These findings were proposed as additional examples of the proposed violations of Items 10-12. The findings were downgraded by management under protest from the inspectors. 13/14/15.1.2 References
.1 CPSES Combined IR 50-445/85-14/11
.2 CPRRG-17, RIV Management Positions on Attacnment MM
.3 01 File 86-10
.4 Transcript, Investigative Interview, T Westerman, July 10-12, 1956
.5 Transcript, Investigative Interview, H.S. Phillips, March 19, 1986 13/14/15.2 Independent Assessment of Inspection Finding The key aspects of these issues are: 1) did TUGC0 fulfill its QA re-sponsibility for the records shipment; 2) did CBI fulfill the require-ments specific to their TUGCD/B&R approved QA program; and 3) were both the TUGC0 and CBI programs responsive to ANSI N45.2.9 as implemented by the FSAR?
First, as a subcontractor, CBI was operating under its own QA program within the umbrella of the B&R and TUGC0 OA programs and the FSAR. Duplication of administrative controls by TUGC0 such as those desired 2*. r ,, ?# l
pa :. 1,,
. 6m (3.0 Continued) 46 E U
% 1 0 1987 .)
by the inspectors (application of TUGC0 procedures, inventory, etc.) is not required if the TUGC0 and B&R vendor surveillance and control pro-grams are in effect. With no evidence to the contrary, CBI had been found to have an acceptably established and implemented QA program by the lic-ensee. Prior TUGC0 audits of CBI activities documented acceptable CBI performance (see Item 16 below). Further, the CBI program, as approved by the applicant, provided for CBI to retain custody of the records until a point of reasonable project completion. Regardless of the considera-tion of " ownership" or owner subcontractor relationships, the applicable procedures clearly held CBI responsible for the custody of the records until the time of turnover. Second, the draft inspection report identifies no CBI noncompliance with its procedures (to the extent observed and/or documented by the inspec-tors). l l l Third, notwithstanding the above, the regulatory requirements and guid- I ance available for records in transit has been identified throughout the l investigative process as general, weak, and ambiguous. In conjunction l with Item 9, regional management initiated a referral of this general subject to NRC HQ for elaboration. Except as furtner discussed in Items 9 above and 15 below, no enforcement action: or unresolved items are considered appropriate. 13/14/15.3 Analysis of RIV Disposition 13/14/15.3.1 Statement of Inscector's Findino and Regulatory Concern The inspector considered that the licensee had not applied sufficient controls to tne CBI shipment of records to safeguard the information from loss or damage. The cause of insufficient control was the absence of a licensee procecure discussed in Item 9 above and TUGCO's failure to directly participate in the activity. The underlying inspector concerns which became inspector / management contentions again involved the inspec-tor's perception that the licensee intentionally failed to safeguard the recorcs and assumed the risk of their loss as an acceptable alternative to the costs associated with providing the safeguards and the magnitude of the potential records loss. Relevant draft narrative on these sub-jects was edited from the final report. 13/14/15.3.2 Development of Finding The initial draft inspection report indicates that the inspectors con-ductec multiple procedure reviews and personnel interviews to research these items. Except for an apparent refusal to accept the concept of CBI's responsibility for custody and turnover of the records, tne span of the inspection, as documented appears reasonable. M i i'"'
(3.0 Continued) 47 -;Yra> r, . s L'I 3 ! @ 1 0 13a7 If accurate, the initial draft text leads the reader to the conclusion that the inspectors were contacting various site organizations' QA and engineering staffs, searching for agreement with their assessment of an inadequate CBI records management program and TUGCO's failure to assume responsibility for the containment records. Followup of the finding by the inspector's supervisor also appears er-ratic and directed at synthesizing positions re the ANSI standard aimed at suppressing the enforcement value of these issues and Issues 8-12 above. Reference .4 provides substantial discussion of supervision's rationale and actions. The espoused positions appear both superficial and specious. Although additional NRC HQ support was sought _by telephone (Reference .6), available evidence indicates that the consultation was quite informal and generalized. M . , 3.1.3 t _:.eri m '.e e# I'*:'. ; Inspector's apparent safety concern and Task Group's evaluation. No direct safety concern is apparent on the part of the inspector. He apparently believes the licensee (and a contractor) did not meet rRinimum standards for records shipments could jeopardize quality records which could prevent substantiation of performance /charac-teristics of quality activities and hardware. The Task Group concludes that essentially no safety significance can be attached to this item; however, potential major economic significance would occur should record reconstruction be necessary. The only element of safety significance would involve both the licensee and NRC accepting less than optimum cata/ records due to the inability to reconstruct lost records to original quality. Should the item have been pursued for more examples of programmatic significance; was it? Additional deveicoment of the issues appears unnecessary. See in-dependent assessment above. 13/14/15.3.4 Nature of Downoracing of Inspection Finding as it Acceared in I Final Repcrt with a Brief Statement of Manacement's Reasoning Item 13 was dropped as a violation; Item 14 was dropped as a violation but left as an unresolved item pending demonstration by TUGC0 that CBI { record controls were implemented; and, Item 15 was dropped as a violation but left as an open item pending Region IV inspection of TUGCO's eventual receipt of CBI recorcs. The narrative report text was also condensed by Region IV management. Pg q7*" i J l
(3.0 Continued) BIR 9.N 4 48 19e muo. r 1 Rg 10 yg } Management's rationale for the technical acceptability of these items was CBI's explicit responsibility for custody and maintenance of the records per their and the applicant's QA program (See 13.2 above) and the unresolved status of regulatory criteria to be applied to records in transit also previously discussed. 13/14/15.3.5 Manacement's Role in Achieving Final Disposition Were management's actions sufficient to warrant downgrade? If yes, explain. Items 13-15 were developed by the inspector based on his perception of the regulatory requirements (which were ambiguous but explicitly addressed by CSI's procedures). Management's rational e #:- cu - grading addressed the salient points of the issue but - .- more conservat ,e tnan pernaps necessary. Items 14 and 15 were downgraded to unresolved items requiring fol-lowup of implementation of the CBI and TUGC0 QA programs and final records transfer to TUGCO. The inspection results do not warrant extensive followup unless other concerns were identified but not documented by the principals. 13/14/15.3.6 If Item was Determined to be Unresolved, was there Sufficient i Information in the Insoection Reoort to Focus Activities of l the Licensee / Inspector to Effective Resolution ' The final report distilled the issues down to two brief paragraphs, each addressing one of the unresolved items. The report does not provide any sensitivity to the inspector's original concerns nor the reinspection perspective desired by regional management. 13/14/15.4 Conclusions Regional management's handling of the technical and enforcement issues was consistent, and in some cases, more conservative and resource inten-sive than the independent assessment of this Task Group. Regional management currently overruled the inspector's contention that TUGC0 had direct responsibility for " supervising" their subcontractor's sctivities in lieu of QA Program overview. Further, the existence and application of a detailed, reasonably prudent CBI procedure in the ab-sence of specific regulatory requirements appears to have been recognized by regional management. The downgrading of alleged violations of failure to inventory records snipped, failure to provide backup copics, and shipping in inappropriate boxes were intrinsic results of that assessment. 7"B O N hj3 j
3 8'ii: F "" b'E N[,l 7 (3.0 Continued) 49 - FEB 101987
-16. TUGC0 Did Not Document Audit of CBI Records 16.1 Backgr,ound This item was identified in 01 86-10 as 85-14/11, Issue 10. It was not a " highlighted" item in Attachment 1, Attachment MM to 01 86-10.
16.1.1 Summary of Issue In conjunction with inspection of Items 13-15 above, the inspector re-viewed portions of the licensee's vendor audit program applied to. Chicago Bridge and Iron (CBI). The text of the initial draft inspection report implies that the inspector was attempting to obtain additional assurance that the CBI records management program was functioning acceptably ~as determined by the licensee in his audit of CBI activities. One of the two TUGC0 QA audit summary reports reviewed stated, in the " Audit Scope," that QA records activities were one of numerous area auditec; nowever, no documentation of the records audit activities was provided in tne narrative " Audit Summary" portion of the report. I The inspector telephoned the corporate (HQ) audit group to determine the. reason for the omission from the audit report as well as obtain addi-tional information regarding the adequacy of the CBI records program. The draf t report (85-14/11) indicates that no responsive information was obtained and a violation was proposed for the failure to adequately document the audit results. The proposed violation was downgraded by management to an unresolved item in draft 3a of the inspection, and eventually eliminated from draft 4a of the report (ostensibly by the inspector, per reference .2). The final report did not discuss the issue. Subsequently, the inspector's supervisor contacted the licensee who pro-vided reference .8 defining the scope of records audit activities con-ducted. 16.1.2 References
.1 CPSES Combined Inspection Report 50-445/85-14/11.
.2 CPRRG-17, RIV Management Positions on Attachment MM. d
.3 OI ,'ile 86-10, Page 14. j
.4 Transcript, Investigative Interview, T. Westerman, July 10-12, 1986. j
.5 Transcript, Investigative Interview, H. S Phillips, March 19, 1986.
.6 CPRRG-17, Atta:hment'15, TUGC0 Audit Summary Report TCB-6, CBI Audit.
.7 CPRRG-16, Notes of H. Phillips.
.8 CPRRG-17, Attachment 16, TUGC0 Speedletter Memo, Clarification of CBI Audit TCB-6 Criterion XVII Record, 1/9/86.
16.2 Independent Assessment Typically, audit summary reports such as reference .6 are succinct and brief. No adverse findings were identified during the audit in question and the report is an executive summary (a 4-8 line paragraph for each ; L
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i jr+4 .a* ;,
(3.0 Continued) b.n?fY 50 N: i C gg7 tion's tranagement. audit scope area) provided for the such a report has littl e audited organiza-documentation; however,e bearing on p s fr paration of the final report.it does indicate a certain carelessn pre-to. Quality or recommendations for improrep n unless conditions adverse identified in the omitted portions vement requiring action were In addition to the inspector identified omissi, w ment document control was also omitted . on, discussion of procure-These anomalies were not identifiedlisted Further procedure control, not in t tional minor discrepancies such asthe thesereporting inspector.ts Acdi-own do n:- evaluate the adequacy of audit cn. documentat In order to fully audit file including the audit checklist , as a minimum, the cetailed and the auditors conclusions must be reviewed i, results audit program requirements and implementing proced n light of the licensee's was not done st.perficial by the reporting inspector review. n adi ures. This apparently s indicative of a somewhat 16.3 Analysis of RIV Disposition 16.3.1 Statement of Inspector's Findings and Recul atory Concern See 16.1.1 above for statement of finding inferred from the draft inspection report . The inspector's conce
,that applied CBI's to CBI records management activities.13-15 above and 3rogram that thewas was tems TUG 16.3.2 was not effective as it Develcoment of Findinq_
junction with Items 13-15.The inspector appeared to co criteria for the inspection. No evidence audit program exists that a rev requirements o identified by the inspector, Further, when similar discrepthe initial discrepanc j andduring tion only the minimal effort inspection. was made toancies obtain wereadditi missed or ignored ! the inspection to support a violation Insufficient basis existed at the to visit the Callas, Texasresolved, TUGO offices fAfter m the insoector plarr.sd No additional agement. followup is evident except or followup sn(reference .2). the report prior to firal issueReference .2 further indicates th the licensee's audit records,exist. seemed even toThestillwas though questions report about i For example, the F. .,.
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-(3.0 Continued)
OMf ' I: 51 FEB 1b hl supervisor received reference .8 sometime in January,1986 time frame. No one has yet verified that the licensee actually has the detailed audit records required. 4 16.3.3 Characterization of Finding Inspector's apparent safety crneern and Task Group's evaluation.. The omission of the records tranagement area audit summary paragraph represented a potential progr ammatic breakdown which evidences TUGCO's lack of control over contractors. Those (that) contractor (s) i had allegedly abrogated their records management responsibilities and therefore jeopardized the availability of records necessary to substantiate the performano characteristics of quality activities and hardware. ; The Task Group concluded that there is not apparent safety signifi-cance to this item since the audit findings did not icentify any condition adverse to quality. The comments missing from the report ostensibly addressed areas inspected, not deficiencies. 16,3.4 Nature of Downgrading of Insoection Finding as it Acceared in Final Report with a Brief Statement of Management The item was downgraded from a violation to an unresolved item pending "further followup," Reference .2 states that the functional impact of the. finding was " moot" in that no adverse findings were identified by the audit and that additional inspection of the matter was necessary. 16.3.5 Management's Role in Achieving Final Disposition Were management's actions sufficient to warrant downgrade? If yes, explain. The Task Group's opinion is that this item did not meet tne criteria for an unresolved item. The discrepancy was so minor that a viola-tion could not have been justified unless significant audit findings were omitted, which was apparently not the case. 16.3.6 If Item was Determined to be Unresolved, Was There Sufficient In-formation in the Inspection Report to Focus Activities of the Lice _nsee/ Inspector to Ef feet Resolution This is not applicable, because, although the item was initially categorized as unresolved, it was dropped before the final report was issued. l
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.(3.0 Continued) 52
.TB 101987 -
16.4 Conclusion Even if fully developed, this finding has negligible safety significance and appears to be an attempt by the inspector to cast doubt on the ef-festiveness of CBI's ~and TUGCO's OA programs in support of other issues (9-15). Even considering its minor, paperwork oriented nature, both regional management and the inspector were delinquent in not completing all inspection necessary to completely disposition the item during the inspection. This item appears to have been handled as part of the group of items 7-15 and was therefore part of the protracted contentions between the inspec-tor and his supervisor. The total deletion of the'ilem from the report without the apparent awareness of regional management is cause for con-cern about the effectiveness and candor of the involved parties. Al-though reference 16.1.2 asserts that tl.e inspector apparen:.iy cele.ed the item, the conclusion could not be corroborated since this issue is not pursued in other OI interviews.
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. m
. E (3.0 Continued) 53 1M WB 101937 17.0 Failure to Preclude Rain from Entering QA Intermediate l'icords Vault 18.0 Failure to Preclude Food and Coffee Pot from OA Intermediate Records Vault 17/18.1 Background These items were identified in 01 86-10 as 85-14/11, Issues 11 and 12.
They were " highlighted" items in Attachment 1, Attachment MM to 01 86-10. 17/18.1.1 Summary of Issue The interim or intermediate record vault is an area within the permanent clant record vault, separated from the permanent vault by a wall. Water leaking through the ventilation system was obsened in a container and the relative humidity had been recorded as abnormally high for about a week. Vault personnel reportedly indicated the roof and vent system had been leaking for about two years. The inspectors also coserved a coffee ' pot, sugar and food crumbs in the vault area. The inspector proposed a violation citing the above as two examples of inacequate protection of records. In the final inspection report (85-14/11), the violation was downgraded by management to an unresolved item for the water leakage. The second example was downgraced to a routine inspection observation based upon the spot corrective ction by the licensee. 17/18.1.2 References
.1 CPSES Combined IR 50-445/85-14/11
.2 CPRRG-17, RI V Management Positions on Attachment MM
.3 OI File 86-10
.4 Transcript, Investigative Interview, T Westerman, July 10-12, 1986
.5 Transcript, Investigative Interview, H.S. Phillips, March 19, 1956 17/18.2 Incecencent Assessment of Inscection Finding The water inleakage had apparently been a chronic problem with periodic licensee attention required and provided. Unconfirmed statements mace by vault personnel indicate that the leak had persisted for "more than two years" Although the draft inspection report does not mention it, reference .2 indicates that steps were being taken to reseal the ventila-tion system and that no records damage had occurred. Additional licensee attention to the matter is indicated by the statement in reference .2 that the licensee had previously replaced the entire roof. No assessment was provicec by the report or the references as to the true exposure of records to the leakage nor the timeliness and vigor of the licensee's remedial measures. Even though a problem may be chronic and resistant to licensee actions, those f actors do not necessarily warrant enforcement action if the licensee's actions are prudent or the actual / potential consequences of the problem are insignificant. Therefore, without acci-
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i /
(3.0 Continued) 54 h)3Q MJj ; FE510 m tional assessment of the licensee's aggressiveness in pursuing the prob-lem, enforcement action is inappropriate. An unresolved item should have been issued to further evaluate the effectiveness cf the licensee's past and current efforts and results. There was the potential for a citation based on past ineffective corrective action to correct the persistent leakage. The food and coffee pot issue represents a minor violation of the prin-ciples of ANSI N45'.2.9 and therefore could be an enforceable violation as a procedural inadequacy. However, the licensee took immediate cor-rective action to have the offending items removed. NRC practice permits such items to be documented as observations in inspection reports without enforcement action if they are of minor safety significance and the lic-ensee's actions are comprehensive and effective. The Task Group con-siders this course of action prudent in this case. However, further action appeared necessary to prevent recurrence, e.g. , veri'ication by the inspectors that procedures prohibited such practices, that personnel were aware of the prohibition, etc. An unresolved item is considered inappropriate in this instance since the decision not to cite this as a violation would not be changed by any later developed information. However, the inspector should have followed-up on the continued adequacy of the corrective actions in a later inspection. An open item, subject to tracking, would provide a mechanism for inspector follow. , i 17/18.3 Analysis of Region IV Disposition 17/18.3.1 Statement of Inspector's Finding and Regulatory Concern The inspector concluced that: chronic water leakage into the vault had not received adequate licensee remedial action (over a several year period); foodstuffs found in the vault could attract rodents; and, a coffee pot in the vault represented a fire hazard. Eacn of these items were considered an example of failure to protect CA records in violation of Appendix B, Criterion XVII. The inspectors regulatory concerr., in addition to those represented above, appeared to follow the general line represented by the prior items in-volving records, i.e., the licensee's records management program was in-effectively implemented and records were at risk. 17/18.3.2 Development of Finding As in previous examples, the regulatory aspects of the findings are relatively simple but the corroborating information is weak with respect to permitting evaluation of licensee actions and enforcement action (See 17.2 above). Essentially no development of specific site procedure re-quirements (or inadequacies) is provided. Again, both the inspector and his supervision were delinquent in thoroughness of either inspection, documentation or both. y3 ;-
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P^ A .4 "m (3.0 Continued) 55 L- ' W .1.0 $)
?EB 10 E67 17/18.3.3 Characterize., den of Finding Inspector's apparent safety concern and Task Group's evaluation.
No direct safety concern is apparent on the part of the inspector. He found that the licensee did not meet minimum standards for record storage facilities and thereby was jeopardizing quality records which could prevent substantiation of performance /characteris*'cs of quality activities and hardware. The Task Group concludes that essentially no safety significance can be attached to this item; however, potential major economic significance would occur should record reconstruction be necessary. The only element of safety significance would involve both the licensee and NRC accepting less than optimum data / records due to the inability to recons'ruct lost records to original quality. Should it have been pursued for more examples of programmatic sig-nificance; was it? Except to the extent that the inspector did not address the adequacy and vigor of the licensee's prior actions and the controlling pro-cecures, no programmatic implications are evident. Was it reasonable to expect further undirected action by the re-porting inspectors? If yes, what action should have been taken. As in previous examples the inspector's development of the issues was superficial as discussed in 17.3.2, 17/18.3.4 Nature of Downgrading of Inspection Finding as it Appeared in the Final Reoort with a Brief Statement of Management's Reasoning See 17.1.1 above. With respect to water inleakage, d%nagement determined that licensee action was reasonaole and no damage had occurred to recorcs. The food / fire hazard issue was found acceptable based on immeciate lic-ensee ccrrective action. 17/18.3.5 Manacement's Role in Achieving Final Disposition Were management's actions sufficient to warrant downgrade? If not, what further action should have been directed to proper resolution. The actions for the water inleakage item was appropriate for tne status of the item at the close of inspection. See 17.3.2, re: rodent / fire hazards and adequacy of the licensee's program. s cm i'
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f% .Xp (3.0 Continued) 56 ! ) LL;d;p t TEB 1013e! i l 17/18.3.6 If Item was Determined to be Unresolved, was there Sufficient In format _ ion in the Inspection Report to Focus Activities of the = Licensee /Insoector to Effective Resolution The final report does not cor.tain sufficient information to characteri:e the unresolved item on water leakage. Additional guidance should have taeen provided in the inspection report to indicate what action was necessary to resolve the item. 7.4 Conclusions m. Regional management's handling was reasonably consistent with the Task Group's independent assessment except for the rigor applied to the fol- l lowup of unresolved items. In particular, insuffi-ient followuo was ' ) applied to the acecuacy of the licensee's existing procedures and pre-ventive actions. Tne inspector's development of the issues was again superficial with an overly aggressive enforcement posture appliec to situations with little or no safety and regulatory and regulatory justi-fication. ge d see 88 O m _ _ _ _ - _ - _ _ ___ _ _ _ - - . - - - - - - . - - - - - - - . - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ^ ~ ~ - '~- ~ ~ ~ ^'~ '~ ~~~
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{ - (3.0 Continued) 57 n - .s? & g ; , ,g
- 19. Failure to Install Fire Suppression System, Drains, and a Sloped Floor at Records Center i
- 20. Plant Records Stand in Folders or Binders in Open Cabinets at Records Center 19/20.1 Summary of Issue The issues as stated in reference .3 are misstated with respect to the items asReport spection written85-14/11).
in the draft and final versions of reference .1 (In~ { Two issues were actually addressed by Item 19 involving two different vault facilities. Issue 20 was a part of 19 throughout the multiple draft inspection reports prrmared. FSAR Section 17.1.17 states that the records storage facility will have L dry chemical or gas fire extinguishers provided (not a suppression system). Section 5.6 of ANSI N45.2.9 (1973 version endorsed by the FSAR) requires that a dry chemical or gas fire suppression system be proviced. A 1974 7 version of ANSI N45.2.9 applicable to the operations phase per FSAR Sec-tion 17.2.16 requires that an " adequate system" be provided. The report and reference .7 are silent on the distinction between the construction phase and operating phase requirements and how they applied to the per-manent and non permanent facilities, indicating that the inspector was either unaware of or ignored the distinctions. The initial draft report proposes a deviation from the above requirements be issued for the use of a water sprinkler system instead of a dry chemi-- ; cal or gas fire suppression system in the TUGC0 Records Center. An in-termediate draft also identified the absence of a sloped floor or drain as a flooding hazard during sprinkler operation. The final draft report downgraded the sprinkler issue to an unresolved item, deleted references to the floor slope / drain aspect, and combined the concern about records stored in open shelves / cabinets with the unresolved item. Note that the open files issue, Item 20 was never a separate finding in the initial draft of tne report. It is being tracked here to rigorously resolve items identified in OI 86-10. Another aspect. discussed in the interim draf t report (1b) identifiec the ! use of fire extinguishers and an exterior hose station in lieu of an in-stalled system for the permanent plant records vault to be a deviation , 1 with respect to the commitment to N45.2.9. The final report discussed the potential deviation, identified the conflict between N45.2.9 the NRC approved FSAR, and downgraded the item to unresolved pending referral of the issue to IE:HQ. l 19/20.1.2 References i
.1 CPSES Combined Inspection Report 50-445/85-14/11 l
.2 CPRRG-17, Region IV Management Positions on Attachment MM
.3 OI File 86-10
.4 CPSES F3AR, Section 17.1 l
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% ~r ?
L.... l I
(3.0 Continued) 58 neb gye FE5 10 198-
.5 NUREG-0800, Standard Review Plan, Section 17
.6 Transcript, Investigative Interview, T. Westerman, July 10-12, 1936
.7 Transcript, Investigative Interview, H. S. Phillips, March 19, 1986 19/20.2 Independent Assessment of Inspection Finding Although the first finding (water fire suppression) above is a support-able deviation from the construction phase licensee commitments and FSAR, enforcement is inappropriate in light of the operations phase commitment to the most recent NRC endorsements of N45.2.9-1974 via Regulatory Guide 1.88 (which specifies only an " adequate" system). Nothing in those docu-ments nor reference .5 prohibits the use of sprinkler systems. Reference
.5 and the standards recommend against open shelf storage of records but NFPA 232, also endorsed by the Regulatory Guide permits it if the records are bound. It is apparent, however, that a routine revision of the FSAR and submittal to NRC per 10 CFR 50.34 is warrante: to account for tne differences between the facility and its description in the FSAR. A ,
licensee commitment to thi: effect should be tracked via an open item. l Similarly, the description in the FSAR deviates substantially from the standards and reference .5 with respect to the use of fire extinguishers versus an installed system in the permanent plant records vault. This item should be referrec to NRC:HQ by regional management and tracked via 1 an open item. The licensee subsequently found that the floor of this latter facility was, in fact, sufficiently sloped to permit fire hose runoff (reference
.2). A routine inspection observation should have been recorded.
19/20.3 Analysis of RIV Disposition 19/20.3.1 Statement of Inspector's Findino and Regulatory Concern See item 17.1.1 above. The inspectors regulatory concern in addition to those represented above appeared to follow the general line repre-sented by the prior items involving recorcs, i .e. , tne licensee's reco-ds management program was inef fectively implemented and records were at risk. 19/20.3.2 Develeoment of Findinc The inspector's initial development of the finding was simplistic but basically adecuate. As the draft reports were developed in sequence, additional aspects were added which contributed to the issues but were
,again presented rather simp fistically. Again, the inspector appeared to take a very aggressive enforcement posture where a functional problem was either not evident or of little quality significance. Otner routine interaction with the licensee and NRC management would have sufficed to resolve this item.
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-(3.0 Continued). 59 L.S m~~ 1 FES 101987 19/20.3.2 Characterization of Finding Inspector's apparent safety concern and Task Group's evaluation, j No direct safety concern is apparent on the part of' the inspector.
He found that the licensee did not meet minimum standards for record storage facilities and thereby was jeopardizing quality records which could prevent substantiation of performance / characteristics of quality activities and hardware. ' The Task Group concludes that essentially no safety significance can be attached to this item; however, potential major economic significance would occur should record reconstruction be necessary. The only element of safety significance would involve both the licensee and NRC accepting less than optimum data / records due to the inability to -ecenstruct lost records to origiral cuality. Should it have been pursued for more examples of programmatic sig-nificance; was it? No. The issues appeared to be independent of broad programmatic issues. 19/20 3.4 Nature of Downgrading of Inspection Finding as it Apoeared in Final
. Report with a Srief Statement of Management's Reasoning See Item 17.1.1 cbove. Management's referral of ambiguous or contradic-tory regulatory criteria to NRC:HQ, for resolution was consistent with prevailing agency policy.
19/20.3.5 Management's Role in Achieving Final Disposition Were management's actions sufficient to warrant downgrade? If not, what further action should have been directed to proper resolution. Management's actions appeared sufficient, were consistent with ex-isting practices of the agency, and appeared to address each of the salient issues. 19/20.3.6 If Item was Determined to be Unresolved, was there Sufficient In-formation in the Inspection Report to Focus Activities of the Licensee / Inspector to Effective Resolution The final report contained sufficient information to characterize the open items, particularly in conjunction with the proposed referral to NRC:HQ. l.
., ., ) 4
_ __________-_..-__m- - - - - - - - - - - - - - - - - - - - IN' A (3.0 Continued) 60 M, ,/;: FEB 101F 19/20.4 Conclusions Regional management downgraded the finding pending resolution of regula-tory requirement questions. This handling was reasonably consistent with the independent assessment of the Task Group. The inspector's develop-ment of the issues was again superficial with an overly aggressive en-forcement posture applied to situations with little or no safety or l regulatory justification. I e G
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y # w' (3.0 Continued) 61 tits in a , o. rG 10ibe7
- 21. Failure to Provide.Temocrary or Permanent Storage for Records Co-Mincled with In-Process Documents in Paper Flow Grouc 21.1 Backaround This item was identified in OI 86-10 as 85-14/11, Issue 15. This was a " highlighted" item in Attachment.1 to Attachment MM to OI 86-10.
21.1.1 Summary of Issue The licensee had established " Paper Flow Groups" (PFGs) and work facili- ; ties to assemble and administer various work record packages. The groups were situated in trailers which did not have ANSI N45.2.9 " records vault"
- instruction.
The typical paper f'ow process invpives mergirg existing records remove: from permanent storage with "new" records received from field fccces to assemble a final, complete recor's package for eventual re-storage in the site's long term storage vaults. The TRT (reference .7 below) had reviewed these activities and found them acceptable based on the TRT's interpretation, of ANSI N45.2.9 for temporary storage requirements and in-process records. One of the salient determinations made by TRT was that when " permanent" records requiring the full protection of ANSI N45.2.9 are removed from storage for use/ revision, the reactors reverted to the status of "in process" records which TRT determined did not re-quire treatment according to the record storage requirements of ANSI N45.2.9. TRT found that the PFG records were being stored in lockable, fire proof cabinets which was in accordance with the temporary storage facility provisions of ANSI N45.2.9. During Inspection 85-14/11, the inspectors found that mechanical and electrical installation records (e.g., steam generator records packages) had been removed from cermanent storage to the PFG and were stored in both fire- and non-fire proof cacinets. A violation of 10 CFR 50, Ao-pencix B, Criterion XVII was proposed. The draft insoection report stated that the previous (implied TRT) review had only involved isolated OC records and tnat the problems identified during the current inspection involved number of records. Regional management determined that the licensee had taken prudent steos to safeguard the records based on the logic that, once removed from per-manent storage for additional rework, the records reverted from being
" quality records" to in process records." The item was downgraded oy management to unresolved (final issue form) in draf t 4a of the report.
21.1.2 References
.1 CPSES Combined Inspection Report 50-445/85-14/11.
.2 CPRRG-17, RIV Management Positions on Attachment MM.
.3 OI File 86-10, Page 14.
rs 7 a ?-'t r- S mw a .d - b
(3.0 Continued) 62 . ' !I.' i
- m 10 W 4 CPSES FSAR, Section 17.1.
.5 Transcript, Investigative Interview, T. Westerman, July 10-12, 1936.
.6 Transcript, Investigative Interview, b. 5. Phillips, March 19, 1956. 4
.7 TRT Results, Allegation AQ-45, Permanent Records Not Stored in a )
Fire Proof Vault. l 21.2 Independent Assessment of Inspection Finding l The key elements in determining the acceptability of storing plant records are: (1) the categorization of a document as a " quality record" and (2) the prudency of the record protection measures. Regional man-agement, the inspector, and the TRT extensively debated the distinction between " quality record" and "in process record," and the risk exposure and consequences of the various levels of protection. This Task Group believes that those arguments a*e specious. A QA record is defined in ANSI N45.2.9 as: "Those records which furnish documentary evidence of the quality of items and of activities affecting quality. ..a document is considered a quality assurance record when the document has been completed." Reverting to a common sense approach: (1) if a document contains discrete unique inf6rmation necessary to establish the quality of an item, and (2) no other document can provide equivalent information on a reasonably available and practical basis, and (3) reconstruction of the document would be impossible or impractical (e.g. , the physical evidence is buried in concrete, etc.), then that document retains the status of a record until ultimate disposal. This logic can also be applied to document packages made up of many individual documents / records. Therefore, the interpretations preferred by the principals in prior evaluations are perhaps legalistically correct out are invalid on the basis of reasonableness and prudency. Obviously the sheer volume of records involved in nuclear projects pre-cludes any attempt to classify individual records per the above logic, resulting in most licensees applying blanket protection per their QA program commitments without trying to discriminate between transient document status changes. Based on the foregoing. the licensee's actions with regard to defining and storing records in non-fire proof containers appear to be a deviation from the FSAR commitment to ANSI N45.2.9, Section 4.5 for storage con-tainers and would require a licensee response. However, reference .2 indicates that the licensee took corrective action in the absence of enforcement action to place the records in fireproof containers. The references are silent with respect to preventive actions, but if evidence of effective licensee preventive action exists, enforcement is not war-ranted. In summary, two enforcement options are available consistent with current agency practices: (1) confirmation of licensee preventive action adequacy'. resulting in no ceviation or open item, or (2) issuance of an unresolved L. a e
p (3.0 Continued) 63 n((g."9I'~r res 10 $87 item making acceptability contingent upon the licensee's presentation and Region IV's confirmation of acceptable preventive action. Issuance of a deviation or violation is supportable but not recommended. Afternote: No evidence exists as to whether either the inspector or his management evaluated the licensee's detailed procedures for the above activities. Additional, unaddressed enforcement potential exists with regard to the adequacy of the procedures and their implementation. 21.3 Analysis of RIV Disposition 21.3.1 Statement of Inspector's Findings and Regulatory Concern The inspector proposed a violation of 10 CJR 50, Appendix B, Criterion XVII for failure to protect records in accordance with ANSI N45.2.9. The inspector's regulatory concern appeared to follow the general line represented by the prior items involving records, i .e. , the 1-icensee's records management program was ineffectively implemented and records were = at risk. 21.3.2 Deveicoment of Findings Although much effort was expended by both the inspector and regional management in developing a rationale for the acceptability of the licen-see's activities, no evidence exists that any of the parties actually evaluated the instructions provided by the licensee's Records Management Manual (discussed in reference .7) to determine whether the program was defective or whether its implementation was defective and how their own rationale compared with the licensee's. Further, regional management, in reference .2, appears to accept the licensee's placement of the records in fireproof cabinets as responsive corrective action but does not address preventive actions or programmatic considerations. The Task Group infers that, because the regional office did not consider the documents to require fireproof storage, they did not seek the additional licensee action for evaluation. 21.3.3 Characterization of Finding Inspector's apparent safety concern and Task Group's evaluation. No direct safety concern is apparent cn the part of the inspector. He found that the licensee did not meet minimum standards for record storage facilities and thereby was jeopardizing quality recorcs j which could prevent substantiation of performance / characteristics l of quality activities and hardware. l l l
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Di (3.0 Continued) 64 15[.l 3."r FEC I C 597 The Task Group concludes that essentially no safety significance can be attached to this item; however, potential major economic significance would occur should record reconstruction be necessary. The only element of safety significance would involve both the licensee and NRC accepting less than optimum data / records due to the inability to reconstruct lost records to original quality. Should it have been pursued for more examples of programmatic sig-nificance; was it? See discussion 21.3.2 above regarding review of licensee implement-ing procedures. The conclusions drawn by the inspector and Region IV regarding program adequacy are not supported by documentation of their inspection for a determination that the program was in place and implemented. 21.3.4 Nature of Downgrading of Insoection Finding as it Acceared in the Finai Report witn a Brief Statement of Management's Reasoning See 17.1.1 above. Management's downgrading was based on (1) their rationale for record definition, (2) the action taken by the lice'nsee to correct the storage conditions, and (3) the previous acceptable find-ings in the same area by TRT (reference .7). 21.3.5 Manaoement's Role in Achieving Final Disposition Were management's actions sufficient to warrant downgrade? If not, what furtner action should have been directed to proper resolution. As described in 21.3.2 ano 21.3.3 above, management's actions were adequate even though the Task Group believes that management's rationale was partially defective with regard to definition of records status. 21.3.6 If Item was Determined to be Unresolved, was there Sufficient In-formation in the inspection Report to Focus Act1vities of tne Licensee /Insoector to Effective Resolution Insufficient information was provided in the final report. The report failed to aodress the items described in 21.3.2 and 21.3.3 above and provided no indication of the expected actions on the part of either NRC or the licensee necessary to close the item. 21.4 Conclusion Regional management's eventual disposition of the item as an unresolved item was essentially consistent with the independent assessment of the Task Group although management's rationale was materially different. ! The overall direct safety significance was negligible. i I
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Neither the inspector nor regional management appear to have completely evaluated the issue with respect to the adequacy of the licensee's pro-gram. Further, management's disposition and documentation of the finding did not adequately address completion of licensee preventive action, due in part to regional management's posture on the item (see 21.3.2 above) did not address the need for programmatic / preventive action by the licensee. The Task Group believes additional licensee action to protect the records is warranted.
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in..;r. r,r~ m (3.0 Continued) 66
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- 22. Weld Red Identification -
22,1 Background This item was identified in 01 86-10 as 86-14/11, Issue 16. This was not~a " highlighted" item in Attachment I, Attachment MM to OI 86-10. 22.1.1 Summary of' Issue During the conduct of inspection 85-14/11 of the CPSES, a Region IV in-spector noted that several weld filler material containers in storage had loose or missing labels. While the material was still identifiable, the procedural requirements specified marking of the subject containers during storage. In the original draft inspection report, this issue was documented as a deviation from procedural requirements. In a subsecuent craf t, tne item ,,as enanged to a vicht or, cf .; JR 5;, Aspencix s, l Criterion V and later dropped as a violation. The final inspection re-port documents the inspector's original observations, as noted, and de-letes any discussion of a finding or open item. Referral of the subject matter to "B & R Welding Engineering for followup" is documented in tne final 85-14/11 inspection report. . 22.1.2 References
.1 CPSES Combined IR 85-14/11
.2 OI 86-10, pp. 16 and 18
.3 CPRRG-17, 85-14/11 Inspection Report (Item 16) and Attachment .,
3, 4, 5 and 20 22.2 Independent Assessment The intent of identification and traceability of weld rod filler material was met in the case of this concern. Weld rod control from site to site, constructor to constructor, differs. The NRC has accepted programs (e.g., Bechtel) where rigorous controls are applied to the weld rod purchased for and allowed on a site, with lesser control provided down to the actual consumption of filler material. In regard to B&R controls at CPSES, "only authorized weld filler material is accepted into the weld rod storage areas". (CPRRG-17, 85-14/11 IR,
- p. 40). However, a B&R procedure (CP-CPM-6.9B), as is stated in all versions of the 85-14/11 inspection report, apparently requires that original conto.Mers be marked during storage. The fact that the marking labels fell off could be construed as a procedural violation.
Where the overall intent and function of regulatory and code requirements has been met (in this case with respect to identification and traceabil-ity), but a licensee / contractor procedure is violated, it is entirely l y=.m 3
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- h. [ i g . ; .g proper not to issue a violation, but refer the problem to the licensee /-
contractor for resolution'. This was done and documented in the final inspection repuet.
'22.3 Analy:ing Region IV Disposition 22.3.1 Statement of Inspector's Finding and Regulatory Concern The inspector believed the examples of missing labels on weld rod con- I tainers that he had noted during the 85-14/11 inspection represented a violation of the applicable B&R procedure. Thus, a violation of 10 CFR 50, Appendix B, Criterion V, had been identified. l 22.3.2 Development of Finding l How issue was researched anc int'y:t:., '.:1uding supportive cases; applicable documents consulted and by whom. Discuss appropriateness of documents' reviewed.
It is unclear why this issue was raised as a concern, if, as is documented in Attachment 20 to CPRRG-17, the Region IV specialist /. I reviewer is correct in the opinion that the inspectors themselves chose to remove the violation from the report. If, as stated, there was a conflict in-the inspection report between closure of an ex-isting weld rod open item and reporting of a new weld rod violation, it appears that it was proper for Region IV. management to correct this conflict. Based upon the decision to drop the violation, close i the old item, and refer the new concern to B&R for followup, it appears that a proper consensus decision was reached. Thus, the statement . concern by the inspector on the handling of this issue is not understood, 1 22.3.3 Characterization of Finding Inspector's apparent safety concern and Task Group's evaluation. Missing labels on weld rod potentially represents a material trace-ability problems which could result in improper filler material being used to make a weld joint. l l The Task Group. concludes there is no hardware or programmatic sig-nificance to this issue since weld rod identification was not really in question. A Criterion V procedural violation could have been written, but would have had no basis in safety or the need for fur-ther NRC followup. bill.) i
(3.0 Continued) 68 rq--"']
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u .a.1 y 9, 22.3.4 Timeliness Was communication between inspectors and RIV Management on final resolution timely? Resolution of this issue during the report review cycle, as is in-dicated in Attachment 20 to CPRRG-17, would appear to have been en-tirely proper. The timeliness of this communication was also appro-priate given the overall circumstances surrounding CPSES inspection reports at that time. 22.3.5 Nature of Downgrading of Inspection Finding as it Appeared in Final Report with Brief Statement of Management's Reasoning A supportable violation could have been written, but would have had very little safety significance, if any. Apparently, the inspectors themselves were given the option to downgrade or not. Given that a violation was not written, referral of the problem to the constructor was appropriate. 22.3.6 Management's Role in Achieving Final Disposition Were management's actions sufficient to warrant downgrade? If yes, explain. Yes; the conflict between the weld rod open item closure and the new proposed violation .should have and did receive management at-tention. The lack of hardware safety significance justified the downgrade and in this case, the downgrade was apparently an inspec-tor decision. 22.4 Conclusions I A deviation, as was originally documented in the first draft report, was not appropriate to the situation because deviations are considered with respect to licensee commitments and not contractor procedures, as was the given case. The violation, as was then developed, was supportable because the B&R procedure was not followed. However, the safety signi-ficance of such a violation was nonexistent with respect to hardware and minimal, at best, with respect to process controls. j Region IV management directed the proper action in asking the inspectors to resolve the apparent conflict in the 85-14/11 inspection report whereby closure of an old weld rod control unresolved item was inconsistent witn statement of the subject concern as a violation. It appears that the inspectors themselves reviewed this conflict and chose not to issue a citation. Management's suggestion to refer the problem to Brown & Root for review and followup was proper and such action was documented in the final inspection report to provide evidence of how the issue was handled. l Further NRC followup was not necessary unless additional similar concerns ) were identified or safety impact was suspected.
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(3.0 Continued) 69 h0 'ljj._'7 gdb J ret 1 0 1987 < It is not clear why the handling of this issue was ever raised as a concern, if in fact the inspectors had a major role and options in how the item would be ultimately reported. 4
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(3.0 Continued) 70 N33 kb 1 FEB 101987
- 23. Failure to Develop /Imolement Procedure to Demonstrate 50.55(e) Deficiencies are Corrected
- 24. Failure to Revise Implementing Procedures Containing 50.55(e) Reporting 23/24.1 Background These items were identified in OI 86-10 as 85-16/13, Issues 1 and 2.
These were " highlighted" items in Attachment I to Attachment MM to OI 86-10. They are combined for analysis because of their similarity, 23/24.1.1 Summary of Issues An unresolved item was presented in the Octcber 1985 monthly construction inspection report (85-14/11), concerning cross-referencing between the l I significant deficiency analysis report (SDAR) files and associatec cv- , rective action. The item was considered unresolved, pending the comple- ! tion of NRC's review of the TUGCo SDAR system procedural adequacy. The l item resulted from the NRC contractor's review of 20 SDAR's, eight of ! which were evaluated as reportable (in letters to NRC Region IV) under 10 CFR 50.55e. However, the NRC contractor was unable to perform field verification of the corrected deficiencies because the SDAR files did not reference the location of documentation that supported the corrective action. In the next monthly inspection report IR 85-16/13 (November 1985) the inspector initially proposed two violations of Appendix B, Criterion V as a resolution of the previous 85-14/11 unresolved item. The first
violation cited a failure to develop procedures that cross-referenced 1 corrective action documentation within the SDAR files (i.e., NEO-CS-1 i issued on November 1, 1985 failed to address this issue). The second violation proposed that the licensee failed to revise lower-tier imple-menting procedures that were now inconsistent with the newly issued TUGC0 governing corporate procedure, NEO-CS-1, which dealt with evaluation of deportability under 10 CFR 50.55(e).
The procedure described as inadequate in the initial draf t of IR 85-16/13 was the TUGC0 corporate policy described in NEO-CS-1. The four lower-tier procedures that were not revised when NEO-CS-1 was issued were: CP-QP-16.1 (Rev. 6.), Significant Construction Deficiencies TNE-AD-5 (Rev. 3.) Identification of Design Deficiencies DQP-QA-12 (Rev. 2 ) Administration and Tracking of SDAR's
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i l i f'!'S i i (3.0 Continued) 71 bdb}.,, ; RE l '3 1987 . The inconsistencies in these procedures included conflicting responsi- j bilities, methods of evaluation, deportability criteria, notification j policy and reporting instruction. { l Region IV management disagreed with the proposed violations and in the i final issuance of Inspection Report 85-16/13 on April 4, 1986, disposi- ); tiened the prncedural treatment of SDAR file contents as an unresolved item. This was resolved in the interim by a TUGC0 management commitment ! to resolve 10 CFR 50.55(e) file tracking problems and procedural incon-sistencies by March 1, 1986. The commitment was elicited by Region IV management at a site meeting (at which the inspector was not present). Further, TUGC0 established a task force of 5-10 persons to develop the requested indexed 50AR information over the subsequent 10 months. 23/24.1.2 References
.1 CPRRG-17; Items law 2 (Pages 1-8) an Attachments 1-9
.2 CPRRG-16, Pages 74-89 and Exhibits 1, 14, 15, 50, 52 and 54
.3 OI File 86-10 (Pages 20-22) and Attachments B (Pa!,es 199-214),
(Pages 348-412), MM (Pages 14-16) and MM (Pages 23-27) I 23/24.2 Independent Assessment The purpose of 10 CFR 50.55(e) is to insure that significant construction deficiencies are reported to the NRC. This includes an assessment of ' the date by wnich the significant deficiencies would be corrected. In order to meet the intent of this regulation, some manageable form of control has to be established by the licensee to track the ul timate dis-position of all 50.55(e) items to insure they are closed out per their commitments and consistent with the schedule for system completion prior to NRC issuance of an operating license. The licensee's prior system, and the newly implemented corporate policy (NE0-CS-1) were not designed for clearly reflecting or tracking correc-tive actions as evidenced by the lack of cross referencing in the SDAR , files. Region IV management and the licensee agreed with the inspectors that this issue required resolution; the SDAR files were inadequate only ; insofar as their ability to direct reviewers to the corrective action ] that had oeen, or was to be implemented. The corrective actions them- {' selves are separately regulated by 10 CFR 50, Appendix B, Criterion XVI. The inspectors made no case for the failure to implement corrective action for any of the identified significant deficiencies. Therefore, the dilemma from the regulator's standpoint is how to convince the lic-ensee to make the needed modifications in his program for tracking l 50.55(e) issues beyond the final report to the NRC. A citation against 50.55(e) is not appropriate because there is no clear-cut support for a violation of 50.55(e) requirements. It is the Task Group's opinion that 50.55(e) reporting need not be subjected to the requirements of 1 Appendix B in order to meet the intent of 10 CFR 50.55(e). While this 1 i.W 3 - = l n$( ,;j l
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(3.0 Continued) 72 U . u A. H.3 1 0 1s07 view can be argued - as all parties involved have already demonstrated - the Task Group feels this is unnecer,sary, sirce satisfactory resolution can be achieved through other means. Failure to revised the lower-tier procedures to match NEO-CS-1 is a-sup-portable violation of 10 CFR 50, Appendix B, Criterion V or VI for main-tenance of adequate procedures as defined by the licensee's program, but not necessarily as a violation of 10 CFR 50.55(e). .Since no functional' reporting problems were identified by the inspectors, the mismatched
- procedures apparently resulted in no actual program failures. The lic-ensee also committed to correct the procedures promptly. Current agency policy permits waiver of enforcement action in such " paperwork" cases.
In this case, the Task Group considers the issuance of u- e:: Ned items to be appropriate. The inspectors either failed to determine or failed to document whether the licensee's procedures and system were adequate to meet the requirements of 10 CFR 50.55(e). No clear-cut violation of those requirements or of_ Criterion XVI had been demonstrated by the in-spectors efforts. By virtue of the unresolved items, the licensee is asked to review and correct the deficiencies in his program. The program must demonstrate continuing and future compliance with 10 CFR 50.55(e). Admittedly, it is unlikely that the licensee's efforts would result in noncompliance, but given the complexities of 'the regulatory. aspects of this issue, this is not considered to be.a misuse of the unresolved item. 23/24.3 Analyzing of RIV Disposition 23/24.3.1 Statement of Inspector's Finding and Regulatory Concern Because'of a concern for the licensee's ability to support inspector field verification and assess status of corrective action to close-out the SDAR's, violations of Appendix B Criterion V were proposed. The proposed violations came one month following an unresolved item to assess procedural adequacy of 10 CFR 50.55(e) deportability. 23/24.3.2 Development of Finding How issue was researched and analyzed, including supportive bases; applicable documents consulted and by whom. Discuss appropriateness of documents reviewed. The inspector inappropriately focused upon a corporate procedure NEO-CS-1 that'was intended to ensure deportability under 50.55(e). The purpose of the deficiency reporting system is to report - not, as assumed by the inspector, to "show objective evidence that de-ficiencies are corrected."
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M.R,8,7"*J q' ' 2 (3.0 Continued) 73
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- 01987 23/24.3.3 Characterization of Finding Inspector's apparent safety concern and Task Group's evaluation.
Loss of management control over corrective actions can result in direct safety consequences. No direct safety significance can be attached to 10 CFR 50.55(e) reporting. The implications of a failure to identify, report, and correct could have significant consequences (at the affected site, or beyond). In this case, however, at issue was the ability nof the licensee's program to track the disposition of the items. Therefore, there was not actual safety significance. Should it have been pursued for more examples of programmatic sig-nificance; was it? No. The sample of 20 items was sufficient to identify that a prob- i lem existed. ; Was it reasonable to expect further undirected action by the re-porting inspectors? If yes, what action should have been taken? Yes, the inspector (or the NRC consultant) during the period 10/85-2/86 could have vigorously pursued field verification of'50.55(e) issues. TUGC0 had previously offered to have TUGC0 personnel assist the inspectors trace to completion corrective action for the 50.55(e) issues in question. This would not have resolved the programmatic issues, but would have determined if there was a functional problem. 23/24.3.4 Nature of Downgrading of Insoection Finding as it Acceared in Final Report with Brief Statement of Management's Reasoning Management downgraded the violation to an unresolved item because they reasoned the failure to have complete SDAR files was not a procecural requirement governed by Criterion V. 23/24.3.5 Management's Role in Achieving Final Disposition Were management's actions sufficient to warrant downgrade? If yes, expiain. Yes. The issue was appropriately downgraded to an unresolved item since Criterion V and XVI violations did not exist. In' resolution of the item, the licensee agreed to form a task force and put the 50.55(e) tracking program in order as well as to achieve the re-quired consistency among the lesser tier documents concerned with deportability. M a n;
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(3.0 Continued) 74 FEE 101987
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What further action should have been directed to proper resolution. From the aspect of corrective action review, Region IV management could have redirected the inspector to inspect beyond the SDAR files to track 50.55e item resolution. A notable weakness in the develop-ment of this issue was the lack of aggressive pursuit beyond the SDAR files to ultimately ascertain if Appendix B problems existed in the licensee's corrective action processes, j l 23/24.3.6 If Item was Determined to be Unresolved, was there Sufficient In-formation in the Inspection Report to Focus Activities of the Licensee / Inspector to Effective Resolution Yes; however, new unresolved items were not created, but management in-cluded these issues in the ongoing evaluation of unresolved items 85-14/ U-02/U-03. There was a statement in the inspection report that the lic-ensee committed to resolving the file tracking and procedural consistency problems by March 1, 1986. Also, new unresolved item 85-16-U-01 addressed the formation of a 4 to 5 person task force. Was this done (i.e. how was the item resolved) As discussed, TUGC0 task force was assembled to improve traceability of 50.55(e) items in the SDAR files and clarify reporting require-ments. Current status of items Apparently the task force of 5-10 persons have been working over the last 10 months to put more complete packages together in the SCAR files. Whether the existence of nonconformance reports and corrective action records was confirmed for the eight reportable SDAR's was unknown at the time of the Task Group's report. 23/24.4 Conclusions The CPSES construction deficiency reporting system is not specifically required by QA Program requirements but is established to meet the regu-latory requirement of reporting to the NRC in accordance with 10 CFR 50.55(e). The SDAR system was apparently marginally adequate at Comanche Peak and not amenable to inspector follow-up. No evidence was presented in inspection findings or later transcripts to support the inspector's assertion that the system was inadequately implemented. The purpose of 50.55(e) reporting is not, as stated by the inspector to show objective evidence that deficiencies are corrected. Correction of deficiencies is a larger and more significant quality question associated with 10 CFR 50 Appendix B Criterion XVI, which encompasses not only 50.55(e) report-able deficiencies, but all quality related deficiencies identified by the licensee's program. m.y
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(3.0 Continued) 75 f?D a - 3 FIE 10 567 1 Inappropriate emphasis was placed by the inspectors upon the status, com-pleteness, and usefulness of the SDAR files. This could be characterized as an accounting problem, but was not sufficiently developed to establish a link to uncorrected design / construction deficiencies. . Corporate pro- ' cedure NEO-CS-1 appropriately addressed the evaluation for deportability i to the NRC of such deficiencies. While the previous report (October 1985; 85-14/11) did address the lack of a cross-reference between SDAR's and documentation of corrective ac- . tion, no earnest attempt was apparently made to find the applicable
- quality documents (i.e., NCR's, DCA's, or TDR's) either on the part of the inspectors or the licensee. Neither the October (85-14/11) nor l
November (85-16/13) inspection reports sufficiently developed the finding i of the incomplete SDAR files to the point where meaningful issues regard-ing corrective action (Criterion XVI) concerns could be presented. The pertinent issue reported in 85-14/11 (Appendix D, Detail 3b) is the fact that the consultant, in reviewing eight 50.55(e) reportable issues in the SDAR files, concluded that field verification of the associated hardware issues could not be performed because the files were not con-veniently cross-referenced. The immediately preceding detail (3a in 85-14/11), made ar. unresolved item (445/8514-U-02; 446/8511-U-01) of the f act that nor,e of the related site implementing procedures addressed the need to cross reference between an SDAR and its associated corrective actions. No regulatory concern was established with respect to the
#ailure to properly implement corrective actions.
Region IV management's handling of this issue attempted to put the in- l spector's emphasis in the proper perspective. The Task Group considers that the purpose of the initial inspection in 85-14/11 was to evaluate the effectiveness of the licensee's program for deficiency reporting required by 10 CFR 50.55(e). When the inspectors became frustrated in their attempts to track the completion of the corrective actions, first an unresolved item was created in 85-14/11 and finally a procedure (Cri-terion V) violation was proposed in 85-16/13. The unresolved item was misdirected and the violation was inappropriate. Both the inspectors and management must share the blame for the initial unresolved item being ineffective. The failure to update lower-tier procedures affected by the issuance of NEO-CS-1 can be constructed as a violation but is a minor paperwork issue that had no safety or reporting significant effects. No violation is appropriate based on the Region IV actions. The creation of the unresolved item by management in 85-16/13 had the desired effect. TUGC0 agreed to aodress the marginal nature of the tracking available through the SDAR files by forming task force. Man-agement and the inspectors had always agreed on the substance of the l problem. However, rather than promptly directing the licensee to resolve the issue, management and the inspectors engaged in a protracted discus-pr
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(3.0 Continued) 76 FE210 SS7 l I sion about how to attack the problem. The debate of whether records which support 50.55(e) tracking must be controlled in accordance with CA Program requirements should never have occurred. This issue did not need to be resolved in order elicit the proper corrective action from the licensee. This position applies equally to Items 25 to 27 discussed below. I l l l r~ ' ~ 3= ,
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+ (3.0 Continued) 77 M ?;[7"'fg;;.f*,~s $si i
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- 25. Failure to Maintain Retrievable 50.55(e) Files
- 27. TUGC0 50.55(e) Files Not Available 25/27.1 Background These concerns were identified in 01 86-10 as Inspection Report 85-16/13, Items 3 and 5. Item 3 was a " highlighted" item in Attachment'l te At- 4 tachment MM to 01 86-10, Item 5 was not.
25/27.1.1 Summary of Issue As described in Issue 23, NRC review of significant deficiency analysis reporting (SDAR) in Inspection Report 85-14/11 identified concerns with the ability to identify and locate associated information referenced in TUGCO's evaluation process for evaluating potentially reportable signi-ficant construction deficiencies. These items are an expansion of Items 23 and 24 which deal with the broad issue of the adequacy of the licen-see's overall 50.55(e) program. The inspector's concerns here are the same; however, the attack on the licensee's program here is from the aspect of the inadequacy of control of QA records which support the 50.55(e) program. The topic of SDAR evaluation and its relation to Appendix B is described in Issue 23; the evaluation of records required by Appendix B as opposed to those enabling TUGC0 tracking of licensing commitments is addressed in Issue.29. The topic of 50.55(e) Report details, specifically final corrective action dates, is described in Issue 26. The eight SDAR files classified as " Licensee Action Complete" reviewed by the NRC contractor were found to have no documentation of or reference to " final corrective action" (CpRRG-17, Inspection Report 85-16/13, At-tachment 2 - first report draft and Attachment 8 - exit interview out-line). The initial audit of the deficiency files by the contractor occurred on October 14-15; his subsequent " request for completed record files" was made 50 days later on December 4, 1985, but the inspector was apparently told that "no additional information" had been placed in the deficiency files. At that point, the inspector proposed a violation of Appendix B, Criterion XVII for a failure to maintain readily retrievable QA records. The subsequent draft of Inspection Report 85-16/13 discussed difficulties in assessing the rationale for making the SDAR file "com-plete," including the lack of a cognizant TUGC0 individual to direct the inspector to the " documentation" (i.e., referenced quality records used to support the SDAR conclusion that the " deficiencies had been completed"). Although 01 File 86-10 (Attachment MM, Enclosure 1) indicates that a separate violation was proposed concerning the auditability of the files, the Task Group's review could not identify a separately proposed citation in any of the inspector's draft reports (CpRRG-17, Attachments 2-8), and concluded that a single violation combining Issues 25 and 27 was proposed. f' 3 7 u.m!!
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.Y R V (3.0 Continued) 78
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Issues 25 and 27 were dispositioned by management as unr> solved. Unre-solved items 85-14/U-02 and 03 pertain to this overall issue and were left open (see discussion in Items 23 and 24); two new unresolved items > were created in Report 85-16/13 as indicated below. 85-16/13-01., TUGC0 formed a Task Force to review incomplete defi-ciency reports to resolve difficulty of documenting, meeting, and tracking corrective action dates. 85-16/13-05, TUGC0 was to complete a review of the program for storing SDAR files (i.e., difficulties were encountered in retrieval because records were not in a central location). 25/27.1.2 References
.1 ANSI N45.2.9-1973, Requirements for QA Records
.2 10 CFR 50.55(e), Construction Deficiency 9eports
.3 CPRRG-16 (Pages 74-89) and Exhibits 14, 15, 43 thru 48, and 54
.4 CPRRG-17. IR 85-16/13 (Pages 9-12) and Attachments 2-8a
.5 OI File 86-10 (Pages 19-26) and Attachments C, D, and MM 25/27.2 Independent Assessment The independent assessment of Items 23 and 24 has direct bearing on these issues. Records which demonstrate compliance with 10 CFR 50.55(e) do not need to be controlled in accordance with Appendix 8 in order to satisfy the requirements for reporting to the NRC and tracking of the final disposition. A licensee may choose to treat 50.55(e) reporting as an element of his QA program which is intended to satisfy the require-ments of Appendix B, Criterion XVI with respect to corrective action.
If this were the case, then an argument can be made for rigorous control of documents created solely to satisfy the requirements of 50.55(e) re-porting. It is appropriate for the licensee to address 50.55(e) reporting in ' Chapter 17 of the FSAR because of its intimate association with the licensee's corrective action program. TUGC0 does address 50.55(e) re-porting in Section 17.1 of the FSAR; however, it is the Task Group's view that this reference could be removed without impacting on the licensee's overall corrective action program designed to satisfy the requirements of Criterion XVI, e.g. , the Standard Review Plan is silent on this matter. As stated earlier in the independent assessment of Items 23 and 24, a:1 parties involved agreed there were multiple minor problems with TUGCO's 50.55(e) program tnat required resolution. For the reasons stated in Items 23 and 24, it is the Task Group's opinion that Items 25 and 27 are an extension of those same issues and should have been resolved accord-ingly. However, new unresolved items need not have been created. The most effective means of dealing with the entire 50.55(e) issue would have t
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'FTc 10 1987 79 (3.0 Continued) been to consolidate NRC concerns into one aggregate unresolve clearly defined all issues that needed to be addressed and resolved the licensee.
25/27,3. Analyzing RIV Otsposition 25/27,3,1 Statement of Inspector's Finding and Regulatory Concern SDAR files were incomplete and lacked quality records which, in ac ance with Appendix B, Criterion XVII, Records,-should be identifiable and retrievable. 25/27.3.2 Development of Finding CPSES Site and TUGC0 Corporate policies prior to November 1985 a sufficiently described in CPRRG-16 or 17 information to enable procer
~
assessment of the SDAR systems requirements as they existed prior to November 1, 1985. Little Report supportive basis was providedSome in development the develo other than that a single convenient file did not exist documentation, but no additional rationale. 25/27.3.3 Characterization of Finding ~ Inspector's apparent safety concern and Task Group's evaluation. Loss of management :ontrol over corrective actions can result in direct safety consequences. l No cirect safety significance can be attached to reporting. correct or beyond). could have significant consequences Therefore,(at licensee's program to track the disposition of the items. there was no actual safety significance. Nature of Downgrading of Inspection Fincings as it Acceared 25/27.3.4 Report with Brief Statement of Management's Reasoning I Management downgraded the proposed violation to tw items (85-16/13-01 and 05). unresolved items from 84-14/11 were reviewed in Report 85-16/ remained unresolved. [ ' I "? W....l l 1
(3.0 Continued) 80 3IMFEB 1019 25/27.3.5 Management's Role in Achieving Final Disposition Were management's actions sufficient to warrant downgrade? If yes, explain. Yes. The inspector's findings did not constitute a violation of Appendix B, Criterion XVI. What further action should have been directed to proper resolution. The NRC consultent did sufficiently develop the issue to determine that a functional safety or compliance problem existed with the licensee's 50.55(e) program. However, additional effort could have been expended by the consultant to track ultimate disposition of . the eight items in question. TUGC0 representatives offered to take ! the NRC to the quality records associated with the SDARs, "one-by- l one." Apparently, the inspectors did not avail themselves of this I opportunity. PS/27.3.6 If Item was Determined to be Unresolved, was there Sufficient In-formation in the Intoection Report to Focus Activities of the Licensee / Inspector to Effective Resolution Yes. However, there were four outstanding unresolved items which per-tained to this issue and could have been more effectively consolidated. Direction to the licensee was adequate, but could have been more appro-priately focused. 25/27.4 Conclusions The inspector tock a literal and strict interpretation with respect to the guidance contained in the NRC:IE Manual on construction deficiency reporting (Exhibit 54 to CPRRG-16) by extending the Appendix B criteria for establishment of procedures and maintenance of records to the issues in question. This guidance may require clarification. The existing TUGC0 CA Plan references the requisite procecures to document deficiencies (cap Section 15.0) using a nenconformance report or otner specified method. Periodic evaluation of NCRs and forwarding to TUGC0 management are specified in order to identify adverse quality trends. Significant audit items adverse to quality are required to be identified as well as to have cause determined and corrective action taken (e.g., Site Proce-dures CP-QP-15.6, 16.1, and 17.0 - not provided as references in this Task) and, in accordance with Appendix B, should be documented and re-ported to appropriate levels of managempft. CAP Section 16.0, Corrective Action (CPRRG-16, Exhibit 15) addresses the corrective action procedures, requiring thorough investigation and docu-mentation of those conditions. But in addition and, most importantly, separate from the procedures referenced in QAP Sections 15 and 16, a smaller subset of significant deficiencies are reportable to the NRC under 10 CFR 50.55(e). Their evaluation for deportability is assumed M 'l y? ; ka .J a
3 (3.0 Continued) 81 h's.[ t t'En 1 0 1987 to be a distinct process for the Appendix B Program outlined in the TUGC0 QA plan for CPSES, and is accomplished by a Corporate Policy outlined in NEO-CS-1 that has no basis in Appendix B. A restatement of this con-clusion is described in FSAR Section 17.1.15: Nonconformance reports and trend reports are reviewed upon issuance by TUGC0 QA for significant conditions adverse to quality... If such conditions exist, procedures require additional action, as appropriate. This may include issuance of corrective action re-quests...or reports to the NRC. Therefore, the procedures and records required by Appendix B relative to resolving identified deficiencies are distinct frcm those used to determine deportability. As evaluated in Issue 24, the issuance of NEO-CS-1 on November 1, 1985, without revising lower-tier procedures that implement the TUGC0 corporate policy on 10 CFR 50.55(e) deportability, was not a violation of Appendix B, Criterion V (Procedures) since the procedural interfaces were only important with respect to 10 CFR 50.55(e) deportability, not with respect j to activities affecting quality. ; l The documentation " package" referenced in NEO-CS-1 for record retention purposes is essentially the form (Figure 7.) used to track a potentially reportable deficiency from identification through evaluation and ultimate disposition. Additional information may include documentation generated during the corporate review. However, to expect all the reference mate-rial associated with a potentially reportable item to be included in the
" package" is unreasonable and unnecessary. Rather, only a single record (i.e., Figure 7.2) of each potential report's disposition is the intent of the quality records required to be maintained by NEO-CS-1. Further, Appendix B documentation control and records' retention should have their basis in a quality-related context; not, as in this case, a deportability concern.
The issue of auditability of SDAR files and docunent retrievability is only a valid question if the form (Figure 7.2) were not available. Al-though NEO-CS-1 was a newly implemented policy, the content or complete-ness of files associated with a CDR was a matter of finding a knowledge-able contact to discuss the item. The only valid records issue involved would be the retrievability of the Figure 7.2 form "without undue delay" (ANSI N45.2.9, Section 6.2). This subjective and qualitative criterion would be a function of whether the quality record in question was onsite or off site, and would be a matter of inspection urgency and quality sig-nificance, ranging in practice from one day to one month. The overall Task Group conclusions of other related 50.55(e) concerns (Issues 23 and 24) raised during Inspection Report 85-16/13 apply equally to the retrievability and auditability of the SDAR files; closure by a,
(3.0 Continued) 82 fl3D
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.gg. 3 g TUGC0 and NRC of reportable significant construction deficiencies is ultimately a licensing concern. Completeness and effectiveness of cor-rective actions - only a case-by-case (i.e., individually nonconforming conditions) bases - is a separate Appendix B, Criterion XVI issue. The closure of all reportable significant deficiencies at Comanche Peak will be, as stated by Region IV management, evaluated prior to operation or fuel load. The timeliness of that effort is a management issue related to schedule.
Proposing violations for Issues 25 and 27 was a premature use of enforce- l ment in a situation requiring management discussions. The apparent in-ability of TUGC0 to assemble comprehensive files for their reportable deficiencies may be an indicator of larger problems such as the rela-tively high number of 50.55(e) reports (low threshold, inadequate engi-neering evaluations, or ineffective design and construction), an inade-quately implemented corrective action program, or schedular and resource problems associated with the ASLB hearings and previous allegations. While unrelated to the issues of retrievable, auditable CDR files, the effectiveness of the corrective action programs and the engineering evaluation of potentially reportable conditions were never assessed since
, the inspectors stopped with the SDAR files and Region IV management only considered the immediate issue of how to close out the reportable cefi-ciencies while convincing the inspector that file content was not a regulatory issue.
The Task Group's conclusion as to how this issue is best addressed has been fully developed in the conclusion section of Items 23 and 24 (23/ 24.4), and the independent assessment section of for these items (25/ 27.2). This is clearly an NRC/TUGC0 management interface issue which could have been resolved in one broad, but clearly defined, unresolved item. As of the writing of this report, it appears that the formulated TUGC0 task force is attempting to address this issue. 9j s . hi.
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(3.0 Continued) 83 FES 1 0 1987
- 26. Corrective Action Commitment Dates in 10 CFR 50.55(e) Reoorts 26.1 Background This item was identified in OI 86-10 as 85-14/11, Issue 4 It was not a " highlighted" item Attachment I to Attachment MM of OI 86-10.
26.1.1 Summary'of Issue } l Literal interpretation of 10 CFR 50.55(e) deportability of significant construction deficiencies led the inspector to conclude that, for the eight reportable significant deficiencies reviewed by an NRC contractor 1 on two occasions in October 1985 (unresolved item 85-14/11-01), and later checked for status in a licensing open items status listing maintained by TUGC0 personnel, "a large number" of final reports did not meet the i " report content requirements" of the regulations. The inspectors first draft of IR 85-16/13 (Attachment 2a to CPRRG-17) suggested that a statement that corrective action "will be taken" (as opposed to "has been taken") classified the reports as interim instead of final because of a lack of completed corrective action required by 10 CFR 50.55(e). Therefore, for three reportable deficiencies with no corrective action date and four with overdue corrective action dates (i.e., licensee submittals not corrected and no supplemental report re-ceived by NRC Region IV), a violation of 10 CFR 50.55(e) was proposed for failure to report on corrective action. The violation was dropped from subsequent drafts of Inspection Report 85-16/13 (CPRRG-17, Attachments 3-8) and final issuance of the report carried as an unresolved item to awess the missing or incorrect cor-rective action dates. 26.1.2 References
.1 10 CFR 50.55(e)
.2 IE Manual Guicance en 50.55(e) (issued 4/1/80)
.3 OI File 86-10 (Pages 74-89) and Attachments C, D, and MM
.4 CPRRG-16 (Pages 74-89) and Exhibits 54 thru 62
.5 CPRRG-17 (Pages 13-16) and Attachments 2-8, and 10 26.2 Independent Assessment Part 50.55(e) construction deficiency report (CDR) descriptions of "cor-rective action" taken are not required to be updated when those actions are completed by the licensee. However, if the licensee is unable to initially supply or later meet an action completion date, followdp tele--
phone notification and/or a supplemental report is warranted. Unless chronic, such issues do not warrant enforcement. In situations similar to this at other construction f acilities, the Task Group concludes that an unresolved item would have been inappropriate since the rauntial for MRM '
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-(3.0 Continued) 84 (W k 5 lu M7 enforcement action is remote and vehicles already exist to expeditiously resolve the types of problems presented. However, due to the contentious '
' nature of the entire 50.55(e) issue in this specific instance, inclusion in a broader unresolved item would have been more appropriate. The re-port is not meant to be a corrective action status or verification mech-anism, and the proposed violations are inappropriate.
A specific action commitment date would not always be warranted if, for example, the reasonable milestone to complete the corrective action were prior to fuel load, startup testing,.or a defined operational mode. Fur-ther, the' dates of the seven CDRs in question in this issue were usually prefaced by the words " current schedule indicates" or "should be com-
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pleted by." In the case of one (CP-85-05, Diesel Control Air Filters, issced on 2/26/85), no actual date was given but the corrective action was appropriately covered by inclusion of replacement parts in a Master Data Base, thereby ensuring final action at a time generally understood - to be prior to emergency diesel generator operation. On the other hand, NRC review of the CDR-is performed, in part, to ascer-tain whether different or more definitive corrective action commitments are appropriate. Cf the seven.CDRs noted in final Inspection Report i 85-16/13 with discrepant dates, only one was general enough t.o warrant additional questions (CP-84-29) for extent and timing of corrective ac-tions. One other (CP-85-04) involved three month overdue corrective action for which a revised corrective action date may have been appro-priate for a supplemental CDR to the NRC. Most of the other " late" ex-amples were apparently behind on an exp1 cit hardware or activity com-mitment by 3 to 6 months, but also had an open-ended commitment with respect to as yet unscheduled activity (e.g., CP-84-27 installation of explosive proof lighting and a hydrogen test of ventilation; or CP-85-12 with revised auxiliary feedwater control valve setpoints by May 31, 1985 but recalibration at some unspecified time prior to operations in Modes 1, 2, or 3). The fact that these CDR corrective actions were only "apparently" behind is because their status as reported by 'he NRC in Inspection Report 85-16/13 was probably based on the TUGC0 open licensing items status list or the SDAR: files, not by verification with cognizant individuals based on reasonanle pursuit of the actual status by the inspector. The position of the Task Group is that it's conceivable that most of the questionable corrective action dates were, in fact, met or that the CDRs were capable of NRC assessment (although not perhaps closure) at the time of Inspection Report 85-16/13. For the CDRs which were open but had not met the projected corrective dates by more than approximately one month, experience has been that licensees should provide telephone notification to the regional office or resident inspector and possible submittal of supplemental reports with revfsed milestones that are more indicative of changing construction schedules. However, there is no compliance i issue over inexact dates insofar as the CDR is a commitment intenced for
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DO R.'""T glj ". / REB 10 50 (3.0 Continued) 85 meaningful evaluation by the NRC of a significant condition adverse to quality for generic and programmatic considerations. . The only instance where the timing (i.e., excessively late or inaccurate dates) is signi-ficant with respect to quality would be where the aspect of irreversi-bility (i.e., concrete pours) may become a factor in tightly monitored corrective action. The true measure of timely corrective action is in assessment of the normal QA Program corrective action process for indi-vidual nonconformances; not, necessarily for the' larger more significant deficiencies which may require a large amount of repair or redesign in a number of facets. 26.3 Analyzirg RIV Disposition 26.3.1 Statement of Inspector's Finding and Regulatory Concern Literal interpretation of 10 CFR 50.55(e) regarding specification of corrective action was taken in the report (i.e., no'CDR was " final" until corrective action was verified [by TUGC0] and reported complete). For three CDRs with no specific dates and four CDRs considered " late" (no corrective action noted in SDAR files or licensing status listing), a violation of 50.55(e) - failure , to report corrective action'- was proposed. 26.3.2 Development of Finding The finding was poorly developed. The consultant's field notes (Exhibit 75 to CPRRG-16) demonstrate a shallow analysis, 26.3.3 Characterization of Finding Inspector's apparent safety concern and Task Group's evaluation. Loss of management control over CDR corrective action can result in direct safety deficiencies. The Task Group believes that no direct safety significance existed. No evidence exists to demonstrate that management was not ensuring that corrective actions were completed, only that the status of corrective action was not totally up-to-date and the NRC should have been notified of schedule change details.
- Should it have been pursued for more examples of programmatic sig-nificance; was it?
No. Each CDR is, in and of itself, an open item on the docket and does not require a separate unresolved tag. A. sufficient sample was reviewed. , M b #:.,
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C q u. :- p !u\ t.f, j (3.0 Coatinued). 86 FEB 10 $6T Was it reasonable to expect further undirected action by the re-porting inspectors? If yes, what action should have been taken? More definitive inspection research (and possible closure) could have been done. It is puzzling that the inspector's supervisor should have accepted the original open item words " .. consequently no field verification could be performed," without either: j (1) directing further inspection or (2) directly eliciting the ! licensee management commitment. 26.3.4 Nature of Downgrading of Inspection Finding as it Appeared in Final Report with Brief Statement of Management's Reasoning The violation was downgraded to an unresolved item after obtaining lic-ensee management commitments for correction of past reports and future improved performance. This was based on regional management's assessment of the negligible significance represented by the date issues. 26.3.5 Management's Role in Achieving Final Disposition Were management's actions sufficient to warrant downgrade? If yes, explain. Yes. Position taken is responsive to the significance of the item (26.3.4). 26.3.6 If Item was Determined to be Unresolved, was there Sufficient In- ! formation in the Inspection Report to Focus Activities of the Licensee / Inspector to Effective Resolution Yes, report adequately bounded the expected actions. 26.4 Conclusions ) The conclusions of Region IV management are considered to be appropriate. It was appropriate (for 3 of the 7 CD'!s) to raise the attention of TUGC0 management to be more accurate in their committed corrective action dates. This issue as with others (see Issues 25 and 27 discussions) demonstrates the inspector's fundamental misunderstanding of 10 CFR 50, Appendix B, Criterion XVI corrective action programs. The 50.55(ei process is not ' intended, as originally posited in Inspection Report 8b-16/13, to provide a " complete paper trail for SDAR closure," i.e. , it is not a corrective action verification process. Undue inspection focus was concentrated upon final " closure" of the CDR. This was not necessarily indicative of the effectiveness of corrective action programs. Therefore, the focus on the dates in CDRs does not accomplish the proper safety insight to quality activities nor does it adhere to the NRC inspection program goal - the acceptability of CDR ! dispositions to support plant licensing. This issue was appropriately
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'(3.0 Continued) 87 g,h.' 7-{f r , -
gg resolved by Region IV management with the licensee. It is, however, unclear whether TUGC0 ultimately d't proterly address corrective action for significant deficiencies in tha: Ge proposed violation to 50.55(e) was too narrow and undeveloped. It is doubtful whether the 50AR files were the only source for NRC
" closeout of the corrective actica paper trail." No analysis or assess-ment of the specific CDR in question is presented; rather, only the accounting for a relatively insignificant date with respect to quality.
This issue suggests that the " closure" of the CDRs was more a review of the TUGC0 licensing items status list. Not much documentation of addi-tional findings or inspection activity is evident (formal documentary evidence presented to this Task Group) beyond the original attempt on October 14 and 15, until the last week in November 1985. Review of Ex-hibit 57 (consultant's notes) shows that the reporting inspector merely copied his cursory write-up and wrote a citation. In summary, the inspector is examining the wrong process by using the 50.55(e) deportability system to assess the TUGC0 treatment of signifi-cant Appendix B, Criterion XVI corrective action programs. These are an integral part of the QA Plan, and should not be confused with only deportability considerations. NRC IE Manual guidance in this regard - if taken too literally - could be misleadir.g (as in these issues examined). Also stated in the independent assessment (26.2), the Task Group con-cludes an unresolved item to be inappropriate. As also discussed in 26.2,
. inclusion of the concerns presented in a broad unresolved item may have , been appropriate in this specific instance.
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(3.0 Continued) 88 f
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- 28. & 33. IE Bulletin (IEB) 79-14 Concerns 28/33.1 Backcround These items were identified in 01 86-10 as 85-16/13, Issues 6 and 11.
These were not " highlighted" items in Attachment I to Attachment MM to 01 86-10. The items are combined for analysis and assessment because of their similarity and their joint review and comment by Region IV in CPRRG-17, 28/33.1.1 Summary of Issue During the conduct of inspection 85-16/13, a Region IV inspector ques-tiened the file and closure status of IEB 79-14, particularly with regard to the perceived incompleteness of the licensee response to Region IV ; on this Bulletin. In the original draft inspection report, this concern,. i combined with other questions about the record files and in-progress Stone and Webster activities, was documented as an unresolved item. .In the final inspection report, as issued, the reopening of the bulletin file, based upon the Stone and Webster analyses work in progress, was reported as an open item. However, no discussion of the concerns re-garding the completeness of the IEB 79-14 response was doctmented. The , inspector questioned the downgrading of the item from unresolved to open. 28/33.1.2 References
.1 CPSES Combined Inspection Report 85-16/13
.2 01 86-10, Pages 22, 23, and 26, and Attachment I to Attachment MM.
.3 CPRRS-17, 85-16/13 Inspection Report (Items 6 and 11), and Attach-ments 2, 4, 8A, 12, and 13.
.4 IE Eulletin 79-14 with Revision 1 and Supplements 1 and 2.
28/33.2 Independent Assessment i i The licensee response to IEB 79-14 (CPRRG-17, Attachment 12) was accept-able as written, It defined the scope of the As-Built Verification Pro-gram for the size and classes of piping recognized to satisfy the re-quirements of the IEB. The requirements addressed by Revision 1 to IES 79-14 (i.e., action items regarding " Seismic Category I piping, regard-less of size which was dynamically analy:ed by computer") were in fact discussed in the licensee response, although not in the specific IEB wording. " Seismic Category I piping" encompasses all the Safety Classes listed in the licensee response, while the small-bore lines which were not " dynamically analyzed for computer" represented a subset of piping for which the IEB requirements did not apply. Thus, properly interpreted, the licensee's IEB response was complete. Also, the fact that the licensee did not intend to report ne,1conformances as they were identified was not truly an exception (to IEB 79-14) which had to be explained in the licensee response. Nonconformances between EMil
(3.0' Continued) 89 C'8 10 set i I 1 as-built and design details, in this context, are processed differently l at a plant under construction like CPSES, than at a plant in oper'ation ' where the reporting of nonconformances was meant to be applied. Since the'IEB 79-14 process at the CPSES was still ongoing with the Stone and Webster effort, closure of this bulletin by either the licensee or the NRC at that time was inappropriate. The need to document a separate - open item is probably unnecessary since the NRC open bulletin status ) already served that purpose. However, the final inspection report (CPRRG-17, Attachment 8A) write-up indicating IEB 79-14 status as open was an acceptable means of tracking the licensee commitment to reopen their file and submit a supplemental report on this IEB. 28/33.3 Analyzing Region IV Disposition 28/33.3.1 Statement of Inspector's Finding and Regulatory Concern The inspector believed that the licensee's response to IEB 79-14 was in-complete in that~it did not address all cases of piping or exceptions to the Bulletin requirements. This and other concerns on the IEB 79-14 file status were initially documented as an unresolved item. 28/33.3.2 Development of Finding In the third draft of IR 85-16/13 (CPRRG-17, Attachment 4), the specific inspector's concerns on the adequacy of the response to IEB 79-14 were dropped and only the bulletin status continued to be discussed. In this version, the ongoing engineering work and file status was still documented as an unresolved item. In the final inspection report (CPRRG-17, At-tachment 8A), the basic report content of the third draft is retained, but the item is categorized as "open" instead of " unresolved". 28/33.3.3 Characterization of Finding Inspector's apparent safety concern and Task Group's evaluation. The inspector appeared to be concerned that the licensee's overview J and the actual quality of the IEB 79-14 reanalysis performed by. I their contractor were both unacceptable. This then might lead to l potentially incomplete or incorrect dynamic reanalyses of piping ] systems. These issues have no safety significance in the Ta.;k Group's assess-ment. The inspector misinterpreted the IEB requirements and at- t tached undue significance to the file closure on IEB 79-14 by the licensee. It appears that the Stone and Webster engineering effort was satisfactorily addressing all IEB 79-14 safety questions. Ad-ditional inspection by the NRC is required to review these engineer-ing efforts to close the bulletin,
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u . (3.0 Continued) 90 Wa W ,a4 , FCU 1 0 IS87 { 28/33.3.4 Nature of Downgrading of Inspection Finding as it Apoeared in Final Report with Brief Statement of Management's Reasoning The unresolved item was downgraded from " unresolved" to "open" in . the final report. However, Region IV management did not consider i this a downgrade since "open" was the proper categorization for ( review of Bulletin-related issues. 28/33.3.5 Management's Role in Achieving Final Disposition Were management's actions sufficient to warrant downgrade? If yes, explain.
~~
Yes;-the specific concerns that were dropped were correctly elimin-ated because the inspector had improperly interpreted the IEB 79-14 requirements. Changing the item from " unresolved" to "open" implied no downgrade in significance since the issue was still being tracked and the nature of the concerns did not raise questions of an en-forcement nature. In fact, it is common NRC practice to track Bul-letins as their open item without initiating new items to effect their closure. 28/33.4 Conclusion The handling of these issues by Region IV management appears to have been proper. The inspector apparently did not understand the technical as-pects of Bull.etin 79-14 to the degree necessary to have been able to judge the adequacy of either the licensee response to the bulletin or the current Stone and Webster engineering activities. Specifically, since the tomographic method of small-bore piping analysis is so conser-vative, Bulletin actions for the smaller seismic piping sizes are re-quired only for that Category I piping "which was dynamically analyzed by computer." Thus, the licensee's bulletin response with respect to { scope of the program is acceptable. Additionally, the need to submit nonconformance evaluations to the NRC, as discussed by IES 79-14, is not intended to be applicable to plants in a construction status where the As-Built verification process is still ongoing. the correct reference for reporting significant design or con-struction deficiencies is 10 CFR 50.55(e), if applicable to specific problems identified in the IEB 79-14 engineering effort. Thus, the in-spector here also misinterpreted the handling of nonconformances at the CPSES as an exception to IEB 79-14 requirements. The final inspection report carries the status of the in process Stone and Webster engineering work as an open item. Such an open item status 1 is appropriate, either as a separate item as was documented or by track- l ing the bulletin itself as open, since further NRC inspection and review of IEB 79-14 was required.
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(3.0 Continued) 91 "h @ S M FEB 101987 The facts and supporting documents on these issues support the position stated by Region IV in CPRRG-17 (Inspection Report 85-16/13), Items 6 and 11. 4 i
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I f' (3.0 Continued) 92 == grg ig g7 i 29.0 Incomplete IE Bulletin Files p l 29.1 Background This item was identified in 01 86-10 as 85-16/13, Issue 7. This was not a highlighted item in Attachment 1 to Attachtrent MM. 29.1.1 Summary of Issue i From a sampling review of six IE Bulletins requiring TUGC0 response, two l (see Issues 28 and 30 on Bulletins 79-14 and 79-28) were selected for hardware verification. The associated files were considered by the in-spector to be prematurely closed, and decentralized, since they were not located in either the QA records center or permanent records vault. An i unresolved item was proposed and was downgraded to an open item by Region IV management. 29.1.2 References
.1 OI File 86-10 and Attachments B, D and MM
.2 CPPRG-16 and Exhibits 1 thru 8
.3 CPPRG-17 and Attachment 15, Licensing Procedure N0E-205 29.2 Independent Assessments Procedure N0E-205, Licensing, provides instructions for reviewing and responding to NRC correspondence (such as IE Bulletins) assigned to the Nuclear Operations Staff. Completion of IEB responses (in Step 4.2.15),
including applicable action items, administratively required a closecut package (Form 0) which would include source information for the response. l A review form (Form B) was to be created for each relevant IEB. The re-view form and closecut package (Forms B and D) were required in Step 4.4 to be retained in accordance with Procedure STA-302, Station Records. Open item 85-16/13-05, presumably to addren the inclusion of Forms B and D from Licensing Procedure N0E-205 for an IEB into the station records program, is an appropriate disposition of Issue 29. The content and extent of the IEB records is a purely administrative concern. The only valid regulatory issues are the adequacy and complete-ness of commitments in IEB responses. For example, a Deviation may be issued if actual corrective actions differ from described, on a case-by-case basis, based upon the relative significance to plant construction quality and reactor operational safety. M il fN
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l (3.0 Continued) 93 29.3 Analyzing RIV Disposition 29.3.1 Statement of Inspector's Finding and Regulatory Concern An unresolved item was initially proposed, pending further review of IE Bulletin processing procedures and policies to address the contents of files containing information on the closecut of IE Bulletin (IEB) re-sponses. This underlying concern is analogous to similar concerns ad-dressed in Issues 23, 25 and 27 regarding file contents. 29.3.2 Development of Finding How issue was researched and analyzed, including supportive bases; ! L applicable documents consulted and by whom. Discuss appropriateness 1 ! of documents reviewed. The inspector referenced Procedure N0E-205 but never described the detailed instructions in that procedure. No other licensee provi-sions for tracking and documenting actual implementation of IEB re-j sponse actions were discussed in the available report information. l 29.3.3 Characterization of Finding Inspector's apparent safety concern and Task Group's evaluation.
~
The inspectors considered the licensee's IEB files inadequately represented the comprehensive response any followup action. No direct safety concern is evident. No safety significance is apparent to the Task Group. The issue involves contentions over the required / desired contents of a speci-fic file category as it affects auditability. Was it reasonable to expect further undirected action by the re-porting inspectors? If yes, what action should have been taken? A commitment could have been elicited directly by the inspector during the inspection period from TUGC0 management, as was subse-quently accomplished by Region IV management after the inspection period. 29.3.4 _ Timeliness Was communication between inspectors and RIV , Management on final resolution timely? Yes, although its unclear why management was not capable of convinc-ing the inspector that IEB files were an administrative concern. t
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(3.0 Continued) 94 );f* s Ub j FE510 387 29.3.5 Nature of Downgrading of Inspection Finding as it Acceared in Final Report with Brief Statement of Management's Reasoning The originally proposed unresolved item was dispositioned in the final Inspection Report 85-16/13 under four separate aspects:
- unresolved with respect to a TUGC0 Task Force on correctness of procedures and records.
open with respect to reopening the specific file for IEB 79-14 unresolved with respect to documentation for 79-28 open with respect to centralized / retrievable records 29.3.6 Management's Role in Achieving Final Disposition Were management's actions sufficient to warrant downgrade? If yes, explain. Management covered all aspects of the issue appropriately, including the commitments related to the TUGC0 Task Force.
- What further action should have been directed to proper resolution.
See Item 29.3.2. The inspector should have been directed to broaden the inspection to the more meaningful actions actually taken in response to the IEBs. A TUGC0 Task Force was subsequently assembled following discussions with regional management to address the completeness of NRC corres-pondence/ commitment files and the retrievability of associated quality records that relate to (but are not necessarily required to be stored in) the IEB files committed to in N0E-205. This appears sufficient. 29.3.7. If Item was Determined to be Unresolved, was there Sufficient In-formation in tne Inspection Report to Focus Activities of the Licensee / Inspector to Effective Resolution Yes, inspection report details was adequate. ; l 29.4 Conclusions Bulletin followup by the NRC is an assessment of the adequacy of the written response and verification of the licensee's implementation of actual commit-ments in that regard. This issue was initially daveloped from legitimate , safety-significant arguments with related potential hardware concerns (see i Issues 28 and 30). It is, however, the same preoccupation with file contents (see Issues 23-27) and is, by and in itself, insignificant, r, A.
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(3.0 Continued) 95 Eda u' J J ': g 1 0 IS87 Because the files ir question were only intended to address licensee actions up to the point of response submittal to the NRC, no regulatory problem ap-pears to have been involved to that point. The open item to clarify down-stream handling of the licensee's followup activities is appropriate, although j no reason is apparent why the inspector was unable to fully address this i during the inspection period. See Items 23-27, 31 and 32 for related but f seemingly redundant issues. I 1 l l l< {
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(3.0 Continued) 96 ,f)bIII' EB 101997 1
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1
- 30. NAMCO Switches (IEB 79-28) Identification Problem
-30.1 Background This item was identified in OI 86-10 as 85-16/11, Issue 8. This was a '
" highlighted" item in Attachment 1 to Attachment MM to 0I 86-10.
30.1.1 Summary of Issue During the conduct of inspection 85-16/13 at the CPSES, a Region IV in-spector identified two NAMCO limit switches that were incorrectly iden-tified on their installation travelers. This inspection was accomplished-to verify hardware replacement in accordance with the guidance provided IE Bulletin (IEB) 79-28. In the original draft inspection report, this data / record conflict was evaluated to be a failure to identify and con-troi parts and therefore cited as a violation of 10 CFR 50. Appendix B, Criterion VIII~. In the second draf t of the inspection report, this issue was changed by management to an unresolved item allowing for additional licensee review of the pertinent documentation Recognition of the licensee's effort to evaluate the subject documentation inconsistency was noted in the final inspection report and the item was issued as unresolved. 30.1.2 References
.1 CPSES Combined IR 85-07/05
.2 CI 26-10, pp. 20, 22-25, and Attachment MM (IR 85-16/13, Concern No. 4)
.3 CPRRG-17, 85-16/13 Inspection Report (Item 8) and Attachment 2, 3, and 8A 4 IE Bulletin No. 79-28
.5 USNRC Regulatory Guide 1-97 30 2 Independent Assessment Verification of hardware replacement to IEB 79-28 revealed documentation inconsistencies on 2 of the 14 installed NAMCO limit switches reviewed.
Since the component replacement was accomplished under IEB 79-28 guidance, and 12 of the 14 limit switches evidenced no record inconsistencies, it appears that enough data was available to the inspector to determine whether actual hardware problems were suspected. Pursuit of this ques-tion with the licensee should have been an important inspection point to place the concern in its proper perspective. Regardless of whether the identified documentation error was considered to be a violation or not, the question of whether improper hardware was installed is of greater safety significance. If only a record problem , existed, justification for a citation would be diminished. 2
(**.P (3.0 Continued) 97 MHnfl ~ rES 10 s; Issuance of an unresolved item was appropriate to allow time to determine i both the exact nature and reasons for the documentation inconsistency. j However, hardware acceptability could have and should have been completely resolved during the 85-16/13 inspection and documented as such in the : final inspection report. 30.3 Analyzing RIV Disposition 30.3.1 Statement of Inspector's Finding and Regulatory Concern The inspector believed that a violation of 10 CFR 50, Appendix B, Cri-terion VIII was identified because two NAMC0 limit switch identification numbers did not match those documented on the applicable installation travelers. 30.3.2 Develcoment of Findir,g
- How issue was researched and analyzed, including supportive bases; applicable documents consulted and by whom. Discuss appropriateness of documents reviewed.
Region IV management was justified in their direction ~ o the in-spector to determine whether additional, more recent tumentation existed to resolve the conflict. The licensee presented evidence of switch / traveler conformance on the one safety-related switch in question prior to issuance of the inspection report. On the non-safety-related switch, the conflict was not yet resolved; hence,. an unresolved item was issued. 30.3.3 Characterization of Finding Inspector's apparent safety concern and Task Group's evaluation. The inspector's concern centers around whether the licensee instal-lation and quality document controls were generically inadequate. With the after-the-fact evidence that hardware was not in question and that adequate documentation to confirm control of the switches was ava-ilable, the Task Group concludes that this issue has little I safety significance. A programmatic review of other part/ item documentation control did not appear justified because of the specific nature of this inspection (ie: NAMCO limit switches) and the fact that proper records were eventually made available. The timeliness of providing the correct travelers to the QA records vault could have been pursued as a document control issue or QA records issue (e.g., Criterion XVII), but apparently was not. P .M. 0 W
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(3.0 Continued) 98 FO 10 m 30 3.4 Nature cf Downgrading of Inspection Finding as it Appeared in Final Report with Brief Statement of Management's Reasoning Region IV Management believed that because the documentation inconsist-ency had been satisfactorily resolved for the safety-related switch, only a similar concern remained for a nonsafety switch. This justified fol-low-up as an unresolved item. 30.3.5 Manageme.t;s Role in Achieving Final Disposition Were management's actions sufficient to warrant downgrade? If yes., explain. Yes; based upon all the facts available to RIV management at the time of their decision to downgrade tne item. However, these facts included information provided by the licensee dirn tly without re-liance on independent evaluation or review by the on-site resident inspector. As stated in CPRRG-17 (IR 85-16/13), page 26, the Region IV-licensee direct contact on this concern, at this point appeared to represent a lack of trust of the resident inspector's judgement on this matter. This is troublesome from not only a managerial perspective, but also from the standpoint where, on the next page (p. 27) of CPRRG-17, the Region IV supervisor accepts the licensee explanation of why QA travelers were used on nonsafety-related switches without independent NRC review of this explanation. In fact, since the CPSES FSAR documents commitment to USNRC Regulatory Guide 1.97, further NRC inspection may establish the fact that be-cause the nonsafety switch is installed on an RHR valve, it provides a Type D variable monitoring function. This would require RG 1.97, Category 2 QA implementation. Such information would have been pertinent to the determination of whether a violation did actually exist. 30.3.6 If Item was Determined to be Unresolved, was there Sufficient In-formation in the Insoection Report to Focus Activities of tne Licensee / inspector to Effective Resolution No; but in this case the resciution was already in part effected directly between Region IV management and the licensee. Ultimate inspection and resolution by the Comanche Peak Task Group on site allowed the inspector , to ultimately pursue closure of their issue, although other problems in i process control were identified later by the inspection (reference: CPRRG-16, pp. 93-95). 30.4 Conclusion During the conduct of the inspection, the inspector should have deter-mined and documented the acceptability of the hardware for the two NAMCD limit switches in question. With tne information provided, development of the documentation concerns as an unresolved item was appropriate. 3 I
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(3.0 Centinued) 99 FEB 10 587 However, as evidenced by the direct contact.between the RIV supervisor and the licensee on this. matter, the apparent exclusion of the. inspector from the evaluation and independent review process is of some concern. The additioni.i. work traveler concerns identified and raised later (CPRRG-16) by the inspector with respect.to NAMCO switch installation do not reflect safety-significant hardware concerns. Whether they are indicative of procedural violations is not germane.to the substance of this concern. The safety -significance of this issue, at this point, is overshadowed by the ineffectiveness of the manager / inspector's ability to satisfactorily resolve valid inspection questions. (
Reference:
Com-pare CpRRG-16 (top of p. 96), inspector opinion to CPRRG-17, IR 85-16/13, (p. 26, last paragraph), RIV supervisor-position on' effective use of inspection time). I
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(3.0 Continued) 100 @ 1 0 1937
- 31. Inadeouate Procedures for Processing NRC-IE Bulletins
- 32. No Focal point in TUGC0 Construction for Tracking 31/32.1 Background l
These items were identified in 01 File 86-01 as Inspection Report 85-16/13, Issues 9 and 10. These were not items highlighted by 01 as underlined in Attachment 1 to Attachment MM. 31/32.1.1 Summary of Issue The inspection of TUGCO's handling of IE. Bulletins as part of Inspection 85-16/13 preliminarily concluded that (CPRRG-17, Attachment 8): " ...it is not clear how evaluations were assigned to construction and discipline engineering organizations ..and how they are factored into final evalu-ation..." Although the issues are never well described in subsequent drafts of Inspection Report 85-16/13, the files for six IE Bulletins (IEB) were l
- reviewed for possible field verification. For two (IEB 79-14 and 28) eackages considered closed by TUGCO, the inspector reviewed further actions required (in the form of supplemental responses.to the original responses to the NRC). The inspector concluded that the TUGC0 licensing procedures to control bulletin processing, including coordination of review activities, were inadequate.
Transcripts of interviews conducted by OIA (Attachment 0, Pages 627-629) with the inspector's supervisor indicate that, initially and prior to the first draft of Inspection Report 85-16/13, the inspector vercally ; suggested violations (presumably of 10 CFR 50, Appendix B). l Although the bases for the discussed violations were never specified, the items were eventually presented as unresolved item 85-16/03-02 and a TUGC0 Task Force review was described M D:::11 h af Insoection Report 85-16/13 to determine tne acequacy of procedures and the completeness of associated records. 31/32.1.2 References
.1 TUGC0 Procedure No. NOE-205 (Revision 1), Licensing Correspondence
.2 01 File 86-10; Attachment D (Pages 573-582,627-629).
,.3 CPRRG-17 Inspection Report 85-16/13( Pages 29-32) and Attachments 2-8A, and 15 31/32.2 Independent Assessment TUGC0 Procedure N0E-205 assigns the responsibility for coordination of I review and response for the IEB to the Operation Support Superintendent, and the maintenance of a log and a plan for response to the Technical rq q *2.;m
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FE3 1 u 1987 - (3.0 Continued) 101 Support Engineer (in Step 4.1). Questions or concerns would be presum-ably directed to the TUGC0 Nuclear Licensing Supervisor, and the licen-see's engineering resources. There is no clear regulatory basis for the administrative processing and the ability to track NRC licensing commitments. Therefore, no enforce- l ment action would be appropriate for perceived deficiencies in the lic-ensee's administrative processing of IEB responses. Clear variance from IEB commitments, depending upon the safety significance of the deviation, would be grounds for a Notice of Deviation. A violation could also be issued if actions taken to correct IEB identified deficiencies are in-adequate. As evidenced in the Task Group's review of Issues 28 and 30, the adequacy of TUGCO's actions with respect to IEB's are subject to NRC review and may be left open until clear safety issues can be resolved. j 31/32.3 Analyzing RIV Disposition 31/32.3.1 Statement of Inspector's Finding and Regulatory Concern Contents of the files used to track the progress of information organized by TUGC0 Licensing in preparing IE Bulletin responses to the NRC (see Issue 29) led the inspector to conclude that unspecified procedural in-adequacies existed. These apparently involved the absence of direction to TUGC0 construction management personnel for IEB action, particularly for files classified as closed. 31/32.3.2 Development of Finding How issue was researched and analyzed, including supportive bases; applicable documents consulted and by whom. Discuss appropriateness of documents reviewed. There was no regulatory basis offered to support the initially pro-posed violations. Issues 28 and 30 do, however, support the fact that specific quality documentation was available to followup IE Bulletin commitments in the licensee's overall records system. 31/32.3.3 Characterization of Finding Inspector's apparent safety concern and Task Group's evaluation. The inspectors considered the licensee's' IES review processes and records files inadequate to develop the comprehensive response and l followup action. No direct safety concern is evident. i No safety significance is apparent to the Task Group. The issue l involves contentions over the required / desired process that the licensee uses to handle IEBs. The adequacy of actual licensee cor-rective action is not in contention. l
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.(3.0 Continued)L 102 '2
- T Should it have been pursued for more examples of programmatic sig-nificance; was itt Yes, apparently only six IEB's were audited and two selected for followup upon which to base the inspector's concerns. A management issue could have been developed if TUGC0 was not tracking and meet-ing their IES commitments to the NRC.
Was it reasonable to expect further undirected action by the re-l' porting inspectors? If yes, wh.at action should have been taken?
.The inspector failed to develop / provide a coherent assessment of
, the licensee's overall processes. Additional broadening of the in-spection to develop either a basis for additional licensee action or-enforcement is well within normal expectations for the inspector. 31/32.3.4 Nature of Downgrading of Inscection Finding as it Appeared in Final Recort with Brief Statement of Management's Reasoning Findings were not downgraded; no enforcement. issues were developed in the draft report (s). 31/32.3.5 Management's Role in Achieving Final Disposition Were management's actions sufficient to warrant downgrade? If yes, explain. I Not applicable, no downgrading occurred, . 31/32.3.6 If Item was Determined to be Unresolved, was there Sufficient In-formation-in the Inspection Report to Focus Activities of the Licensee /Insoector to Effective Resolution Sufficient information was not provided for the general concerns of Items 31 and 32. Report-85-16/13, Detail da was vague and consisted of two i sentences with reference to unspecified IE Bulletins, Circulars and l Notices, and associated procedural inadequacies, j l 31/32.4 Conclusig i Issues 31 and 32 were never proposed as violations wnich were later down-graded. The unresolved item was not warranted since it is unclear what , was unresolved (i.e., potential noncompliance) other than the inspector's i questions as to the process of putting a Bulletin response together. I The inspector was assessing the in process status of specific IEB's that he assumed were closed because their associated tracking files (under N0E-205) were closed. However, while TUGC0 Licensing's responsibilities were considered finished since no further responses to NRC were'antici-pated, the inspector incorrectly interpreted closure of Licensing's bul-N y..), .i,t"* a , 1 I
(3.0 Continued) 103 M ?iJJ31j t 2 ryg ;9 gg7 letin files as being in a status which would permit final verification of corrective actions. As previously concluded in Issues 23 and 29, the completeness of administrative files is not a primary concern in NRC Bulletin followup. However, the unresolved items associated with the TUGC0 Task Force established on March 1, 1986 should serve to improve the coordination and status tracking of licensing commitments. Con-sidered collectively, the concerns surrounding Items 28 through 32 cculd have been combined in a single paragraph with no unresolved items. t t
t b,)]P* (3.0 Continued) 104 OM.I3[ 4R 10 W
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3 4 '. BISCO Fire Barrier Seal Certification 34.1 Background
'This item was identified in 01 File 86-10 as Inspection Report 85-16/13, Issue 12, and was a " highlighted" item of discussion as underlined in f Attachment I to Attachment MM. - -
34.1.1 Summary of Issue Original Finding During conduct of Inspection 85-16/13, the inspector followed the progress of a previous unresolved item from Unit 1 Inspection Report 84-22, issued in October 1984, concerning the certification of-chemical and physical testing for BISCO fire seals used in electri-cal penetrations. The inspector questioned the lack of a reference to required testing in associated certificates of compliance (C0C). Item 84-22-04 remained unresolved pending test certifications. Exoansion of Findings - The inspector was notified by TUGC0 QA personnel that unresolved item 84-22-02 was ready to be closed. The inspector left the pre-vious item open and proceeded to adaitional concerns based on memor-anda and telephone discussions with BISCO and TUGC0 personnel. TUGC0 Nuclear Engineering generated a design deficiency report (TODR) on 8/27/85 and recommended corrective action on 10/1/85 to address the questionable certification of certain BISCO electrical penetration seals (PCA-76 design). The inspector worked with a consultant during conduct of Inspection Report 85-16/13 on the BISCO seal issue, and initially proposed a violation (Appendix B, Criterion XV, Nonconforming Material) for failure to document the deficient fire seals on an NCR, per QI-QP-16.0-4 Identification of Class IE Equipment with Deficient IEEE 323/344 Test Reports. A second violation was proposed for failure ! to adequately evaluate and report a significant construction defi- ! ciency under 10 CFR 50.55(e). Further, the inspector recommended ; an 0I investigation, through memoranda to Region IV management, into the the ciscrepant statements as to original (1975-1976) test fail-ures. The inspectors selected 8 penetrations, which were identified for rework by TUGC0 engineering, for further records review. Apparently conflicting information was found in a series of six letters between TUGCO, BISCO, and American Nuclear Insurers ( ANI) during the one-year period, November 1984 - October 1985. The inconsistencies in-volved were: i 1
. 3 . a t .
.(3.0 Continued) 105 lJ FEb' u W87 retest of an upgraded sample with a design change that added a 3/8-inch proprietary coating.
ANI versus BISCO test standards in meeting ASTM E-119. 1 ANI had Oescinded their original certified acceptance (referred to ' as S-26) of the BISCO seal design configuration (referred to as PCA-76). The conflicts addressed in Inspection Report 85-16/13 centered about BISCO's statements in their 9/16/85 letter to TUGC0 that ANI testing standards were more stringent than those required by the ASTM or NRC. Although the BISCO seal design as installed at CPSES' apparently... had original 1976 test certification lost, failed a subsequent ANI retest, and had S-26 rescinded by ANI, BISCO stated that the' design still met' required test standards. However, the next paragraph on Page 2 of the 9/16/85 letter de-scribed an additional 3/8-inch proprietary coating (" retrofit and/or design change") that was not part of either the originally accepted S-26 or the installed seals. A related memorandum discussing the test record discrepancies, and recommending possible OI investigation and NRC vendor inspection of BISCO QA records was prepared in November and revised twice prior to being sent to NRC Headquarters by Region IV for generic consi-deration. Final Disposition Two unresolved items (06 and 07) were. finally included in Inspection Report 85-16/13 to address: (a) re-evaluation of available 1976 test documentation versus more recent test failures for deportability under either Parts 21 or 55(e); and (b) the inconsistency between i ANI testing "in accordance with" ASTM E-119 and BISCO's claim that the ANI testing " exceeded" the standard. i The inspector's memorandum discussing broader implications routed to his Region IV Division Director, was revised and eventually directed to the NRC Vendor Inspection Branch for generic considera- . tion in April 1986. 34.2.1 References 4
.1 CPRRG-17, Attachments 2 through 8; and Attachment Ba, Report 55-16/13, Appendix C, Details 2h and 6 (Pages 7-9) {
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.2 OI File 86-10 (Pages 26-28) and Attachments MM (Pages 17-18), GG I (Pages 2-19), and 0 (Pages 631-669)
.3 CPRRG-16 (Pages 96-101) and Exhibits 67, 68, and 69
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(3.0 Continued)" 106 W 20 W
.4 CPRRG-17 for Inspection Report 85-16/13 (Item 12, Pages 33-38) and:
Attachment 16, TDDR-FR-85-063 Attachment 17, QI-0P-16.0-4 Attachment 18, December 2, 1985 Memo (H. Phillips to G. Zech)
.5 A5TM Standard E-119, Standard for Fire Protection of Building .
Material
.6 IEEE.634, Standard Cable Penetration Fire Stop Qualification Test
.7 FSAR Section 9.5
.8 ' Federal Register Notices (Volume 45, No. 225, Page 76608), Final Appendix R Rule, Section M. Fire Barriers
.9 Fire Protection Generic Letter 86-10 dated 4/25/86
.10 National Fire Codes, NFPA 251-1979, Standard Methods of L % - .m of Materials 34.1.3 Discussion of Details Because of the complexity of the issues involved, the following para-graphs address in detail the circumstances surrounding the BISCO seal qua li fi cati on '. A chronology of events is also included in an att' Ached table to more clearly assess the development of the concern for certified fire test data for BISCO cable penetration seal design PCA-76:
Oricinal Fire Tests Conflicting statements in two letters dated 11/13/84 and 9/16/35 from BISCC to TUGC0 (Attachment 18 to CPRRG-17) were found as re-por ted in Inspection Report 85-15/13. These involved a large scale i fire test which, because of its size, required a separate hose stream test apoarently conducted at the Portland Cement Association in 1976. The records of the separate hose test were either de-stroyed or lost by SISCO. It was noted that botn tests, as origin-ally submitted to ANI, received certified acceptance. When ANI was later unable to locate their file copy, and reevested a replacement from BISCO, the documentation for the 1976 test was ciscovered to be unavailable. Retest Recuested by ANI
]
The ANI then requested that BISCO conduct a new retest to ANI stand-ards at that time which BISCO stated in their 9/16/85 letter were
" ..more stringent than those required by the ASTM or NRC." The retest experienced a burn-through at 2 hours, 35 minutes; however, the BISCO position was that, for the seal design which failed the retest (i.e. , did not demonstrate a required 3-hour rating), other test documentation was available which "... substantiates the fire seal cesign tnat f ailed the ANI fire test standards. . ." and which would ".... meet and surpass the test standards of ASTM E-119 and the NRC." The ANI position on this retest, as stated by BISCO in their
4 4 FG 10 q' (3.0 Continued) 107 9/16/85 letter to TUGCO, was that acceptance of the electrical cable tray blockouts sealed with RTV silicone foam (i.e., the BISCO design) would be based on the prior certified acceptance, but "for insurance purposes only." TUGC0 Corrective Action A Nuclear Engineering Design Deficiency Report (T00R) No. FP-85-063 was reported on 8/27/85 to document the rescinded ANI acceptance of S-26 for the 3-hour rated fire barrier. The corrective action approved by TUGC0 management on 10/1/85 was for BISCO to supply evidence of satisfactory testing and up-to-date ANI acceptance for all designs covered by S-26. Preventive action included the intent that BISCO provide evidence thst "the balance of ANI acceptances used at CPSES are current." The actions were due to be implemented by 10/15/85. The approval of the corrective action also recommended that the deficiency was not reportable under either 10 CFR Parts 21 or 50.55(e). Test Standards IEEE 634-1973 (Exhibit 68 to CPRRG-16) establishes type tests for qualifying the performance of cable penetration fire stops when mounted in rated barriers. The test requirements confirm the ade-quacy of the design, in this case BISCO penettstion detail PCA-76, in meeting the t,<o and three hour fire ratings coscribed in tne FSAR and Appendix R requirements. The IEEE standard set: criteria to be met (i .e. , temperature on the cool side of the fire stop, an intact barrier) and a method of testing in accordance with the time- 1 temperature profile of ASTM E-119. The CPSES FSAR states that these materials be tested in accordance with the IEEE and ASTM standards. 34.? Independent Assessment 3a.2 1 Disposition of Deficiency Section 15.0 of the TUGC0 QA Plan for Nonconforming Items (CPRRG-16, Ex-hibit 15) states that a nonconformance report is used to document defi-ciencies unless another method is prescribed by a specific procedure / instruction. The TODR initiated to address the fire seal qualification records met this intent. Further, the seal is an Appendix R concern and the SISCO foam is in no way governed by TUGC0 commitments with respect to IEEE Standards 323/344 whose scope is qualification of Class IE elec-trical equipment. 34.2.2 Determination of Deportability j The TDDR corrective action, as initially aporoved, was concurred in by I TUGC0 management as not reportable under either Parts 21 or 50.55(e). j While the evaluation for deportability is not sufficiently described, -
l . JW 4* W4Ti.hf ;f ! (3.0. Contin'ued) 108 ID E than a discussion by the inspector with a TUGC0 engineer regarding a i question on the effort of the affected seal / penetration / cable.on safe i shutdown systems is documented. The limited amount of rework (8 pene-trations), the outstanding questions as to BISCO records, and the rele-vance of ANI certification to NRC qualification criteria all point to 1 a nonreportable condition, pending further information. On the other i hand, the questioning by the inspector cf deportability and the subse-- ; quent open item (85-16/13-06) was appropriate, eventhough later TUGC0 re-evaluation concluded (bases unknown) that the issue was not reportable i under 50.55(e). Further research into.and discussions with TUGC0 Engi- 1 neering personnel were required for this issue before a balanced assess- ) ment as to the adequacy of the initial 50.55(e) decision could be mode. The Part 21 deportability is similarly unresolved (and the item 85-16/ 13-05 therefore appropriate) as to BISCO's test methods,' records, and the penetration detail in question. The inspector does not clearly de-velop wnat actually is in question, although the bottom line concern of . BISCO Detail PCA-76 for test qualification as a 3-hour rated seal is - valid. Test results certified by the ANI have no regulatory significance or bearing; the ASTM E-119 methods are identical but ANI certification is not an NRC requirement. Test results prior to 1977 are practically i outdated and not usually pertinent. Also of note is that the IE generic I correspondence sent from Region IV in April 1986 has not bad any measur-able. impact to date. 34.2.3 Recommendations for OI Involvement (Phillips 12/2/85 Memorandum to Vendor Branch) The reco:nmendation in the memorandum for possible 01 investigation is a reasonable item for the inspector to raise to his supervision, although the issue (material falsification by inconsistent test qualification claims in BISCO letters) is not well developed. In the first memorandum
- to his supervisor en Novemoer 25, 1985, the inspector does not establish the clear connection between his impressions of " wrongdoing" or "falsi-fication" and the ultimate safety concern, i.e., the adequacy of the installed seals as cesigned 3-hour barriers. Since the basic concern has already Deen identified by the licensee on the TDDR (CPRRG-17, In-spection Report 85-16/13, Attachment 16), it appears that the inspector could have additionally assessed the licensee's evaluation of this issue, to furtner support the need for 01 involvement at that time.
On the other hand, Region IV management's direction to the inspector to rewrite the memorandum improcerly emphasized the need for such a memo at that time. What was needed was supervisor / inspector interaction to refocus-inspector attention to the basic safety concern. The inspector recommendations to Region IV were proper since they represented the in-spector's perception of a serious concern, even though that concern may not have been sufficiently developed by the facts. Management's role should have been something more than a passive reviewer of the inspec-
109 E9E (3.0 Continued) tor's write-up. Additional Region IV specialist expertise could have been dedicated to clarify the technical concerns in order to determine whether either 01 or IE Vendor Program Branch followup were necessary. In the handling of this concern regarding the request for 01 involvement, the apparent inability of the inspector and his supervisor to work to-getner on this issue represents the root of the problem. An inspector should be able to discuss and/or document his concerns with his super-visor without being criticized for the content of such concerns. If the recommendation for 01 involvement was improper, as stated by Region IV, further evaluation and effort by Region IV was appropriate to clarify their understanding of the concerns. Both the inspector and his manage-ment cculd have wor (ed on resolving the questions and differences in a more timely manner. 34.2.4 Generic Implications The inspector's memorandum to NRC Vencor Inspection Branch (datec 12/2/85 but apparently not transmitted until properly addressed to the Region IV Division Director on 3/6/86) was ultimately directed to IE Headquarters in April 1986. The successive personnel interactions on this issue be-tween November 1935 until April 1986 were driven by the need for sub-stantive technical discussion (never fully provided) on the generic issue in question: the test method and seal design configuration qualified by BISCO and later apparently disapproved by ANI. The memorancum was, in its initial version, substantive enough for Region IV supervision to: Request Vendor Inspection assistance. Seek OI (Region IV) opinion. l
-- Direct the inspector to clarify requisite technical details.
Region IV eventually took action on each of these items, although both the timeliness and interaction with their inspector were questionably nandled. Based upon what was ultimately done, more active Region :V participation in the issue cefinition and development, earlier in the process, could have effectively resolved the overall concerns. 34.3 Analyzino R:V Disposition 34.3.1 Statement of Insoector's Findings and Regulatory Concern The inspector's review of a deficiency with BISCO fire seals which was documented by TUGC0 en TOOR FP-85-063, led him to believe that:
-- a failure to document the deficiency on an NCR was a violation of Appendix B, Criterion XV.
b7 (3.0 Continued) 110 E ' ^ 1987 inadequate evaluation (i.e., no significant reportable deficiency report) was identified and represented a violation of Part 50,55(e). his request for an 01 investigation into apparently conflicting test results was ignored by Region IV management. 34.3.2 Develo: ment of Finding How issue was researched and analyzed, including supportive bases; applicable documents consulted and by whom. Discuss appropriateness of documents reviewed. The findings were expanded from review of an existing unresolved item which could not be closed and led to the identification of in-consistencies between BISCO letters addressing certain test methods and ANI acceptance rescinded for certain records. The inspector l (anc his consultant): (1) read the letters, (2) called BISCO and TUGC0 engineering, and (3) proposed violations as well as recommend-ing 01 and generic NRC Vendor Inspection Branch involvement. At i the time of the inspection, review of IEEE ASTM test methods was I apparently performed and field inspections to describe where and l what kind of barriers were involved, was conducted. l 34.3.3 Characterization of Finding Inspector's apparent safety concern and Task Group's evaluation. The inspector expressed generic concerns (e.g., falsification) over the vencor supplied material and design with respect to BISCO seals, their testing conduct, records and certification process, and potential Part 21 implications. The Task Group determined that the basic safety concern was that the adequacy of certified fire test data to support 3-hour barrier rating for BISCO caole penetration seal design PCA-76 was suspect and therefore represented a legitimate safety question. However, the fundamental concern was initially identified by the licensee and their corrective action was in progress and properly directed. While any generic implications as they apply to BISCO are being reviewed by the Vendor Programs Branch, the hardware impact at CPSES was limited, and the overall issue was of non-safety significance. Was is reasonable to expect further undirected action by the re-porting inspectors? If yes, what action should have been taken? More interaction with TUGC0 engineering was reasonable since tne item was originally initiated by the TUGC0 TDDR and corrective actions were in process of implementation. I
- q f en 08 $ i tv7) 9 [ 30..
(3.0 Continued) 111 34.3.4 Timeliness Was communication between inspectors in Region IV Management on final resolution timely? The only item that appeared to have been not handled in a timely manner was the memorandum from the inspector recommending OI inves-tigation and Vendor Programs Branch followup, was delayed by Region IV management unnecessarily. 34.3.5 Nature of Downgrading of Inspection Findings as it Appeared in Final, Report with Brief Statement of Management's Reasoning The violations were appropriately dispositioned. The NCR issu, was clearly not a violation, the 50.55(e) evaluation was discreti: nary and ultimately justified as nonreportable. 34.3.6 Management's Role in Achieving Final Disposition Were management's actions sufficient to warrant downgrade? If yes, explain. Yes; in fact, the existing unresolved item had previously embraced i the substance of the concerns and expansion of the item to include. ' the later information would have adequately treated this issue. j What further action should have been directed to proper resolution. Additional inspection by inspector to expand information basis More clarification on the inspector's reasoning for a potential l falsification, in particular: !
- Differences (if any) between ASTM 119 and IEEE 634
- Purported 1975 versus 1976 fires. l Specialist inspection / Consultant inspection i Development by the consultant of the conterns raised by this issue was inadequate. The inspector did nothing to clarify this inadequate development or resolve the questions, but in- j stead evaluated the concerns to broader questions of compliance !
and generic implications. l l 7
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(3.0 Continued) 112 13 sir 3J'1 fee .; 397
~ Referred to other NRC office (IE)
A more active role by Region IV management in developing the content and basis for the potential 01 involvement and generic considerations, including use of a fire protection specialist for further review of the inspector's origiati concerns, was appropriate. 34.3.7 If Item was Determined to be Unresolved, was the _ Sufficient In-formation in the Inspection Report to Focus Activ?.ies of the. Licensee / Inspector to Effective Resolution The 50.55(e) proposed violation was appropriately downgraded and handled as an unresolved pending TUGC0 corrective action and re-evaluation of deportability. Current status of item The 50.55(e) deportability was later determined to be not required by TUGCO. The inspector raised a legitimate concern for the 3-hour rating of, essentially, 8 penetrations concerning BISCO seals. More development of the question of what constituted a valid qualifica-tion test'(i.e., ASTM and IEEE specifics) was necessary to place the inspection issues and the controversial memoranda into better perspective. This development might have answered, in a more timely anc effective manner, the larger outstanding issues regardir;- Part 21 and falsification allegations toward BISCO. The actual notice of the rework on the 8 penetration seals (e.g.. , were they modified to add damming boards, proprietary coatings, or internal blockout subdividers). 3*.4. Conclusions The inspector's basic concern represented a valid safety issue that the fire seals in question had to meet a 3-hour barrier rating per the FSAR. The development of these concerns, providing additional technical ques-tions to the year-old unresolved item 84-22-04 (which fundamentally posed the same question) was premature and, in the case of the lack of an NCR wnere a TDDR already existed, was incorrect. Had the inspector maintained focus on the more fundamental quality issue of the seal rating qualifi-cation, other related concerns (e.g., 50.55(e) and Part 21 deportability) would have eventually " fallen-out" of the ultimate resolution of BISCO seal detail (PCA-76). That a violation could have been written (and that latitude was apparently given the inspector) for the undeveloped (at the time of Inspection Report 86-16/13) 50.55(e) report is peripheral to this issue at this point since TUGC0 subsequently determined the seal quali-fication to be nonreportable. w _ - _ _ _ _ . _ . _ - - .---
u Ph7 (3.0 Continued) 113 led'$$$) l FEB 10 ss; , Finally, the. inspector's memoranda to Region IV management appeared ato lack substantive supporting evidence to-justify immediate 01 involvement, j However, these memoranda did portray valid questions requiring further ; NRC review (OI investigation, IE generic-vendor inspection, and Region ! IV technical followup). At this point, Region IV management could and j should have directed the insaector to focus on the immediate safety 1 issues at hand at.Comt.nche Peak, pending further support frem othe* NGC l inspection resources (e.g., fire protection specialists or consultants). To have directed the inspector to merely rewrite the memo provided im- i proper guidance to this issue at that time and to then criticize the in- ' spector for the content of that memo constituted a failure of management in the proper handling of this issue. em + 8
(3.0 Continued) 114 I gg 3 g -)gg CHRONOLOGY OF EVENTS FOR ISSUE 34 Date Correspondence ' Subject and Comments
- l October.1976' N/A BISCO test data for PCA-76 (eventually lost in fire).
10/11/84 NRC Inspection Report Unresolved item 02 on test certification. 50-445/84-22 issued. 11/13/84 BISCO to TUGC0 Stated the seal met test requirements (IEEE and ASTM). 8/20/85 ANI to BISCO Withdrew acceptance for BISCO' S-26. 8/20/85 ANI to TUGC0 Informed of test failure and rescindedL acceptance (upgrade test to ASTM-319) 8/27/85 TUGC0 TCCR No. Reoort initiated by TUGC0 Engineering for FP-85-063 deficiency. 8/29/85 TUGC0.TDDR No. Documented the seal deficiency. ! FP-85-063' 9/16/85 BISCO to TUGC0 Details supporting withdrawal of test acceptance (still met ASTM-E-119) 10/1/85 TUGC0 TODR No. Proposed corrective action for TDDR approved FP-85-063 by TUGC0 management. 10/15/85 TUGC0 TODR No. Due date for TODR corrective action imple-FP-85-063 mentation. 10/16/85 TUGC0 Interoffice Memo- Discussion of rework. randum (Creamer to Kennedy) 10/24/85 BISCO to TUG:0 (Trent Identified 8 penetrations for rework. to Anger) 12/2/85 NRC Interoffice Memo- Recommendations to NRC Vendor Programs randum (Phillips to G. Branch to inspect BISCO QA Program (dis-2ech, Vendor Programs cussion of potential false statements). Branch) 3/6/86 Memorancum Redirected to Same as 12/2/85 memo. Directcr (Johnson) 4/2/86 Region IV Correspondence Same as 12/2/85 memo. to IE (Johnson to Partlow) 4/4/86 Inspection Report Final issuance (discussion of BISCO in 85-16/13 Detail 6). l
i "? 115 f&)f[ i . ero1O g-4.0 OVERALL
SUMMARY
AND CONCLUSIONS This section of the Task Group 2 Report depicts the summary findings, conclu-sions, and recommendations resulting from the examination of the issues re-lating to the process and disposition of the inspection findings of OIA Report 86-10. The format of this section will include: Task Assignment (Section 4.1 through 4.5)
- Summary and Conclusion Recommendation Where appropriate, the applicable section(s) of the report will be referenced.
I In addition to the task charter assignment contained in Appendix 5.2, the Task Group is providing, as Section 4,6 of tnis report, findings and opinions for consideration by the CPRRG in assessing the potential for " broader" implications. M
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. l (4.0 Continued) 116 t[ I Fre10 m !
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4.1 Task Assignment Review information provided by IE, Region IV, the Comanche Peak Project Office, or others to become familiar with the investigation and CPRRG record. Where applicable, assess the accuracy and completeness of the records provided against the primary or source document. 4.1.1 Summary and Conclusion
- Report Section 1.3 details the methodology used to compile the -
record, establish pertinent records, and item files. ,
- OI File 86-10 address only 16 of the 34 issues. Attachment MM in-dicates that these were the only issues discussed by Phillips during his OIA interview. This tends to provide an incomplete picture of the technical issues at question. If more than one half of the issues (18 of 34) argued by Phillips and Westerman were considered trivial by Phillips, this could have significant bearing on Phillips' allegations of harassment and intimidation. By not analyzing all 34 issues the 01 effort does not present a complete balance of the technical issues.
- OIA interviews of Phillips, )Hunicutt,and )donot focus on the pure technical aspects of the 34 items to t e extent the interviews of Westerman, Barnes, and others do. Goldberg was not present when Phillips was interviewed; accordingly, the techni-cal aspects of the issues were not addressed in depth, and a fol-l lowup intery w not conducted. Additionally, interviews with Hunicutt and might provide additional perspective on the l
technical issues presented in Inspection Report 85-07/05.
- The Task Group does not have a clear picture of when management changes occurred in Phillip's reporting chain, what his charter was, or what his relation was to the other assigned inspectors. The lack of this information does not impact on the Task Group's technical evaluation, but may be pertinent when addressing broader Region IV concerns.
- Records were generally complete. The availability of the CPSES FSAR would have been helpful to provide background review of licensee commitments for technical assessment. When determined necessary, calls to NRR readily obtained the needed information.
l t
- In some cases, the testimony appeared to provide conflicts between the different parties regarding the facts surrounding events. Re-solving these conflicts would also have been helpful, but the Task Group did not consider additional interviews necessary to resolve these conflicts.
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(4.0 Continued) 117 g g g )gg 4.1.2 Recommendation
- Consi ration should be given to further interview of Hunicutt and i to get their views on: (1) the technical aspects of the 85-07 l issues (i.e., why they concurred without question), and (2) what was Phillips' charter from their perspective (i.e., QA/ allegations versus in process hardware inspection).
- In order to facilitate further review, in appreciation for line responsibilities, Region IV should provide a paper that addresses:
(1) relationship of Phillips, Cummins and Kelley, (2) Phillips' charter as SRI, and (3) time line of who supervised and interfaced with Phillips, and when, from early 1985 thru mid-1986.
- The Task Group 2 findings, specifically relating to the 18 items
not evaluated by the OIA 86-10 report, should be considered in the overall assessment of whether the proposed 34 items were unjustifi-ably downgraded in the final reports as a result of Region IV man-agement harassment, intimidation, and pressure on inspectors. 1 e l l l 5.,
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.. 3 aD, (4.0. Continued) 118 w /L j rec ; O 1997 4.2 Task Assignment Identify tne specific process and disposition issues from OIA Report 86-10 (34 issues of Attachment 1 to Attachment MM).
l 4.2.1 Summary and Conclusion
- The. specific process and disposition issues developed from the record are contained in Sections 3.1 through 3.34 of this report.
4.2.2 Recommendation
- OIA Report 86-10 should be clarified to cross-reference the 16 technical items analyzed for dispositia to the 34 item listing in Attachment 1 to Attachment MM of the report.
- Each issue nas been, analyzed independently of other issues, except where they have been Combined as noted. It is recommended that tne conclusion for each individual issue be viewed as an independent assessment of that single issue. Overall conclusions reached by the Task Group are documented in this section of the report and in the Executive Summary, i
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(4.0 Continued) 119 m : ? se7 y 4.3 Task Assionment ] I Analy:e each issue, independently assess and describe the process and disposition by which the item should have.been handled. Identify the -] q NRC, IE or Regional process, guidance or practice that was used in making this independent determination. 4.3.1 Summary and Conclusion
- Each issue was independently assessed in Section 3.1.2 through 3.34.2 of this report using the process described in Section 1.3. '
= The process, guidance, or practices utilized in independently as-sessing the individual issues have been, in. general, based upon in- ,
spector experience and lessons learned from field experience in dealing'with licensees and implementing the inspection program. In ecst cases, judgement was required in addressing these issues. For example, where safety significance was determined to be minor, the' intent of the inspection program might be better met by not issuing a low-level citation, even though a procedural ' violation might exist.
- The. working relationship between any inspector and his supervisor is extremely important in reacning a proper conclusion when handling individual inspection items. At CPSES, the inspector / supervisor relationship broke down'and deteriorated to the point that the in-spection items were apparently not being viewed objectively by either side. The technical review process was adversely affected by these interpersonal problems.
4.3.2 Recommendation
- It should be emphasized that IE guidance (e.g., inspection modules, etc.) is.just that, and should not substitute for judgement or the normal discussion process used by inspectors and their management in reaching inspection decisions. It is recommended that tne IE Manual itself provide discussion of the importance of this relation-ship in line with the intent of inspection versus a totally pre-scriptive enforcement policy. There should be less reliance en strict / literal interpretations of IE guidance.
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(4.0 Continued) 120 dh[3 l FEB 10 $87 4.4 Task Assignment j Analyze the actual process and disposition of each issue. Describe the ] process by which it actually was handled including where applicable, the { identification and classification as a finding (with references) by the ! inspector, inclusion in the draft reports, evaluation by Region IV man-agement, and inclusion in the final report. Particular attention and discussion will be provided to items where there is an absence of agree-ment on process or disposition. The basis for the disagreement and documentation thereof, including timeliness of review, signature, con-currences, and report issuance will be described. 4.4.1 Summary and Conclusion
- The Task Group analysis of the Region IV disposition of each isfue is represented by Sections 3.1.3 through 3.34.3 and the metnodoicgy described in Section 1.3.
* 'he inspectors apoeared to emphasize the use of inspection guidance (e.g., modules) as requirements and viewed Appendix B compliance as an end in itself instead of a means of assuring a quality con-struction product. In this light, the inspectors' development of most findings was insufficient, stopping at the perception of an Appendix B violation, without further inspection and determination of safety significance, root cause, or programmatic implications.
- On the other hand, Region IV failed in several instances to redirect the inspector to properly develope the safety issues. The disposi-l tion process stopped short at the inadequacy of the inspection items as documented and thereby neglected, in some cases, to discern an underlying valid concern. For almost all of the 34 issues, however, the safety significance was either non-existent or minimal.
- Based on the record, technical support for the inspectors aopears to have been marginal. The record shows little or no involvement of region-based tecnnical experts. The use of an independent party to establish the tecnnical issue (s) was not pursued. The inspection focus and SRI supervision of the contractor inspectors involved in these issues appears to have contributed to the technical problems l that developed.
- There was a propensity on the part of the inspectors to attempt to write multiple citations in dealing with one central identified licensee deficiency. The most blatant application of this philo-sophy was in dealing with the programmatic 10 CFR 50.55(e) issue.
i l
l (4.0 Continued) 121 fih Wgg3.[DT 4,4.2 Recommendation
- Region IV philosophy en inspection must be established and conveyed to all inspectors, and the inspectors charged with conduct of field inspection in line with this philosophy. Where technical differences on items exist, management is responsible for resolution. Where differences in philos.ophy exist, administrative action may be ao-propriate.
Region IV management should carefully evaluate the use of consult-ants / contractors in meeting regional inspection program goals. N .;-) .
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l (4.0 Continued) 122- " Tf-4910 lor 4.5 Task Assianment I In addition to describing the above process the Task Group's final report i will:
- a. Describe how the task was performed. I
- b. Identify where there are differences between agency ' guidance, IE guidance, and Region IV guidance and areas where guidance does-not exist or is subject to wide interpretations. Include where applic-able:
+ !
Where and how this failure to follow guidance has occurred. ! For items of disagreement, express an opinion on whether the guidance for process and disposition was, or was not, followed. l For disagreement for wnicn no guidance exists, express an opinion on the appropriateness of the process and disposition actually performed in light of the signifi::ance and implica-tions of the disagreement.
- +. Where guidance does not exist, express en opinion as to what guidance is needed.
Where guidance'does exist, but there are differing interpreta-tions, recommend a course of action. 4.5.1' Summary and conclusion The Task Group Review Method is described in Section 1.3 of this report and the analysis of disposition issues is contained in Sec-tions 3.1 through 3.34. Failure to. follow existing NRC procedures was not the root cause of these problems. Improved guidance on resolution of inspector / management differences or better concurrence procedures for repc-ts woulc not, in the Task Group's opinion, have prevented these proolems.
+
However, some guidance /NRC procedural discrepancies did exist: Instances occurred where the intent of unresolved issues were misapplied by management, particularly in report 85-07. In these instances, management used the unresolved item as a l vehicle to acknowledge, in the inspection report, that an in- l spection concern existed, and perhaps in some cases, to appease the inspector. However, in other instances, management used ! the unresolved item to force licensee actions where stronger enforcement was not warranted and probably would never have cccurred. In these latter cases, the Task Group considers the ! use of the unresolved item to be proper in lignt of current inspection practice. I
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v (4.0 Continued) 123 77 10 1987 IE Guidance on 50.55(e) was not properly interpreted by the inspectors. , An immediate OIA investigation into these issues may have not ' been appropriate. A peer technical review could have been initially directed to scope the technical validity of the in-spector's concerns. It is the Task Group's opinion that the technical review by OIA was not rigorous and shows instances of predisposition of the investigators. This is particularly supported by the failure of Goldberg to interview Phillips and the manner in which Westerman was questioned, particularly during the second day. The differing professional opinion (DPO) policy was not pursued and therefore a timely independent overview of the differing technical opinions was not provided prior to establishing wrongdoing. A fundamental questien arises regarding the identification of legally-supportable Appendix 8 violations (e.g. , failure to follow procedures) with minimal safety significance. While the enforcement regulations imply the issuance of citations, guidance suggesting that a viola-tion may at times not be appropriate is lacking. The relationship oetween and inspector and his supervisor at reaching the proper decision to achieve inspection program goals in this regard is crucial. The Professional Differing Opinion process, while pertin-ent to a specific technical question, is not especially cogent to philosophical differences on the way inspection results are handled. It is essential that regional management overview and maintain effective implementation of the inspection program, including the recognition and resolution of philosophical differences. 4.5 2 Recommendation Consider a NRC policy statement regarding different professional j opinions to address instances when a difference of opinion develops i which adversely impacts on the 1.nspection process and delays report issuance. i Guidance to OIA should be provided to insure a careful review of i cases (such as these) where harassment and intimidation are alleged. The technical issues should be competently resolved first, preferably , by a technical peer review, prior to further investigation of harass- l ment and intimidation issues. 1 IE guidance on 50.55(e) inspection criteria should be clarified to prevent develec ent of the interpretation differences. Region IV management should take steps to insure that the QA in-spection philosophy is oriented toward " effectiveness" of the over-all QA program versus " compliance" with NRC requirements. iD E ? {WE f
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124 (4.0 Continued) , FEB 1 C 1cg7 } 4.6 Task Group Findings and Opir. ions for Consideration by the CPRRG in Assessing the Potential for " Broader" Implications
- The record Indicates that philosophical differences existed in the approach to inspection of records versus hardware as expressed by the Division Director g and inspection program supervision (Westerman).
- The record is mute on management awareness and involvement above Westerman to recognize and deal with the obvious inspector / super-vision conflicts and inspection report timeliness issues (s).
- As evidenced by the Task Group 2 reviews, many of the findings were insuf ficiently developed by the inspectors to support the proposed violation. Although management is accountable for providing guid-ance to inspectors, it is not appropriate to expect Regional man-agement tc control inspection methods and techni. lues to provide for credible inspection findings. Instances were found where further direc; ion to inspectors would have been appropriate, however, the technique of citing against strict compliance without qualifying the overali NRC concern is not consistent with the intent of the inspection program. -
- Based on the Task Group 2 independent assessment of the 34 inspec-tion findings, it appears that lengthy involvement and discussion between management and the inspector was warranted to achieve dis-position of the findings. The compliance threshold established by the Region IV management was not found to be inappropriate based on the significance of the findings and status of plant licensing.
The Task Group 2 technical reviews did not support the contention that the inspection findings were " unjustifiably downgraded."
- In the final analysis, it is not evident to the Task Group 2 members that the management and inspection staff involved with these con-cerns have come to grips with the subject issues. This is supported by the apparent lack of critical self-analysis in the Region IV response to the thirty-four items of Attachment 1 (CPRRG-17) to Attachment MM of OIA 86-10. Both the technicP1 and philosophical differences that existed, and allowed the items to escalate to an inappropriate level of disagreement, must be addressed and suffi-ciently resolved to prevent this situation from recurring.
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1.50 I .I ! FT 9 1 C 1997 APPENDIX 5.1 RESUMES k l l l l n - A 'n 1 - -J u s l
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RESUME Donald A. Beckman Organization: Prisuta Beckman Associates, Inc.
Title:
President and Special Consultant . Education: BS, U.S. Merchant Marine Academy, 1969 Experience: (Nuclear Industry - 21 years) 1985 - Present Prisuta Beckman Associates and affiliated companies. President and co-owner involved in day to day management and performance of nuclear consulting engineering practice, mechanical con-struction contractor, and related services. Personal engage-ments include multiple technical consulting projects for NRC. 1982 - 1985 Prisuta Corporation, ACC Consultants and Engineers and Energy Consultants, Inc. Vice president and special consultant pro-viding engineering and consulting services to nuclear utilities and NRC. 1977 - 1982 USNRC Region I. Multiple positions including Senior Resident Inspector and Chief, Plant Systems Section. Extensive involve-ment in all aspects of nuclear power plant engineering, con-struction and operations. _ Recipient of agency's Meritorious Service Award in 1979. 1976 - 1977 Burns and Roe, Inc. - Plant test and operations supervisor startup and operations of nuclear and nonnuclear power stations. 1971 - 1976 Newport News Shipbuilding - Testing supervisor for naval sub-marine nuclear plants.
'1969 - 1971 First Atomic Ship Transport, Inc. - Watch engineer, reactor ;
operator, health physicist, water chemist on board Nuclear Ship ' Savannah. Special Qualifications: USDOE Management Oversight Risk Tree Analysis Training USDOE Accident Investigation Training USNRC BWR Operations Training USNRC PWR Operations Training LMBFR Systems and Maintenance Training, Rockwell Int'l . Construction Estimating, Planning, Seneduling, RS Means, Inc.
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5.1-1
Donald A. Beckman . FEB 101987 Special Qualifications: (Continued) USAEC, Reactor Operator License, Nuclear Ship Savannah USCG Marine Engineer's License, Steam & Motor Vessels USERDA Certification, Submarine Reactor Plant Shift Test f Engineer USCG Certification, Health Physics Technician l 1 L , ,D
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FEB 10 'M7 RESUME Antone C. Cerne Organization: U.S. Nuclear Regulatory Corr. mission Region-I, Division of Reactor Projects
Title:
Senior Resident Inspector Education: Bachelor of Science, United States Military Academy, West Point, New York Master of Science in Nuclear Engineering, Massachusetts Institute of Technology, Cambridge, MA Experience: 1980 - Present NRC Senior Resident inspector at Seabrook Station, Seabrook, NH. Responsible for conducting the NRC Light Water Inspection, Program at a pressurized water reactor facility. Completed the construction and preoperational testing inspection programs with special emphasis upon plant design,, construction disci-plines, and integrated system testing. Currently engaged in the conduct of the Startup Testing inspection program. 1978 - 1980 Member of NRC regional technical staff, engaged in inspection, analysis and evaluation of nuclear power plant construction. Managed conduct of inspection programs as the Project Inspector for Seabrook', Nine Mile Point 2 and Millstone 3. 1975 - 1978 Chief of Construction Supervision, Charles River Dam Area Office, New England Division, Corps of Engineers. Supervisec inspection staff and reviewed design change implementation for a thultimillion dollar flood control construction project. Also served as Resident Engineer on another Corps project. 1968 - 1975 Various assignments with the U.S. Army Corps of Engineers, involved with project management and construction supervision at military installations in the United States and overseas. Technical Completed series of NRC sponsored courses in concrete, welcing, I Qualifications: NDE, QA, electrical and I&C disciplines leading to certifica-tion as a construction inspector. Completed series of NRC courses in pressurized water reactor systems and technology
. leading to certification as an operations inspector.
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l j l rre ' O 1987 . RESUME Samuel J. Collins Organization: U.S. Nuclear Regulatory Commission Region I, Division of Reactor Projects
Title:
Deputy Director Education: Bachelor of Science, Maine Maritime Academy, Castine, ME Graduate Business Program, Southern Vermont College, Brattleboro, VT Experience: (Nuclear Industry - 16 years in Design, Construction, Operations, Inspection and Management) 1986 - Present Deputy Director, Division of Reactor Projects, USNRC, Region I Provides project management; conducts inspections and evalu-ations of assigned NRC programs for all power and non power reactors within Region I; directs and performs Regional efforts . toward reactor licensing activities and the Systematic Assess-ment of Licensee Performance (SALP) Program; implements the NRC resident inspector program and related enforcement actions for assigned facilities. Administers and conducts the operator licensing program. 1985 - 1986 Branch Chief, Reactor Projects Branch No. 2, USNRC Region I Provides project management, including inspections, implemen-tation of SALP, resident inspection and enforcement for eleven assigned power reactor sites in operation and under construc-tion. 1984 - 1985 Section Chief, Reactor Projects Section No. 2C, USNRC, Region I Responsible for implementation of the routine and reactive inspection program at six assigned power reactors during new construction, testing and operation. Accomplished through supervision of Resident Inspector offices at assigned facili-ties. Cumulative responsteility included two operating Boiling Water Reactors, three operating Pressurized Water Reactors and one construction phase Boiling Water Reactor. ! 1983 - 1984 Senior Resicent Inspector fer Operations, Yankee Nuclear Power Station DRP, USNRC Region I. Supervised inspection and event response program at operating Westinghouse PWR power reacter facility. !
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Samuel J. Collins M9 1019V 1980 - 1983 Resident Reactor Inspector for Operations, Vermont Yankee Nuclear Power Station, ORP, USNRC Region I, Field inspector at operating General Electric BWR power reactor facility, i Private Industry 1971 - 1980 Tenneco Corp., Newport News Shipbuilding. Various positions ! as contractor to U.S. Navy Nuclear Program including: Project Manager - 55W Steam Generator Chemical Cleaning Project Chief Test Engineer - Chairman and NNS representative to Joint. Test Group for 55W overhaul and construction Shift Test Engineer - Shift supervisor for reactor overhaul and refueling Shif t Test Engineer - Shif t supervisor for reactcr new con-struction Mechanical Test Encineer - Shift mechanical test for reactor new construction Reactor Design Engineer.- design support for recctor new con-struction Special , Qualifications: Senior Executive Service Candidate Development Program, USNRC 1986-87 Qualified BWR Resident Inspector Qualified PWR Resident Inspector Qualified 55W Shif t Test Engineer Third Engineer License, USCG l l 1
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1 1 1mr[a ; ' RESUME m i U IS87 Thomas C. Elsasser, P.E. Organization: U.S. Nuclear Regulatory Commission Region I, Division of Reactor Projects
Title:
Chief, Reactor Projects Section 3C Education: Bachelor of Science, United States Naval Academy, Annapolis, MD U.S. Navy Nuclear Power Training Program Experience: (Nuclear Industry - 22 years) USNRC 1981 - Present Section Chief, Division of Reactor Projects, USNRC Region I. Responsible for implementation of the routine and reactive in-spection program at assigned power reactors during new con-struction, testing and operation. Accomplished through super-
-vision of Resident Inspector offices at assigned facilities.
Cumulative responsibility has included all sites in New England as well as Calvert Cliffs 1&2. Responsibility has also in-cluded all Region I* test and research reactors and fuel cycle facilities. Oversight during construction Phase has included Millstone 3 and Seabrook'I. l 1978 - 1981 USNRC Office of State' Programs, Regional State Liaison Officer, Region I. Regional contact ^for State and local government agencies in -areas of interest to the NRC, particularly reactor licensing, emergency planning and commercial uses of radioac~- tive materials. Three Mile Island During the accident at TMI, served as a spokesman for the NRC 1979 - 1980 to the national news media. Following the accident, repre-sented the NRC before legislative committees and public in-quiry groups on matters related to the accident and clean-up operations. From April to November 1980 was assigned to the NRC Middletown office, to assist with public and local govern-ment liaison in matters pertaining to the krypton venting and the Environmental Impact Statement, on Unit 2 clean-up. 1975 - 1977 Reactor Inspector, Reactor Construction and Engineering Support Branch, NRC Region I. Assigned as project inspector for various new construction projects including Millstone 3. Also respons-ible for overall implementation of the SNUPPS inspection pro-gram which included leading and participation in team inspec-tions at SNUPPS headquarters, Calloway 1&2 and Wolf Creek. 5.1-6 y-
^'!
cf. Thomas C. Elsasser m 101987 UE&C Nuclear Engineer, United Engineers and Constructors, 1974 - 1975 Philadelphia', PA. Responsible for PSAR and EIR development. for various new nuclear projects under' development by UE&C. Served'as project manager.for an HTGR piping optimization study performed for General Atomic. L.S. Navy Member, Nuclear Propulsien Examining Board, U.S. Atlantic Fleet. 1972 - 1974-Duties involved conducting operational reactor safeguards examination of nuclear powered units' of U.S. Atlantic Fleet. 1970 - 1972 Chief Engineer, nuclear submarine USS Will Rogers. Responsi-- bilities including directing the operational, maintenance and testing of the ship's nuclear reactor and all support facilities. 1968 - 1970 Training Officer, S1W Nuclear Prototype, Idaho Falls, ID. Served as principal Navy assistant to the Westinghouse plant manager for training of all officer and enlisted operators assigned to S1W for initial nuclear indoctrination. '1966 - 1968 Division Officer, nuclear submarine USS Simon Bolivar. 1964 - 1966 Completed U.S. Navy nuclear power and submarine training. Special Registered Professional Engineer (Nuclear), Commonwealth of Qualifications: Pennsylvania Completed NRC sponsored courses in quality assurance, concrete, and NDE leading to certification as an NRC construction inspector Completed NRC sponsored courses in BWR and PWR technology Completed 00E Radiological Emergency Response Training, Nevada Test Site, Mercury, NV M t '- - e , v bY '. 5.1-7
1 1 I FEB 13 ER7 i RESUME 1 ( Eugene M. Kelly Organization: U.S. Nuclear Regulatory Commission 1 Region I Division of Reactor Projects
Title:
Senior Resident Inspector - Limerick Education: 8.5. Physics - Villanova University M.S. Mechanical Engineering - University of Pennsylvania Experience: 13 years in nuclear industry 1985 - Senior Resident at Limerick Unit 1 managing inspection programs Present power ascension testing and operations. Supervise detailed inspec-tions of system design and modifications, surveillance testing and maintenance, and other program areas. Special project assignments include team inspections at LaSalle, Peach Bottom anc Nine Mile Point sites. 1982 - 1985 Reactor engineer assigned to ten plant sites, conducting inspections NRC and allegation followup. Major projects included licensing of Susquehanna Unit 2, extensive allegation followup at Shoreham, com-pletion of construction and design inspection programs at Seabrook and Hope Creek, and overall engineering evaluations of Yankee Atomic f acilities (Vermont, Maine, Rowe), 1980 - 1982 Project engineer responsible for plant modifications including de-Catalytic Inc. sign specifications, procurement, coordination of detailed engineer-ing and calculations, and test and installation. 1979 - 1980 Nuclear engineer responsible for isotopic analysis, shielding calcu-General lations, sump water sampling coordination, and krypton venting Public assessments. Utilities Corp. l 1974 - 1979 Safety analysis engineer contributing to PSAR and FSAR preparation United for several nuclear projects. Startup test and licensing assign-Engineers ments for nuclear facilities.
& Constructors Inc.
l Technical Qualifications: l Completed NRC EWR & PWR operational course series ) l j 5 - week PRA training program I tD gh " ] GE and CE Station Engineering courses. 5.1-8 1 I I
d n'i M.*': 1 0 1987 l l l 1 ( APPENDIX 5.2 s TASK GROUP 2 CHARTER 1 i'
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TC 1 0 1587 e h j
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, , , Task G2-02
;;'g , 2-1 (2/02/87) l
( TASK GRCUP 2 ,)[2j
'j,7 -
TASK FOR EXAMINATION OF ISSUES RELATING TO PROCE55 AND DISPC51 TION OF b' INSPECTION FINDINGS OF OIA REPORT 86-10 yf' 4 44ll . 8 3 w
, ihis task relates to examination of the M issues of Attachment 1 to Attacnment MM of OIA Report 86-10 and any additional relative issues revealed by the f)
; activities of Task Group 1 as a result of activities under Item 5 (and cocu-mented in Item 6e) of the Task 1 description.
>j The basic task is to review the processing and disposition of issues and inspections findings in the Fjgien IV inspection of the Comanche Peak project anc r.a compare the actual pro es sing against the identified pelicy er practices of the NRC, IE, anc Region IV.
As a minim m. the Task Group will have available to it:
'/
- 1. CP4RG-7, the information from E in response to CPPRG Letter RG IE-02.
This information establishes the basis from IE for inspection reporting; 7 tem identification, classification and disposition; and responsibilities Y for inspection performance and reporting. Q> vt Uk- .
" y b;[ #
5.2-1
~,- - _ _ - - - - _ , N Draft 2-2 (2/02/87) @ 10 I.
- 2. CPRRG-8, the information from Region IV in response to CPPRG Letter RG RIV-02. This information establishes the basis from Region IV for inspection reporting; item identification classification and disposition, and responsibilities for inspection performance and reporting.
ornac6A
- 3. Information fromA8C relative to NRC policy and practices for processing l and disposition of issues and inspection findings, this shall be forwarded to Task 2 by CPRRG 1etter.
- 4. The information of specific process and disposition issues from OIA Report 86-10 (essentially the 34_ issues in Attachment I to Attachment MM of OIA Report 86-10).
- 5. Any process and disposition issues forwarded to Task Group 2 from the work -
of Task Group 1, this shall be forwarded to Task 2 by CPRRG letter. Insefar as possible, the performance of this task should rely on the written recorc where that record provides sufficient information to support conclu-sions. Where it is necessary to extend this record, this should be cone in coordination with OGC. 5.2-2
)
Draft 2-3 (2/02/87) FEB 10 7S87 This Task Group shall: 1
- 1. Review information provided by IE, Region IV, the Comanche Peak ;
Project Office or others against the primary or source document to become familiar with the investigation and CPRRG record. Where I applicable, assess the accuracy and completeness of the records providedx , 1
- 2. Identify the specific process and disposition issues from OIA Report 86-10 (34 issues of Attachment 1 to Attachment MM).
- 3. . \y Analyze each issue, independent assess and describe the process and \
p I disposition by which the item should have been handled. Identify the hRC, IE er Rnemi ' 3 process, guidance or practice that was used in making this indepen-dent determination.
- t. . Analy:e the actual process anc disposition of each issue. Describe the *ocess by w.icr it actually was handled incl; ding where appif-cable, the identification and classification as a 'inding (with references) by the inspector, inclusicn in tne craft reports, eval-uation by Region IV management and inclusion in the final report.
Pa-ticular attentien anc cisc.ssion will be : vided to items where there is an absence of agreement on process or disposition. The basis for the disagreement and documentation there of, including timeliness of review, signature, concurrences and report issuance will be described.
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1): , t=. ' - l
,;s 1 5.2-3
_ _ - - _ _ _ = - - _ Oraft 2-4 (2/02/87) r yg g Gn:c95
- 5. In addition to describing the above process thedsk f report will:
.ce:id:r ir,'th; f' ul report, !
Tercnbe. .
- a. 4 ::::c. i .ivu vi how the task was performed.
r [
- b. Identify where there are differences between agency guidance, IE guidance, and Region IV guidance and areas where guidance does not exist or is subject to wide interpretations. Include where applicable:
Where and how this failure to follow guidance has occurred. For items of disagreement, express an opinion on whether the guidance for process and disposition was, or was not, followed. For disagreement for which no guidance exists, express an opinion on the appropriateness of the process and disposition actually performed in light of the signi-fi:sr.:e anc imp 14:at'ons of the disagreemer.t. Where guicance does not exist, express a, opinion as to what guidance is needed.
' I Where guidance does exist, but there are differing inter- '
pretations, recommend a course of action. i I
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efl
- i . 2-4 I
;i Draft 2-5(2/02/87) FEB 191987 Schedule ,. .1/20/67 .-Task Leader appointed 1/29/87 Membership; Organization & Approach established 1/31/87 Start work on example (pilot effort) 5-2/0)I/87 Review pilot effort with CPRRG 1 l
2/05/87. Check for possible impact of Task 1 on Task 2 2/10/87 Task 2 report complete, provided to CPRRG 1: l l I 5
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l 5.2-5 i
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Mc C 1967 APPENDIX 5.3 CRITERIA FOR ANALYZING REGION IV DISPOSITION 1 r.r.qN' a e-I
l
. Comma che Peak Allegations CPRRG Task Group 2 fag 4 p.
CRITERIA N d FOR ANALYZING RlTOISPOSITION . TEE 10 587 - X3 Analyzing Region IV Disposition X.3.1 Statement of Inspector's finding.and regulatory concern l l l Development of Finding How issue was researched and analyzed, including supportive bases; a;;licable cocumerts consulted and by whom. Discuss appropriateness Of cocuments reviewed. Person I.9 s pe c t o r Document ( ) Dnillips Westerman Barnes NRR Other Part 50 Acc B 1 l l l l l PSAR/FSAR Commit. l l l l l l i Code or Stc. ! I 1 l l l 1 TUGC0 QA Prog. l l l l l l l Contractor CA Piar i i i i i i I QC Procedure (s) l l l l l l l TUGCo l l l 1 l l l Contractor i l l l l l l Other l l [ ] l l l (YES, NO BLANK = N/A]
- Narrative mm , == =
~; J' J .i 5.3-1
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=.- ,
Nhu FFE ' C 1987 Characterization of Finding Inspectors apparent safety concern and Task Group's evaluation. 4 Should it have been pursued for more examples of programmatic significance; was it? Was it reasonable to expect further undirected action by the reporting inspectors? If yes, what action should have been taktn? Timeliness Was communication betweer inspecters and RIV Management on final resolution timely? Was lack of timeliness a detriment to effective resolution?
=~ ,9 - ]c= =
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A, .
,e s ,i aJ fr3 l's ISs7 N6ture of downgrading of inspection finding as it appeared in final report with brief statement of management's reasoning.
i Management's role in achieving final disposition j
' l Were management's actions sufficient to warrant downgrade? If yes, explain.
What further action should have been directed to proper resolution. Accitional inspection by inspector to expand information base Actions by licensee on his contractors to provide additional information , Discussion with upper Region IV management. Specialist Inspection / Consultant inspection Referred to other NRC of fice (IE, NRR etc.) mm 3,
.) :: a
.., 24; ;
5.3-3
, m
. ag f= l FE9 1 0 $87 If item was determined to be unresolved, was there sufficient information in the inspection report to focus activities of the licensee / inspector to effective resolution.
was this done (i.e. how was the item resolved) current status of item X.4 Conclusions (Discuss [as appropriate): Region IV handling vis a vis Group 2 incepen-dent assessment; potential safety significance of improper handling; whether adcitional action is still needed for effective resolution;
' implication of broader Region IV problems; if NRC policy / procedures require revision) j eh
.u . s p 5.3-4 1
. _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ - _ _ - - _.__-- - - Q
_ - ~ , - - - , - - - Af ns FEE 10 # i ( APPENDIX 5.4 DOCUMENTS REVIEWED 1 1 1
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1 1
i o . 02/04/87 g}LhI L7 rEs 101987 i 1 DOCUMENTS RECEIVED BY CPRRG 12/18/86 DESCRIPTION to G. Mulley g Supplemental statement, Del Norman t chments (superseded t RG-PO-01 by) 1 l CPRRG-1 Memo. Noonan-to-Davis, 1/6/87, w/at aThis is respons , CPRRG-2 CPRRG-9) (Note: follows: Ten CPP0-furnished documents as CPRRG-3 Special Review Team Report SSERs, 7, 8, 9, (1) Technical Review Team Reports - (2) 10, 11 and 13 and ram Plan Comanche Peak Response Team Prog (Some of (3) completed results reports.notyetcompleted.) results reports are Review (4) TUGC0 Quality Assuranceeport Program Cable tray and hanger inspection r (5) inspection report HVAC and support ' (6) CPRT-0A Program Review Report D0 dated (7) dated (8) Contention 5 Panel (memo from E 2/28/85,) superseding earlier memo 12/24/84 O dated (9) Intimidation 12/24/84) Panel (memo from ED l (letter, NRC (10) Report of Intimidation Pane OGC REVIEW to TUGC0 dated 11/4/85) /86,
Subject:
E Parler-to-Commissioners ,12/23ON I Memo. GATION NO. 86-10) CPRRG d 0F OIA REPORT /6/87,
Subject:
CONCERN 0IA COMANCHE P age 34 and 35 of Femo. Connelly-to-Stello,1(Transmits c CPRPG-5 REPORT . basic issues.) report, sumarizing Mr. draft re IE response (1/9/87) to CPRRG draft request CPRRG-6 IE response !'./9/87) to CPRRGR Part 2, 49 CPRRG-7 ( NRC Enforcement Policy 10 CF (W45 ;;DEC CPRRG-7A
;.4-1
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i ' 02/04/87 23 FEB 101S87 CPRRG-78 NRC Manual Chapter 4125, Differing Professional Opinions . CPRRG-7C IE Manual Chapter 0400, Enforcement Program CPRRG-70 IE Manual Chapter 0610, Inspecticn Reports CPRRG-7E IE Manual Chapter 1245, Inspector Qualifications CPRRG-7F IE Manual Chapter 94300, Status of Plant Readiness for an Operating Licensee CPRRG-7G IE Manual Chapter 2512, Light Water Reactor Inspection Program - Construction Phase CPRRG-7H Letter to TUGCO, April 11, 1983,
Subject:
CONSTRUCTION APPRAISAL INSPECTION 50-445/83-18; 50-446/83-12 CPRRG-71 Letter to TUGCO, January 21, 1986, Subiect: INSPECTION OF COMANCHE PEAK DESIGN ADEOUACY PROGPAM SCOPE VALIDATION PROCESS AND REVIEW CHECKLIST DEVELOPMENT 445/85-17, 50-446/85-14 CPRRG-7J Letter to TUGCO, September 9, 1986,
Subject:
INSPECTION OF COMANCHE PEAK DESIGN ADEOUACY PROGRAM (DAP), IMPLEMENTATION OF DISCIPLINE SPECIFIC ACTION PLAN (DSAP)X, MECHANICAL SYSTEMS AND COMPONENTS - 50 445/86-18, 50-446/86-15 CPRRG-7K Letter to TUGCO, September 10, 1986,
Subject:
INSPECTION OF TERA'S QA PROGRAM FOR THE COMANCHE PEAK DESIGN ADEQUACY PROGRAM 445/86-17, 50-446/86-14 CPRRG-7L Letter to TUGCO, November 4, 1986,
Subject:
INSPECTION OF COMANCHE PEAK DESIGN ADEOUACY PROGRAM IMPLEMENTATION OF SPECIFIC ACTION PLANS VIII, IX, and IX; 50-445/86-19, 50-446/86-16 CPRRG-8 RIV response (1/9/87) to CPRRG draft request (RG-RIV-02) l CPRRG-9 Memo. Noonan-to-Davis, 1/13/87, w/ attachments (supersedes CPRRG-2) (Note: This is response to CPRRG reauest RG-P0-01) CPRRG-10 Memo. Dircks-to-Office Directors, 3/13/84,
Subject:
COMPLETION OF OUTSTANDING REGULATORY ACTIONS ON COMANCHE PEAK AND WATERFORD CPRRG-11 Memo. Dircks-to-Office Directors, 10/17/84,
Subject:
COMANCHE PEAK PROJECT DIRECTOR CPRRG-12 Letter to TUGCO, 9/18/84,
Subject:
COMANCHE PEAK REVIEW CPRRG-13 Letter to TUGCO, 11/29/84,
Subject:
COMANCHE PEAK REVIEW CPRRG-14 Letter to TUGCO, 1/8/85,
Subject:
COMANCHE PEAK REVIEW
* 'A DOCUMENTS RECEIVED BY CPRRG 5.4-2
.fY' % A
7 fj[]$ f 02/04/87 uf013 j(EB 101987 1 CPRRG-15 Memo. Martin-to-Davis,1/20/87,
Subject:
REFERENCE MATERIAL FOR CPRRG - NOTES OF D. NORMAN I CPRRG-16 Memo. Martin-to-Davis,1/20/87,
Subject:
REFERENCE MATERIAL FOR CPRRG - NOTES OF H. PHILLIPS CPRRG-17 Memo. Martin-to-Davis,1/20/87,
Subject:
REFERENCE MATERIAL FOR CPRRG - REGION IV MANAGEMENT POSITIONS ON ATTACHMENT MM CPRRG-18 Memo. Martin-to-Davis, 1/20/87,
Subject:
REFERENCE MATERIAL 1 I FOR CPRRG - REGION IV INSPECTION AT COMANCHE PEAK (Note: This is response to CPRRG draft request--RG-RIV-01) CPRRG-19 Memo. Martin-to-Davis, 1/22/87,
Subject:
BACXGROUND INFORMA- ; TION ON CPSES INSPECTION REPORTS CPRP.G-20 Memo. Martin-to-Davis, 1/23/87.
Subject:
ERRATA REPLACEMENT SHEETS FOR REGION IV ASSESSMENT OF COMMANCHE PEAK IDENTIFIED TECHNICAL ISSUES CPRRG-21 Note. Martin-to-Davis,1/23/87 transmitting amendment to CPRRG-16 CPRRG-22' Memo. Martin-to-Davis, unsigned, undated.
Subject:
EVALUATION OF INSPECTION ACTIVITIES (w/5 attachments) ( l l l
" 3-? 1! ! ,.rw
^ ' 'I J DOCUMENTS RECEIVED BY CPRRG 5.4-3
~ -- _ ' - ' ' ' - - - - - - _ _ . _ _ _ - - . _ 02/04/87 Rift REB 10 W DOCUMENTS RECEIVED BY CPRRG l 12/18/86 to G. Mulley DESCRIPTION ITEM Supplemental statement, hments (superseded by) st RG-PO-01 G-I Memo. Noonan-to-Davis,1/6/87,w/attacThis is responl (Note: follows: CPRRG-2 CPRRG-9) , Ten CPPO-furnished documents as CPRRG-3 Special Review Team Report SSERs , 7, 8, 9, (1) Technical Review Team Reports - (2) 10, 11 and 13 and ram Plan (Some of the (3) Comanche completed results are Peak reports.Response Team Prog results reports ~ Review TUGC0 Quality Assurance i report Program (4) Cable tray and hanger inspect rt on (5) HVAC and support inspection repo (6) CPRT-QA Program Review Report EDO dated (7) dated (8) Contention 5 Panel (memo fro DO dated 12/24/84 (9) Intimidation 12/24/84) Panel (memo from E l (letter, NRC (10) Report of Intimidation/86, Pane
Subject:
OGC TIVE REV toTUGC0 dated 11/4/85) Parler-to-Commissioners,12/23ON I Memo. GATION NO. 86-10) CPRRG 4 OF OIA REPORT CONCER DIA COMANCHE P 87,
Subject:
n page 34 and 35 Memo. Connelly-to-Stello, 1/6/(Transm CPRRG-5 REPORT. basic is t,ues .) report, summarizing Mr, draf IE response (1/9/87) to CPRRG draftrequest(L CPRRG 6 IE response (1/9/87) to CPRRGFR Part 2 ( CPRRG-7 NRC Enforcement Policy 10 C CPRRG-7A gy i
,9 ' J111 }
ATTACHMENTS To oIA % 10 PEB 101987 A. Technical Issues Raised by PHILLIPS During OIA Interview. B. Interview of Shannon PHILLIPS, dtd March 19, 1986. C. Interview of . dtd April 10, 1986. D. Interview of Tom WESTERMAN, dtd July 10, 11, 21 and 23, 1986. E. Memorandum from Chief, RSB, to E.H. JOHNSON, Acting i Director, DRSP, dtd January'13, 1986. F. Draft Inspection Report 85-07/05, dtd February 3, 1986. G. Interview of dtd April 9, 1986. H. Interview of Charles J. HAUGHNEY, dtd June 17, 1986 and November 25, 1986. I. Interview of Thomas Holton YOUNG, dtd May 29, 19,86. J. Interview of Ian BAPNES, dtd July 25, 1986. r.. Matrix of Drafts for Report 85-14/11. L. TUGC0 Speed Letter, dtd January 9, 1986. M. Interview of John GILRAY, dtd July 17, 1986. N. Interview of Cliff HALE, dtd July 24, 1986. O. Matrix of Drafts for Report 85-16/13, dtd May 12, 1986. P. Interview of Eric JOHNSON, dtd July 22, 1986. Q. Interview of Edwin F. FOX, Jr., dtd July 17, 1986. R. Interview of dtd June 24, 1986. S. Interview of Robert C. STEWART, dtd May 28, 1986. T. Interview of dtd May 28, 1986. U. Interview of Lawrence E. ELLERSHAW, dtd July 24, 1986. V. Memorandum from H.S. PHILLIPS, to T. WESTERMAN, dtd April 29, 1986. W. Interview of _ dtd July 9, 1986. X. Interview of dtd July 9, 1986. Y. Interview of dtd July 9, 1986.
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bU 5.4-4
Interview of Dennis Lee JEW, dtd June 26, 1986. b 2. Interview of Allen Louis MAUGHAN, dtd iune l 26, 1986. FEB 101987 AA. BB. Interview of William Dwaine RICHINS, dtd June 26, 1986. CC. Interview of Jimy Richard DALE, dtd June 26, 1986. DD. Interview of Mitchell Keith GPAHAM, dtd June 26, 1986. EE. 'I[terview of Joseph Lee BIRMINGHAM, dtd June 26, 1986. FF. Interview of Wanda WARREN, dtd July 24, 1986. GG. Interview of James SUTTON, dtd March 20, 1986. HH. Memoranda to George MULLEY, JR., 01A, from Thomas G. SCARBROUGH, dtd July 8. July 15, 1986, November 5, and November 25, 1986.
~~
II. Memorandum to E.H. JOHNSON, from T.F. WESTERMAN, dtd May 23, 1986. Interview of . dtd June 25, 1986. JJ. KK. Interview of James GAGLIARDO, dtd July 23, 1986. LL. Interview of Bob TAYLOR, dtd July 22, 1986. MM. Technical Review of PHILLIPS' Issues Contained in Comanche Peak Inspection Reports, prepared by Stephen GOLDBERG. NN. Frequency of QA Modules Based on Past Versions of the MC 2512 Program.
- 00. Interview of Arthur B. BEACH, dtd November 24, 1986.
PP. Interview of James PARTLOW, dtd November 26, 1986, 5.4-5 V:.h'
FEB 10 1S87 FRcM C.PR9.Gi-% LIST OF E1HIB175 pp 413-416 8............................ pp 17.1-14 thru 10
'* ~
l P ar t 50, 4ppendix B, Crateria 1Contro!......................... ...P 1 2 FSAR Section 17.1.3. Contro1.................... Design gn ..pp 1-11 TUGCo 04. Section 3.0, 3 DesiCPM-6.3......................... .....pp 1-8 4 B&R Traveler Frecedure CF-
. ........................ ..p 1-6 Westinghouse Procedure....... ..........................
5 pp 3-4 79'249-550u......... e Traveler ME ...........................
......pp i.-99 thru 102 7
Contention 5.....................s 2...................... Item NUREG-0797, Mtscellaneou and page 3................... 8 79-03/03 and Letter 9 R]V Report llation: 50051................. 104 IE Frocedure for Vessel Insta 50053.......................... 10b IEF for Vesse! Insta!!ataon: 500:5.......................... 10c IEF f or Vessel Installation: 65-07/05 tion Reportnn2 cutt..................... Original Final Draft inspec/Hu 1 11 Submitted to Report C5-07/05, F:evision HQ............ tted to RIV and 42, 43 12a Second Final Draf t inspectsenSigned ..................pp ...pp 30, Octob Consents 12b01AMReport........................................................ ... OIA Attachment................... February 3, 1986.......................pp 17.1-38 thrc 13 Feport 85-07/05 1ssued ....................... ....pp 1-2 17.1.16............ 1 FSAR Section ........................ ..p I i 14
......................... ..p
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1 15 TUSCO 16.............. QAP Section 15............Se B&R QAM, Section 16
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i LI57 0F E1HIBITS i j
.17 FSAR Section 17.1.16, Audtts.................................p 17.1-3s ;
1 i l l- 18 ANSI M45.2.12, Oraft 3. Reviston 0, lo73. Requirements for-l Aud s ti ng C A Progr ams f or Nucl er Pl an t s. . . . . . . . . . . . . . . . . . . . . pp 1.$ o 19' TUGCo QAF Section 18, Audits................................p 1 20 NRC Inspection Repcrt 84-02/11. Not1CE of V1Clation ar.c Lettar........................ ..............................;c 1 ~. 21 M4; Audit of TUGCc anc Respense.............................pp 1-6.15.le 22 Wersham Forsytne. Samples & Woc!crtge Memo. May 29 19st....pp 1~ 23 NRC. Board Notification N 5. 85-06~ and 65-07c Mem:..........pp 1-2 24 FS Locetn Report. February 1982.............................pp 2, 3, 44 2$ TUGCo Transmittal Letter to NRC. (enclosure Lobbin Report).. 26 NRC CAT Report..............................................pp B-1 thre ! VI!!-! thru 5 27 NUREG-0797, SSER No. 11......................................pp 31-23 28 Cosmanene Peak Respense Action Flan--!SAF Vll.a.4...........pp 5-9 29 Results Repert--! SAP VII.a.4................................pp 1-53 30 Letter and Draft of the Notice of Vaclation 86-08/04........pp 4-9 31 Last of Quainty 4ssurea Structures. S,stees, and Components..................................................pp 1-2 30 Oractnal anc Final Inspect 2cn Report Deta115................pp 16-17 33 Identification and Control of Materials Parts and Components, FSAR 17.1.8.................................pp 17.1-25 thru 17 34 TU8CO QAP, Section 8.0, Identification and Control of Itees............................................p 1 SM: JJ.iv)
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hr - ? ern 101987 i LIST OF EtH18115 l l 35 Code Requirements NCA 3886.o and NCA .4134.8.,................pp 36. 4o 3o BkR QAM, Section'9.0........................................pp 1-4 37 B&R Procedure CP-CPM-6.9E, Revisions 2 and 4................pp 18-19 01-QAP-11.1-26, Fevistons 4 and 18......'............ .......pp 6. 7. E ; I l 38 6LR lsometric FRF-C5-2-RB-076 and Stil of Mater:als.........
"9 IE Inspection Frececures 49051.-5~.-14.-55.'anc -5o.........
40a Portions of Cla attachment D Statement......................pp 112.11: and 145-15S 40c Attachment J................................................pp 1 , anc 5-1, ) 41a AttaChaent MM of 014 Report.................................p 9 424 Original Draft inspection Report 95-14/11...................pp 1-4 42b 5econe Draft Report E5-14/11 (with directed changess........pp 67-7E 42c Final Inspection Report E5-14/11 March 6, 1986.............pg.lu and 13 4: FEAR Section 17.1.17 0A Recorcs............................p; 17.!-40 tne; 41 44a ANSI N45.2.9, Requirements for Collection, Storage, and Maintenance of Ow Records...................................pp 11-12, 14 16-21 44b FSAR Comattnent, ANS! N45.2.9............................... 45 TUSCC QAP, Section 17.v. Ette Construction Quality Records and Record Rctention anc Storage.,..........p 1 4e Attachment MM to OIA Report.............................. ..pp 11-12 47 Attachment MM cf 014 Report.................................pp 13-14 48 TUGCo GA Record Receipt Controll/ Storage Procedure CP-QP-18.4, Revision 7............................pp 1-2 CP-CPM-7.1, Revision 3, and.................................pp 2-4 STA-302, Revtsion 11.... ...................................
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'AJ 3 T9 10 1987 LIST OF EXHIBITE 49 O!A Report. Attachment MM...................................pp 14-18 50 Original Rougn Draft Repcet 85-16/13........................pp 3-1 tnru ;-e 4-1 thru 4-4 6-1 thru c-4 51 Ftnal NRC Inspection Report 85-16/13........................pp 5-9 5; Regulation 10 CFR Part 50.55te).............................p .58 1
5; TUGC0 QAF. Section e.0 Document Centesi....................; 1 54 IE.Guadance on 10 Coce of Federal Regulatton...... .........p 8-4 55 Trenc 4nal.sts..............................................pp 1-le 5e South Texas Memerancum tLessons Learnee.....................pp 1-5 B&R Engineering Memorancum.................... .............pp 1-; 57 McCleskey's Field Notes 57a Review of Procedure NED CS-1................................p 1 57b Revtew of Construction Deftetency File......................pp 1-10 58 Johnson's Comments on Draft Report 86-16/13.................pp 1-5 SC Comanche Peal 50.55(ei Tracking.............................p 1 60 NUREG 0797, SSER 11, Comments on 50.55(e) Reporting.........pp 0-279-280 Correction..............; ; 61 TUSCD Letter (TXX-4508) Unit Numoer e2 OIA Report, Attachment MM...................................pp lo-18 1 63 'McClesky Field Notes on IE Bulletin Review Notes dateo November 1, 1985................................p .- Notes dated November Oc, 1985........................... ...pp 1-10 Notes dated November 26, 1985...............................pp 1 ane 3 TUSCO Official Contact List.................................pp 2 64 65 RIV Traveler for Report 85-16/13............................p 1 66 Conversation Record, Phillips--Baker........................pp 1 and 3 b '.
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9 7% tu 1 . . I. an/ M.id[] ge 101S87 LIST OF EXHIBIT 5 67 BISCO Fire Penetration Seal Memorandum Novem0er 25, 1985. Draft....................................pp 1-3 March o. 1981, Final........................................pp 1-3 8 Attachments (14 pagesi 68 IEEE Standard 64...........................................pp 9-10 69 TUGC0/EI5CO 5eal Eccuments Design Deficien v Kepert....................................p 1 T21-453'.... ..... .... . ..................................p 1 T13-49eo...... .............................................? ! Txx-49ss....... ............................................p 1 - 50.55te) Evaluat:cr. ho. 0177................................p i T5G-15c c 5..... .. . . ..... ...............................pp 1-2
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rE; 101987 f APPENDIX 5.6 INSPECTORS APPARENT SAFETY CONCERN AND TASK GROUP 2 EVALUATION J J
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QP f... . , , iREli 2 01987 Accendix 5.6 Insoector's Apoarer.: Safety Concern and Task Group's Ev a l ua t '. e n Item 1/2 -Design information must be-crocerly controlled, otherwise i n s t a l : a t '. o n of sa f ety. rela ted comoonent s ma y occur out side carameters of the design envelope. The Task Group considers this item to have moderate potential safety impact in that the inspector and his management did not ensure that the licensee's program for control of design information in ' installation instructions was rigorously controlled. This had the potential to result in actual hardware cuality defects: however, with the evidence that the operations traveler system was fully functioning at the. time of installation. any concern of adverse hardware imoset is diminished. Item 3 On thebroad scale. the failure to imolement a meaningful aud1+. prooram fif this were the case). represents a failure of an important part of the licensee's CA Program. The Task freuo pelieves. that, for this specific cage. the failure to audit the EFV installatten when coupled with the design con, trol issues cocumented by concerns 1 anf 1. reoresentsover reliance on the contractor procedure and program to assure cuality worr.. This nas moderate ootential to imcact safety but is sufficiently removed from the actual cuality related ecutement activities to have not had direct safety 1meact, particularly Level I QC activities for this activity were in evidence, item 4 Without procer traceability. the potential existed for the installation ;f non-code controlled material in safety related systems. The Task Group considers this to be an apparently isolated instance which has no direct safety significance. Further examoles or evidence that the licensee's oregrams had feiled te provide One recu. site traceability would crovide a safety concern of generte a:elicacility to the site. However, further inspection for additional examples was not ! accomplished and therefore, no evidence of safety impact exists. ; i l 7 5.6-1 Yd. k7 Vw l 1
Appendix 5.6 i' 3
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^'O. *m1~i Jff Item 5 The inseector's only concern was than an ASMI cod + requirement had been violated ar.d it then ic11 owed that the ASME Code s a .m r for tne subject pipino subassemolv had been improceriv soolled.
The Task. Group considers this item to have ne direct safety significance in that tho technical concern was not valid for the identified example. i.e. the spooloiece would be subjected to a system level hydro and this fully comolied with the ASME Code requirements. Item 6 The imolied safety concern was that the absence of ceriodic nixer blade inspections coulo cermit blade degradation which would oroduce defective concrete for olacement in safety related structures. Since this was not aeoarent from the concrete test results. the insceeter assumed t ", i s issue recresentec e failure to documen'. :m recuire: inscection. Given the reenr: stat + men: tna; the mixing clades had Deer oericcicallv insoected and that strengtn and uniformitv tests of the resultino concrete were cens i stent iv acceotaole , the lace. ei recoired I documentation is of neal:oible safety sionifteance. Item 7 No direct safetv concern is aoearent on tne part of the insoector. He apoarently believes tne : censee did not meet minimum standards for record storace facilities wnien could geocardize cuality records which could orevent substantiation of performance / character 1stsee of cuality l i activities and hardware. The Task Grour cine.uced t r. a essential.y no s a ir* v ' t-icenc+ can De attacned to tnis iten: nowever. ostential mATor economic significance would occur snould record reconstruction be necessarv. The only element of safety sionificanc+ would involve both the licensee and NRC acceptino less tnan optimum data < records due to the inability to reconstruct lost records to original cuality. Item e No direct safety concern is aoparent on the part of the inspec:cr. ne apparently believes the licensee did not address all committed minimum standards for record storage facilities which could jeopardine cua.ity records which could prevent substantiation of performance / character-1stics of quality activities and hardware. M ,( F 5.6-2 M{ M ' ,! ,
Apoendix 5.6
,g ; y jgg7 .The Task Groue concludes that there was negligible direct safetv impact.
This iten is an editorial oroblem with no evidence of a programmatic ime11 cation. j 1 Item 9 Original single coov design records were beino shioped from Texas to { New York to support a major reanalysis effort. Loss of records woule j have substantially reduced the confidence level in the data available j for reanalysis. 1 i The Task Group concludes that essentially no safety significance can l be attached to this item: however, potential major economic i j significance would occur should record reconstruction be necessarv. The only element of safety significance would involve both the ] { licensee and NFC acceptino less than optimum data / records due to the l inability to reconstruct lost records to original quality. 1 Item 10/11/12 No direct safety concern is acoarent on the part of the insoector. He arcarentiv telieves the licensee rand a contractor) did net meet minimum standards.for records shipments could jeopardize cuality records which eculd oret'ent substantiation of cerform&nce/ character-1st ics of cuality act ivit ies and hardware. The Task Group concludes that. essentially no safety significance can I be attached to this item however, cotential major economic sionific.ance would occur snould record reconstruction ce necessary. The only element of safety significance would involve octn the licensee and NRC acceptino less than optimum data / records due to the inability to reconstruct lost records to original cuality. l Item 13'14/15 Ne direct safety cericern is apoarent on the part of the inspecter, he acoarently believes the licensee (and a contractor) did not meet minimum standards for records shioments could jeopardize cuality records wnich could orevent substantiation of performance / character-1stics of cuality activities and hardware. The Tesk Group concludes that essentially ne sa f e t y s t or.i f i ca nce can be attached te this iten: hewever. ootential majer economic significance wou.d occur should record reconstruction ce necessary. The only element of safety significance would involve both the licensee and NPC accepting less than optimum data / records due to the inability to reconstruct lost records to original quality. 5.6-3 i
Apoondix 5.6 . r jif/l. . " tg 101c87 Item 16 The omission of the recorde manacement area audit summary paracraon l represented a cotential orocrammatic creakdown which evidences TUG:0's I leck of control over contractors. Those (that) c o n t a c t o r ' .* na d ! allegedly abrogated their records ranagement responsibill. ties and therefere ?eopardized the availability of records necessarv to substantiate the performance / characteristics of cuality activities and hardware The Task Groue concluded that there is no apparent safety significance to this item since the audit findings did not identify any condition adverse to quality. The comments missing from the report ostensibly addressed areas inspected, not deficiencies. Item 17/18 No direc: safety ccn + - .s 2:: =r+r: ct :ne cart of th+ -:- - ne fcund tnat tne licensee cic not neet minimum standards for record storage facilities anc tnereby was $ecoardizino quality records which could crerent substantiation of Performance /enaracteristics of cuality a c t i v ! *. i e e and hardware. The Task Grouc concludee ina: eerentially no safety signiilcance can ce attacned to tnis item; nowever, potential ma 1or economic significance woulc occur enculd record reconstruction ce necessary. Tne only element of safety significance would involve both the licensee and NFC accen*ino lees than oo:1 mum data / records due tc the inacility to reconstruct 4?F: recorde to original cuality. Items 19' 0 Ne direct referv :ncern is accaren on the cart of the insoector. He f urc :ne qe _icenree did na 9 eat ninimum stanca-dr fer "ecerc st: race facili*i+t si._ * . e r e t '. .si *e a co r c i:1 r. c t: a l i t y recorer +- n cou.c trevent sut?tantiation Or performance /enaracteristics of cua.;;y activities and hardware. The Task Groue conclucer tnat essentially no eafety significance can be attached t: tnis iten: newever, ootential major economic significance would occur enould record reconstruction be necessary. The only element of safety significance would involve both the licensee ard NFC aceeo:::m lere than ortimum data / records due to in+ inability to reconstruct los: records to orig!nal quality. Item 21 No direct safety concern is e3 parent on the part of the insoector. He found that the licensee did not meet minimum standards for record storage facili:les and thereoy was $eacordizine cuality records which t 5.6-4
f ' Appandix 5.6
]h;'f(( .. ; FEF 101987 could crevent substantiation of performance / characteristics of ouality l activ! ties and hardware. l l
l The Task Group concludes that essentially no safety sionificanc+ can ! ce attached te this item: nowever. ootential ma,1or economic s i g r. i f i c a nc e w: i.d occur sheuld reecrd reconstruction be necessarv. The only element of safety significance would involve both the 4 licensee and NFC acceoting lese than optimum data / records due to tn+ inao111ty to reconstruct lost records to original quality. Item 22 . Missing labels on weld rod potentially represents a material traceability problem which could result in improper filler material being used to make a weld foint l The Task Grouo concludes there is no hardware or orogrammataic significance to this ise m s i r.ce weld rod iden*ificati n was n-t res!.v .. Juesti:n A Criterion V orocedural v i o la t i . ' . . . .sv-ceen written, out wcule have nad no casis in safety or the neec for further NRC followup. l Iten .: .- Loss of manacement centrol over corrective actions car. result 1: direct sa f et y consecuenc+s . l No direct safety sientficance can be attached to 10 CFR 50.55Je'. recortino. *he imo;1ca:lons of a failure to identify. report. and correct could na"e significant consequences fat the affected site. or oeyond). In this case. the issue was the ability of the licensee's program to t r a c r. the disposition of the items. Therefore, there was no actual sa fety significance.
't+rs if-:~
Less of management control over corrective actions can result in carect eafety consequences. No direct safety significance can be attached to 10 CFF 50.55ce) reocrting. The implications of a failure to identify. recort, and correct could have significant consequences rat the affected site. er beyend?. In in;s case. In+ i s r;e was tne ability of the licensee's program to track the disposition of the items. Therefore, there was nc actual safety significance. Item 26 Loss of management control over CDR corrective action can result in direct safety deficiencies. 5.6-5 [7) 3.7
Appendix 5.6 s,'.
- f. .j 0 1 0 ISS7 The Task Grouc believes that no direct safety significance exis*ed.
N: evicence exists to demonstrate that management was not ensurino that corrective actions were comoleted. only that the status o: corrective action was not totally uo to date and NRC should nave been notified of schedule e n a r.oe details. Items 29/33 The inspector appeared to be concerned that the licensee's overview and the actual cuality of the IEB 79-14 reanalysis performed by their contractor were both unacceptable. This might lead to potentially incomplete or incorrect dynamic reanalyses of piping systems. These issues have no sa fety signi ficance in the Task Grouo's assessment. The inspector misinterpreted the IEB requirements and attached undue significance to the file closure on IEB 79-14 by the licensee. It accears that the SWEC engineering effort was satisfactortiv addresetn- al: IEE 79-14 safety cuestions. Addittena: i ns t e :: in- -' 'i; ~ -: ..re *c review
- r. e s e enoineerir.o efforts to clcse the bulletin.
Iten 20 The ind;90*cre considerei inat the licensee's IE5 files inadetuatelv reDresentec ne cent.renensive resoonse ano followuo action. Nt dire;* safety concern is evid+n* No safety significance is accarent to the Task Grouo. The issue involves contentions over tne recuired/ desired contents of a soecific file catecory as it affette auditability. Item 3C The inerecter's etncern centers around whether licensee inetal.e-ton centrc.e -e % wn+rie ... ina:ecuate. With the after-the-fact evidence that hardware was not in cuestion and that adecuate documentation to confirm control of the switches was available, the Task Groue concludes that this issue has little saf+ty significance. A programmatic review of other part/ item documentation control did not appear justified because of the specific nature of this insoection ft.e.. NAMCO limit switches) and the fact that orocer l reecris were e"+ntuallv na:+ a"ai;able. The tinelin+ss c :: .v . 14 tne correct travelers to the OA records vaults could nave been eersuec as a document control issue or QA records issue C.e.g., Criterion XVII) but apoarently was not.
?% T
5.e-6 NeiInf a L -- . - - - - - - - - - - - - - - - - - - - - - - ------- .-
l Appendix 5.6 f pq - j y/ .., a 101987 Items 31/32 The inspectors considered the licensee's IEB review crocesses and records files as inadecuate to develop the comprehensive response anc followuo' action. No direct safety concern is evident. No safety significance is apoarent to the Task Group.. The issue involves contentions over the reautred/ desired process that the licensee uses to handle IEBs. The adequacy of actual licensee corrective action is not in contention. Item 34 The insoector expressed generic concerns (e.g., falsification) over the vendor suoplied material and design with respect to B!SCO seals, their testing conduct, records and certification crocess, and cotential Part 21 implications. The Task Grout deternine? that tne caric :aiety concerr. war ina- ina adecuacy of certified fire test data to support 3-hour barrier rating for BISCO cable penetration seal design PCA-76 was susoect and tnerefore represented a lecitimate safety cuestion. However, the , fundamental conern war initially identified by the licensee and their I corrective actien war i r. trocreer and creperly :1re:ted. Wn11e any generic im:11 cations at t hey acoly to BISCO are beino reviewed bv the Vendcr Procrams Bran-'. --
*he na'dws e imoact at CPEES was 'imited and the everall issue was of minor safety significance.
- 5. 6-7
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