ML20238A867
Text
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MhLdDt10N l
.-. g UNITED 8TATES l
1 NUCLE AR REGULATORY COMMIS$10N
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r wasocTow, o. c. sosss y
V..O April 14,1987 ME!!.ORANDUM FOR:
Chairman Zech j
FROM:
Victor Stallo, Jr.
I i
Executive Director for Operations
SUBJECT:
IMPLEMENTATION OF RECOMMENDATIONS OF l
COMANCHE PEAR REPORT REVIEW GROUP In November 1986, the Office of the Inspector and Auditor (O!A) issued its Report of Investigation, 86-10, addressing a21egations of Region IV management wrongdoing relative to inspection activities regarding the Comanche Peak Steam Electric Station.
In broad terms, the O!A Report dealt 1
l with three allegations: (1) harassment and intimidation of an inspector in connection with the preparation of inspection reports and ' the consequent downgrading or deletion of violations: (2) failure of the Region to carry out re;guired inspections of the permittee's quality assurance programs and, (3) l deficiencies in the NRC Form 766 reports prepared by inspectors to document inspection activities.
With the approval of the Commission, on January 21, 1987 I estab!!shed the Comanche Peak Report Review Oroup (CPRRG) to evaluate the OIA Report.
Consistent with the Commission's direction, the CPRRG was charged with l
providing recommendations on five matters: (1) the safety significance of the 34 issues identifled in the O!A Reports (2) whether the issues identified in the O!A Report were appropriately handled in terms of process and dispositions (3) whether the current augmented review and inspection effort at Comanche Peak is suffielent to compensate for any identified weaknesses in Region IV's quality assurance inspection programs (4) the purpose and significance of NRC Form 766 and, (5) whether the issues raised with l
respect to Comanche Peak have broader implications in Region IV.
The CPRRO specifically did not duplicate the OIA investigation nor develop any independent record of testimony (although it did request and receive some additional documentation): it did not address the !!censability of the Comanche Peak faci!!ty; and, it did not investigate or otherwise incluire into any matters of wrongdoing. misconduct or. mismanagement except to the oxtent that such matters were explicitly identified in tt.e CIA Report and its l
i attachments and then only for the purpose of identif>4ng factors that might have caused or contributed to the matters considered in the O!A Repo'et.
However, the CPRRG did perform a complete review of the OIA Report and M1 the supporting attachments.thereto.
Copies of the CPRRO Report were provided to the Commission on March 17, 1987.
It is appcrent that I treated this entire matter very seriously and devoted extensive management and staff effort to the task.
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's The CPRRG, in its Report issued to me on flarch-12,1987,~ addressed each of -
the five isr,ues identified above. To o,uote the CPRRG's conclusions:
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g (1) None of the 34 issues identified in O!A Report 86-10 was found to be significant in terms ; of any direct adverse impset on plant safety.
(2) Region IV's disposition, f.e.,
classification, of the I
identified issues was appropriate, and the Region acted within its authority bcsed on the information centained in the inspection' reports and on the guidance available for determining the classification.of.the findings, e.g.,
violation, unresolved [sle). CertrJn issues were not appropriately processed e.g., inspection findings were in some cases not developed by the inspectors in accordance with agency
- guidance, and. Region IV i
L supervision did not always provide ~ the guidance necessary to properly focus and resolve ftoms.
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(3) When rnessured against the 3986 inspection program requirements, raps were identified in the total inspection program.
The current augmented review and inspection effort at Comanche Peak has, for the most part, compensated for Faps in scope and coverage in Region IV's QA inspection program.
(4) The 166 system, primarily used by IE and little used by I
the Regions, is not used ~ in making safety decisions.
The accuracy, completes,ess, and timeliness of the data i
are not adeo.uate for many reeds.
Overall, the 766 l
system does not satisfy current agency needs.
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i (5) The CPRRG's judgment is that broader implications are likely for facilitics in Region IV other than Comanche Peak.
Additional considerations may influence the significance of these implications.
(CPRRG' Report r
at 4-1).
In addition to the forogoing conclusions, both the CPRRO Report and its coveral Appendices contain numerous recommendations for specific l
improvements and corrective actions.
We have extracted from the CPRRG Report and its Appendices all explicit reconsmendations and have categorized them as follows:
Category 3 additional and confirmatory actions and inspection efforts-needed to assure complete. disposition of the 34 issues in the O!A ~ Rcport 'and to compensate' for gaps identified in the Comanche Peak QA inspection program;
Category 2 clarification of inspection philosophy and practiecs,
authority to determine l
significance level of inspection i
findings, and documentation requirements and procedures for. inspection findings; and.
l Category 3 review of existinF data management systems with application to inspection activities, including NRC Form 766, and necessary revisions - to enhance the reporting, management and use of the I
inspection data for both' Headquarters and Regional purposes.
(CPRRO Report at 6-1, item 4 and Appendix D, Sec.VI!!)
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in order to carry out the CPRRG Report recommendations in the most timely
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manner possible and with due recognition of the recent establishment of the i
Office of Special Projects and the sgency-wide reorganiz6 tion, the above recommendations will be assigned sa follows:
category I recommendations apply specifically to the l
Comanche Peak faellity
- and, accordingly, will be I
assigned to the Office of Special Projects:
categories 2 and 3 recommendations, because of their programmatic nature, will be assigned to the Office of I
Nuclear Reactor Regulation with the assistance ' of-the Office of Administration and Resources !!nnagement.
In addition to implementing the CPRRG's explicit recommendations, I am directing these -offices to further review the. Report to determine whether there are any further actions to be taken based on other statements, implicit recommendations or lessons learned contained therein.. Euch of the recommendations will be implemented except as approved by me upon adequate' justification. is a preliminary listing containing those recommendations which are explicitly set out in the CPRRG Report.
As noted above, the staff w!!! continue to review the Report to extract other recommendations or suggestions which may be irleluded in the text and i
elsewhere in the Report.
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i 1Thile concluding that " broader implications are likely for facilities in Region IV other _ than Comanche Peak" (conclusion (5) above), the CPRRO makes no express recommendations for resolution of this concern.
The-CPREC does, however, make several observations regarding the significance of enhanced inspection activities at Comanche Peak and in terms of l
character!r.ing the nature of the causes of the events at Comanche Peak, which. bear on this issuc.
These. matters, along with a more detailed discussion of the evolution of the NRC's inspection program and other Region IV incilities, is presented in Enclosure 2.
In brief, it would not be 1
kh
4 unexpected that, if measured against the 1986 inspection program, gaps would be found elsewhere.
Moreover, the philosophy of the modularized inspection program is such that each line item need not be " completed" by the inspector.
Rather, the inspector is to consider each line item in l
determining whether the facility is being constructed (or operating) safely.
Nevertheless, the operating history of the other facilities, the team and other special inspections and on-site technical audits that were performed by the staff in addition to the various independent and utility-conducted verification efforts, suggest stronF y that such gaps as might exist would be l
few and not of safety concern.
Consequently, I have no cause to believe that the reasonable assurance which was previously found to eWst with i
l respect to other feellities within Region IV has been eroded.
Nevertheless, while I have no reason to conclude that the initiation of an inquiry to determine whether specific gaps in the inspection process exist for other I
facilities is immediately warranted, I propose to direct NRR to examine in l
more detail, the inspection records for a fae!!!ty within Region IV which did receive as much attbntion through either NRC-or utility-conducted not efforts.
If the results of such review require, further staff reviews of other plants will be performed.
Based on the findings and conclusions of the CPRRG Report, in pr.rticular l
those regarding the implementation of the inspection program for Comanche Peak, in terms of process and disposition, I also intend to take appropriate personnel setions to assure that, to the extent possible, the circumstances which culminated in the OIA investigation do not recur.
In this regard, I propose to personally write to the principal individuals involved to inform them of the CPRRG Report and provide each with a copy.
A draft of my proposed letters is attached as Enclosures 3-6.
Further, I intend to meet with each of the principals to inform them of my decisions for resoMng the remaining issues and to discuss with them their future roles in the Region.
I will also meet with other Region IV and site personnel to explain my actions.
I intend to stress the importance to be attached to professionalism, teamwork and the need to be sensitive to the views of others which may not coincids with one's own, within the framework of the inspection process as well as within the agency as a whole.
In addition to implementation of CPRRG's programmatic recommendations to provide further
- clarity, consistency and understanding of the NRC's inspection process, the principal individuals involved, both inspector and management, w!!! n!so be given specifle trajning to improve their interpersonal skills and communication as appropriate to the indMdual.
The Region-wide training program and l
guidance initiated by the Regional Administrator, descrlhed in his December 17, 1986 memorandum to me, will be continued for all appropriate j
Region IV personnel.
l In addition to the recommendations which are discussed above, the CPRRG Report contains recommendations and observations directed toward l
improvement in OIA's investigt.tton process.
CPRRO Report at 1 2-4 I
Appendix B at 17, items 1.7.30 and 3.7.31.
The Commission may wish to refer these matters to OIA for its consideration.
An additional, related l
recommendation is in order.
The CPRRO Report fundamthta!!y substantiates i
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5-the General - Counsel's observation, stated in his December 23 1966 i
memorandum to the Commissioner, that:
1t is unclear why re11snee on the Regional Administrator and adherence to the N R C's longstanding i
, procedures for handling Differing Proitssions) Opinlo:.s. as set forth in NRC Nanual Chapter, NRC-412b would not *, ave sufficed to permit a timely and effective resolution of all issues without having the situation escalate at the outset to the point of a full-scale CIA investigation involving charges such as harassment and intimidation.
The central issues
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which gave rise to thi.s matter sppear to involve differences J
in professional views on severa] matters.
It is my judgment that in this instance, the conduct of this protracted O!A investigation has served only to further polarise the individue.ls involved 6nd by distracting personnel from their assigned responsibilities, has been i
detrimental to the agency's mission to protect the health and safety of the public.
This suggests the need for the Commission to examine the policy question of requesting an O!A investigation when management-type issues are involved.
Perhaps by improvement in the existing procedures for resolving differing professional opinions, the Commission can better pro-l vide for the prompt disposition of such issues.
l I recomcend the release of the CPRRG Report and its Appendices to the public consistent with any limitations determined appropriate by the C tmmission regarding the release of the O!A Report, Investigation 86-10.
I further recommend the public release of this memoran'dum, except for Enclosures 3-6, upon Commission. approval nf the actions recommended, i
Appropriate Congressional Committees wi!! be notified at that time.
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The Commission's spproval of the foregoing actions is requested.
l Criginal signed by yict.cE ts)1ep f
3 Victor Stello, Jr.
Executive Director for Operations
Enclosures:
1.
CPRRO Recommended Actions I
2.
Implications for Other Region IV f
Facilities L 0. htteir te.~~-6 ?qtn "7 pewmet edre eN cc w/
Enclosures:
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Commissioner Roberts Comn.issioner Asselstine Commissioner Dernthat Commissioner Carr SECY OGC SConnelly. DIA 1
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CPRRG RECOMMENDATIONS i
l Comanche Peak Actions ID RICOP.MINDATION ORGANIZATIONS REFERENCES 02 Reinspection of OSP pc 3-8 hardware and design
-l during current Commanche Peak re-review. (Explicit r
recommendations in sequence numbers 22 through 50.)
18 Clarify agency CSP pg 5-1, pg 3-25 guidence: Clear lines recommenda tion #2 of responsibility between the Commanche Seak augmented inspection program and the established licensing, and inspection and j
enforcement processes I
were not established l
or maintained in i
implementing the inspect. program 20 Confirmatory NRC OSP pg 5-1 App A, Table f
action. Perform a recomenda 1., IR 85-07/05 detailed riview of tion #1 Item 1 (1)
Westinghouse's engineering evaluation regarding translation 1
of design criteria into installation specifications, procedures and drawings and failure to control deviations regarding Unit 2.
21 Confirmatory NRC OSP pg 5-1, App A. Table actions: Perform a recommenda.1, IR visual inspection of tion #1 85 07/05 Item the accessible reactor 1 (2).AppA vessel surroundings pg3-3 l
l during or after het functional test.
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i CFRRG RECO MENDATIONS Comanche Peak Actions ID RICOMENDATION ORGANIZATIONS REFERENCES 1
22 Confirmatory NRC 0$p pg 5-1 App A. Table l
action: Perform a recomenda 1. IR l
detailed review of tion #1 85 07/05, Item Westinghouse's 2, App A pg engineering 3-3 evaluation. Failure to I'
maintain tolerance required and failure j
to report tolerance 4
deviations on an NCR with regard to Unit 2 RV support brackets and shoes.
23 Confirmatory NRC OSP pg 5-1, App A, Table action: Verify that an recommenda 1. IR adequate qu;11ty tion #1 85-07/05, Jtem a
control procedure 4
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exists for QA App A pp 3-12
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i inspectors to witness l
the transfer of l
i marking for material i
l that would otherwise lose its traceability when cut into smaller I
sections.
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l 24 Confirmatory NRC OSP pp 5-1 App'A, Table action: !ssue: FSAR recommenda 1, IR 17.1.17 does not tion #1 85-14/11. Item i
describe TU. Electric 1 (1),AppA records system.
p3-22 Action: Review the I
revised NEO procedures l
upon their completion i
and verify the implementation. Verify adequacy of applicants 1
corrective action.
25 Confirmatory NRC OSp pg 5-1, App A, Table q
action: Issue:QA recommenda 1. IR 1
nanual does not tion #1 85-14/11, Item address ANSI N45.2.9 3
requirements /commitmen ts. Action: 53e actions of Sequence Nw.ber 24 above.
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CFRR6 REcuMMENDATJONd j
Comanche Peak Actions L
ID RIC0KMINDATION ORGANIZATIONS REFERENCES l
25 Cc.firmatory NRC OSP pg 5-1 App A, Table Action: Issue: TU recomenda 1. IR Electric failed to.
tion #1 85-14/11, Jtem have/use procedures to 3
control shipment of design records for piping to Stone and Webster, NY. Action:
See secuence Number 24 above.
27 Confirmatory NRC 05p pg 5-1 App A, Table action: !ssue:
recemmenda 1 IR original design tion #1 85-14/11,' Item records shipped in 4
i cardboard boxes to j
Stone and Webster.
l Action: See Sequence Number 24 above.
j 28 Confirmatory NRC OSP pg 5-1 App A, Table-action: No backup copy recommenda 1. IR of records made for tion #1 85-14/11, Item records shipped to 5
l Stone and Webster.
Action: See Sequence I
Number 24 above.
29 Confirmatory NRC OSP pg 5-1, App A, Table action: Issue: Failure recommenda 1. IR to control and account tion #1 85-14/11, Item 1
for QA design records 6
transferred from site to Stone' and Webster, NY. TU Electric stated.... Action: See l
Sequence Number 24 above.
30 Confirmatory NRC OSP pg 5-1, App A, Table action: Issue: Site recommenda 1,.!R records containment tien #1 85-14/11, Item liner and mechanical 7
penetration.cf Cnicago Bridge and Iron shipped to Houston, Texas, in cardboard bexes. Action: See Seouence Number.24 above.
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i CPRRG RECOMMENDATIONS l
Comanche Peak Actions -
ID RECOMMENDATION ORGANIZATIONS REFERENCES 31 Confirmatory NRC OSP pg 5-1, App A. Table action: Issue: No recomenda 1. !R backup copy of records tion #1 85-14/11, Item j
made for records 8
shioped to Chicago Bridge and Iron.
Action: See Sequence f.nt.ber 24 above.
32 Confirmatory NRC OSP
.pg 5-1 App A, Table l
action: Issue: TU recommenda 1, IR Electric failed to tion #1 85-14/11,! tem inventory records sent 9
to Chicago Bridge and Iron. Action: See i
Sequence Number 24 I
above.
l 33 Confirmatory NRC OSP pg 5-1, App A, Table recomenda 1 IR action: Issue: Plant tion #1 85-14/11, Item records stand in 14 folders or open binders in open face cabinets at records center. Action: See Sequence Number 24 1
ibove.
34 Confirmatory NRC OSP pp 5-1, App A, Table i
recomenda 1, IR action: Issue: Failure tion #1 85-14/11, Item to provide temporary 15 or permanent storage App 8 pg 101 facility for records entered into the permanent records center then co mingled with in-process documents in paper flow group. Action:
See $equence Number 24 above.
35 ' Confirmatory NRC OSp pg 5-1, App A Table recomenda 1 IR action.
Issue:
tion #1 85-16/13, item Failure to 1, App Ap develop / implement 3 28/9 procedure to demonstrate 50.55(e) l deficiencies corrected. Action:
Audit the CDR program to verify its adequacy. (Applicant' should revise procedure NE0 CS-1.)
CPRRG RECOMMENDATIONS Comanche Peak Actions 3D RECOMMENDATION ORGANIZATIONS REFERENCES l
Cc.firmatory NRC 0$P pg 5-1, App. A. Table j
a:: ion.
Issue: TU recommenda 1, IR i
Electric failed to tion #1 85-16/13 Item l
revise implementing 2.
procedures centaining 50.55(e) reporting before corporate NEO j
Procedure CS-1 was j
implemented resulting I
in a conflict with 5 ether procedures.
Action: See Sequence No. 35 above.
37 Confirmatory NRC OSP pp 5-1 App A Table action.
Issue:
recommenda 1, IR Failure to maintain tion #1 85-16/13, Item retrievable 50.55(e) 3.
i files (i.e., could not i
produce record in j
almost a month).
l Action: See Secuence Number 35 above.
38 Confirmatory NRC OSP og 5-1, App. A, Table pction.
Issue:
recommenda 1. IR 4
Failure to report to tion #1 85-16/13, Item NRC actual corrective 4.
action taken on 50.55(e)s. Action:
l See Sequence Number 35 above.
39 Confirmatory NRC OSP pg 5-1, App. A, Table action.
Issue: TU recommenda 1. *R Electric's 50.55(e) tion #1 85-16/13, Item files not auditable.
5.
Action: See Sequence Number 35 above.
4D Additional NRC action.
OSP pp 5-1, App. A, Table l
Issue: TU Electric recommenda 1, IR never responded to all tion #1 85-16/13. Item aspects of IEB 79-14.
6 & p. 3-33.
l Action: Provide l
applicant with clear &
l concise written evaluation of actions taken to date &
specify additional actions required to c1cse the issue of IEB 79-14.
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CPRRG RECOMfiENDAT!ONS.
Comanche Peak Actions ID RECOM'iENDATION ORGANIZATIONS REFERENCES App. A, Table pg 5-1, da 1, IR 48 Confirmatory NRC OSP recomen action.
Issue: TU l
Electric's IEB record tion #1 85-16/13. Item files were incomplete 7 & p.
l (1982 & 1985).
3 36,37.
Action: Evaluate effectiveness of applicants' program through an audit.
(Assure that all Bulletins were received, processed, &
l corrective actions l
l initiated...
l 42 Cor.firmatory HRC OSP p3 5-1, App. A, Table actfon.
Issue:
recomenda 1 IR tion #1 85-16/13, Item l
l Deficiency in TU procedures to handle 9 & p. 3 36.
)
IEBs. They do not l
describe how construction l
management personnel handle IEBs requiring action, especially hardwara repair, replacement &
modification. Action:
See Sequence No.41.
43 Confirmatory NRC OSP pp 5-1,
' App. A, Table action.
Issue: No recomenda 1 IR tien #1 85-16/13, Item focal point in 70 10.
Electric to track IEB items. Action: See Sequence Number 41 above.
44 Confirmatory NRC OSP pg 5-1, App. A, Table action.
Issue: 70 recomenda 1. IR Electric's internal tion #1 85-16/13, letter stated that TU Item 13.
Electric would not identify nonconformances on IEB 79-14 to NRC. Action:
See Secuence Number 41 above.
CPRRG RECOMMENDATIONS Comanche Peak Actions ID RECOMINDATION ORGANIZATIONS REFERENCES 45 Confirmatory NRC OSp pg 5-1, App. A, Table action. ' Issue:
recomenda 1, IR Insufficient evidence tion #1 85-16/13, Item of successful testing 12 cf 515C0 fire seals -
filing of falso reports by 815C0, validity of 81500 seal cuestioned. Action:
Verify adequacy of new seal installation.
46 Confirmatory NRC OSP pg 5-1 App. A, Table i
action.
Issue:
recomenda 2, IR Failure to maintain tien #1 85-07/05, Item tolerance and to 2, App A pg report tolerance 3-6 deviations on an NCR re Unit 2 RV support trackets and shoes.
Action: Examine traveler and NCR procedures, confirm changes are in plant specif. design +
maintained...
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47 Confirmatory NRC OSP pg 5-1, App. A, Table action. Issue:
recommenda 2, IR Failure to perform tien #1 85-07/05, item i
audits of 3
l surveillance of reactor pressure vessel specs, procedures &
installation. Action:
Monitor applicants' i
response to staff concerns raised in SSER 11 regarding their audit program.
48 Confirmatory NRC OSP pg 5-1, App. A, Table actions. Issue: No recommenda 2, IR j
objective evidence tion #1 85-07/05, Item (records) that mixing
- 6. App A p l
blades had been 3-17 i
inspected quarterly since 1977. Action:
Review statistical esta re uniformity of l
l concrete and review larger sample of concrete compression 1
tests.
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'CPRRG RECOMMENDATIONS Comanche Peak Actions j
3D RECOMMENDATION ORGANIZATIONS REFERENCES
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49 Confirmatory NRC 0$p pg 5-1, App A Table 2, j
action.
Issue: NAMC0 recomenda 1R j
switches IEB 79-28 tion #1 85-16/13, Item were not properly 8,93 41,42: pg identified on 3-8 1
installation
'l travelers. Action:
Monitor applicants' EQ CAP. Note (3)
Applicant actions. list 50 Confirmatory NRC OSP pg 5-1, App A, Table action: Issue:
recomenda 1 IR Insufficient evidence tion #1 85-16/13, Item of successful testing 12 & pg 3-46 4
of B1500 fire seals, I
filing of a false
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report by
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SISCO---validity.
Action: Reinspect seals and J
certification documentation.
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51 If spool CVCS spool OSP pg 5-1, pg 3 10. App B piece was not marked recommenda pg 15 at.the time of tion #2 inspection, then 1
additional review l
would be warranted.
Resolve uncertainty associated with when the spool piece was I
marked.
l 52 Inspections included OSP App C, i
in the 1986 inspection Table 1, program, but not pp.10-12 completed at Unit 1, should be reviewed, and those determined to be necessary to confirm plant quality, j
should be accomplished.
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CPRRS RECOMMENDATIONS Comanche Peak Actions 2D RECOMMENDATION ORGANIZATIONS REFERENCES i
93 The status of the OSP pg 5-k, pg 3-27/28, recommenda App C pg 4 inspection programs tion #3 for Unit 2 should be monitored with respect to all NRC inspection activities to assure that inspections keep pace with construction and " windows of opportunity" are not lost.
59 Further review of OSP App B pg 15 Operations Traveler -
criteria, control and effectiveness is warranted if it has not been done as a part of inspection activities completed to date.
60 A need to verify the OSP App B pg 15 adequacy of Level ! QC inspection of RPV installation may exist.
61 Further NRC review of OSP App B pg 15 the completeness of QC coverage and technical acceptability of the actual inspection criteria for the j
installation of all the major NS$$
components is possibly warranted.
62 Inspection of other OSP App B pg 15 installed field fabricated spool pieces should be considered, 4
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l CPRRG RECOMMENDATIONS l
Cornanche Peak Acticas 10 REC 0 mENDATION ORGANIZATIONS REFERENCES l
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63-Verify adequate OSP App B pg material 15 identification and traceability program for earlier work or l
review procurement and control program for i
the bulk piping stock l
st CPSES with further inspection directed to i
the checks and l
balances precluding
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install. wrong material 66 Determine if the OSP App B pg Regulatory Guide 1.97 16 QA commitments have been properly I
implemented at the CPSES and whether Region IV has monitored such
, implementation.
67 The adequacy of the DSP App B pg licensee's program to 16 update permanent installation i
documentation when components are changed should or replaced should be reviewed, if not already evaluated in inspections to date.
The need to evaluate OSP App B pg safety significance 17 Rec. #
and all pertinent 1.7.9 aspects of the licensee's QA Program may need to be emphasized.
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CpRRG RIC0 EMENDATIONS Comanche Peak Actions 3D RECOMMENDATION ORGAN 11ATIONS REFERENCES 72 Additional inspection 0$p App B pg by NRC is required to
- 4. 6-EF review engineering Items 28/33 offerts to close IEB j
19-14.
73 Region IV selectively OSP App C pg 3 I
review records to see if specific inspection gaps were caused by l
non-performance. If so, Task group recommends "the i
Region" (sic) take appropriate action to close those gaps where i
there remains a clear benefit to... plant cuality.
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d CPRRG REC 0W.ENDATIONS l
General Programmatic Actions-2D ~RECOP.INDATION ORGANIZATIONS REFERENCES l
04 ANSI N45.2.9 is silent NRR RES pg 3-15 app B pp 75-77, pg 3 14 on shipping records. A two places.
definitive and documented reguistory position does not exist on controls j
during transfer l
between organizations.
'pp 5-1 pg 3-25, pg I
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'05 Clarify agency recomenda 318, App B pg j
.guidence: IE MC 9g00 tion 2 16 App B pg j
guidance was 116 misinterpreted on applicability of 10 CFR 50, Appendix 5 criteria to to the requirements of 10 CFR 50.55(e).
21 Clarify agency NRR NMS$
DE pg 5-1,'
pg 3-24, pg recomenda 3-22 guidance:
tion #2 App B p 10 Philosophical differences... on two issues: first, to what extent should inspectors focus on
" hardware" vs QA I
" records" second, to what I
extent should violations be developed prior to issuance.
64 The philosophical NRR NM55 App B pg 16 position as stated by Region IV (that although a procedure required blade inspections, it did riot. require documentation of such inspections) requires careful consideration.
CpARS RECOWENDATIONS General Programmatic Actions 1
a 2D RECOMMENDATION ORGANIZATIONS REFERENCES j
1 65 Consideration should NRR NMS$
RES App B pg I
be given to the TRT 16 j
position that i
" permanent" records i
removed from storage for use or revision revert to an 4
"in process" status,
)
which do not require i
application of the full ANSI N45.2.9 provisions.
75 NRC Headquarters NRR App C pg 9 i
should improve its I
regional assessmant function to require more frequent and timely in-depth evaluations of the region's plant inspection performance and documentation practices.
App B pp App B pg 17 discretionary guidance 6-11 Recommendation provided to
- 1.7.8
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supervisors and management when dealing with non-escalated enforcement. When does i
a non-compliance become a violation?
Expand MC 0400 and 0610 accordingly. Also see Sequence number 68.
EB Consideration should OE NRR NMSS App B pg be given to amplifying 17 Rec. #
MC 0400 and MC 0620 1.7.9' regarding how to develop and document violations of 10 CFR 50 Appendix B Criteria. Also see Sequence number 57.
CPRR8 RECOMMENDATION.3 General Programmatic Actions 3D RECOMMENDATION ORGANIZATIONS REFERENCES D7 No NRC guidence exists CE NRR NMSS pg 3-Z3 l
en the time permitted l
a licenses to retrieve E
a document which is required to be l
retrievable.
pg 5-1, pg 3-25 guidance: Authority of
. recomenda inspectors and tion #2 supervisert to disposition violations,
involving isolated l
matters having minor
- safety significance and for which the licenses takes immediate, effective corrective action.
pg 5-1, pg 3-25 guidance: No recommenda definitive guidance tion #2 exists regarding the acceptability of multiple violations for.the same underlying cause.
17 Clarify agency CE NRR pg 5-1, pg 3-25 guidance: The FSAR is recommenda part of the tien #2 application for an cperating license and enforcement submitted to NRR for review. The role of the FSAR in the inspection process i
for facilities under construction is unclear (IE MC 9900).
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CPRRG RECOMMENDATIONS 1
Data Manegement Improvements ID RECOMMENDATION ORMN!1ATIONS REFERENCTiS pp 3 28 32, i
pg 5-1*, da App C pg 9,
$4 Develop a more NRR OIRM recommen l
comprehensive, unified tion #4 App D pg 1-2 j
l 766 System that meets current agency needs.
and pg VI!!
l Consider.the l
monitoring of site 1
specific inspection programs, periodic regional monitoring of f,
inspection program i
status, c4 He l
l overview. Possibly then do Segu#s 76 and j
i 77.
l 76 Establish inspection NRR 0!RM App D pg App D pg VI!!
1-2 Rec, # Rec #2 4
and enforcement data 2
l 1
quality assurance 1
policies ard procedurces as well as a training program to 4
help assure a consistent, reliable.
1 and timely agency data source. This could be accomplished after sequence number 54.
77 Consider collecting NRR 0!RM
' App D pg App D pg VI!!
l 1-2 Rec. 4 Rec. #3 l
all inspection and 3
i enforcement staff resource data in RITS.
Evaluate the benefits of collecting i
inspection information by SALP functional area rather by inspection module.
This could be accomplished after Sequence number 54.
si:
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IMPLICATIONS FOR OTiiER REGION IV TACILITIES With respect to the issue of whether Region IV failed to conduct required activities for Comanche Peak, the principal focus of O!A's investigation was on-the inspection of the ut!!!ty's Quality Assurance Program, mainly at the company's headquarters, pursuant to 3E Manual Chapter 2512.
(OIA Report I
at 37-46)
The CPRRG, however, expanded this scope and examined the riatter from the broader perspective of all required inspection activities called for by the current IIRC inspection program.
The CPRRG concluded that *... broader implications for other fac!!!tles in Region IV cannot be ruled out and are !!hely to exist.'
However, while no specific recommendations are made, a number of observations stated by the CPRRG do provide useful gufdance.
For example, the CPRRG stated that:
... to the extent that limited resources were a factor at Comanche Peak !!n terms of def!clencies in Region IV QA inspection activities), some evidence arists that this factor may have affected other planta.
Construction programs at 17aterford, Comanche Peak, South Texas, it'olf Creek, and River Bend were all under way at the same time.
- This fact could have aggravated the situation, particularly since Region IV has a re16tively l
small staff.
Testimony in the record indicates that inspection activities at Comanche Peak and t.'aterford were adversely affected as a result of limited regional resources.
Further, some of the factors that apparently lead to the difficulties at Comanche Peak, and ultimately to the OIA investigation, appear to he rather fundamental in nature and may not be limited to one alte.
In this regard, it is not at a!! clear that for Ccmanche Peak there was an established and understood philosophy for the conduct of the inspection pregrams a commonality of purpose on the part of both inspectors and managements and good l
communications and interchange in the development and dispositioning of inspection findings....
!!owever, there are factors apparent from the CPRRG review that tend to m6ke it difncult to gauge or assess the significance of such imp!! cations.
Tha heart of the Comanche Peak conflict seems to be a dispute between an inspector and his management.
This dispute reficcted differences in inr.pection emphasis, enforcement policy, and the role of the inspector in the inspection and enforcement program...
Additionally, despite much controversy over the issues reflecting this dispute, the record does not estab!!sh that any unsafe condition ex!r.ts at Comanche Peak.
In feet, none of the 34 issues
j'
.i raised by the inspectors and included in thb OIA report have direct safety significance.
Further, the record contains considerable testimony that, for the most part the Comanche Peak activities were being pursued by individuals attempting to properly discharge their responsibilities as they understood them. These findings suggest that the controversy in this case involves a limited number of individuals and s l limited number of lisues.
(CPRRG Report at 3 3-4 )
The language. quoted above is presented to provide a perspective on. the appropriate breadth of actions necessary to estees whether the situation as it. erdsted in regard to Comanche Peak, existed with respect to othar l
facilities within ReFion ?.V.
It is also necessary/ however, to understand the evolution of the NRC's inspection program over the years in orden to assess the significance of any gaps that might exist.' In fact, the findings 'of bMh
'. rI the CIA and CPRRC Reports with respect "to the NRC's inspection prcgram are, in a general sense, consistent with the-Commission's own findinp.,
presented in "A Repert to Conpess, Improving Ruslity rnd the Assurance of QuaMty in the Design and Construction,of Nuclear Power Plants,"
NUREO-1055, May 1984.-
Through the late-1970's, the inspection propam was fttndamentally oriented towards a review 'of a Ifansee's written qua!!!y assurance propam and program documentation with s little emphasis on observation of work and inspection of hardware. The. propan, uhich has always been based on inspections / audits of caly a fraevien of all such setivities, be they construction-related or operaf3on re16ted, exceeded manpqwer resources.
Such manpower constraints have'been magnified from time to time and from Region to Region because of specific Regions!
manpower shortfalls and/or because of peculiarly heavy inspection demands resulting from the number of facilities within a Pegion requiring like, manpower-intensive efforts in the same timeframe.
In the 1980's, the focus os the program was reviced somewhat to put increased emphasis on the inspection and observation of work and less on records review, and to better accommodate resource limitations.
At each stage of the evolution of the inspection program, the IE Manual end its impection modules, which provides guidance to NRC. inspectors, have been changed to ccrrespond to the then-current inspection philosophy.
It should also be recognised"that Eteral completion of each inspection module is not required.
Rather, as the II Manual makes clear, an inspector is obligated to p'ive consideration to the inspection requirements of each module whleh, due 26' facility-specific considerations, may result in any given. module not being " completed".
fforeover, as a practical matter, completion of au modules has genera!!y not been achieved completion of the inspection programi has ranged from about 80-Ht to 90-200%.
The foregoing background is discucsed at !cngth in Appendix D to the above-mentioned Report to ConCross.
Also reicvant to the queption of broader implications.fs !the implementation of-augmented Nhc inspection shd audit activitics (such as CATS, PATS, IDI6
% ?lihe) at many sitec as well as the implementation of a variety of ara 2 inde$ ment and utility-conducted design, construction' and quality assurance purification programs prior to the licer sing of all recent plants. While both L_.
F
l 4
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of' these efforts have tended to focus on selected areas of a facility, they have taken into consideration applicable QA/QC requirements and have been
~
sufficiently broad in scope, in terms of the spectrum of structures, systems and components of a plant under scrutiny, to piovide a well-rounded retros)/ective picture of the adequacy and effectiveness of the respective QA program.
Both the OIA cud CPRRG Reports acknowledge the contribution of such efforts, in the case of Comanche Peak, to compensate for possible gaps in the NRC routine inspection process.
The existence of similar undertakings elsewhere, therefore, is of significance in deciding whether m:ssures are warranted to determine whether such gaps in the inspection program as utre found at Comanche Peak are of concern at other facilities.
In Ifght of the foreFoinf:, the CPRRG's - conclusion regarding broader implications is addressed.
As noted by the CPERG, a number of facilities in Ragion IV were under construction in generally the some timeframe.
- Thus, 1
en the one hand, Ifmitations on Region IV resources lodeally could have had an effa.et on inspection. efforts related to all of them.
On the other hand, the Region was fully budgeted for these activities and a variety of special and augmented inspection and audit activities were condqcted at several of 3
these facilities which provide confidence that any gapsTin the Region !Y l
program wou!d not !!kely have resded-in the fe.ilure to detect deficiencies with safety slgnificance.
For instance, as at Comanche Peak, e:ctensive staff technical audits were undertaken at the k'sterford, South Texas, Wolf Crvek and River Bend facilities in econection with the Maff's operating licence reviews.
These activities included detsfled reviews of the applicants' site records on selected (but widely var!cd) issues and team inspections on selected important safety systems.
As pr.rt of thest/ efforts, emphasis was placed on implementation of QA programs related to the matters under review.
- hilarly, Fort St. Vrain has' been subjected to detailed scrutiny in cennection with factors surrounding the extended plant shutdown, compliance l
with thit Commissien's environmental qualification recluirements and the staff's
_ review of tha Chernoby! implications.
Although these reviews focused principally ont harduare and systems - design, related QA elements were
-implicitly conside. red in the !!censee's overall improvement program.
In addition..Reipon.IV conducted an sugmented inspection of the licensee's quality programs as a result of a SALP category 3 finding..
The Cooper Fort Calhoun end Arkansas lluclear One faellities have been in cperation fcr many years, indeed, prior to the development of the NRC's
- ~ increased emphasis on construction inspection setivities and were not subjected to such deta!!ed audits and inspections.
Nonetheless, heesuse their periode. of construction preceded by some years some of the evolutionary changes in the inspection process, the uncertainty as to the e
proper' 2nspection philosophy is.likely less than was found to exist in later
~yvors when more changes occurred. Furthermore, e.1though the staff did not marform any specint er augmented audits or inspections 'ct these plants, their
- ent operational histories strongly suggest thht gr.ps that might be found are of litt!,e' morrent in terms of safety.
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I As noted above, the CFRRG also observed that the conflict regarding Comanche Peak appearc to have at its heart "a dispute between an inspector ud his management."
This factor, unquantifiable thouEh it may be, could tend to limit the potential for far-reaching implications; we are not aware of simUst disputes of such broad scope that have arisen in connection with any
(
other facility in Region IV.
bloreover, the CPRRG's found that, in general, l
Region IV's disposition of each of the 34 items at issue in regard to I
Comanche Peak was appropriate and that none of these issues was of direct safety signincance.
The CPRRG Report gives no reason to suspect that such disputes as might have existed in connection with other faciliths were i
not also appropriately dispositioned or that issues of direct safety
.I significance are likely to have been discarded or ignored because of process-related conflicts.
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