ML20238A868
| ML20238A868 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/04/1987 |
| From: | Crutchfield D Office of Nuclear Reactor Regulation |
| To: | Arlotto G NRC |
| Shared Package | |
| ML20237K807 | List:
|
| References | |
| NUDOCS 8708210105 | |
| Download: ML20238A868 (3) | |
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UNITED STATES
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q NUCLEAR REGULATORY COMMISSION
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WASHINGTON, O. C. 20555
- .Q MAR 4 ty7 HEMORANDUM FOR:
Guy A. Arlotto, Chaiman Comanche Peak Report Review Group FROM:
Dennis M. Crutchfield, Assistant Director Division of PWR Licensing-B Office of Nuclear Reactor Regulation
SUBJECT:
REVIEW 0F RECOMMENDATIONS CONTAINED IN THE TASK GROUP 2 REPORT The purpose of this memo is to document Task Group 3's comments on the recommendations provided in the CPRRG Task Group 2 Report, Revision 1, dated March 2, 1987. As discussed in the Task Group 3 Report dated February 27, 1987, we believe that the conclusions reached by the two Groups correlated well with each other.
Similarly, as a result of an evaluation of the recommendations, we find that the recommendations of the two Groups correlate well with each other. Accordingly, we endorse the recommendations contained in Sections 1.7.1 and 1.7.3 and one of the two recommendations contained in 1.7.6 of the Group 2 Report. We do not support the recomei%ations contained in Sections 1.7.2 and 1.7.5 and one of the two recommendations contained in Section 1.7.6 of the Group 2 Report at this time primarily because of ongoing applicant programs that should resolve the concerns.
Specific coments on each of the recommendations are provided in the enclosure.
We have discussed our comments w1th the' leader of Task Group 2 and he concurs with our proposal for disposition of the Task Group 2 recommendations.
g Dennis M. Crutchfield, Ass stant
' rector Division of PWR Licensing i
Office of Nuclear Reactor Regulation
Enclosure:
As stated cc w/ encl.:
C. J. Heltemes, Jr.
C. Paperiello J. Lieberman R. Erickson P. McKee S. Collins R. Hartfield k[ kDoh
[
G
i TASK GROUP 3's COMMENTS ON TASK GROUP 2's RECOMMENDATIONS 1.
Section 1.7.1 of the Task Group 2 Report recommends a review of the j
applicant's traveler development program to determine how design infonnation and design changes were handled.
Based on our review of the concerns associated with the reactor pressure vessel installation and the NAMC0 switch replacement program, we find broader implications of deficiencies than those stated in OIA 86-10 related to the development and use of travelers at CPSES. Accordingly, we recomend confirmatory NRC actions (Task Group 3 Report Section 3.2) and additional applicant actions (Task Group 3 Report Section 3.14) to focus on the adecuacy of the traveler program. Although less prescriptive than Task Group 2 in discussing acceptable methods for addressing concerns related to the traveler development program, we make a similar recommendation in Section 3.14 of the Task Group 3 Report. Accordingly, we support the Task Group 2 recommendation.
2.
Section 1.7.2 of the Task Group 2 Report recomends further NRC review of the completeness of QC coverage and technical acceptability of actual inspection criteria to compensate for deficiencies in the audits and surveillance at CPSES.
Based on our review of concerns associated with audits and surveillance, we find broader implications of deficiencies than those stated in 0IA 86-10 related to the audit plan for overall program assessment.
Recognizin ISAP (as discussed in the SSER)g the CPRT program Plan and the ongoing, we' re programs (Task Group 3 Report Section 3.3).
If through these efforts the NRC determines that the applicant's programs are inadequate, additional action such as recomended by Task Group 2 may be required.
However, we do not recomend new initiatives, stTch as those proposec by Task Group 2, at this time.
3.
Section 1.7.3 of the Task Group 2 Report recomends verification of the existence of an adeouate material identification and traceability program, and proposes methods for performing this verification.
Although less prescriptive in discussing acceptable methods for accomplishing this verification, we make a similar recommendation in Section 3.4 of the Task Group 3 Report. Accordingly, we support the Task Group 2 recommendation.
4.
Section 1.7.4 of the Task Group 2 Report makes no specific recommendation, l
but discusses a perceived philosophical position at Region IV on records.
We have no specific recommendation on the issue. We note in Section 3.6 of the Task Group 3 Report that neither the B&R procedure nor the ACI Standard recommend documentation of inspection, however, maintaining such records would be prudent.
5.
Section 1.7.5 of the Task Group 2 Report recommends additional NRC review of the CPSES record control program, specifically focused on the applicant's treatment of in-process documents.
As discussed in Section 3.7 of the Task Group 3 Report, the applicant has recognized a deficiency in this area and comitted to revise procedures as corrective action. We recommend that as a confirmatory action NRC review this revised procedure to determine if it is adeouate to resolve the deficiency. We believe this applicant comitment and our recomended NRC action should resolve the concern. Therefore, we find the Group 2 proposed action is not necessary at this time.
' 6.
Section 1.7.6 of the Task Group 2 Report recommends a review to determine if the Reg. Guide 1.97 QA commitments have been properly implemented at CPSES and a review of the applicant's program for updating records.
Baseo on additional review of the FSAR and SSER sections related to Reg. Guide 1.97, we determined that the NAMC0 switches in question are not within the scope of the Reg. Guide. Therefore, no additional review of this issue is required.
However, as discussed in Section 3.14 of the Task Group 3 Report, we recommend additional applicants action to determine the root cause of the record / hardware mismatch.
Our recommendation and.
that of Task Group 2 are quite similar on th.is issue. Accordingly, we support-t,he recommendation.
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