ML20245A051
| ML20245A051 | |
| Person / Time | |
|---|---|
| Issue date: | 02/02/1987 |
| From: | Rehm T NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Kammerer C NRC OFFICE OF CONGRESSIONAL AFFAIRS (OCA) |
| Shared Package | |
| ML20238C237 | List:
|
| References | |
| FOIA-87-726 NUDOCS 8702090167 | |
| Download: ML20245A051 (5) | |
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FEB 12 M87 cf2/T
~ MEMORANDUM FOR:
Carlton Kammerer, Director
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Office of Congressional Affairs FROM:
Tom Rehm Assistant for Operations Office of the Executive' Director for Operations l
SUBJECT:
CLARIFICATION OF ITEMS RELATED T0 THE NRC REVIEW OF TVA COMPLIANCE WITH'10 CFR, PART 50, APPENDIX B In your letter to me dated. January 12, 1987, you requested clarification' for, the subject items. Your specified items along with clarifications are provided in Enclosure 1 to this letter. Additionally, for your information and perspective, a brief outline regarding'the scope.of_this particular effort is included in Enclosure 2 to this letter.
As a result of the effort. the staff concluded that interviews of TVA and TVA contractor personnel involved in the process of_ preparing the March 20, 1986, letter were needed to understand the process and to determine if additional' information was available. These interviews were conducted on January 5-through 8, 1987.
In addition to your letter, Henry Myers wrote a letter (enclosed) to Harold Denton, dated-December 23, 1986, requesting related clarifications..
Henry Myers' specified items along with clarifications are provided in Enclosure 3 to this letter.
Tom Pehm, Assistant for Operations Office'of the Executive Director for Operations
Enclosures:
As stated se.& 4Hm Nn/t9
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ENCLOSURE 1-1 HOUSE INTERIOR COMMITTEE INQUIRY (1) Request-
"The conclusion to the NSRS perception that the 'as-constructed weld program is indeterminate' states '(t)his documentation supports a non-compliance welding program, but the procedures and QC reports do support a [ program that would be indicative of a_ well structured] welding program.'
Interior Comittee staff says that this sentence is' subject to various
_ interpretations and asks the meaning of the statement."
Brackets added to correct quotation.
Cisrification J
Documentation supplied by TVA included procedures which, if adequately.
implemented, would constitute a well structured program. However, the documentation supplied by TVA (NSRS' reports, employee concerns reports, and NCRs), indicated that the procedures were not being ~ adequately _
implemented.
(2) Request "Regarding the discussion of electric cable qualification, the Interior Committee staff would like to know if the NRC staff is aware of'a July 1985 NSRS report on cables and whether that report was considered in the NRC staff's review (See, for_ example, the discussion in sectice-2 of'the December 17,~1986, congressional staff memorandum, " Staff Review of NRC Responses to Quality Assurance Breakdown within TVA's Nuclear Program".);"
Clarification The documentation provided by TVA included NSRS_ Report No. I-ES-06-WBN, dated July 9,1985, " Investigation of an Employee Concern Recerding Cable 3
Routing Installation, and Inspection at Watts Bar Nuclear Plant."
Hence, the staff is aware of this report.
Regarding the consideration of the NSRS report in this specific review,
.l the assigned reviewer was a specialist in quality assurance requirements 1
and felt that the documentation provided in this area by TVA was bighly..
technical in nature and beyond his expertise. He concluded that he could 1
not make a determination in this area,~ and he recommended a furtherc l
technical review. Therefore, the subject. report was not considered, ether than noticing its presence, during this specific review.
The staff group responsible for the technica'l review of electrical cable at Watts Bar is aware of and has a copy of 'NSRS Report No. I-85-06-WBN.
l This group's technical review of electrical cable issues 1s; ongoing. -
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2 (3) Request "In the conclusion to the review on construction processes, it is not clear what the differences are'between ' excessively loose control of the construction process,' and ' cases of failure to follow controls.'"
Clarification The two. phrases from the' tyoed draft conclusion do seem to be nearly of.
the same meaning; however, the difference between these phrases is implementation. Discussicn with the reviewer reveals the following intent:
The example problems cited in the documentation supplied by TVA appear to be more of the nature of problems with implementation of the program rather than problems with the program itself. The reviewer, therefore, felt that the program identified sufficient controls; however, those controls were not always implemented properly.
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ENCLOSURE 2 SCOPE OF 00' }lNTATION REVIEW The staff review, conducted on December 3 through 5, 1986, of the documentation submitted by TVA as backup documentation for substantiation of 1
Mr. White's statements in his March 20, 1986, letter to Mr. Dentem, was-preliminary in nature and was intended for a limited purpose.
This effort was not a review of the technical adequacy of the documentation.
Technical reviews of TVA issues are ongoing by separate, line staff groups.
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Reviewers for the effort consisted of NRR, IE, and Region II personnel who, l
while not necessarily technical experts in their respective areas, had l
knowledge of quality assurance program requirements or knowledge of the overall TVA situation.
l The assignment to the reviewers was to read the documentation with the goal of answering the following questions.
(1) Based on the documentation submitted by TVA, could a prvdent, i
senior manager conclude that there was no breakdown in the quality assurance program? Consider the following:
(a)
Is there evidence of a program?
(b) Is there evidence of implementation of the prograer?
(2) Is there a need for further investigation?
(a) Does it appear as if all necessary inforttation is included or does it appear as if more information l
is required?
(b)
Is there a need for personal interviews?
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ENCLOSURE 3 i
DR. HENRY MYERS' INQUIRY TO HAROLD CENTON, DATED DECEMBER 23, 1986 (1)
Request
"... provide the NRC's ground rules involving such matters as:
-- The classes of documents subject to review by the NRC (e.g., NSRS reports and memoranda existing as of March 20, 1986, NRC inspection j
reports, employee concerns received by QTC as of March 20, 1986, QTC j
reports submitted to TVA as of March 20,1986) and the rationale for not
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including any such classes of documents in the review."
Clarification
)
The documentation reviewed consisted of that which.TVA submitted as substantiating documentation for Mr. ' White's March 20, 1986, letter.
]
On December 19, 1986, Dr. Myers requested and received, via your office (Letter from Rehm to Kammerer, dated December 23,1986), the portion of i
the above documentation for the NSRS PERCEPTI0tl, " Construction Processes, in General, Are Loosely Centro 11ed.". The classes of documentation present in that documentation are the classes of documentation reviewed.
Since the intent of the effort was to make determinations, as stated under " SCOPE OF DOCUMENTATION REVIEW" (ENCLOSURE 2), based upon document-ation submitted by TVA was used in the review.
(2)
Request
"... provide the NRC's ground rules involving such matters as:
-- The criteria used by the NRC in its " reasonable-man" review to detemine whether or not TVA had documented support for conclusions stated in its March 20, 1986, letter.
Clarification Please see the discussion under " SCOPE OF DOCUMENTATION FEVIEW" (ENCLOSURE 2).
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