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=Text=
=Text=
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July 15, 1986
July 15, 1986
                        . MEMORANDUM' FOR:       George A. Mulley, Jr., OIA FROM:           72ECi   ' Thomas G. Scarbrough, ASLAP
. MEMORANDUM' FOR:
George A. Mulley, Jr.,
OIA FROM:
72ECi
' Thomas G.
Scarbrough, ASLAP


==SUBJECT:==
==SUBJECT:==
COMANCHE PEAK q
COMANCHE PEAK q
In a July 8,       1986 memorandum to you, I discussed my review of the concerns expressed by H.S.           Phillips regarding'                 ,
In a July 8, 1986 memorandum to you, I discussed my review of the concerns expressed by H.S.
the Region IV inspection program for Comanche Peak.                             With respect to the adequacy of the Region IV QA inspection effort, I stated my opinion that the Region IV QA effort had been weak for that plant.             One of the bases for my opinion was the review of various QA inspection reports by Region IV and a comparison of the content of those reports with the insp%ction procedure guidance provided in IE Manual Chapter' 2512. Because of time constraints, I used a March 1984 I
Phillips regarding' the Region IV inspection program for Comanche Peak.
version of Chapter 2512 as an example of the recommended frequency for the performance of the QA inspection e
With respect to the adequacy of the Region IV QA inspection effort, I stated my opinion that the Region IV QA effort had been weak for that plant.
procedures.             Since preparing my July 8 memo, I have had an l
One of the bases for my opinion was the review of various QA inspection reports by Region IV and a comparison of the content of those reports with the insp%ction procedure guidance provided in IE Manual Chapter' 2512.
l opportunity to backtrack through the IE Manual change notices to determine the past. inspection frequency l                 recommendations.               In this memo, I discuss the results of my l                                                                                                         4 l                 search regarding each QA construction inspection procedure.
Because of time constraints, I used a March 1984 I
l l                                                                                                                     .
version of Chapter 2512 as an example of the recommended frequency for the performance of the QA inspection procedures.
t
Since preparing my July 8 memo, I have had an e
: j.  .
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l 8708200126 070819 PDR- ADOCK 05000445 l   .G                     PDR
opportunity to backtrack through the IE Manual change notices to determine the past. inspection frequency l
?                                                         _                          _ _ - _ _ _ - - _ _            .l
recommendations.
In this memo, I discuss the results of my l
4 l
search regarding each QA construction inspection procedure.
l l
t j.
l 8708200126 070819 PDR-ADOCK 05000445 l
.G PDR
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2 1
2 1
Ins'pection Procedure.35020 Audit of Applicant's Surveillance of Contractor QA/QC Activities
Ins'pection Procedure.35020 Audit of Applicant's Surveillance of Contractor QA/QC Activities In a January 1, 1977 change, the IE Manual recommends 1
* In a January 1,   1977 change, the IE Manual recommends 1
that this inspection be performed between 5 months after docketing and construction completion.
that this inspection be performed between 5 months after docketing and construction completion. As indicated in my July 8 memo, while a minor inspe,ction was documented in report 78-07, a thorough inspection in accordance with this procedure was not performed until 1984 as-described in report 84-32.           Thus, this procedure was not satisfied until the plant was nearing completion.
As indicated in my July 8 memo, while a minor inspe,ction was documented in report 78-07, a thorough inspection in accordance with this procedure was not performed until 1984 as-described in report 84-32.
Inspection Procedure 35060 Licensee Management of QA Activities In a July 1,         1980 change, the IE, Manual recomme.nds that this inspection be performed every 18 months.               As indicated in my July 8 memo, this inspection procedur'e was not satisfied until the inspection documented in report 84-32.
Thus, this procedure was not satisfied until the plant was nearing completion.
Inspection Procedure 35060 Licensee Management of QA Activities In a July 1, 1980 change, the IE, Manual recomme.nds that this inspection be performed every 18 months.
As indicated in my July 8 memo, this inspection procedur'e was not satisfied until the inspection documented in report 84-32.
Therefore, at least two inspections in this area were not performed as recommended by Chapter 2512.
Therefore, at least two inspections in this area were not performed as recommended by Chapter 2512.
Inspection Procedure 35061 In-Depth QA Inspection of Performance In an April 1,         1980 change, the IE Manual recommends.
Inspection Procedure 35061 In-Depth QA Inspection of Performance In an April 1, 1980 change, the IE Manual recommends.
that this inspection be performed annually. In my July 8 memo, I stated that only report 84-22 documented an inspection in accordance with this procedure but also that                     '
that this inspection be performed annually.
other reports had described'some inspection effort in this area.         Therefore, I expressed my opinion that the Region IV       '
In my July 8 memo, I stated that only report 84-22 documented an inspection in accordance with this procedure but also that other reports had described'some inspection effort in this area.
j I
Therefore, I expressed my opinion that the Region IV j
___-_-.____-_-____________,.-____2______               - _ _
I
___-_-.____-_-____________,.-____2______


3 effort in meeting this procedure had been weak.       My opinion remains unchanged as the history of the IE' Manual indicates that at.least 3 ins'pections in accordance with this procedure were not performed'as recommended.
3 effort in meeting this procedure had been weak.
                                                                                                ' Inspection Procedure 35065 Procurement, Receiving, and Storage In a July'1, 1980 change,'the IE. Manual recommends that this inspection be performed annually. .In my July 8 memo, I indicated that report 84-26 was the only report that documented the performance of this inspection procedure.
My opinion remains unchanged as the history of the IE' Manual indicates that at.least 3 ins'pections in accordance with this procedure were not performed'as recommended.
While other reports document inspections in this. area,, they were not as extensive as required by this procedure. Thus, at least 3 inspections that were to have satisfied this procedure were not performed.
' Inspection Procedure 35065 Procurement, Receiving, and Storage In a July'1, 1980 change,'the IE. Manual recommends that this inspection be performed annually..In my July 8 memo, I indicated that report 84-26 was the only report that documented the performance of this inspection procedure.
l Inspection Procedure 35100 Review of QA Manual In an April 1, 1976 change, the IE Manual recommends           ..
While other reports document inspections in this. area,, they were not as extensive as required by this procedure.
that this~ inspection be performed as required.       As indicated in my July 8 memo, while the 766 data only listed report 84-22 as documenting this inspection, other reports
: Thus, at least 3 inspections that were to have satisfied this procedure were not performed.
                                                                        , described the review of QA manuals.       My concern in this area     ,
l Inspection Procedure 35100 Review of QA Manual In an April 1, 1976 change, the IE Manual recommends that this~ inspection be performed as required.
remains with respect to the recent indication that the               ~
As indicated in my July 8 memo, while the 766 data only listed report 84-22 as documenting this inspection, other reports described the review of QA manuals.
My concern in this area remains with respect to the recent indication that the
~
applicant saw a need to revise its QA Manual so late in the construction process.
applicant saw a need to revise its QA Manual so late in the construction process.


1
1 R
                                    .                                                      .                                          R H
H
                                                                                                  .4 In'spection Procedure 35200 Mid-term Construction Permit QA Inspection In an April 1,                             1976 change, the IE Manual recommends that this inspection be performed between 18 to 30 months after the beginning of construction..
.4 In'spection Procedure 35200 Mid-term Construction Permit QA Inspection In an April 1, 1976 change, the IE Manual recommends that this inspection be performed between 18 to 30 months after the beginning of construction..
In my July 8 memo, I indicated that I considered the inspection performed in thic area (and documented in report 78-23) to have been inadequate.                                                                                         i Therefore, this inspection procedure was not                     1 satisfied as recommended by the April 1976 version of Chapter 2512.
In my July 8 memo, I indicated that I considered the inspection performed in thic area (and documented in report 78-23) to have been i
Following my: review of the Chapter 2512 history of
inadequate.
* recommended frequencies for the performance of,the QA                                               ;
Therefore, this inspection procedure was not 1
construction inspection procedures, I. remain of the view that the Region IV'QA inspection effort for Comanche. Peak was weak.         As discussed, a significant number of the QA inspections recommended by Chapter 2512 were not performed                                           j l                                 in a timely manner.
satisfied as recommended by the April 1976 version of Chapter 2512.
l The fact that the Region IV QA inspection effort was weak is not the major concern at Comanche Peak by itself,                                             1 because the applicant's QA program could have been satisfactory despite the weaknesses in the Region IV effort.
Following my: review of the Chapter 2512 history of recommended frequencies for the performance of,the QA construction inspection procedures, I. remain of the view that the Region IV'QA inspection effort for Comanche. Peak was weak.
However, the Technical Review Team in Supplement 11-to NUREG-0797 identified numerous deficiencies in the implementation of the applicant's OA program. In, particulars the Technical Review Team concluded that I
As discussed, a significant number of the QA inspections recommended by Chapter 2512 were not performed j
L____________.__.__________..________________ _$ _    . _ . _ _ _ . _ _ _ _ . . . .
l in a timely manner.
l The fact that the Region IV QA inspection effort was weak is not the major concern at Comanche Peak by itself, 1
because the applicant's QA program could have been satisfactory despite the weaknesses in the Region IV effort.
However, the Technical Review Team in Supplement 11-to NUREG-0797 identified numerous deficiencies in the implementation of the applicant's OA program.
In, particulars the Technical Review Team concluded that I
L____________.__.__________..________________


15                                                               ;
15 failures by QA and QC personnel to detect deficiencies suggested an ineffective Brown & Root and TUGCO inspection system.
failures by QA and QC personnel to detect deficiencies suggested an ineffective Brown & Root and TUGCO inspection system. It therefore. appears that the weaknesses in the Region IV QA inspection effort may:have contributed to-inadequacies in.the applicant's QA program.
It therefore. appears that the weaknesses in the Region IV QA inspection effort may:have contributed to-inadequacies in.the applicant's QA program.
As a result, I do not believe that the past Region IV                                     l QA inspection effort.provides strong support for the safe construction of Comanche Peak.     Other efforts, such as'the Construction Assessment Team Inspection 83-18/12, Region IV Special Inspection 84-26, the Technical Review Team                                             ..
As a result, I do not believe that the past Region IV l
8
QA inspection effort.provides strong support for the safe construction of Comanche Peak.
                        ,      activities, and inspections of technical work by Region IV over the years, should be relied upon to determine the adequacy of plant construction.                                                                     l t-t b
Other efforts, such as'the Construction Assessment Team Inspection 83-18/12, Region IV Special Inspection 84-26, the Technical Review Team 8
activities, and inspections of technical work by Region IV over the years, should be relied upon to determine the adequacy of plant construction.
l t-t b
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l                                                        .
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                                                                                                                            ~q I
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?                                                                                    _ _ _ _ _ - . _ _ _ _ _ _ - _ _ -
                                                                                                                                  .]}}

Latest revision as of 06:24, 2 December 2024

Discusses Concerns Re Region IV Insp Program Per .Believes That Past Region IV QA Insp Effort Does Not Provide Strong Support for Safe Const of Facility
ML20237L221
Person / Time
Site: Comanche Peak  
Issue date: 07/15/1986
From: Thomas Scarbrough
NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
To: Mulley G
NRC OFFICE OF INSPECTOR & AUDITOR (OIA)
Shared Package
ML20237F760 List: ... further results
References
NUDOCS 8708200126
Download: ML20237L221 (5)
v • d • e


Text

..

July 15, 1986

. MEMORANDUM' FOR:

George A. Mulley, Jr.,

OIA FROM:

72ECi

' Thomas G.

Scarbrough, ASLAP

SUBJECT:

COMANCHE PEAK q

In a July 8, 1986 memorandum to you, I discussed my review of the concerns expressed by H.S.

Phillips regarding' the Region IV inspection program for Comanche Peak.

With respect to the adequacy of the Region IV QA inspection effort, I stated my opinion that the Region IV QA effort had been weak for that plant.

One of the bases for my opinion was the review of various QA inspection reports by Region IV and a comparison of the content of those reports with the insp%ction procedure guidance provided in IE Manual Chapter' 2512.

Because of time constraints, I used a March 1984 I

version of Chapter 2512 as an example of the recommended frequency for the performance of the QA inspection procedures.

Since preparing my July 8 memo, I have had an e

l l

opportunity to backtrack through the IE Manual change notices to determine the past. inspection frequency l

recommendations.

In this memo, I discuss the results of my l

4 l

search regarding each QA construction inspection procedure.

l l

t j.

l 8708200126 070819 PDR-ADOCK 05000445 l

.G PDR

?

.l

2 1

Ins'pection Procedure.35020 Audit of Applicant's Surveillance of Contractor QA/QC Activities In a January 1, 1977 change, the IE Manual recommends 1

that this inspection be performed between 5 months after docketing and construction completion.

As indicated in my July 8 memo, while a minor inspe,ction was documented in report 78-07, a thorough inspection in accordance with this procedure was not performed until 1984 as-described in report 84-32.

Thus, this procedure was not satisfied until the plant was nearing completion.

Inspection Procedure 35060 Licensee Management of QA Activities In a July 1, 1980 change, the IE, Manual recomme.nds that this inspection be performed every 18 months.

As indicated in my July 8 memo, this inspection procedur'e was not satisfied until the inspection documented in report 84-32.

Therefore, at least two inspections in this area were not performed as recommended by Chapter 2512.

Inspection Procedure 35061 In-Depth QA Inspection of Performance In an April 1, 1980 change, the IE Manual recommends.

that this inspection be performed annually.

In my July 8 memo, I stated that only report 84-22 documented an inspection in accordance with this procedure but also that other reports had described'some inspection effort in this area.

Therefore, I expressed my opinion that the Region IV j

I

___-_-.____-_-____________,.-____2______

3 effort in meeting this procedure had been weak.

My opinion remains unchanged as the history of the IE' Manual indicates that at.least 3 ins'pections in accordance with this procedure were not performed'as recommended.

' Inspection Procedure 35065 Procurement, Receiving, and Storage In a July'1, 1980 change,'the IE. Manual recommends that this inspection be performed annually..In my July 8 memo, I indicated that report 84-26 was the only report that documented the performance of this inspection procedure.

While other reports document inspections in this. area,, they were not as extensive as required by this procedure.

Thus, at least 3 inspections that were to have satisfied this procedure were not performed.

l Inspection Procedure 35100 Review of QA Manual In an April 1, 1976 change, the IE Manual recommends that this~ inspection be performed as required.

As indicated in my July 8 memo, while the 766 data only listed report 84-22 as documenting this inspection, other reports described the review of QA manuals.

My concern in this area remains with respect to the recent indication that the

~

applicant saw a need to revise its QA Manual so late in the construction process.

1 R

H

.4 In'spection Procedure 35200 Mid-term Construction Permit QA Inspection In an April 1, 1976 change, the IE Manual recommends that this inspection be performed between 18 to 30 months after the beginning of construction..

In my July 8 memo, I indicated that I considered the inspection performed in thic area (and documented in report 78-23) to have been i

inadequate.

Therefore, this inspection procedure was not 1

satisfied as recommended by the April 1976 version of Chapter 2512.

Following my: review of the Chapter 2512 history of recommended frequencies for the performance of,the QA construction inspection procedures, I. remain of the view that the Region IV'QA inspection effort for Comanche. Peak was weak.

As discussed, a significant number of the QA inspections recommended by Chapter 2512 were not performed j

l in a timely manner.

l The fact that the Region IV QA inspection effort was weak is not the major concern at Comanche Peak by itself, 1

because the applicant's QA program could have been satisfactory despite the weaknesses in the Region IV effort.

However, the Technical Review Team in Supplement 11-to NUREG-0797 identified numerous deficiencies in the implementation of the applicant's OA program.

In, particulars the Technical Review Team concluded that I

L____________.__.__________..________________

15 failures by QA and QC personnel to detect deficiencies suggested an ineffective Brown & Root and TUGCO inspection system.

It therefore. appears that the weaknesses in the Region IV QA inspection effort may:have contributed to-inadequacies in.the applicant's QA program.

As a result, I do not believe that the past Region IV l

QA inspection effort.provides strong support for the safe construction of Comanche Peak.

Other efforts, such as'the Construction Assessment Team Inspection 83-18/12, Region IV Special Inspection 84-26, the Technical Review Team 8

activities, and inspections of technical work by Region IV over the years, should be relied upon to determine the adequacy of plant construction.

l t-t b

?

l

~q I

l

?

.]

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