ML20154S801

Responds to 860328 Request for Programmatic Comments on Rev 3 of Comanche Peak Response Team Program Plan.Opposes Review & Approval Process & Inadequacy of Program Plan. Related Correspondence

ML20154S801
Person / Time
Site:	Comanche Peak
Issue date:	04/02/1986
From:	Garde B Citizens Association for Sound Energy, TRIAL LAWYERS FOR PUBLIC JUSTICE, P.C.
To:	Noonan V Office of Nuclear Reactor Regulation
References
CON-#286-647 OL, NUDOCS 8604080120
Download: ML20154S801 (37)

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- TRut LAWYERS FOR Pusuc Jusuct. P.C .aELATED CMM N COUN5tLLOR$ 4T LAW f' * **

SulTE 6tl ANTHONY L ROI5 MAN 2000 P STREET. NORTHWIST WASHINGTON. O C. 20036

[ (202)463 8600 LMLCUTht DeatCTOR ARTHut SAYANT p.,

sTAn ATTORNtv . 1-4 p7 g stutC4ADE DIRECTOR. EPMRONMLNTAL VWif5TL18Lowit PROttCT R

RATHL11N CUMetRSATCH April 2, 1986 ocCKET flUMetR - ,jf g stCRETARY PRUDt(T*!t.FAC.,,pbw ... ..

Vincent S. Noonan, Director PWR Project Directorate #5 Division of PWR Licensing-A U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Noonan:

This letter is provided in response to your March 28, 1986, request to provide programmatic comments on Revision III of the Comanche Peak Response Team Program Plan. As you know, CASE is strongly opposed to the piecemeal process the agency is pursuing in resolving the safety questions about Comanche Peak, and is providing these comments only to put on the record our opposition to the review and approval process and the inadequacy of the program plan itself.

Revision III of the Comanche Peak Response Team (CPRT)

Program Plan and the Issue specific Action Plans were submitted to the NRC on January 27, 1986. The objective of the plan is to insure that the Comanche Peak nuclear power plant receives an operating license. In order to receive a license the Nuclear Regulatory Commission (NRC) must find that there is reasonable assurance that the facility, as built, does not endanger the public health and safety.

j It is the position of the Citizens Association for Sound Energy (CASE) that such a finding can only be made after (1) the completion of a 1004 reinspection of the plant, (2) a complete design review analysis, and (3) the successful implementation of an acceptable corrective action program that includes a commitment to 10 CFR Part 50, Appendix B.

Background

After a major NRC inspection effort in 1984, the NRC staff concluded that there had been a systemwide breakdown in the quality assurance / quality control (OA/QC) program at Comanche Peak. The finding, first expressed by the staff in January 1985, resulted in both immediate and long--term responses from TUEC.

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e o ey necessity TutC's response was to determine the actual condition of the plant, and whether or not, based on the condition of the plant, there was reasonable assurance that the plant had been designed and constructed in a manner such that its operation would not affect public health and safety.

The means by which the applicant was going to achieve that end was through the CPRT program plan. The plan was first submitted in October 1984 in response to early NRC findings of the Technical Review Team (PRT) inspection, and later expanded to respond to other NRC findings, conclusions, and concerns.

because there has been little substantive public participation in the development and approval of the CPRT, CASE's ,

involvement with the plan to date has been minimal. However, CASE's attempts to be part of the process are noteworthy. First, through numerous workers and former workers, CASE initially raised the majority of the external source issues which the NRC examined during the TRT inspection. Second, in. January 1985, CASE recommenced a program plan to adequately resolve the questions about the conditions at the plant. (See CASE's Motion to Establish an Evidentiary standard, January J1, 1985, Appendix i A./ Third, CAS: has participated in virtually all of the public meetings regarding the proposals for and progress of the CPRT, and finally we have submitted several sets of written comments to tne Staff about the program. Our comments have consistently raised a number of issues which nave either been resolved in TUEC's favor, deferred by the NRC, or ignored. We raise these issues again in this letter because we believe the process for resolution of outstanding Comanche Peak issues is dangerously flawed.

For its part the NRC staff has taken shifting positions toward the process of resolving Comanene Peak issues. Initially tne staff was going to issue all SSERs detailing the investigation of allegations, and a " super SSER" which would incorporate the staff's overall position on the meaning of all of the preliminary findings. This has not been done, and apparently the concept has been abandoned. There are still several hundred allegations not identified or incorporated in any SSER, and there has been no SStR issued about the overall Staff conclusions about l the Comanche Peak plant.

After it became obvious that the applicant had begun reinspection and rework activities, CASE was told that there would be a public meeting between CASE and its techical assistants (i.e., tne allegers) and the Staff to discuss the I

inadequacies or incompleteness of the CPRT Issuo Specific Action

. Plans (1 SAPS) to resolve the identified concerns. That meeting never took place, in part because tne allegers needed the checkiluts to determine the adequacy of the individual ISAPs. an alternative approach, the production of written comments, was

tnen going to be employed by CASE after the allegers told and

now) had studied the checalists and program plans in order to i provide the NHC statf feedback on the adequacy of the CPRT.

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f Since the checklists have still not been provided, this never

! occurred either.

l nowever, the public review process became essentially i meaningless anyway because, even as the CPRT was being reviewed l by'the staff, TUEC embarked on its reinspection and corrective l action program. No official notice was given to the staff, the Board, or tne parties, and no commitment was given by TUEC about what course of action would be followed.

I i Tnroughout the past 13 months, the staff continuously told TUEC that the reinspection and rework being done at the site was "at its own risk." This unrealistic approach gave way to Staff concessions in the fall of 1985 when the Region IV staff began to conduct onsite inspections and audits of the CPRT work. During these audits and inspections, tne staff found repeated violations of WRC requirements, and the applicant's commitment to the program plan. No enforcement action is being taken based an the i CPRT violations.

l l

l Nonetneless it is the staff's current position to issue an l SSER on the Program Plan's overall approach and methodology.

! This SSEM will exclude tne inspection checklists and implementation failure of the CPRT to date, as well as ignore the lack of a QA program for the CPRT. (See letter from Vince S.

Noonan to Billie Pirner Garde, March 28, 1986.)

Suramary Casa disagrees with the Staff's fictional approach to the program plan. Approving the scope and methodology of the CPRT, while ignoring TUEC's current inability to implement even a bad program, is tantamount to deregulating Comanche Peak. Such action is not permitted by federal regulations, and the staff's conduct flaunts an arrogance toward public health and safety that CAde believes is unacceptable.

l as a practical matter tne approval of the scope and l methodology of the plan carries with it approval of several basic programmatic deficiencies:

l 1. The program plan itself, and the reinspection work done i to date, does not now comport with and has not been done to 10 CFR Part SO Appendix 3 requirements.

J. Tne program plan is unable to reach conclusions about the total extent of the quality assurance / quality control breakdown or tne condition of the as-built plant because of inadeguate sampling plan and the use of homogeneous groupings.

3. There is no independence in the rework activities, and very little in the reinspection work.

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4. There are no NMC "nold points" in the prograu which enables the NhC'to insure tnat the reinspection work completed by the CPRT has' appropriately identified all potential generic flaws and that the proposed rework incorporates findings on generic deficiencies and root causes.

5. The plan ignores agency regulatory policies and practices for similarly deficient construction pro]ects.

6. There is no meaningful oversight or participation by the public or the atomic Safety and Licensing Board.

Perhaps the most irresponsible aspect of the NRC's piecemeal approval strategy is that the agency has ignored the most damning information available on the CPRT -- the failure of TUEC to be able to implement even a bad program. In December 1985, TUEC confirmed at a public meeting that ut inspectors had not followed procedures regarding vc inspections and had succumbed to production pressures tsee transcript of December 18-19, 1985, meeting, pp. 9-15). Also there have been repeated problems with the safety significance evaluations and tne identification of deficiencies.

The NRC nas ident.ified througn the Region IV audits numerous

-discrepancies between the program plan and the ongoing work.

Tnese implementation problems should nave been identified by an internal VA program. However, the NMC has apparently accepted a CPRT without a VA/vc requirement.

The failure of TUhc or tne Statf to produce the inspection and design review procedures and tne attribute chec411sts has prevented CASE from doing an adequate assessment of the extent to which the programmatic flaws listed above impinge on the overall effectiveness of the CPRT.*

Contrary to tne assertion in Mr. :voonan's March 28, 1986, letter, the fact is that the Staff has relied heavily and continues to rely on the checklists to do their work in preparation for hearing, while preventing CASE from doing the same. The staff has repeatedly utilized the checklists for review of the CPRT and inspections and audits. See IER US-17, u5-14, Appendix 12, wnich provides 15 pages of specific comments and questions on checklists, and all hogion IV inspection reports which contain audits of the CPRT that rely upon the use of the CPRT checklists.

Additionally, the checklists are not g minimis, as the Staff tries to imply. In the August 9, 19ub, letter to TUEC, the Staff noted, "tne criteria for acceptability are based on inspection of hardware using a list of attributes which are considered to be vital to assurance of safety significance, ...

these attributes are not genuric, var / for a given item, and must include design considerations" (p. J4).

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1. Noncompliance With Appendix B Requirements 10 CFR Part 50, appendix B, establishes quality assurance requirements for the design, construction, and operation of safety-related structures at nuclear power plants. The requirements of Appendix B apply to "all activities affecting the safety-related functions of the structures, systems, and components; these activities include designing, purchasing, fabricating, handling, shipping, storing, clearing, erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling, and modifying. " (Emphasis added.)

Appendix B sets fortn 18 criteria which provide detailed explanations of what is required by federal regulations during the design, construction, and operation of a nuclear plant. It specifically requires, for example, under Criterion XVI:

Heasuures shall be established to assure that conditions adverse to quuality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. In the cace of significant conditions adverse to quality, the measures shall assure that the cause of the

, condition is determined and corrective action taken to preclude repetition. The

! identification of the significant condition a'dverse to quality, the cause of the condition, and the corrective action taken shall be accuraented anc reported to appropriate levels of management.

Contrary to federal requirements the Comanche Peak Response Team (CPRT) Program Plan (" program plan") does not conform to Appendix B requirements for prompt identification of deficiencies and corrective action. Instead, the program plan establishes the process for the applicant to take a regulatory detour.

It is TubC's posttion that the CPRT program plan does not provide the information "of record" about Comanche Peak. This concept is not explained in the program plan per se, but it is evident by a review of the process that the results of the initial preliminary reinspections are not going to be created, maintained, or relied upon as part of tne inspection records of the various systems, components, or structures.

According to the CPRT Program Process, Rev. J, p. 16, the scope of the actual work of the reinspection program, as outlined in the IsaPs/DSAPs "will be based on a preliminary assessment of the root cause and potential generic implications. ...

accordingly, most of the ISAPs and DSAPs will utilize iterative or phased traplementation approaches that include an initial phase that is exploratory in nature."

Since the reinspection work has already begun, and in some cases is already completed, it is apparent that the exploratory pnase has been finished and preliminary assessments of the root cause and potential generic implications have already been identified. Yet none of the preliminary assessments have been disclosed, produced to the public or the NRC. Nor have they been completed using a Quality Control /uuality Assurance prcgram for the CPRT, since such a program has not been developed. It is not clear from a reauing of the program plan whether the resalts of the exploratory phase have ever been -- or will ever be --

documented.

This example is indicative of a program plan which does not include compliance witn Appendix 3 requirements. That is, although the program plan asserts that it strives to meet regulatory requirements, it does not place the work under the requirements of Appendix u. This is a significant difference.

Since the procedures for identification of deficiencies in Revision 0, 1, or 2 did not programmatically require the recording of deficiencies and the trending and/or analysis of such deficiencies, it is now impossible for CASE to rely upon the preliminary work done under the earlier revisions.

Yet the individual action plans rely precisely on such preliminary, non-recorded information.

The lack of a va/uc program does not just apply to the identification and resolution of substantive deficiencies or deviations identitied oy CPKT inspectors. It goes to the program plan itself. All that currently exists for the CPRT is a management overview process. (See Appendix G.)

The overview uuality Team tout) is the epitome of non-independence. It is composed of the same third-party personnel reporting to a TutC vice-President, also in charge of the Senior Review Team (SRT). The SRT has organizational responsibility for all the CPRT activities. It is impossible for it to also be organizationally independent of the CPRT to perform uA/QC activities on the program plan implementation.

The implementation of the plan to date has been abysmal, e.g., failure to detect production quotas, harassment of inspectors, numerous substantive flaws in the identification of deficiencies, and safety significance evaluations. These are significant problems, and the NRC's action in accepting a CPRT witnout a UA/uc program is foolish. The NRC Staf f simply cannot, and will not, be able to perform a substitute audit function to a programmatic un plan.

The NHC Staff nas compounded the problem by not using appendix 3 requirements to conduct the Staff's audit of the CPRT.

Tne Staff inspection reports never find a violation of Appendix 0 requirements for work done within the scope of the CPRT, even though identified deviations are obviously violations of Appendix 8.

f 9 For example, in 65-13/03-U9 (Appendix A, Item A), the NRC Staff issued a notice of violation tor violations of Criterion V, tor failure to accurately record information required by procedures. In the same report, the NRC identified violations of ERC procedures by inspectors and found only a deviation of TUEC

" commitments" to the NRC (p. 45, Item 5, Appendix E).

Similar examples abound in all recent inspection reports reviewed by CAdE (IbR 85-17; CHK d5-14; ILR 85-14, 85-11; IER 65-1J, 65-09; and IER 85-11, 85-06).

2. The pry ram plan g unable to reach conclusions about tne total extent or the quaIItf assur_ance/, quality control breakdown or the condttron of the as-ouilt plant because o f, an inacequate sampling plan and the use of homogeneous groupings.

Tne va/UC deficiencies are further complicated by the fact that the program plan begins with the premtse that the UA/UC program at the site did not break down in the ftrat place, and therefore the CPRT program work WLil not replace the UA/uC program of record and will only sample hardware, records, documents, etc., to determine if the original program was acceptable. (Kev. J, p. 10.) dince the premise of the program is confirmatory as opposed to remeatal, it cannot and does not provide a comprehensive reinspection of the safety-related structures, systems, or components such that there will be reasonable assurance that all undetected deficienctes and deviations are identtfled and corrected.

The program plan incorporates and has reacned near-completion by reliance on a random sampling plan, as yet unapproved by the staff, which is supposed to provide for an escalated sampling approach to enable conclusions to be drawn on the entire population based on a limited look at some attributes of a randomly soleeted portton of homogeneous populations.

Tne deficiencies in the sample inspection program are different for eacn ISAP because the 16APs are all unique and have uniquely developed programs.

This plan, contained in appendix G, calls for an evaluation of the safety significance of deviations prior to consideration of expansion of the sample size. This presumes, with no basis, tnat all otner deficienciou or deviations not identifted would be of similar safety uignificance. Such an ausumption is not statistically sound. Then if problems ate found, the expanded sample is limitec to only similar characteristics.

The 6taff asserts that untti tne samplinj plan is approved, the results drawn uunder it are not approvud, but the program plan specifically permits reliance on previoaaly performed work.

-U-In any event, without more information on what the sampling plan actually entails for each ISAP, it is impossible for CASE to take any position other than that the plant requires a 1006 reinspection of all accessible attributes.

J. LacA of independence of~~ the CPMT, specifically ~in regard to~~

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reworE~and repair.

The NaC imposed on TUEC a requirement for inclusion of an

" investigation of the role of the principal contract personnel (arown and Root and Ebasco) in regard to uuality Assurance / Quality Control concerns," and asked them "to consider the prudence of continuing to rely on contractor personnel involved in ongoing work and recovery efforts when they are the same people directly responsible for the problems identified herein." (bSER sil, p. P-30.)

On both items the program plan is non-responsive. There is apparently no ongoing or concluded investigation of the principal UA/uc management personnel. To the contrary, without investigation, virtually all of the personnel formerly involved witn site ua/uc decisions have been promoted or retained in management positions.

More significantly, tut.C has continued to rely on the substantive work done by the former site uA/uc personnel to resolve deficiencies identifted by tne reinspection personnel.

Since the program permits resolution by personnel directly involved with naving caused the problem in the first place, it seems unlikely that the reform program can do more than confirm the original actions taken by the involved personnel.

For example, a significant number of CPRT-identified deficiencies are dispositioned by C. T. urandt, former assistant quality assurance manager, now ud supervisor.

One example of tne type of problem identified above is found in NCR No. Eus-101540 SX (attached). The ExC inspector identified in an uncontrolled deviation report, pursuant to checklist item 5.2.C, that in 19dj inspector J. Mtller had improperly signed off inspection reports while his certifications were expired. The deficiency was then identtfied on an NCR. The NCR was subsequently dispositioned by C T. Brandt on November 1J, 1985, based on a second inspection certification, a.llegedly slyned by C. T. urandt for R. G. Tolson on September 20, 1983.

The NCR'S disposition does not attach or explain the initial deviation whicn found the certification was not in place until 10/26/u4. The inadequacy of the resolution is by itself insufficient, bu t. it is even more so because the disposition in done by urandt based on his own flawed work from two years previous.

_9_

In short, all evaluations and corrective action remain under the control of TUSC, and TUEC remains virtually the same organization with the same people and the same problems as before.

The lack of independence in the program plan has resulted in other problems. The CPRT program plan suf fers from a confusing and unclear methocology being implemented by numerous separate organizations. This multiple level approach invites programmatic breakdowns and failures in implementation of even the best program plans. To illustrate, the program contains an independent design verification program tlDVP) using the vertical slice methodology of one safety system, a horiaontal review of two other systems, a sampling program (employing both a random sample and a bias sample), a tous review of the large bore piping, a design analysis review, and hundreds of response inspections to 16APs and UdAPs. Each portion of the program plan is being accomplished accordtng to a different set of criteria, and being cirected by separate management teams. Those teams have changed personnel, procedures, reporting instructions, and objectives. The standards or attributes against which inspections are accomplished are ambiguous, open to interpretation, or unknown. The organization structure for the interface of tne programmatic elements is either non-existent or appears to be unworkaule.

In short, business at Comanche Peas is more complicated, more confused, and ultimately more unrollaole.

4. The program plan does not r_equire NRC h_op points.

Tne NRC's approval of the CPRT is apparently based on blind trust. There is nothing in the nistory of the construction of Comanche Peak resemuling regulatory compliance. Additiornally, there is no QA/uc program to insure internal compliance with CPRT commitments, and there is no assurance that the site QA/uc program, run by the old va/uc personnel, is institutionally capable of handling the results of a rejor reinspection ef fort.

As stated before by CASE, this plan guarantees no reasonable assurance of anything except more controversy.

CASc. nas pleaded for " hold points" in the CPRT program to insure tnat reinspection and rework would be quality controlled and the incentive for time pressures r eiaoved. Since no hold points have been instituted, it lu understandable that implementation prouleras and substantive evaluation errors have occurred.

b, Tne plan iJnorus g n,cy regulatory poli _cies,and prpetices for simil,arly de_ftelent, construytion projects.

At two other plants where the uhe reached similar conclusions at>out failed va/vc programs, it was based on much .

, e more limited breakdowns than is evident at Conanche Peak. (see, generally, inspection history on Midland and Zimmer.)

At these plants the NRC withdrew its " reasonable assurance" prescription, required a halt to all construction and inspection activities, and then ultimiately approved reinspection and rework activities which would, upon successful completion, restore reasonable assurance.

At Comanene Peak there are two significant deviations in the CPRT from past "get well programs." These flaws, which are briefly nighlighted below, provide two additional opportunities for TUtc to escape the realities of the as built condition of the plant. These flaws are the iterative reinspection and rework process and the in process inspection. Both processes were the basis of stop work orders and enforcement action at Zimmer and Midland, respectively.

Zimmer At Zimmer, the Commission issued a Show Cause order

.and an order immediately duspending Construction after a reinspection program /uuality confirmation Project confirmed numerous examples of constructionn deficiencies and noncompliance with the 18 quality assurance criteria which "could have been prevented or identified in a timely manner by tne licensee and its contractors had there been a properly managed UA program" (Cincinnati Gas & tiectric (dimmer), CLI-82-33, 1b NRC 1489

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(1962) and other uA/uc and construction deficiencies.

The Commission found that the NRC lacAud " reasonable assurance" that the Zimmer plant was being constructed in conformance with the terms of its construction permit and 10 CFR Part 50, Appendix u, or tnat there was adequate management control over Zimmer to assure NRC requirements were being met.

The basis of the Commission's withdrawal of reasonable assurance was stated as (1) 41mmer was constructed without an adequata QA program to govern construction and monitor quality, resulting in a facility of indeterminate quality; (2) numerous deficiencies nave been identified such that both reanalysis and rework will be required to bring the facility into conformance with the re9ulatory standards; and (3) rework of deficiences has been undertaken prior to completion of other relevant reinspection tasks, resulting in the potential for additional reworking of the same item if further deficienctes are found.

The Comancne Peak CPRT is based on thu very iterative process which the Commission specifically rejected in Zimmer.

Midland: At the Midland facility, the NRC staff confirmed repeated construction and uA deficienclos up through October 1982. The IJRC Staf f then required consumers Power Company to verify the adequacy of virtually all previous construction activities and to verify the adequacy of future construction.

This program, the construction Completion Program (CCP), required 100% reinspection of accessibic installations, NRC hold points,

. i retraining anc recertification of all QC inspectors, development of the new quality control checslists, and an independent third party overview of the reinspection and reconstruction activitics.

The need for this plan was based on a history of QA violations far less serious than Comanche Peak's own history of violations.

i One of the most serious violations identified at the Midland project was the use of "in process" inspections. An in process inspection consisted of the failure of site UC inspectors to identify "as non-conformances all of the deficiencies they observed during their inspections." According to the inspection report, tne failure to systematically record all observed deficiencies diminished management's ability to determine the root cause of non-conformances so as to prevent recurrence, and resultea in a failure to provide information to management for the in-depth analysis by trending so a determination could be made wnether or not work affected by the non-conformances should be stopped. It also cited a lack of consistency in the dispositioning of deficienctes as a serious problem. Consumers Power Company (Midland), inspection Report 82-22 (Feb. 6, 19aJJ.

The in process inspect. ion that was the basis for enforcement action at Midland is at the heart of the ongoing work activities at Comanene Peak, according to the information available to us about the CPRT work on the uite.

b. The program g,lan does not p_r_ ovide for public gartici_pation.

Our requests for participation in the programmatic development have been effectively denied. We continue to object to a process which does not include those organizations and individuals wnose only objective is to insure that Comanche Peak, if operated, does so safely.

Attached as Appendix u to tnis letter are our previous specific comments. We incorporate them in their entirety into this letter. Except for a fes issues, these comments have r.ot been responded to by the Staff or the Applicant.

Conclusion CASE believes that the staff's actions at Comancho Peak are motivated by .a single-minded determination to create a

" licensable record," and not an intent to determine the truth about the as-built condition of the plant. Our belief is based on the Staff's actions at Comancho Peak in comparison to other similarly situated projects and the information plaenout initiated in January 1985 oy TUEC and perpetuated by the Staff.

The.htaff's conduct of late on these matters has been extremely objectionable.- CASE had hoped that the question of safety, not of licensability, would dominate the Comanche Peak efforts. This does not seem to be the case.

Sincerely, Billie P. Garde BPG/bp

Appendix A

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Inspection NA Report E-6 349 3 NA NA 1

maasIzc a Deviation Report #R-E-CDUT-042-DR-01 a

• Per above D.R., Evidence of inspector certification to support above inspection report could not be found.

- A *See attached Certification Sheet.

5 No Hold Tag Applied.

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• C I

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This is not a nonconforming condition as Jirt hiller was certified when I.R.

, E-63493 was signed by him on 9-28-83. Ite was certified in 01-0P-11.3-44 on 9-16-83 and it was in effe,ct until 9-16-84. , see attached certification sheet.

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Appendix B TRIAL LAWYERS FOR PUBLIC JUSTICE. P.C.

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, ANTHowv t nonman %ASHINGTON. DC. 20036 (202)463 8600 oscuTNttuntcfoe ARTHua naVANT sTAM AffonNEY sAmonA swerweno omct mANActa August 15, 1985 Mr. Darrell Eisenhut U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Vince Noonan U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Sirs:

The Comanche Peak Response Team (CPRT) Program Plan and the Issue Specific Action Plans were submitted to the NRC on June 28, 1985. The objective of the plan is to insure that the Comanche Peak nuclear power plant receives an operating license. In order to receive a license the Nuclear Regulatory Commission must find that there is reasonable assurance that the facility, as built, does not endanger the public health and safety.

It is the position of the Citizens Association for Sound Energy (CASE) that such a finding can only be made after (1) the completion of a 1004 reinspection of the plant, (2) a complete design review analysis, and (3) the successful implementation of an acceptable corrective action program.

The CPRT Program Plan, even if successfully implemented, lacks significant programmatic controls, and is substantively deficient in a number of key areas. The process and substance deficiencies identified in the document submitted to date are described in this document. Since the CPRT itself is not complete (i.e. the QA/QC program for the plan has not yet been submitted, the inspection attributes are missing, the checklists for retraining are missing, etc.) these comments are not defini-tive. Further comments will be submitted after receipt and review of the other portions of the plan.

It should be noted that it is CASE's position that the plan itself should be litigated before the ASLB, and that additional hearings should be held on the adequacy of implementation of the reinspection effort, as well as the appropriateness of the pro-posed corrective action plan and the implementation of the corrective action program. It is also CASE's position that the ambiguity in the plan is so great that approval should not be granted prior to discovery on the program elements. It is our belief that the Applicant's commitments are not the actual program plan.

Finally, CASE objects to the proposition that the Staff's view of the questions raised in this letter (and the review of TUEC's response to Staff questions) will be committed to an SSER prior to a public meeting on the final proposed program plan.

The efforts of the public and the whistleblowers to review TUEC's final program plan will be meaningless without providing for public review and comment on the CPRT.

We look forward to meeting with the Staf f on these matters in the near future.

Sincerely, 5k _

Billie Pirner Garde cc: Service List

e #

9 PRELIMINARY REVIEW OF THE COMANCHE PEAK RESPONSE TEAM PROGRAM PIAN (DOCKET 2)

PRELIMINARY CRITIQUE OF THE PROGRAMMATIC ASPECTS OF THE CPRT PROGRAM PLAN This critique contains observations on the following aspects of the CPRT program plan:

1. Overall inadequacy of the proposed approach.

2. Programmatic deficiencies with the third party ef forts proposed.

3. Programmatic deficiencies in the integration of the various overviews, reinspections, evaluations, and ongoing work activities.

4. Programmatic deficiencies in methodologies.

5. Programmatic deficiencies in scope, i.e. the depth and breadth of the review.

6. Programmatic deficiencies in the sampling techniques.

7. Programmatic deficiencies in the ISAP/DSAP approach to External Source Issues.

8. Missing elements of proposed program.

9. Comparison of CASE proposal and the CPRT.

In each of these categories there are both specific and general observations. These comments- however are not definitive.

There is no attempt to address the specific inadequacies of various ISAPs/DSAPs, nor is there any attempt to guess the inadequacy of the CPRT QA/QC program. Several charts have been attached as Exhibit 1 to this document to demonstrate the missing elements of the proposed program. (We have taken the liberty of modifying the charts contained in the progam plan submitted by the Applicant for illustrative purposes.)

I

2-OVERALL INADEQUACY OF THE PROPOSED APPROACH The most significant defect in the CPRT Program Plan is that it perpetrates the iterative process of design and construction failures. TUEC has chosen to " push ahead" with the reinspection and corrective action program, and only incorporate retro-spectively any rework or reinspection requirements which result

~

from the conduct of the CPRT.

According to the CPRT Program Process (Rev.2, p.15), the scope of the actual work of the reinspection program, as outlined in the ISAPs/DSAPs "will be based on a preliminary assessment of the root cause and potential generic implications of the identi-fied deviations...Accordingly, most of the ISAPs and DSAPs will utilize iterative or phased implementation approaches that include an initial phase that is exploratory in nature."

Since the reinspection work has already begun it is apparent that the exploratory phase has been completed and preliminary assessments of the root cause and potential generic implications have already been identified. Yet none of the preliminary assessments have been disclosed, produced to the public or the NRC. Nor have they been completed using a Quality Control /

Quality Assurance program for the CPRT, since such a program has not been developed. It is not clear from a reading of the program plan whether the results of the exploratory phase have ever been - or will ever be - documented.

TUEC's inability to successfully implement the iterative design and contruction process has caused major regulatory, I

safety and financial problems. The choice of an iterative

approach to the reinspection and corrective action program is indicative of current management's inability or unwillingness to choose the prudent approach to getting the Comanche Peak project under control.

It is our view that the only way to successfully approach the reinspection, reanalysis, and corrective action project is to start with a clean slate. That is, to halt construction entirely until the CPRT program plan has received the full approval of the NRC Staff and the Licensing Board. Only then will it be prudent to begin the operation through a phased approach -- first reinspection, then rework.

The second major inadequacy of the program is that it is not comprehensive in scope, breadth or depth. As submitted, the program plan results will not be able to support the reasonable assurance objective sought by TUEC. Some details of the program inadequacies have been summarized in following sections.

Most importantly the CPRT proposes that concerns are resolved at the time that "TUGCo has defined actions" which "when implemented will correct identified deficiencies and preclude similar deficiencies." (Rev. 2, p. 5) The history of implementation failures at Comanche Peak provide no basis for the Staff or the public to be able to rely on the successful implementation of any corrective action. This is particularly true since it is TUGCO, not the independent third party, that is recommending the corrective action in the first place. This l

l situation makes it even more crucial that NRC hold points be mandated for review of any correction or rework ef fort.

4-The third major inadequacy of the proposed program is that it is not controlled by third party personnel, but instead remains under the control and direction of TUEC. For example, TUEC controls all modifications of ongoing work in Unit II' (Rev.2, p.4) and also the " future plant operations" (Rev 2, p.5).

The lack of independence of the third-party teams to control their work eliminates their value, adding only confusion, not credibility.

Fourth, the management team remains a mystery. It is not sufficient for TUEC to have ostensibly removed the former QA/QC executives of the Comanche Peak project and replaced them with a team of borrowed professionals who march to the beat of an unknown drummer. The current management team is a completely diversified group of consultants, loaned employees, contract employees, advisors, and others. It remains unclear what has happened to the former executives, or why, and it is even murkier who is currently running the project - either the reinspection /

corrective action program, or the remaining construction project.

This confusion surrounding the management personnel is a critical weakness in the current proposal.

We believe that the reinspection program and any subsequent required corrective action must be done by truly independent third parties. They must have clearly defined reporting respon-sibilities to the NRC under 10 C.F.R., as well as the responsibi-lity for drawing the conclusions about the scope of the problems.

The remaining work to be done on Unit II should be handled by a new team of TUGCO and/or prime contractor personnel who have not had anything to do with previous construction problens.

5-The CPRT program plan also suffers from a confusing and

. unclear methodology being implemented by numerous separate organizations. This multiple level approach invites programmatic breakdowns and failures in implementation of even the best program' plans. To illustrate, the program contains an indepen-dent design verification program (IDVP) using the vertical slice methodology of one safety system, a horizontal review of two other systems, a sampling program (employing both a random sample and a bias sample), a 100% review of the large bore piping, a design analysis review, and hundreds of response inspections to ISAPs and DSAPs. Each portion of the program plan is being accomplished according to a different set of criteria, a different company's quality control / quality assurance criteria, and being directed by separate management teams. The standards against which inspections are accomplished are ambiguous and open to interpretation. The organizational structure for the inter-face of the programmatic elements is either non-existent, or appears to be unworkable.

Other problems with sampling methodology, and major elements of the program which are still missing are described below.

Finally, a major fatal flaw of this program is its failure to produce the necessary level of detailed information to preclude misinterpretation. This is particularly important in this plan since there is a myriad of different personnel working on a plethora of reinspections, and the reinspection personnel are not the individuals drawing conclusions, or making recommen-dations about the findings.

Another result of having no comprehensive attribute check-list for reinspections is that there will be no meaningful way to assess whether adoption of a previous external inspection is appropriate.

Finally, the failure to produce detailed attribute check-lists renders paperwork reviews by third-party overviewers or the NRC virtually meaningless.

The NRC must at a minimum require the CPRT program (1) to be reorganized into a logical step-by-step process, (2) to be based on the reinspection of systems and components against detailed attribute checklists, (3) to establish NRC inspection hold points at critical junctures, (4) to require an independent overview of the required corrective action, and (5) to remove TUEC from the task of determining the consequences of generic / programmatic defects.

i i

PROGRAMMATIC DEFICIENCIES WITH THE PROPOSED THIRD PARTY EFFORTS

1) None of the third parties are independent of TUEC, since all of the consultants are under the direction of the CPRT.

2) The third parties were selected solely by TUEC, dis-regarding the importance of the concurrence of the public, and the nomination and approval procedures for independent third parties used by the NRC since 1982. This after-the-fact assertion does nothing to restore the confidence of the public in the " fresh perspective."

3) The review team leaders, issue coordinators, and advisors are primarily responsible to, or are, in fact, TUGCO personnel who have been involved in the construction project for a long time.

4) The asserted qualifications, reputation, and integrity of the third-party consultants have not been tested through discovery or cross-examination, nor have the consultants answered questions from the public on their experience, competence, integrity, or the direction from the CPRT regarding the scope of their work.

5) The third-party consaltants, individually and organiza-tionally, are apparently not being considered a part of the normal regulatory process, and therefore not required to report all safety related information reportable under 10 C.F.R. 50.55(e) and 10 C.F.R. Part 21 to the NRC directly.

6) The third-party consultants can only recommend correc-tive action to TUEC/TUGCO, but they cannot control the implemen-tation of the corrective action. It is not even clear whether the third party has the authority to insist on accomplishment of a particular corrective action as a caveat for any conclusions.

7) The SRT responsibilities, under the direction of a TUGCO Vice President, control the CPRT effort through selection of management personnel, approval of the action plans, review and approval of the " safety significant" determination, and root cause and generic implication assessment, and approval of corrective action.

8) The same TUGCO Senior Vice President, is also in charge of the issues raised through the SAFETEAM, and other project activities, i.e., there is no procedure for inclusion of new issues without approval of TUGCO management.

PROGRAMMATIC DEFICIENCIES IN THE INTEGRATION OF THE VARIOUS OVERVIEWS, REINSPECTIONS, AND EVALUATIONS

1) There is no status assessment of system commodities or defined baseline of items subject to the CPRT. Without such a document the completion date or progress made can not be quantified.

2) Interfaces between the ongoing project and the program reinspection plan are almost non-existent. (Interface between the design, construction, reinspection, and corrective action aspects of the project are critical for successful implementation of the program plan.)

3) The use of the Collective Evaluation Reports providing information at the end of the DSAP/ISAP process precludes consi-deration of critical information by all disciplines during the reinspection.

4) The circular approach to expanding issues is, as described on page 2 of revision 2, not detailed in a manner which provides confidence that the all generic implications and root causes will be extrapolated to other areas of the plant.

. s .

j PROGRAMMATIC DEFICIENCIES IN METHODOLOGY

1) The methodology is not supported through references to established professional codes (ASME, ANSI, AWS, etc.).

2) The methodology is ambiguous about commitnent to the FSAR, and provides no criteria upon which an exception will be sought.

3) Reporting procedures for third-party auditors exclude independent contact with the NRC.

4) Issues " closed out" by the external source for whatever reason are not considered for potential root cause or generic implications.

5) The program plan does not include all vendors, or separate construction activities and therefore presumes that work was accomplished in accordance with regulatory requirements.

There is nothing to justify this position.

6) The hardware categories proposed in the self-initiated evaluation are not comprehensive. There is no explanation for how homogenous populations were selected. There is no explana-tion of how the selected populations will provide the foundation to reach the broad conclusions predicted by the CPRT.

7) There are no attribute checklists for inspections, or for inspectors to be retrained to.

8) There is no new retraining, recertification programs for TUEC or B&R QA/QC or craft personnel which insures that the identified failures in the training program implementation is not repeated.

9) The criteria for determination of defects is its " safety significance", not necessarily non-compliance with FSAR require-ments.

10) There is no provision for assessing deficiencies in inaccessible hardware components.

11) There is no provision for logical consideration of potential programmatic generic defects, such as inadequate design review. All defects, deficiency reviews, etc. are going on simultaneously.

l

PROGRAMMATIC DEFICIENCY IN SCOPE, DEPTH AND BREADTH

1) The program plan does not provide the breadth of review necessary to reach any conclusions about the overall design and construction of the plant (i.e. insufficient number of systems proposed and a lack of attributes on the selected systems).

2) No basis has been provided to justify the selection of the civil / structural, electrical / mechanical, instrumentation systems proposed.

3) The external source issues have identified massive specific or programmatic deficiencies. The proposed program fails to accommodate the reported failures substituting instead the review of the smaller number of systems as a first cut.

4) The size of the sample of systems to be reviewed is inadequate to reach any meaningful conclusions about the systems or components which are called into question by external source issues.

5) The information provided on the large bore piping reanalysis is insufficient to determine whether the " major concerns about the system" are the only concerns which should be considered. (There are no submitted procedures, checklists, programmatic details about the program.)

6) The vertical slice approach for the mechanical components is supposed *.o extrapolate the IDVP results to other systems, but the slice is not comprehensive enough, it relies upon other inspection results to eliminate inspection attributes.

7) The IDVP plan should include the timely consideration and implication of the root cause of all IDVP issues on other compo-nents and systems.

8) There is no justification provided to exclude the Westinghouse-designed portions of the plant. Since the design OA breakdown apparently stems from implementation failures, all vendors must be subjected to the design review analysis to insure the adequacy of the design for CPSES.

9) The scope of the DAP was developed by eliminating inspection elements by reliance on the inspection by numerous other external sources, which themselves were separate from the current effort and conducted according to totally different pro-cedures, and intended to discover different information.

10) There is no justification for the creation of arbitrary homogenous hardware groups to use as a base to extrapolate results of the DAP.

11) Expansion criteria for components are ambiguous and rely on no developed acceptability level.

PROGRAMMATIC DEFICIENCIES IN THE SAMPLING TECHNIQUES

1) The proposed sampling approach is generally based on the conduct of reinspection of both bias and random samples. The reinspection itself is done against unknown baseline criteria (i.e. sometimes the FSAR, sometimes " safety significance,"

sometimes an unknown attribute checklist) using a 95/5 sampling plan. The attributes are, as of yet, unidentified so there is no way to determine by reviewing the plan whether the reinspection will be of sufficiently detailed attributes to periait meaningful conclusions about the acceptability of any one component.

2) The bases for the CPRT decisions will be engineering evaluations of the safety significance of design, construction, or process deficiencies, not raw data. Therefore, only those defects which are judged to have any safety significance will ever be used as a basis to reach the threshhold for expanding the sample size.

3) Exploratory evaluations which are not recorded are used to identify the specific sub-population rendering the sampling process biased from the beginning.

4) The sampling approach is not committed.

PROGRAMMATIC DEFICIENCIES IN THE APPROACH TO EXTERNAL SOURCE ISSUES AND SELF-INITIATED EFFORTS

1) The ISAP/DSAP approach ignores the critical need to assess the project as a whole, instead of on a piecemeal approach.

2) ISAPs are not prepared on any issues not yet identified by the NRC-TRT, including over 700 internal allegations in the SAFETEAM files.

3) ISAP development, done by the issue coordinators or field consultants, do not coincide with a standard set of requirements (i.e. some ISAPs use the FSAR as the acceptance criteria, some use regulatory guides, some use professional standards). Therefore it is not possible to draw conclusions about compliance with the originally prescribed standards.

4) ISAPs do not address the history of other problems related to the specific issue (i.e. each ISAP is self-contained, except for the end-of-line review).

5) Each ISAP has individual close-out criteria which do not qualify acceptability.

6) There is no inspection criteria or uniform attribute checklists which can be used by QA/QC personnel, auditors, or third party reviewers to determine the adequacy of the ISAP.

7) The ISAPs/DSAPs do not include the results of the exploratory investigations which are used as a basis to develop the ISAP.

MISSING ELEMENTS The following elements are missing entirely from the program plan:

. 1. There is no accurate, up-to-date list of remaining work against a defined baselinc of actual work necessary to complete Unit 1 and Unit II.

2. There are no work controls on on-going work, including ongoing reinspection work and any on-going corrective action work.

3. There are no NRC inspection and review hold points at critical reinspection points.

4. There are no inspeccions attribute checklists available for review and analysis to insure that the reinspection effort will be comprehensive.

S. There is no significant change in the organization and management personnel associated with the construction of the plant (as opposed to QA/OC).

6. There is no internal management analysis to determine the root cause of the implementation failures of the initial construction and inspection effort.

7. There is no verifiable central control over the multiple reinspection programs to insure that the interfaces necessary for successful implementation and communication exist at the facility.

8. There has been no significant reduction in the con-struction activity of Unit II to accommodate changes.

9. There is, to date, no quality control / quality assurance program for the reinspection program.

10. There is no acceptable protocol between the CPRT-SRT, TUEC, and other contractors.

11. There are no third party controls over the implementa-tion of the corrective action measures.

12. There is no contractual independence of the evaluators on the SRT from TUEC management.

13. There is no separation between the reinspection effort and the work completion effort.

14. There has been no review of the third-party organiza-tions or individuals (either through the hearing or through a public meeting).

. - * - 15. There is no program to consider the implications of harassment and intimidation on the work atmosphere.

16. There is no program for retraining and recertifying all inspectors to new inspection criteria.

17. There is no justification provided for the identification of the homogenous hardware groups which are to provide the basis for the conclusions of the self-initiated evaluation.

18. There is no adequate plan for implementation of oversight controls on the self-initiated evaluations, or the ISAP/DSAPs.

1

n"

, - . COMPARISON OF APPENDIX A (SUGGESTED CONSTRUCTION REVERIFICATION PROGRAM) TO THE CPRT PROGRAM PLAN On February 4, 1985, CASE submitted a proposal for a comprehensive reinspection program as an attachment to their REQUEST FOR AN EVIDENTIARY STANDARD. The Board deferred final ruling on the proposal, suggesting that TUEC's proposal may be acceptable to CASE.

The key elements of CASE's proposal are listed on the left.

The right-hand column denotes which recommendations are included in the CPRT Program Plan.

CASE Proposal CPRT Program Plan I. Selection of 3rd Party:

a) Provide for Board selection of inde- No pendent auditor to perform reinspection using following criteria: (1) indepen-dence; (2) competence; (3) integrity.

b) Selection after a public No meeting about the nomination prior to staff approval.

c) Board approval of independent No auditor.

II. Overall Program Plan - Phase I:

a) Reorganize TUEC & B&R upper management. Partial b) Reorganize site and mid-level Partial management.

c) Reorganize work force into teams. No d) Installation and status assessment of No current work completion.

, . . CASE Proposal CPRT Program Plan e) Establish NRC " hold points" for No review of work plans.

f) Complete revision for all procedures. No g) Issue new procedures and inspection No attribute checklists after NRC review.

h) Review documentation and incorporate No design changes into final design.

1) Re-qualification of equipment. No j) Review vendor QA programs. No k) Recertify and retrain personnel. No III. Overall Program Plan - Phase II:

a) Reinspect hardware and report No results.

b) Monthly meetings on implementation. No c) Develop corrective action plan, Partial submit for review, and revise.

d) Board approval of corrective action No plan.

IV. Overall Program Plan - Phase III-a) Resubmit design for NRC approval. Partial b) Work Authorization Procedure for No items requiring repair.

c) Work completion accomplished.

d) Monthly meetings to review progress. No

o.. . CASE Proposal CPRT Program Plan V. Cooperative Participation by Parties and Boards a) Board approval of CPRT. Partial b) Continuous documentation oversight by 3rd party. No c) Monthly public meetings. No d) Mandatory compliance with approved No methodology.

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