ML20237L285

Discusses 860708,15 & 1105 Ltrs Re Review of Hs Phillips Concerns Concerning NRC Insp Program for Facility.Author Found 7 of 16 Concerns Required More Info Before Violation Could Be Imposed

ML20237L285
Person / Time
Site:	Comanche Peak
Issue date:	11/25/1986
From:	Thomas Scarbrough NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
To:	Mulley G NRC OFFICE OF INSPECTOR & AUDITOR (OIA)
Shared Package
ML20237F760	List: IR 05000445/1980026 IR 05000445/1985018 IR 05000445/1986010 ML20237F757 ML20237K977 ML20237L009 ML20237L052 ML20237L058 ML20237L073 ML20237L183 ML20237L187 ML20237L193 ML20237L212 ML20237L221 ML20237L240 ML20237L244 ML20237L264 ML20237L285 ML20237L293 ML20237L327 ML20237L341 ML20237L352 ML20237L358 ML20237L369 ML20237L386 ML20237L409 ML20237L426 ML20237L431 ML20237L478 ML20237L496 ML20237L507 ML20237L519 ML20237L554 ML20237L564 ML20237L594 ML20237L616 ML20237L623 ML20237L628 ML20237L642 ML20237L652 ML20237L656 ML20237L679 ML20237L705 ML20237L711 ML20237L718 ML20237L754 ML20237L767 ML20237L814 ML20238A011 ML20238A033 ... further results
References
NUDOCS 8708200158
Download: ML20237L285 (4)

Text

I .

No~vember 25, 1986 MEMORANDUM FOR: George A. Mulley, Jr., Assistant Director for Investigations Office of Inspector and Auditor FROM:

% Thomas G. Scarbrough Atomic Safety and Licensing Appeal Panel

SUBJECT:

COMANCHE PEAK l'

In memoranda to you: dated July 8. July 15, and November 5,1986, I discussed my review of the concerns expressed by H. S. Phillips with respect to the NRC inspection program for the Comanche Peak Nuclear Power Plant. Some of those concerns involved the allegation that violations proposed by Phillips and other inspectors as a result of their findings during inspections were

~

unjustifiably downgraded to unresolved items by Region IV management, especially T. F. Westerman. In my July 8 memorandum, I discussed each of the inspection eports that Phillips asserted had involved improper downgrading.

Phillips, hovever, alleged only 16 specific instances of improper downgrading, in his interview with OIA. Below, for each of the 16 instances, I indicate my

~

position regatding whether sufficient information existed for a violation to be imposed at the time of the' inspection report.

INSPECTION REPORT 85-07/05 Concern Nos. I and 2 These concerns relatt to the use of a traveler during the installation of the-Unit 2 reactor pressura vessel. These concerns were discussed on pages 12-14

~

of my July 8 memorendum. After reviewing the July 10 interview of WESTERMAN 5

gs2gg{g$$$$ ,

O f a_-____ ___- =.

. f and the detailed traveler used in the installation, I now believe that it was within management's prerogative'to classify this as an unresolve'd item.

Concern No. 3-

)

i This concern involved the failure to audit the reactor vessel installation {

activity. Ir. my July'8 memorandum (at pp.14-15),'I stated my opinion that it

. was acceptable for WESTERMAN to classify this item as unresolved. My opinion -)

remains the same,

. 1 1 'I Concern No. 4 This concern related to the marking of a piping spool piece. I remain of the i view, as indicated in iay July 8 memorandum at pp. 15-16, that no violation

, occurred.

Concern No. 5 This concern involved the failure to provide a record of. inspection of the concrete mixing blades. This matter was listed as a violation but the cover letter of the inspection report indicated that no applicant response was necessary. I discussed this concern in my July 8 memorandum at p. 17. While there does not appear to be a safety problem, I consider the reasoning for not following through with the violation to be questionable.

I e

s INSPECTION REPORT 85-?.4/11 Concern Nos. 1, 2, and 3 These concerns related to the shipment of original records to Stone and Webster in cardboard boxes without a backup copy, without procedures, and without accounting for the records. As discussed in my July 8 raemorandum at pp.18-19, I consider the failure to properly ship the records to Stone and  ;

Webster to be a violation. In my opinion, management's reasoning for downgrading the violation is questionable.

Concern Nos. 4 and 5 These concerns involved the shipment of Chicago Bridge & Iron records to a

,, location offsite. As discussed in my July 8 memorandum at p. 20, I do not believe that there was sufficient evidence to write a violation because the shipment had occurred months earlier.

~

Concern No. 6 This concern related to the storage facility for records comingled with in-process documents in the Paper Flow Group. In my July 8 memorandum at l

)

p. 22, I stated my view that the temporary storage of records in non-fire rated cabinets was a violation. I consider mam gement's reasoning for down-gradirig this violation to be questionable.

l i

4

• l INSPECTION REPORT 85-16/13 Concern Nos. 1, 2, and 3 These concerns involved the applicant's system for controlling 10 CFR 50.55(e) j documentation. As I discussed in my July 8 memorandum at pp. 23-25, it appears that violations were s'upportable in this area. I consider manage-ment's reasoning for downgrading the violations to be questionable.

Concern No. 4 '

This concern related to the improper identification of two NAMCO switches on l

an installation traveler. As stated in my July 8 memorandum at pp. 25-28, I l l

believe that the failure to properly identify a switch on documentation should ,

,be considered a viola' tion.

1 i

Concern No. 5 This concern involved the questionable testing of BISCO electrical penetration seals.

As stated in my July 8 memorandum at p. 27, I agree with management's decision to classify this item as unresolved. This item is potentially serious, however, and it must be investigated thoroughly by the staff.

In summary, I found seven of the 16 concerns required more information before a violation could be imposed. For nine of the concerns, however, I consider that either sufficient information existed to impose a violation or

-.j 4

_ _ _ . _ _ _ . _ . _ _ _ . _ _ _ . _ . . _ . _ . . . . _ . _ _ _ _ ._ _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ _ _ _ . _ _ _ _ _ _ . _ _ _ _ _ _ _