ML20206J044

Final Response to FOIA Request for Records.App J Documents Encl & Available in PDR

ML20206J044
Person / Time
Issue date:	11/21/1988
From:	Grimsley D NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
To:	Murphy M AFFILIATION NOT ASSIGNED
References
FOIA-88-344 NUDOCS 8811280034
Download: ML20206J044 (2)

Text

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U.S. NUCLEAR REGULATORY COMM'S$10N hac sod Riovist NuustRs<se FOlA 344

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RESPONSE TO FREEDOM OF l l'ih*'

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I l an^' I s INFORMATION ACT (FOIA) REQUEST NOV 211988 s,e e... i oocm huvum< son .-.am REQUElf0R '

Michael Murphy PART l.~ AGENCY RECORDS RELEASED OR NOT LOCATED fSee checked boaes)

No egency records subpect to the request have been located.

No additional agency records subrect to the reovest have been located.

T.eouetted records are are>lable through another pu%c Ntribution piogrew See Comments Section Agency records subre ct to the request that are edertdied on Appendialent are s' ready avariable for public w" ,ettion and copying m the NRC Pu%c Document Room. 2021 L Street. N W . Washington. DC 20555 A9ency records subpect to the resvest that are adentif.ed on Append.atesid* are becg ma$e ava.lable for public espection and copymg in the '

NRC Pu%c Document Room. 2021 L Street. N W. Wash.ngton. DC. in a f older under this FOIA number and reavester name.  ;

The tsonproprietary we's.on of the p40posalts) that you agreed to accept in a tetechorse conversation mth a memt.or of my staff is now be.ng made avadable for publ.c inspecte and copyng at the NRC Puta Document c Room 2021 L Street, N W . Wa:Nngton. DC. m a folder under th.s FOf A number and reavester name-Agency records subse ct to the request that are identif+d on Appendimies) mag be ar upected and cop ed at the NRC Local Public Document Room ideet f.ed in the Comments Section.

Inclosed is information on how you may oblac access to end the charges for copyeg records pis<ed in tN NRC PutAc Documeat Room. 2021 L Street N W .

l Washogton, DC Agency records subject to the reovest are enclosed Eecords subpect to the request have been referred to another Federal agencyt.est for review and d. rect resu>rse to you.

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You wdl be tafled by the NRC for fees totakng 8 in view of NRC's responsa to thes request. no further action is beeg tshen on appealletter dated No PART 11 A-INFORMATION WITHHELD FROM PUBLIUSCLOSURE Certe>n eformation e the reovust.M records is be.ng *rthoe4 from pubbe desciesv r e pursvart to tre esempters descr.t+1 e end for the reasons stated e Pa t

• sect.ons 9 C, and D Any re'esitd portions of the documents for wh.cn on:, part of the .eco rd is beco *.tv 'd ea<e beeg made avalatae for pubLc inscwt on sad copyeg in tee NRC Put+c Document Room. 2021 L Street. N W . Washington. DC.in a toMer veder ins FOIA nurnber and reauester name I

COMYENTS j

• Copies of the records lis ted on Appendix J are enclosed.

I Actual costs for processing this request were $2,292.82. You will be sent a refund in the amount of $1 s901.04. ,

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PDR FDIA MURPHY 88-344 PDR tyts FRIEDOM OF INf 0RV ATION AND PUBUC ATION. SERVICES

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Re: F0!A 88-344 APPEN0!X J RECORDS MAINTAINED IN THE POR UNDER THE ABOVE REQUEST NUMBER NUPEER OATE DESCRIPil0N

1. 1/25/84 Memo for the Files from William J. Manning,

Subject:

1/17/84 Meeting Between NRC Staff and Commonwealth Edison Regarding Byron Operating License Proceeding (4 pages) '

2. 5/4/84 Memo from J. P. O'Reilly to R. DeYoung,

Subject:

Enforcement Guidance for Fire Prevention / Protection Violations (2 pages)

(2 page enclosure is outside scope of request) 1 i

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Chic a go, 11. 60614 June 16,1988

[REE03M OF INFORMAT ACT REQUEST Director, Of fice of Administration U. S. Nuclear Regulatory Commission Washington, DC 20555

[d[-[/ d Yf f Q h h-N 'hb RE: FREEDOM OF INFORMATION ACT REQUEST

Dear Sir:

I would like to obtain some information related to the Byron and i Braidwood Plants.

In accordance with Title 10, Code of Federal Regulations, Part 9, please provide copies of the documents listed on the attached.

I am willing to pay the charges related to copying the documents requested. Please contact me at (312) 266-2139 if a deposit is required, or if ther e are any questions.

Thank you f or your assistance.

Sincerely, PY Michael M phy i

cca Bruca A. Berson, Esq.

NRC Region 111 Counsel U.S. Nuclear Regulatory Commission - Region !!!

799 Roosevelt Road Glen Ellyn, 11 60137

& G1 J A> lmi t o o ' WW t I i g

Freedom Of Informatlon Act Request List of Documents Requested - Page 1

{._INFORMATION RELATED TO FI.RE_PROTEC_TJON REOp.IREMENTS Please furnish all internal NRC correspondence, t elephor.e notes, conference notes, and other documents generated by the NRC organizational elements specified related to the interpretation ard application of regulatory requirements for fire protection at Byrcri NRC 1 and 2. The time frame of interest is 1982-1985.

organizational elements of interest are the Chemical and Mechanical Engineering Branch (CMEB) (V. Benaroya Branch Chief), and Inspection and Enforcement Region III (Mr. Ramsey inspector). Limit the information provided to the application of National Fire Protection Association (NFPA) standards, in the following areas: fire detector type and location, sprinkler head location, water supply valve type and configuration, diesel tank high level alarms, fire door sills, and fire pump check and relief valves.

Information is also requested related to NRC Inspection Reports 454/03-62 and 455/80-42. Provide inspector notes, work papers, internal NRC correspondence, minutes of meetings be tw een NRC pere. anel and Edison personnel or Edison contractor personnel, and minutes of meetings within the NRC, related to the inspection.

II.__INF_0RMATION RELATED T_O VA_RIOUS NRC INSPECTION REPORTS Information is requested related to several NRC inspections conducted at Byron and Braidwood. Provide inspector notes, work l

papers, internal NRC correspondence, minutes of meetings between l

NRC personnel and Edison personnel or Edison contractor personnel, NRC and minutes of meetings within the NRC, related to the f

inspections and inspection reports listed below, l

l A. Braidwood Inspections l

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A1. 50-456/77-05 and 50-457/77-05, conducted m l

September 1977 t

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A 2. Inspection 50-456/02-03 4.co 50-457/82-07.

l conducted May 24-20 and June 1-4, 1982 l

A 3. 50-456/02-05 and 50-457/82-05, conducted April through July 1982 l

I Freedom Of Information Act Request List of Documents Requested - Page 2 A4 50-456/93-02 and 50-457/8!-02, conducted in January and February 1983 AS. Inspection 50-456/83-09 and 50-457/83-09 conducted f rom Juree 1983 to February 1984.

B. Byron Inspections B1. Inspection 50-454/80-25 and 50-455/80-23, conducted from December 1980 through March 1981 B2. Inspection 50-454/82-05 and 50-455/02-04,

' conducted in March through May 1982 B;. Inspection 50-654/80-04 and 50-455/80-04 conducted in Marr.n through May 1980 11!.._1NFORMAT10N RELATED VARIOUS HARDWARg SPECIFIC DEFLC_!ENCIES A. Provide all documentation related to any analyses performed by the NRC to determine the potential cause(s) of the quality deficiencies noted by the NRC, during inspections 50-454/80-25 and 50-455/80-23, associated with the Hatfield Electric Company electrical installations at Byron.

Provit .t copies of all Repor table De ficier.::les (10 CFR 50.55(e)

B.

reports) submitted to the NRC related QA/DC activities or hardware deficiencies associated with electrical installations I

at nuclear power plants under construction in the period of .

1974 ttrough 1986. ,

C. Provid,t copies of all Reportable De ficiencies (10 CFR 50.55(e) reports) submitted to the NRC related QA/DC activities or I I hardware deficiencies associated with R/AC installations at nuclear power plents under construction in the period of 1974 f through 1986.

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Freedom Of Information Act Request List of Documents Requested - Page 3 D. Please provide the inspection procedures utilized by NRC inspectors for the inspection of HVAC 'nstallations in the period of 1975 to 1985.

E. Provide all reports of studies or evaluations conducted by or for the NRC related to QA/DC inspector qualification deficiencies in nuclear power plants under construction.

F. Provide all repnrts of studies or evaluations conducted tey or for the NRC related to electrical hardware installation or inspection deficiencies in nuclear power plants under construc tion.

G. Provide all reports of studies or evaluations conducted by or for the NRC related to HVAC installation or inspec tion deficiencies in nuclear power plants under construction.

H. Provide all reports of studies or evaluations conducted by or for the NRC related to the need for changes in the NRC inspection practices for nuclear power plants under construc tion, and all internal NRC correspondence, meeting minutes, and notes related to this topic.

JV. INFORMATION REL ATED TO NRC COMMUNICATION WITH ED]S_0_N Please provide all presentation materials, inspector notes, minutes and work papers related to the preparation for, and the participation in, enforcement conferences / management communication meetings conducted between Edison and the NRC regarding the Byron and/or Braidwood projects beginning in August, 1982. If the following list is not complete, please supplea ent with the above requested 1.ti or ma tion, any additional enforcement conf erences/ management communication meetingc.

Enforcement conferences 8 0 2 Related to Draidwood Steam Oenerator and safety related mtchanical equipment installation 11 8 2 NSSS Installation 12-20-83, 3-07-84 Piping and electrical and HVAC at DW related to inspection 93-09 findings

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Freedom Of Informatten Act Request List of De<uments Requested - Page 4 6-26-84 Systems control Please esclude the f ollowing Enforcement Conf erences 5-2*,-83 Pr eoperational testang 4-22-85 Vital a' ea access control l

4-09-85 Viti.i area access control 6-27-85 'Aadiation exposure protection 7-22-85 Radiation exposure protection ,

t 11-22-85 Failure to follow technical specifications MJ ,nagement Communication Meetings 7-26-83 Summarized in inspection report 50-456/83-12, '

l 50-456/83-12 9-29-83 Second management communication meeting regarding regulatory performance and NRC -

Edison communication 10 8 3 Third management communication meeting i

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k...) y edeiosevnet Ogp January 20, 1984 M MU UO MEMORANDUH FOR TRE F2LES y r tt FRC41: William J. Manni

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suaJECTa JANUARY 17, 1984 NESTING BEtwstW Mac STArr Aan CCMHOMWrJWTAR ED18000 t REGARDING BY20lt CPRRATING LICE 388E PROCIEDINC On January 17, 1984, 2 attended a Eeeting held between the WDC staff and Coaumonwealth Edison officials to discuss the 1

Liospoing Board's denial of the Syron Operat Licenaa application. h following.are rough notes during the meetings (i understand that the mad staff prepared a record

,, of the meeting which it intends .to serve on the parties 4)

.a I arrived approximately ten minutes after the meeting begam as CNalth Edison's attorney was explaining that he i felt that the Licensing Board.woteld prefer not to see this case agains he thought that under Part 2 of Wac's

! regulations the Board should have asked for Surther' evidence  !

if it thought the record ihadequate. Ris view was that the  ;

4 reverse and rename, or Appeal Board could bold heariage of itsaffirm, own - rowerse,ferable the pre course la his  !

opinion. ,

Comenonwealth Edison (*CE*); asked what the tara around time  !

on the report it had given to NBC ataff would be and bow i i long a new bearing would reqeira. cm also asked if the unc '

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staf f bad any thoughts on evadeince necessary to tura areenad  !

the decision. They also eeked.whether the umC statt >

I . believes additional work is aseded.  !

l--- Repplers mothing la decision escold cher.ts the course of .

I action of the Mac review of the report. heek Friday, CE furnished a reinspection report (QC inspector qualifications  !

- at request of NBC staff) - will have to be reviewed.

The re t Amat e oaty with gealifAcations of inspectors, not I

t with work reviewed by unqualified inspectors. The reinspection covered the work.dene by 2ifth Oc ,

,- inspector during his first 94 daye on the ,

i cza in May 1982, the Begion raimad apsestions regarding Jne  !

! apaalification of QC inspectors .per hust 4524 - different '

views ce bow to interpret, the progrees to sheer goalificatAos of OC inspectors.-- reinspect first 90 days of  ;

work on site, 20% of inspectors - but only for repeatable  ;

inspections. If the results of the first 3 anenths of work are not good, then they look at the namt a months. If that o ni> ,i,- i i At S

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. 3 inspector is still not passing, they look at 100% of his work, plus increuse sample mise for that contractor by $04.

i Keppler: after Simmer, mini-CAP team sent to each site. At I syson Oc inspectors' qualifications were a problem but no -

hardware problems. Some contractora with bad prior records were redone to 100t s.g. Reliable mvAC).

CE: objective critaria (e.g. length) - 954 reinspection had to pass. For subjective (e.T. weld surfacel -- 90%

threshold. Locked at 40,000.weldd and 150,000 other "attributes". 200,000 inspection reports had to be a reinspected - by employees of original .oubcontractor. See

. man-ponths of inspection. 154 'of inspection . work, 31% of individual oc inspectors reviewedi et least in part. -

Subsmitted results to NBC 10/28/93, supplemented 1/12/84.

- Now rafining statistical. assessment of work done. Trying to l establimb reliability (954) and coaifidence (9st) levels -

limited to Batfield 4 Munter. Natfield - 9 attributes. 7 i of 9 -- 954 confidence, with reliability higher than l rainspection requirement. Two attributes with insufficient sample for 9st confidence. cant t esake 956 confidemos for a actual work product for the 2 attributes (ob$ectiW) *= l bolting w/A-325 bolte a equipment mods - backfits to t electrical equipment under Batfie5d's ocetrol. Up to today l have not disqualified any Matfield inspector -- but did have to go to 6 months for weld ' inspections, Espplers in agreement with 10/28/84 r rt - cs wanted to L

. ond program -- think it showed no unque...if Led inspectors.

NRC wanted to exclude one cI inspector - act sufficiently i independent -- ca re?ackaged, data to emolade that person -

led to adding 3 mmontas in mosse . cases.

Kepplers wanted final report and reinspection against it before letting Boara knew whether or not the C3 program took r care of problems. All this took place after record closed.

. on 1004.rainepection, stdf f thiAke ok - so does..Soard.

Repplere Board questions sampiing approach for Natfield and Hunter in light of prior problesse -- Statf had been comfortable with 25% sampling - did not tell Doard would go to 1004 if tansatisfactory .results at 25% level. Doerd asked whether anythiaq issa than 1004 Le acceptable. Doerd iguestioned whether could rely on s reinspection for Batfield (CE contests this). Mtc comid lead to questhose staff Matfimid's poor records bow can you know if reinspecting?

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sisenhuts toard concluded that.cannot have confidence in reinspeetion progran. Bogics unable to speak to rasults. '

cze Scr 2 attributes ecesid get.954/954 in a few montha. It do 1006.rainspection of Matfield'-- 45 to 63 Veeks. First 3 I

w. . e e.

4 anonths of all Batfield ins 96 Batfield otors only 3 samp,

.nopectors, 2 led.gg all First 3 inspections.

months of 63 inspectorm -- 1 year. If 100% of all work --

more time -- minimus of 3 years. Natfield begna work in 1977. If you can demonstrate inspector qualified, think work okay. $cene inspectors were not qualified ~ powers '

Asco Pope 100% reinspection. Aapot't does not have'  !

statistical assessment for all contractors. . l l

MRCs Does lect mean 100% of an inspector's work og 100% of  !

tJast man's first 3 monthet CE: 100% of work.

Board only found 100% of all work okay -- delegable to staff. who.n did not sxist -- up to Soard to ' decide adequacy. .

4 Did not bring out ^Jsat failure of one Hatfield wold i inspector would lead to lett of inspectors for iirst 3 sconths.

@nestion whether reinspection prograsa litigated. Agree that l did not litigata whether actual construction is ok.

cs: Mac staff was pretty cautious La ondereirq prham.' i masto caveas -- whether certain aspects of visual inspecties  :

of welds were objootive or subjective.

DeYoung p. 276 - top - no saatter what they de -- no cookidence, lack of records, cs natfield - bad a failed. But other contractors lousy yet passed with corrective program. p. 304 -- half of Matttold inspectors need retasting, half oseded further if f

1 on-the-3ok steeraining spaperwork not in order) . Nacs s 14, no assurance get all of these. C3 question of -

N45 4 interpretatica -- paper qualification of inspectors - <

education and experience. cas approach was not to look at paper qualifications of inspectors but icok directly at  !

work. Made sure that reinspectors meet the paper qualifications. W4524 can be backfitted -- 061y by idet reinapection. CE: feels had met . intent of W4526. Did not bias seleccion of inspectors by education and orperience but Wac staf f added inspectors whosa.they felt were suspect.

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cs it ask to supplementsystems. Yeoord, ceber parties will have control -- possible fraud.

equal chance to do so, Batfield - fraud ailegatior.s.

i Denton: will keep NDC resources working on matters.which

- would have hed to be ocespleted.anyhow.

Css report, embaitted to Mace working on statistical rearray to desmanstrata adeqtancy of works could check qualifications i

of level.EE inspectors; could again check records for

! falsification.

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~4 CK: una st decide if a, r. ling or soving to reopen record by next Noriday. ELD can sane or wait until after CE files.

sepplers first business is to review oc inspectors g.,m q,.

Also want to do scene inspection. Wants to get back to ct later this week on his views of report. .

Denton doet CE consider report as a responeet CE: one interpretation of the Board's decision to that l'004

. reinspection is peeded -- Cs man't. live with this. W111 probably have to supplement report to sneet Board's concerns.

Direks: does NRC need acre informationt Repplers het at the anosnent. ,

sepplers queation is whether MAC staff has to chante its -

position ifight Board) or agree with Board standard.

. I CEt 12 MRC staff accepts Board's dectaice,, than asamme that would fight c3 on appeel. CE. teele need the ataff's sopport on appea1 want in give WRC staff whatever they need.

Eepplers ball is in our court. CE has given what, needed ensil acw. .

DeYoung need 3ustification for 236 sample. ,

cze better to go to soard or Appeal Board with reiespection etfort? Time to get a decision - reopening record wili

= require a Let of evidence. If go to Appeal Board can argue legal points -- lookin of evidentiary issue. g Wantgor restand to get Appealwitn precise Board hearing definitics oc  ;

that issue - lika versmat Yankee, TMI, piable canyon.

• ~ Denton that is a CE decision, amc can't advise. coesider i risk. of belag bounced straight eback to Licensing Board. At  ;

Appeal Board everything takes snore tisme - stakes higher. ,

Repplert snay need snoeting to hear detailed CE review of ,

findings. Ready to schedule che next week. Reppler will have views on initial review of report this week.

32C stafts have you thought of doing far score on Renter &

Natfiedid7 Denton citas Diablo Canyon example. .

Ct data Onse far is good, and program would escalate rapidly is prebtems encountered.

Etat wants to talk privately with CE inter regardA28 18981 approach.

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MEMORANDUM FOR:

Richard C. DeYoung, Director, IE at.

FROM:

James P. O'Reilly, Regional Administrator g,O, -

SUBJECT:

ENFORCEMENT GUIDANCE FOR FIRE PREVENTION / PROTECTION VIOLATIONS

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In response to your April 26, 1984, memorandum we have reviewed the revised dr guidance and offer the following comments:

1. Attachment 1 to your memorandum, "Overview of Regional Coments and IE Response," provides beneficial infortnation with regard to the disposition of the Regional comments by IE. However, we are of the opinion that it pro-vides no enforcement guidance and recorrend that it not be considered for inclusion as a part of the final guidance for enforcement actions concerning fire protection.

2. Attachment 2 to your memorandum, "Guidance for Enforcement Actions Concern-ing Fire Protection Requirements," provides the basis for the necessary criteria for giving guidance concerning enforcement actions for all plants regardless of their licensing dates with respect to failures to meet all regulatory fire protection requirements, not just Appendix R, for protecting trains of safe shutdown equipment. However, some items contained within this revised guidance require additional clarification. Therefore, Region Il has prepared the enclosure which revises the draf t guidance to incor-porate our concerns and address those items which required additional clarification.

3. The assigned Severity Level 111 proposed by paragraph 2.c of the draft enforcement guidance is based on the assumption that as a result of the fire protection violation, a postulated and credible fire would probably damage all trains of equipment for one or more systems required for safe shutdown.

It is recommended that the enforcement guidance allow violations which fall into this severity category to be reduced if there is a reduced probability of fire due to a low fire hazard, low combustible loading, the adequacy and availability of the early warning fire detection system and the availability of either the primary and/or back-up fire suppression systems (fixed suppres-sion system, inanual fire hose stations, etc.).

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It is our opinion that upon resolution of the Regional coments, that IE take the appropriate measures to incorporate this enforcement guidance into 10 CFR Part 2 Appendix C and that upon Comission approval this guidance be made effective in the interim pending receipt of public comments.

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s g (.O' M O J mes P. O'Reilly

Enclosure:

c Guidance for Enforcement Action Concerning Fire Protection Requirements cc w/ encl:

V. Stello, DEDR0GR T. E. Murley, RI J. G. Keppler, Rll!

J. T. Collins, RIV J. B. Martin, RV H. Denton, NRR J. M. Taylor, IE E. Case, NRR

( R. Vollmer, NRR V. Benaroya, NRR J. Axelrad, IE J. Liebennan, ELD P. Farron, IE W. Shields ELD W. Johnston, NRR i

J. G. Partlow, IE

! J. N. Grace, IE

! P. F. McKee, IE S. D. Richardson, IE J. Craig, IE l

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