ML20011F401
| ML20011F401 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/27/1989 |
| From: | Miraglia F Office of Nuclear Reactor Regulation |
| To: | Crutchfield D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20011D121 | List:
|
| References | |
| NUDOCS 9003050289 | |
| Download: ML20011F401 (29) | |
Text
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- UNITED STATES y S 17 ' ).
NUCLEAR REGULATORY COMMISSION
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t' WASHINGTON, D C,20556 y.,a p
December'27, 1989 MEMORANDUM FOR: Dennis M. Crutchfield, Associate Director n
for Special Projects FROM:
Frank J. Miraglia, Chainnan DP0 Review Panel on Comanche Peak.
l
SUBJECT:
COMANCHE PEAK DP0 ON SALP
, As we discussed, the DP0 Panel is prepared to meet with members of the Comanche' Peak SALP Board, Messrs. Grimes, Warnick, Livermore and Wiebe on January 4.1990.
The meeting time is 8:30 a.m. in'12-B-11.
As we previously discussed, the DP0 Panel has identified some areas'that we would like the SALP Board members to be prepared to address. is a review of the DP0 connents related to the SALP process, compared to the SALP Manual Chapter guidance and matters that the DP0 Panel would like to discuss. is a similar matrix of comments from the CASE letter sent by Billie Garde-'on November 20, 1989.-
4 There. are certain differences in SALP drafts identified in enclosure 3 relating to engineering and technical support and plant operations. The DP0' Panel would like to discuss the reasons for these differences with the SALP Board.
Frank f.>Mi
, Chairman DP0 Re Mew Panel on Comanche Peak
Enclosures:
As stated.
cc:
J. Sniezek J.,Partlow C. Grimes
~R. Warnick
. H. Livermore J. Wiebe i
n 90030 $ $$ Nobh )U
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s CASE _ N RELATED NC__ GUIDANCE ANALYSIS. AND. QUESTI_ON_S 1.
Our review and 1.
The NRC will normally-1.
The SALP.MC'does not analysis revealed that the review and evaluate each ci m ly address the use of the SALP process power reactor licensee criteria for discontinuing-for Comanche Peak.at this possessing.a construction or restarting the SALP.
q~
time-was inappropriate permit every 15 months.
process for a particuiar and, thus, inherently
[0516-04) facility.
3 problematic.
The restart of the SALP When the Regiorial process for the period Administrator determines l
September 1, 1987 to July that the performance of a l
31, 1988 was inappropriate particular utility or:
l' because many of the areas facility warrants a more m
4 l
of performance were still frequent evaluation, such less than Category 3 as as.in the case of Q1A How many SALP defined in MC 0516.
11censee's that'were Catagory 3's did CP have assigned a Category 3 during the previous performance rating in period?
several functional areas during the previous evaluation, the period
- between SALP evaluations should be reduced to about 12 months..[0516-04.b]
4
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I:N CT M U RI: (7) l m
W
~
NATRIE ~ OF CASE CUISIENTS CONCERNING SALP VS SALP NC The SALP process was When a'SALP evaluation.
It is not clear why the suspended by the NRC from will be used as part of a
'SALP process'was 1984 until,1987 because of determination of the discontinued when it was-TU Electric's massive readiness.for new plant
.and what were the' criteria-corrective' action program startups, a SALP for restarting.
i to address eleven specific evaluation should be areas of design and conducted approximately A letter was issued FEB
~ '
construction problems.
It one month before the 20, 1985 which stated that-is CASE's understanding expected milestone date.
the SALP would be ommitted that this suspension
[0516-04.c!
due to the considerable recognized that TU resources devoted to CP by.
Electric's performance was Unacceptable performance the NRC to evaluate the by definition less than is addressed through NRC's utility.
The letter also Category 3.
stated the next SALP
[0515-01]
period would be set when the present special NRC activities conclude.
2.
CASE believes that 2.
See #1 above.
2.
The SALP period was under the unique situation set at 12 months as at Comanche Peak the required by the MC.
The recent SALP should have extension of the period is.
t followed the NRC's review generally for good of operational readiness performance.
In-addition, by the operational CASE seems to think the Readiness Assessment Team data will be lost and does l
(ORAT).
We do not.
not acknowledge that SALP understand how the Board is meant'to be a i
could even perform a valid continuous process and the SALP without the ORAT would be captured in i
information provided by the next SALP which is
.. 1 the ORAT.
already 4 months old.
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3.
If the agency decides 3.
See #1 above.
l 3.
The SALP period was I
correct i.n accordance with to use the SALP process at Comanche Peak, our the MC and should not be evaluation indicates that revised, or redone.
l 0 new SALP evaluation However, a 6-month mini-l should be considered and SALP could be perform)
'(
should follow the final prior to operatzen as was-f operational readiness done at TMI.
inspection.
CASE believes j
t that the standard SALP process should not be assed i
et this point but a l
l special modified process l
l should be developed to l
evaluate TU Electric's j
performance including the l_
character and competence to operate a nuclear plant.
I i
4.
The emphasis (of SALP) 4.
The SALP process is 4.
The elements to be f
should be on eveluating used by the NRC to considered in evaluating i
management performance synthesize its each functional areas are
[
from TU. Electric's observations of and very clear in the MC.
corporate management down insights into a licensee's These same areas suggested to site level supervision performance and to by CASE are reviewed in j
to determine attitude, identify common themes or each area.
The
[
l character, competency and symptoms. [0516-01]
" emphasis", however, is to i
l operational performance understand the reasons for l
ekills.
the licensee's performance.
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HATRIE OF CASE CC.WEENTS CONCERNING SALP 78 8ALF NC 5.
The composition of the
- 5. See #'s 1, 2,
3 and 4 5.
Sec 8's 1,
2, 3,.and 4 board was stacked with in Enclosure (1).
in Enclosure (1).
managers who in some cases had little or nothing to This comment impiies the do with the day-to-day managers can not make an site inspections.
On the objective judgement on the other hand senior resident performance level of the inspectors, who were most utility based on the input knowledgeable and of the inspectors, so it represent the inspectors, is difficu1t to address.
were excluded from the It does not recoonize that process in 1988 and 1989.
many inspectors perforn inspections at the site i
and even the SRI does not have the detailed knowledge of the utititics performance in each area.
It is the managers function to be aware of i
all the inspection activities and come up with an overall picture.
The SALP Board composition in 1988 was smaller (H),
but similar.
The 1989 Board had two more RIV representatives.
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.V' NATRIE OF CASE COISBNTS CONCEIRIBIEMB SALP TS SALF NC 6.
The senior resident 6.
See #1 in Enclosure 6.
The 1ist of for construction provided (1).
participants in the SAi,P a very negative input and report is typically only memorandum about TU those personnel who Electric performance; however, this was not.
attended the actual SALP Board meeting.
The nany reflected anywhere in the individuals wi:o provide SALP process or report.
input are not 1isted In fact, according to the separately.
list of those l
participating in the Q6A Why was the SRI-I process, the senior construction not an resident inspector was not attendee at the SALP r
i l
even acknowledged as Board?
I participating in the i
process.
Also an NRC l
consultant who performed
[
isportant inspections was
}
i dropped from the participants, while one consultant who had been on l
site less than~a month was included.
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5 I:NCID";Ulti: (7)
t IIRTRIE OF CASE CogEENTS CORBCB5551EOS SALP V8 SALF ffC 7.
IIItc management 7.
See 810 in Enclosure 7.
j excluded and did not (1).
The Service water synt em l
consider significant problem should be i
performance problems discussed in one of the during the 1988 and 1989 SALP periods i f it isa SALP periods.
Performance significant issue concerning a breakdown in providing insight into the j
the On program service utilities performance.
water system was deferred for more than two years i
because of pending.
enforcement in report (50-445/88-47:50-446/88-42) in j
the 1988 SALP period.
}
This issue was still not picked up and evaluated during the 1999 SALP l
process, because it was referred to the IIstC Of fice j
of Investigations.
8.
The AFtt check valve 8.
See 810 in Enclosure 8.
j failure and backflow (1).
l incident was discussed but i
management action that led to enforcement issues was
[
not discussed because of J
pending enforcement.
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.i I-NATRIE OF CASE COIWWWTS CONCEMtING SALP TS SALP HC l
s 9.
The SALP process 9.
See #1 above.
9.
The SALP p#riod is I
apparently went forward
'only allowed to bc without considering extended for good extending the SALP period performance and not weak to include important performance.
If the program deficiencies such utility has problems as l
as discussed above.
MC severe as presented by j
0516 allows extending the CASE then the period i
l SALP period from 12 to 18 should not be more than 12 I
months.
In the face of months.
critical performance l
indicators, we believe the NItc should have considered l
extending the period to include information crucial to evaluating performance and deciding whether or not to grant a i
license.
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NATRIE OF CASE CUISIENTS CONCBEINING SALP vs SALF IOC l
- 10. The functional areas 10.
For reactors in the 10.
The MC allows scne for design and preoperational phase, fIexibi1ity, as needed, in I
construction were functional areas for selecting the functional deemphasized by placing either operating phase areas to be evaluated.
It i
eore emphasis on other reactors or construction is routine to deemphasize 1
areas where there was not phase reactors should be the construction areas real performance to selected, as appropriate.
when nearing the pre-evaluate.
Eleven
[0516-062) operationa1 phase.
functional areas in However, the rationale for 4
construction that should Although not all selecting the areas in the have been independently functional areas need to draft report is not evaluated were combined be assessed in a given specified as required by into one area and this review, an explanation the MC.
diluted negative findings should be given in the in these areas.
SALP report if a Disciplines were not functional area r,
l specifically addressed as appropriate to a licensee required by NC 0516.
is not evaluated. [0516-06]
Q1 4 How were the functional areas for the a
current SALP selected?
- 11. NC 0516 states that 11.
The SALP Board 11.
The SALP report the attributes and members shall evaluate states that the criteria criteria listed in the licensee performance in were used in the appendix to NC 0516 should each functional area after evaluation process.
be relied on to develop a considering the evaluation uniform aged consistent criteria with their approach.
Our analysis of associated attributes l
a sample of the dra f t listed in Appendix A, i
reports showed that the Table 1.
[ APP B, B.3]
approach did not rely on the specified criteria and l
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8 T.NCIDSURI: (?)
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l NATRIE OF CASE COIWWWTS CONCERNIWS SALP VS SALF NC attributes.
1
- 12. The general statements 12.
The SALP Board 12.
in the SALP draft appear members shall review and to be selected from the discuss the SALP report.
.(
criteria in Appendix 0516 They shall ensure that i
that indicate CAT 2 each functional area performance; however, section concisely conveys these statements were not the Board's views, with supported by date in the selected examples to same paragraph or by illustrate key findings.
l reference to data.
They shall ensure that a Instead many such conclusion has been statements were only reached regarding licensee l
i supported by examples that perfor1mence within each l
l appear to support a CAT 3 functional area.
They l
finding.
Thus many of the shall ensure that the i
l CAT 2 conclusions were not discussion of performance supported by any data within each functional l
indicating the equivalent area identifies common l
t performance.
themes or symptoms of that l
l performance if known. [ APP l
4 B, B.3) f i
13.
NC 0516 does not 13.
The word repetitive 13.
The Board did not j
define the term repetitive is used several times in consider the deticiencies i
deficiencies.
Instead it the evaluation criteria
- to be repetitive or i
is interpreted narrowly for Enforcement History.
indicative of a l
and subjectively without For example:
programmatic breakdown.
)
j supporting data.
Category 3:
013A What factors were
[
-l Minor violations ~are weighed when considering repetitive and indicative whether the findings were of programmatic breakdown.
not repetitive?
l
[ APP A)
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NATRIE OF CASE N CONCBIENIIIG SALP VS SALF DOC 14.
Comments and 14.
See #6 in Enclosure 14.
i observations about TU (1).
Electric's inability to address root causes which were evident in inspectors' input in early l
SALP drafts but were either dropped or j
minimized in the SALP draft.
In the case of W t
Electric responses to violations in NItC reports l
t 50-445/84-32: 50-446/84-11, and 50-445/86-08:50-i 446/96-06 the subjects l
were not addressed at all, even though meetings were held during the SALP l
period to discuss i
inadequate corrective 1
action regarding these i
issues.
j t
l 15.
CASE's asselysis 15.
See 96 in Enclosure 15.
[
showed that many of the (1).
WItC staff's other negative findissgo were provided in l
the original draft reports but were dropped from the i
initial SALP draft or were rewritten to minimize i
them.
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MRTRIE OF CASE COIEENTS CONCERNIWS SALF TS SALF NC 16..
'Ibe NRC should have, 16.
Formal trend analysis 16.
but did not' perform a is not required or
~
formal trend analysis of mentioned by the MC.
repetitive deficiencies t
identified by the NRC.
Instead the SALP Board i
i made general statements that mejor or minor i
violations were not i
repetitive and did not i
indicate a program breakdown.
.I There is no evidence of 4
any detailed trend analysis to determine if findings in the 1988
-3 versus the 1999 SALP were,
- l l
in fact, repetitive.
Similarly, there was no i
trend analysis of i
violations and i
j deficiencies found during i
j the 1989 SALP period which i
was compared to findings of violations and l
deficiencies by the NRC in the CAP from the time
[
period 1995 to the present to evaluate recurrence.
i 17.
Alt @ no formal 17.
See #16 above.
17.
i trending was performed, it is CASE's understanding I
that inspectors attempted
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IIRTRIE OF CASE COgEIENTS CONCEEINING SALF VS SALP IOC to point out;the repeat program weaknesses in the initial drafts, i.e.,TU Electric's QA program was still not identifying and correcting problems that l
are now part of their j
corrective action program.
18.
Several years ago 18.
See #1 in Enclosure 18.
The SALP Board SAIX Boards were generally (1).
composition over time h--:::3 of fewer managers should be reviewed and and supervisors, but had a reevaluated.
larger number of inspectors who performed CASE's complaint concerns the inspections, had a how RIV became top heavy, i'
personal and direct but in this instance NRR involvement with an is much more represented applicant or licensee, and on the Board than by voted.
As the Regions procedure.
have become top heavy with more and more managers, the Board composition has steadily changed in the i
other direction where the senior resident inspector (SRI) is the only working level person on the Board.
19.
Since the SRI is 19.
See #1 in Enclosure 19.
See #1 in Enclosure l
classified as a (1).
(1).
supervisor, no working inspectors are usually on the board.
The SALP i
Boards for 1988 and 1989 t
12 l'NCist :ttps: (,' )
i
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. _ +. _ - -.
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.n.
t 9
i MRTRIE OF CASE COIEEENTS CONCERNING SALF VS SALF HC at Cosenche Peak were selected by the Office-of Special Projects.
They went a step further than the. rest of the agency and j
removed the senior resident from the board.
t i
20.
h composition of 20.
See #1 in Enclosure 20.
CASE seems to think i
the Board was lopsided and (1).
that there was more than l
stacked with 5 high one board for the SALP.
managers who had no day-l
.l
.to-day involvement with
~
inspections versus one site manager and two site supervisors who did.
N i
The final board composition became even 6
more lopsided.
i 21.
Senior inspectors had 21.
See 51 in Enclosure 22.
See 81 in Enclosure j
no vote and would have (1).
(1).
}
been outvoted even if they j
had been allowed to vote as board members.
The
.r eleven to twelve site NRC f
inspectors / consultants who did the work had the least to say in the whole matter.
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13 I'rscinst' ret: (.' )
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. 4-i-
MRTRIE OF CASE COIBIENTS COIOCERNIEIG SALF V8 SALF 99C 22.
Specific areas for 22.
See 810 above.
- 22. See 810 above.
construction were not i
addressed per HC 0516; j'
soils / foundations; containment, major i
I structures and steel i
supports, piping systems / supports; mechanical components, auxiliary systems, electrical i
equipment / cables; and, instrumentation.
l 23.
The draft SALp 23.
See #6 in Enclosure 23.
reports do not really (1).
i address the seriousness of T
I the program deficiencies.
l The exclusion of these l
l matters appears especially i
suspect eince the final l
SALP excludes the negative comments about Unit 1, but praises the corrective action taken for work on Unit 2 service water i
system.
24.
19te lesse of TU 24.
See #6 in Enclosure 24.
Electric's response to the (1).
service water system l
enforcement action not i
being accurate and.
complete was not 14 F:NCID*:t'If t: (. )
i i
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unTRIE OP cast C N concBRNING BALP vs SALF HC considered in the as yet unissued NRC inspection
]
report 50-445/89-23; 50-1 446/89-23.. 'Ihe NRC deferred the evaluation of
_i the issue effecively forever by referring it to j
be investigated and j
considered in the next i
SALP.
i f
f 25.
TU Electric 25.
See 96 in Enclosure 25.
performance in this area (1).
(AFW) was also understated
(
i l
in the SALP report and
{
evaluation of enfortw.nt i
activity as relates to i
performance in this area has deferred for another i
year on the basis of considering escalated
[
enforcement.
26.
The NRC policy of 26.
Not addressed.
26.
i deferring key programmatic failures connected with
~
enforcement or l
investigations that l
occurred during the SALP period until the next SALP h
i is illogical and is a i
4 serious flaw in the SALP
}
process as sec 0526 does not specifically prohibit
~
l such practices.
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MhTRIE OF CASE COIEWNTS CONCERNING SALF VS SALF NC I
27.
Most of the negative 27.
See 96 in Enclosure 27.
findings quoted and (1).
t discussed (inability to address root cause) were either dropped from the SALP final draft report or reworded to the point that i
the negative finding was minimized.. Inexplicably, in some cases, the findings were changed to become positive i'
program /manag n..;.
statements.
I 28.
In general the SALP 28.
See 96 in Enclosure 28.
[
drafts showed a lack of (1).
data or references to data i
to support conclusions about large complex areas of work performed by TU l
l Electric.. Without such a collection of all of the i
i data about each functional area, ratings became a
extremely arbitrary and lost much of the purpose for the SALF.
i 1
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i 16 1:ticiostfiti: (7)
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4 MRTRIE OF CASE COIEEENTS CONCERNIWW SALP V8 SALP NC g.
29.
Insufficient 29.
See #10 above.
29.
Inspections were done in l
the functional area of maintenance / surveillance and should not have been rated.
I 30.
TU Electric 30.
See 512 above.
30.
performance is obviously, at a minimum, a Category 3 in the area of corrective 4
action and root cause i
analysis by virtue of j-their performance in the l
service water system j
evaluation and check valve incident.
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17 I:tICIOS11HE (2)
P
m DFT_ m RELATED NC GUIDANCE ANALYSIS AND OUESTION_S 1.
Ten NRC managers made 1.
.A Board quorum will 1.
Ten individuals were up the SALP Board.
consist of a minimum of 1isted in the draft SALP six persons.
Generally, report as SALP Board there should be no more members. 6 than nine persons on the 6
i Board. [ APP B, B.2]
.{
'f C
I The composition of the The SALP Board composition i
SALP Board is was not as required by the l
multidisciplinary in NC, but a review of i
nature and is intended to equivalency is required result in an integrated due to the unique
[
assessment of licensee organization of Special performance. [ APP D, B.2]
Projects.
i l
The SALP Board composition
['
shall be as follows with l
each member having a vote:
}
Reg. SES= Grimes $
f a.
SALP Board Chairperson a.
j (Regional SES-level manager):
b.
Senior Resident-
- b. SRI = Livermore g j
Inspector c.
NRR Project Manager;
- c. NRR PM= [?]
d.
NRR SES-level manager;
- d. NRR SES= Mckee-[Y]
e.
Regional Projects
- c. Reg. DRP= Gwynn [Y)
Division Director, Deputy Director, or Branch Chief:
[
1 ENCIOSURE (1) h l
t i
h
.-s
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NATRIE OF DFF COISEENTS COIOCERNIWS SALF VS SALF NC f.
Regional Specialist
- f. Reg. DRS-Jaudon {Y)
Division Director, Deputy Reg. DR55= YandelI [Y]
Director, or Branch Chief (at least one-from each j
Specialist Division);
g.
Others as designated
- 9. Others = Lyons by the Regiona1
= Warnick
.{
i Administrator for any
= Wiebe specific Board. [ APP B,
= Wilson B.2]
w i
i Q1A Who appointed the ten j
l members to the Board?
I k
Q18 Was there a conscious decision to appoint more than the recommended nine l
members? Why?
l f
OIC What procedure was I
used to control the I
)
process?
i i
i
}
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7 ENCLOSURE (1)
{
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NATRIE OF DFT CogWtENTS CONCERNIHS SALF VS SALF NC l
2.
Three of the SALP
~2.
See #1 above.
2.
According to the MC,
j Board members were Region at least four members of IV managers who had no the SAI,P Board should have direct and significant
.been from Heqion IV, I
involvement with the site.
therefore there is less l
than required.
l i
02A How much inspection activity was conducted by Region IV?
Q28 Did the Region IV t
t I
members represent a significant amount of inspection coverage?
1 3.
Two of the SALP Board 3.
See #1 above.
3.
It appears that the members were involved with two Assistant Directors site matters but they from CP Project Division administered their project do not have an equivalent management and licensing in the SALP MC, except for duties from their White the Specialist regional Flint Offices.
~ divisions which were also f
on the Board.
- However, the MC states that the RA can appoint others as j
necessary.
l 03A Were both the CP Asst Di rectors.m.I Hiv l'oput y 3
ENCLOSURE (1) 1
f-i IIATRIE OF DFT COINEENTS COIOCERNING SALF VS SALP MC i
Directors needed on the l
Board?
Q3B Why was the MRR PM
' {
not on the SALP Board?
4.
NRC Senior 4.
See #1 above.
4.
There was no one on Resident / Resident and the Board with the title Consultants who were Specification of the of " Senior Resident i
entirely knowledgeable of Board's voting members is Inspector "
r ired by licensee performance had not meant in any way to the MC.
i no vote on the board.
limit presentaticas before
?
}
the Board by other NRC f
staff members when appropriate.
The staff 6
l members closely associated I
with a functional area should be requested to 6
discuss their views with r
the SALP Board. [ APP B, Typically, per the MC, l
B.2) there is only one f
" inspector" on the SALP Board.
l f
j The Resident's function is to l
participate at the meeting l
and to provide insight to the Board members.
f j
Q4A What in the equivalent j
position of the ::HI at the t
4 ENCLOSURE (1) l v
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I MATRIX OF DFT COOWOENTS CONCERNING SALP VS SALP MC i
CP site and was he on the t
Board?
l I
I 04B Two individuals with i
the word " inspector" in their title were on the Board.
What is their j
i eg'sivalent position in relationship to the MC
'l titles?
l I
1 I
5.
All of the 5.
The functional area 5.
The MC states that the recommendations for below ratings will be determined majority vote rules, so if l
aterage, coming from those by a majority vote of the there was one or more j
who knew the real Board's voting :wmbers.
recommendations for a i
performance, were outvoted
[ APP B, B.3]
"below average," they by managers on the SALP could certaint be i
I Board.
outvoted.
l M-6 i
i l
l 05A How many Category 3
{
votes were cast in the i
ditterent areas?
i OSB Did any participants voice thei r viisaqrcement with any f unct ion.tl atca i
ENCLOSURE (1) l
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sehTRIE OF DFT COOSEENTS COIOCERNING SALF VS SALF NC rating durinq the mec+inq?
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6.
Information and 6.
The SALP Board members 6.
AlI information and i
findings brought to the sha11 review and discuss iindings discussed at the l
attention of the SALP the SALP report.
They Board cannot be included
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Board were deliberately shall ensure that each in the report.
- However, j
excluded.
functional area section it is each inspectors concisely conveys the responsibility when i
Board's views, with developing the SALP report selected examples to to ensure the important illustrate key findings.
findings and information l
[ APP B. B.3) are included in the report so the Board is aware of j
j the significant issues.
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The draf t report does not j
l list any regional inspectors as l
l participating in the Board meeting.
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l 06A Did the site l
inspectors develop the j
l regmrt input 7 4
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ENCIA)SURE (1)
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HATRIX OF DFT COIWEENTS CONCERNING SALF VS SALP WC I
06R Did the i nr.pect orr, (site and regional) f actively participate in the SALP Board meeting?
l 7.
The pending SALP 7.
See #6 above.
7. -- -,.._ _
report is neither an accurate nor complete
- The SALP Board members reflection of *IV Electrics shall ensure that a performance during this conclusion has been SALP period.
reached regarding Iicensee performance within each i
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l functional area. [ APP B, i
B.3]
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t 07A Do the Board members consider the report an 3
accurate and complete i
reflection of the uti1ities performance?
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Q78 Do the site and I
regional inspectors consider the report an accurate and complete j
reflection of the 1
utilities performance?
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4 7
ENCLOSURE (1) i i
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t IIRTRIE OF DFT COISISWTS CONCERNING SALP VS SALP MC a
3.
If the information 8.
Voting members are 8.
were properly considered expected to participate a,n i
and evaluated, it would Board discussions of each j
indicate a less than functional area in order satisfactory performance to contribute erfectively rating in some areas, a to the assessment of the 6
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need for increased licensee's performance and i
attention and applicant the identification of f
action prior to NRC cosmon themes and symptoms l
approval to load fuel.
of that performance.
As a Q8A Did the Board ask the 4
result, SALP Board participating inspectors
{
3' deliberations should be for input during the oriented toward reaching a meeting?
consensus view when possible. [ APP B, B.2]
08B How much experience did the Board members have in the SALP process?
9.
The SALP Board did not 9.
See 96, #7, and 98 9.
l adequately consider the above.
full implications of Q9A Did the Board members discuss the ASME issues j
certain ASME issues i
identified during the during the meeting?
i reporting period by staff Q98 were these issues l
inspectors.
discussed in the draft i
report?
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ENCLOSURE (1)
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DEATRIE OF DFT Cog 5EBMTS CONCERNIIBO SALF TS SALP NC 10.
The SALP Board did 10.
See 86, 97, and 88 10.
not adequately consider above.
the inability of the Q10A Did the Board appilcant to. recognize members consider the I
conditions potentially or service water and AFW actually adverse to system issues during the quality as demonstrated by meeting?
l events surrounding service 810s~ Were these assues water system and the auxiliary feedwater system discussed in the draft (check valves and motors).
repor t
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11.
11te SALP Board did 11.
See 96, 97, and 88 11.
not adequately consider above.
the inability of the Q11A Did the Board applicant to identify and consider the utilities evaluate root causes of corrective action process l
deficiencies and program during the meeting?
i failures necessary for effective corrective Q118 were these issues action.
discussed in the draft report?
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ENCIOSURE (1) t 9
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4 trer tN Category ? ratino listte in the dr6't finel vers 1t,r.). Tht ct er ce s de rrt, towe,er, r aise safety cuestier.5 tut involvt c'ifferences in the character 126titt cf the apriitant's per'errance it-6r twn areas.
l A discussion of the applirtid's subriittels and responses to NPC recuette l
for ir.'ernation reprding FSAT arnenamenu, t.rd technicel specificttiers (paracr6f t H) was sutstanticily rewritter.
Several strongly neptive cent.ents we re cr ieted f ror. this subsection. AlthouT,h sorte e st e c t s of these deletec statert.ents are refle cted in the iinal report, the character.
124 tier. cf this subsection appears tn be more positive as a result of ttt charets. The bases for chance
- tre not apparent frorn a review of the docur4 r.t s. Howiser, the 1erpage in ttt craft report coes indicete sore incertistency 1r tret, whiin the sumary statementt 6re generally l positist, the discussion /exarrples of the ectivities are, generally, strercly r+gative. The final dr6ft langu6ge. converse ly, is consistent witt pr.erally r e sitivt sunnary stattrerts and less r.egatiu cervents.
In the suh'.ection accressino assessment 01 the configurt, tion control prograrn (paragraph 28) it was noted thet the applicant has *...dif ficulties in irtplerentine e truly eff ective confiperation cortrol prograr [which) hase resulted it, repetitive riner vioittions." Thi: ttatement is replacet
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p ir ttc final draf t with staterients that the applicent *..has implemented an effective configrration certrol prograr..." and "[o]nly a few rirer discrtrencies have been idertified..." Accitiorelly, the 11r.t1 craft addec that prograrratic er.hentert.ents hat been made to acdress the troblers.
These ettiges appear to result ir. a more favorable assessr.ent of the app!) cant's performance in this area.
Although the bases for these l
charges are not clear from a review of the cocuments. it appears ttat the Boarc concluded that the " repetitive minor violations" noted in the draft version were not indicative of the overall effectiveness of the progr6r.
A strongly negative corrent regardirp the procurement prograrr was deleteo l
in the final tr6ft (paragraph B9). Although the statement that notec
...other procurement problems...have resulted in the staff's impression that the applicant appeared to be meeting only minimal requirements..."
wes ret supported with exerples and itay be covered to some extent by the aedition, in the final draft, of noted problers in the removal of coatires ir the service water systers, the bases for deleting this corrsnent is net clear from a review of the documents. A statement indicating that correc.
tive actiuns were being implemented at the end cf the SALP period was
- added to the final draft and may represent updated information on this I
issue.
A number of other changes, which did not significantly change the subsec-tion assesstr.ents, were also made. For exarnple, changes to a discussion of the statistical aspects and the programatic significance of violations (paragraph B5) were made. This appears to be based on additional or updetec infortnation not reflected in the draft report. There is, however, i
no supporting data, such as an inspection report / violation matrix, which I
would perr.it cross checking of these numbers.
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- el 11 35 1 4prifictrt to note the' t rerly ell surm ary ste'erents in the taalu6 tier criteria subsectier s within this f ul.ctict.el area rerein esser,.
t ia ' 1) urthanp c betwell. tre craf t enc 11nal creu 1ersions of the repcrt.
Fer er arrrle, bcit versions (f.et paragret h (f.) note tt61 the *...artlicant 'f.
proprer 1or the 1dertificatiet. and correction of non. conf orm1 rig er deficit ti trrcitions wt b ef f ectiu." surqr,ary !tetements rtleted to ranagement involverttt, prior planning and assigorent oi prioritit!, resolutict, cf ceficier cie!. resprr $1veness tc t$C issuer anc idC assestrent of th ('iant eteluation group, were aise substantially uncharced. The tr.ccificatior t trat were mact te the draf t $ Alp inclucirp; 3) additions anc of t deletier previously noted, M rumerous ecitcrial charpes, and 3) deletleti of two posit h e corwer t s (paragrept s (3 anc (4), did not ref t '.t in chat.rgt s to the subst(tlon surraries and de not signifitertly charge the characterizatitt o' thi! functior.a1 area in the SAlp report.
4 f lant Dpera*.it.r This sectier underwert a substantial rewor6ing betweet. the draft erd draft fitEl 5 ALP r perts.
For th( riost part the changes were editorial in nature arc co not appter to substantively change the assessinent of tht app 1' cant's performance ir this functier.a1 area.
Stat'ttical ch6rges were noted in the atelysis of viol 6tions (parecraph 07). Ite lack 01 otte, such at e ratrix of inspection reports included and viciations, Oces not allow cetermiti6 tion of the basis f or the ctanges.
tcwever, the statements only represer t a f actual tabulation of violaticrs, therefort this change 15 not considered sigt.111 cant.
A discussion of an NRC inspection of operating procede*es was rewritten (paracraph DE). Both draf ts were critical of tht qu.'lity of the procedurrs as inspected anc noted that corrective actions had beer initiated; however, e strongly negative statement in the draft to the effect that precedures were not at a quality '.evel necessary for plant operatier was deleted.
The basis for dtletion of this statement is not apparent f rom a review of prior drafts. However, since both versions indicated existing problers with procedures and that the applicart had initiated corrective actions, the change does not significantly irrpott the characterization of this issue. Additionally, the final draf t did add a Board recoteendation specifically air +d at correction of procedures, tr.itiation of correctivt actier.!, coupled with the Board's recorrencation, fr.ay have been the basis for the deletion of the coseent.
A majcr ciscussion (paragraph DB) regarding the applicnit's poor performance relative to several auxiliary feedwater check valve battleakace events was rewritten. Both writeups refrained critical of the applicant's performatice regarding this series of events. The changes are essentially editorial.
However, the final draft notes a subsequent increased sensitivity te events anc provides an example (not in the draft) to substantiate the cossnent.
Several subsections in the draf t final report were added, including a positive discussion of the prestart test group's performance (paragraph D9) and a neutral discussion of the training program for operations and support personnel (paragraph Dll). Several positive coments in the draf t