IR 05000445/1980025
| ML19290G695 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/12/1980 |
| From: | Burwell S, Crossman W, Seidle W, Seyfrit K, Renee Taylor NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV), Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19290G694 | List: |
| References | |
| 50-445-80-25, 50-446-80-25, NUDOCS 8012180372 | |
| Download: ML19290G695 (11) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION IV
Report No. 50-445/80-25; 50-446/80-25 Cocket No. 50-445; 50-446 Category A2 Licensee:
Texas Utilities Generating Company 2001 Bryan Tower
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Dallas, Texas 75201 Facility Name:
Comanche Peak, Units 1 & 2 Meeting at:
Dallas, Texas (October 30,1980)
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NRC Participants:
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K. V. Seyfrit, Director!..Regi'on IV Date
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S ii,/(,/jp W. C. Seidle, (6upport Branch Chief, Reactor Construction and Date Engineering
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W. A. Crossman, Chief, Projects Section Date Uff/8D R. G. Taylor, Resident Reactor Inspector, Comanche Date Peak Station
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/g15. B. Burwell, Licensing Project Manager, NRR Date
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W. A. Crossman, Chief, Projects Section Dat 80321so37A
Meeting Summary:
Meeting on October 30, 1980 (Report No. 50-445/80-25; 50-446/80-25)
Meeting Topics:
Announced meeting with TUGC0 corporate management concerning Region IV's evaluation of the licensee's performance.
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DETAILS 1.
Persons Attending Meeting Licensee Particioants R. J. Gary, Executive Vice President and General Manager, TUGC0 L. F. Fikar, Executive Vice President and General Manager, TUSI B. R. Clements, Vice President, Nuclear Operations, TUGC0 J. B. George, Vice President and Project General Manager, TUSI D. N. Chapman, Quality Assurance Manager, TUGC0 R. G. Tolson, Site Quality Assurance Supervisor, TUGC0 NRC Particioants K. V. Seyfrit, Director, Region IV Office of Inspection and Enforcement W. C. Seidle, Chief, Reactor Construction and Engineering Support Branch W. A. Crossman, Chief, Projects Section R. G. Taylor, Resident Reactor Inspector, Comanche Peak Station S. B. Burwell, Project Manager, Licensing Branch 2, NRR 2.
Meeting With Texas Utilities Generating Comoany Management a.
Puroese of Meeting The purpose of this meeting was to describe the regional evaluation under the Systematic Assessment of Licensee Performance program.
This evaluation is an intergal part of the Systematic Assessment Performance (SALP) program which is being implemented in accordance with the commitments of the " Action Plan for Implementing Recommen-dations of the President's Commission and Other Studies of the TMI-2 Accident." The attached Appendix B is the performance evaluation for the Comanche Peak facilities for the period August 1,1979, through July 31, 1980, compiled by the NRC participants and a Regional Review Board.
To begin the meeting, the Regional Director outlined the following objectives for the Systematic Assessment of Licensee Performance program:
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Identify exceptional or unacceptable licensee performance
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Improve licensee performance
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Improve the IE inspection program
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Provide and achieve a means of regional consistency in evaluating licensee performance-3-
b.
Enforcement History The enforcement history for the Comanche Peak facilities was reviewed.
The following noncompliances, during the above stated review period, were identified by Region IV IE inspectors:
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Personnel not properly trained and indoctrinated
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Failure to follow procedures for verification of the performance of automatic welding machines
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Failure to follow nonconformance procedures for electrical cable
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Failure to follow procedures for hoisting safety-related components
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Failure to update procedures
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Failure to provide appropriate instructions for installation of Class IE equipment
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Failure to follow welding procedures
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Failure to provide instructions and procedures appropriate to installation of Class IE battery chargers
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Failure to follow procedures for cable pulling
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Failure to follow procedures for reporting and repair of damaged electrical cable
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Failure to follow welding procedures
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Failure to follow electrical inspection procedures
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Failure to establish quality assurance program for Class 5 pipe support systems
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Failure to follow inspection procedure for returning inspection stamps
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Failure to follow inspection procedure to initial and date operations traveler
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Failure to report a significant construction deficiency (50.55(e))
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Failure to follow construction procedures required by drawings-4-
c.
Status and Summary of Noncomoliance Items The NRC participants stated that as of this time all of the above items have been closed out by subsequent inspections.
The item in regard to the QA program for Class 5 pipe supports will be followed closely during future on-going inspections since it involves a substantial backfit inspection effort on the part of the licensee.
The NRC participants stated that 1689 NRC inspector-hours were consumed in 26 routine inspections at the Comanche Peak site.
Based on the 17 items of noncompliance identified, this indicated about 100 inspector-hours were expended per noncompliance which is typical of an acceptable construction QA program but could not be rated as exceptional performance.
d.
Construction Deficiency Reoorts - 50.55(e)
The following construction deficiencies were reported by the licensee during the evaluation period in accordance with the requirements of 10 CFR 50.55(e):
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Spacing of Concrete Anchor Bolts
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0A of Welded Conduit Supports
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QA of Seismic I (NNR) Pipe Supports
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Honeycomb of Unit 2 Containment Interior Walls
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Anchorage of Main Control Boards
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Material in Service Water System Valves The NRC participants indicated that it appeared that the licensee's threshold for reporting significant construction deficiencies to the NRC was appropriate and timely, particularly since the management meeting discussed in Inspection Report No. 50-445/80-12; 50-446/80-12.
e.
Escalated Enforcement Action An Immediate Action Letter was issued on September 7,1979, confirming a licensee decision to not place concrete in the wall to dome transition area of the Unit 2 Containment Building until such time as a proper engineering evaluation could be made of the omission and subsequent addition in another location of a group of reinforcing steel shear ties.
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Licensee's Responsiveness and Ability to Take Meaninaful Corrective Action The NRC participants indicated the following positions in regard to the licensee's response to various levels of NRC identified problems:
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Bulletins ud Circulars - The responses to this class has been adequate although much work still remains to be accomplished in regard to Bulletins 79-01 (Class IE Equipment Qualification) and 79-02 (Pipe Support Systems).
The licensee stated that they recognized that much work in these areas must be done and that they would fulfill requirements as construction progresses.
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Enforcement Action Responses - The NRC personnel indicated that the licensee's responses have been concise, effective and to the point.
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Effectiveness and Attitudes of Licensee Personnel in Complying witn NRC Requirements Licensee Quality Assurance Personnel - The NRC personnel stated
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that the overall impression was that the licensee had upgraded the quality of their personnel at all levels during the past two years.
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Licensee Construction and Engineering Management - The NRC personnel stated that it appears there is a continuing tendency to engineer away construction problems rather than enforce compliance to drawings and specifications.
The licensee stated that he is taking several management actions with the engineering and construction personnel to alleviate this situation.
The NRC personnel stated that there was no specific regulatory concern since safety does not appear to have been compromised as yet but could possibly be sometime in the future if appropriate actions were not taken as indicated above.
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Brown and Root Quality Assurance - The NRC personnel stated that overall abilities of the Brown and Root QA personnel appeared to have been improved during the past year, in part because of much improved procedural direction being given to them.
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Brown and Root Construction Supervision and Labor Force - The NRC participants indicated that their impression of this area indicated that there is a need to make this group more aware of nuclear power plant construction requirements.
That there is a considerable difference to those of a conventional fossil plant.
The licensee responded that he has issued instructions to Brown and Root to reduce the labor crew size reporting to foremen and the number of crews reporting to general foremen.
The licensee stated that it is expected that this will provide increased control over the quality affecting actions of the labor force.
3.
Sumary of Licensee Performance The Region IV Director, at the conclusion or the meeting, emphasized that the licensee has the principal and legal responsibility for all matters regarding the construction and operations of a nuclear power plant as specified in the law and in the Regulations.
Corporate management is essential in all phases of the project to assure appropriate execution of the licensee's responsibilities.
The licensee responded that he is aware of his responsibilities and that in response to these responsibilities, he continuously increased his involvement in the project during the past three years until he is now essentially in cceplete control of the project except for the immediate line supervision of ne labor force.
The licensee indicated that as new or additional involvement becomes necessary, he will respond accordingly.
. The Director stated that the region's evaluation of the licensee per-formance is that it is generally acceptable although continued improve-ment in certain areas, already discussed, would certainly be desirable.
The Director stated that, on the basis of the evaluation, Region IV does not currently see a need to make any adjustments in the IE inspection program as it relatas to the Comanche Peak facilities.
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APPENDIX 3 LICENSEE PERFORMANCE EVALUATION (CCNSTRUCTICN)
Facility:
Comanche Peak Steam Electric Station Licensee:
Texas Utilities Generating Ccmoany Unit Icentification:
Docket No.
CP No./Date of Issuance Unit No.
50-145 CPPR-126/ December 19, 1974
50-446 CPPR-127/ December 19, 1974
Reactor Information:
Unit 1 Unit 2 Unit 3 NSSS Westinghouse Westinghouse-0-MWe 3411 3411 Aopraisal Period:
August 1, 1979, through July 31, 1980 acoraisal Ccmolation Date:
Cctober 2, 1980 Review Boarc 'demaers:
W. C. Seidle, Chief, Reactor Construction & Engineering iupcor Branch, RIV W. A. Crossman, Chief, Projects Section, RIV R. E. Hall, Chief, Engineering Supcort Section, RIV R. G. Taylor, Senior Resident Reactor Inspector (CPSES), RIV
'. C. Stewart, Reactor Inspector, Projects Section, RIV S. 3. Surwell, Project Manager, NRR*
- NF.R Project Manager was contacted in regard to panel review, but did not have comment and did not atten APPENDIX B
A Numcer ano Nature of Noncemoliance Items Noncomoliance Category:
Unit 1 Unit 2 Unit 3 Violations
0 Infractions
8 Ceficiencies
4 Areas of Noncomoliance:
Unit 1 Unit 2 Unit 3 (List Areas as Required)
(Points)
(Points)
(Points)
QA/ Management
10 Piping and liangers
42 Electrical Equipment
4 Electrical Cable / Tray
30 Reporting
Total Points 136
B.
Numoer and Nature of Ceficiency Recorts 1. Scacing of Concrete Anchor Bolts 2. QA of Welded Conduit Supoorts 3. 0A of Feismic I (NNR) Pipe Supports 4. Honeyc0mb of Unit 2 Containment Interior Walls 5. Ancnorage of Main Control Boards 6. Material in Service Water System Yalves C.
Escalated Enforcement Actions Civil Penalties None Orcers None
'.mmeciate a tion Lettars c
Sectemoer 7,1979: Omission of Unit 2 Containment Shear Ties
APPENDIX B
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D.
Manacement Conferences Held Curinc Past Twelve Mentns Aoril 8,1980:
Discuss 50.55(e) Reporting Requirements E.
Justification of Evaluations of Functional Areas Catecarizec as Recuirinc an Increase in Inscec:1cn.;recuency/Sccoe (see evaluation sneet; The review board considered an Increased Inspection Frequency and/or Scoce for Items 6 (Piping & Hangers) and 9 (Electrical - Tray & Wire) since they represented the most dominate proclem areas encountered during the past year.
The board reviewed the IE inspection history and determined that most of the enforcement actions in these areas had occurred relatively early in the review period and that the licensee's actions acceared to have been effecti ve.
On this basis, tne board determined tnat an increase of inspection and/or scope was not warranted at this time.
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APPENDIX B
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Inscection Frecuency and/or Sccce FUNCTIONAL AREA INCREASE NO. CHANGE CECREASE 1.
Quality Assurance, Management & Training X
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Substructure & Foundations (ccmolete)
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Concrete y
Liner (Containment & Others)
(ccmolete)
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Safety 3 elated Structures X
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Piping & Hangers (Reactor Ccolant
& Others)
X*
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Safety-Related Ccmoonent.s (Vessel, Internals & HVAC)
X 3.
Electrical Ecuipment x
9.
Electrical (Tray & Wire)
X*
10.
Instrumentation X
11.
Fire Protection X
12.
Preservice Inspection X
13.
Reporting X
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'See Item E for discussion of these items