ML20052A497
| ML20052A497 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/17/1980 |
| From: | Crossman W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Hubacek W, Stewart R, Renee Taylor NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20052A488 | List: |
| References | |
| NUDOCS 8204280391 | |
| Download: ML20052A497 (8) | |
Text
f? " %'o,3
.-).,
,, / c..
/
UNITE D ST ATES CASE ATTACHMENT A - Page 19-
' 8 y,.,.,f *l j NUCLE AR REGULATORY COMMISSION t
REGION IV Q, A k!!!4
[
611 RY AN PL AZ A DRIVE, $UITE 1000
%,
- e [f Anunctos TEXAS M012 es.
January 17, 1980 MEMORANDUM FOR:
W. G. Hubacek g
R. C. Stewart R.
G. Taylor C. R. Oberg H. S. Phillips.-
FROM:
W. A. Crossman, Chief, Proj ects Section
SUBJECT:
TREND ANALYSIS - 1979 Please perform a trend analysis of the performance of each of your assigned " active" licensees for the calendar year 1979.
Your analysis should include the following information:
a.
Number and Repetitiveness of Construction Deficiency Reports b.
Enforcement History For each facility list:
(1)
Inspection Report Number (2) Dates of Inspection (3) Number of Violations (4) Number of Infractions (5) Number of Deficiencies (6)
Number of Deviations (7) Mandays involved (for that inspection)
(8) Remarks (indicate if repeat from 1978 and 1979)
(9) Number of unresolved items c.
Responsiveness of Licensee to Enforcement Action
'(1)
Is licensee on time with answer to our letter?
(2) Are answers adequate?
Do we have to go back for more information?
(3) Are any inadequate answers our fault?
(4)
Is corrective action done promptly?
(5)
Is the licensee responsive?
d.
Unresolved Items (1) Are unresolved items cleared rapidly?
(2) Are nu=bers/ inspection on the increase? Why?
(3)
Number of unresolved items escalated to enforcement items.
820428o3eq
~~
~
CASE ATTACHMENT A - Page 20 Inspectors - Proj ects Section January 17, 1980 e.
Corocrate Management Involvement in Reculation Matters (1)
Sufficient management representation at exit interviews?
(2) Attit'ude receptive?
(3)
Signature on licensee letters appropriate level?
(4)
Is management involved?
(Indicate basis for answer) f.
Effectiveness of OA/OC Program This is a very subjective matter.
I desire your own opinion and basis for your opinion.
If too early in construction phase to state, indicate this.
Also indicate what you believe we can do to have them improve their program.
This information should not be' included in the documented analysis, but yoit should be prepared to discuss it with Mr. Seidle.
g.
Any Other Trends Indicative of Poor Performance List and discuss any other indications that may point out poor / good performance.
Please have your information to me by COB on February 15, 1980.
& /, ) W N p k'.
A. Crossman, Chief ProjectsSection I
cc:
k'.
C. Seidle 4
e
n m
CASE ATTACHMENT A - Page 21 Comanche Peak, Units 1 6.2 DN 50-445; 50-446 TREND ANALYSIS - 1979 f
c.
Number and Repetit'iveness of Construction Deficiency Reports t
(1) Two items were officially categorized by the licensee as 50.55(e) items.
(2) The two item's did not appear to be repetivie.
b.
Enforcement History (See attached sheet) c.
Responsiveness of Licensee to Enforcement Action (1) The licensee has generally been on time with his response to letters
.and when,he has not been able to do so, he has informed us promptly.
(2)
The response letters are generally adequate as forwarded to,the office.
The licensee site QA personnel usually coordinate the answer with me prior to sending it to the office.
(3) Any unsatisfactory answers given are not usually the licensee's fault,..
but also not necessarily our fault either in terms of the way the noncompliance is written.
It is primarily a matter of our wanting something a bit stronger for the record.
(4) My experience has been that the promised actions have been implemented by the dates promised.
(5) The licensee has been generally responsive to our. findings.
d.
Unresolved Items (1) Unresolved items have gotten a bit out of hand since they are not being worked off very rapidly.
I have been promised increased attention will be paid to them.
4 (2) The numbers of unresolved items are on the increase, but I view this as normal at this stage of construction since they are now well into every aspect of the construction and this will naturally lead to more questions on our part that the licenser does not readily have available answers for.
4 s e*
~
CASE ATTACHMENT A - Page 22 c.
' Comanche Peak, Units 1 6 2
'2-r
)
(3) No unresolved items were escalated to enforcement items in 1979.
e.
Corporate Management Involvement in Regulation Matters (1) The licensee always has.enior site management available for the various interviews.
(2) The licensee sends all letters to us signed by the legally responsible company officer.
(3) The site management appears very responsive to our inspection findings.
(4)
It is my impression, based on discussions with the licensee's two Executive Vice-Presidents most involved with the construction phase, that they are very involved and knowledgeable of our inspection findings.
f.
Effectiveness of QA/QC Program This item seems to need addressing in two parts to be effectiver Part one is the overall theory of Quality Assurance as a management tool.
In this area, I believe that the licensee has been led down,a poor path by Brown & Root during past years.
It appears to me that B;own & Root has, in many instances, provided construction procedures to fulfill Appendix B that provide a minimum amount of direction to the construction force and yet comply to the words, if not the spirit of Appendix B.
This is not too bad if the construction force is really a competent group but leads to some pretty bad things if that is not the case.
What I have begun to see, but.have difficulty proving, is that the Brown & Root construction philosophy is to build something any way they want to and then put it up to the engineer to document and approve the as-buil t condition.
If the engineer refuses, he is blamed for being to conser-vative and not responsive to the client's needs.
Thus the driving fo.rce force behind my request for a special engineering audit of site operations.
The second part of the addressment is to that phase called QC.
Only recently has there been a real effort on the part of the licensee itself, or on the part of Brown & Root, to write explicit instruction to the line inspectors on what they were to inspect.
Previously, the procedures were frequently pretty general, again not too bad if the inspectors are knowledgeable in the subject being iaspected but terrible if they are not.
In a couple of cases, I have been able to show them that their people are essentially incompetent even though they had been through the site training and had been certified as competent.
I see a desire on the part of the licensee to turn this situation around in the important areas of' electrical and piping installation.
However, the situation discussed above has a bearing since too often an installation clearly accomplished other than as originally designed and buildable has been approved by the licensee's on-site engineering arm as ful-filling requirements.
In effect, the engineer has approved a non. con-e forming installation in advance of QC being called.
QC is then signing for the as-built condition and the underlying problem is not addressed.
O, CASE ATTACHMEf4T A - Page 23 Comanche Peak, Units 1 & 2 '
I'm not at all sure that what CPSES is doing in this area is very different than what other utilities and/or engineers have done on other i
projects but I don't like it.
I believe that much the same thing went on in Bechtel at ANO-2, but it wasn't as obvious nor was I there as much.
g.
Any Other Trends Indicative of Poor Performance I don't see any other problem not discussed above except possibly a,
future development in the public relations arena.
It seems likely to me that the licensee will use his full powers to be less open with us in the area of identified construction deficiencies than he has in the past.
I think he will take maximum advantage of part 50.55(e) and the guidance to go through the necessary formalities but avoid, if at all possible, having to report to us.
It is, of course, premature to really get into this arena until we prove a case.
e b
4 0
4 9
.O
_e_
m
,y
TREND "'ALYSIS - 1979 COMANCHE PEAK INSPECTION REPORT SLDNARY
=r DN 50-445; 50-446 N
4 S
i f
REPORT DATES V.
I DF DV M/D RRI RCL RUT INV REMARKS
-U t
79-01 1/2-31 0
0 0
0 11.4 X
X 1
79-02 1/8-10 0
0 0
0 8.6 X
X 0
$5 Q
79-03 2/1-28 0
1 0
0 9.4 X
X 0
79-04 2/5-8 0
1 0
1-10.9 X
X 1
- E$
79-05 2/13 0
0 0
0 N/A Granbury Town Officials Meeting 0
79-06 3/1-30 0
1 0
0 10.0 X
X 1
79-07 3/8-13 0
0 0
0 5.8 X
X 2
79-08 3/26-29 0
0 0
0 4.0 X
X 1
79-09 4/5-5/7 0
0 0
0 18.6 X
X 0
79-10 4/6-6/1 0
0 0
0 4.2 X
X 0
79-11 4/2-23 0
1 0
'O 4.9 X
X 0
79-12 4/12-7/20 0
0 0
0 1.9 X
X 0
79-13 5/14-31 0
0 0
0 7.0 X
X 2
79-14 5/15-18 0
0 0
0 3.5 X
X 0
79-15 5-29-6/4 0
0 0
0 3.5 X
X 0
79-16 6/1-29 0
0 0
0 8.8 X
X 2
79-17 7/9-31 0
0 0
0 3.8 X
X 0
79-18 8/1-9/24 0
2 2
0 18.4 X
X 1
2 79-19 8/8-16 0
1 0
0 11.5 X
X 1
V wtolation I-Infraction DF-Deficiency DV-Deviation RRI=RRI Report RCL= Regional Report RbT= Routine INV-Investigation
j ll1
!lll11 l!l j
2 n
f r
i o
U t
0 0
0 2
1 1
1 1
1 1
0 0
a 2
g i
2 t
g s
e e
j vn I
g n
V i
N t
I eeM en t
i n
t e
u m
o e
R g
=
a T
n U
a R
M s
t n
r o
D; i
p S
t e
K a
R R
r A
e l
M p
a Y
E O.
n R
R o
A ig 10 e
F U
V R
S N
X X
X
=
I L
T C
R R
OP T
X X
X X
X X
X x
U E
6 t
R 4
r R
4 s
p N
O 0
le L
k I
5 X
X X
X X
x i
C T
R I
C E
5 R
P 4
R
=
S 4
I I
R X
X X
X X
R N
I 0
R B
5 K
5 A
N 1
8 6
2 1
9 6
3 4
9 0
2 s
E D
D o
P
/
3 1
4 3
8 1
1 0
0 6
2 8
i_
M 1
1 1
t E
a ll i
C v
N e
A V
0 0
0 0
0 0
0 0
0 0
d 0
D M
D
=
O V
C D
F 0
0 0
0 0
0 0
0 0
0 0
0 tz D
cn i
e i
c 0
0 0
0 0
0 0
2 1
0 0
1 i
I f
e D-F 0
0 0
0 0
0 0
0 0
0 0
0 D
V n
9 o
7 i
9 t
b c
1 4
8 3
a 1
1
/
2 8
/
/
0 1
9 1
0 3
1 1
s r
f 9
0 1
3 1
3 1
3 1
S 1
1 7
2 n
I S
I 5
9 2
9 3
1 1
4 1
1 1
S E
=
1 2
7 2
/
/
/
/
/
/
/
H Y
T I
/
/
/
/
0 0
0 1
2 2
2 L
A 8
8 9
9 1
1 1
1 1
1 1
l A
D N
n A
o i
D T
0 1
j
}
/3 g
g f
g g
0 t
3 R
a N
2 2
j
}
3
}
j
}
}
j 3
O E
g g
g g
g g
9 8
i l
P R
9 9
g g
o E
T 7
7 J
}
3 3
3 J
j J
7 1
V H
V Aj
~
j o'
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION *
'82 tv,,22 ei<,.
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD if. _
In the Matter of I
^*
I APPLICATION OF TEXAS UTILITIES I
Docket Nos. 50-445 GENERATING COMPANY, ET AL. FOR AN I
and 50-446 OPERATING LICENSE FOR COMANCHE I
PEAK STEAM ELECTRIC STATION I
UNITS #1 AND #2 (CPSES)
I i
CERTIFICATE OF SERVICE By my signature below, I hereby certify that true and correct copies of CASE's 4/20/82 Motion for Additional Time for Discovery on Contention 5 have been sent to the names listed below this 20 th day of Aprii i
1982, by:
Express Mail where indicated by
- and by tirst class mail elsewhere.
- Administrative Judge Marshall E. Miller David J. Preister, Esq.
j U. S. Nuclear Regulatory Commission Assistant Attorney General Atomic Safety and, Licensing Board Panel Environmental Protection Division Washington, D. C.
20555 P. O. Box 12548, Capitol Station Austin, TX 78711
- Dr. Kenneth A. McCollom, Dean Division of Engineering, Architecture, and Technology Oklahoma State University Stillwater, Oklahoma 74074
- Dr. Richard Cole, Member Atomic Safety and Licensing Atomic Safety and Licensing Board Board Panel U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission Wuhington, D. C4 20555 Washington, D. C.
20555
- Nicholas S. Reynolds, Esq.
Atomic Safety and Licensing Debevoise & Liberman Appeal Panel 1200 '17th St., N. W.
U. S. Nuclear Regulatory Commission Wtshington, D. C.
20036 Washington, D. C.
20555 j
- Marjorie Ulman Rothschild, Esq.
Docketing and Service Section Office of Executive legal Director Office of the Secretary U. S. Nuclear Regulatory Commission U. S. Nuclear Pegulatory Commission Washington, D. C.
20555 Washington, D.
C.
20555 i
kJ Ca
[ CASE
.rs.) Juanita Ellis, President (CITIZENS ASSOCIATION FOR SOUND ENERGY) t