ML20087B037

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Describes Commitments Made to NRC in Rj Gary 830928 Response to Notice of Violation & Proposed Imposition of Civil Penalty
ML20087B037
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 11/29/1983
From: Clements B
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To: Jay Collins
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20087B027 List:
References
FOIA-84-2 EA-83-064, EA-83-64, NUDOCS 8403080332
Download: ML20087B037 (11)


Text

e-2 w-TENAS t Fil.lTIES GENERKilNG COMPANY 2001 BM AN TO% EM DAILAh. TF XAb ??-20:

BsLLY R CLEMENTS

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November 29, 1983 i

DEC -2198 S.,

Mr. John T. Col 1 ins L__..__..

Administrator U.S. Nuclear Regulatory Commission Office of Inspection and Enforcement, Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011

Dear Mr. Collins:

As you know, Mr. R. J. Gary made eight commitments to the NRC in his September 28, 1983 letter of response to the Notice of Violation and Proposed Civil Penalty in Enforcement Action (EA) 83-64.

Please find attached a list of those commitments and their status.

If you have any questions, please do not hesitate to call me.

I Sincerely, 9

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BRC:kh At t achment c:

R. J. Gary i

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- e November 14, 1983 i

i COMMITMENTS MADE TO NRC IN R. J. GARY'S LETTER OF RESPONSE TO NOTICE OF VIOLATION AND PROPOSED CIVIL PENALTY IN EA No. 83-64 DATED SEPTEMBER 28, 1983 Connirment 1.

Licensees are developing an audiovisual This audiovisual presentation program to reemphasize the commitment to has been completed and is quality at Comanche Peak. The program currently being shown to all will stress that quality is the business personnel associated with the of everyone at Comanche Peak, that all Comanche Peak project. This QA/QC personnel are required to report initial phase will be complete by the end of December, 1983.

nonconforming conditions, and that no interference (such as harassment) with The viewing of this presentation proper performance of QA/QC functions will continue to be a requirement at Comanche Peak will be tolerated.

for new employees.

Individuals involved with quality-related work at Comanche Peak (including QC inspectors and craft) will be required to view this program. The program will continue throughout the duration of construction. All current and future cuployees will be required to view the pr Tram. Licensees intend to complete the 9scablishment of the program by Decemb r.

2.

Licensees' management has met and will be The Vice President, Nuclear meeting with selected personnel at has met with the construction Comanche Peak to emphasize its rea:mitment supervisors to emphasize to quality. During the meetings manage-management's strong commitment ment will stress that it will continue to to quality.

He stressed the implement an effective QA/QC program at need to continue maintaining-Comanche Peak.

It will further re-emphasize quality as the highest priority.

that the quality of plant construction has These were introductory comments been and always will be of the highest to 'a viewing of the presentation priority.

discussed above.

Furthermore, the Manager,' Quality Assurance made the same presentation to the QA/QC Supervisors.

This commitment is considered closed, s

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Licensees' management will re-emphasize during This commitrent.i.s being these meetings, as well as through other means met via the audiovisual described below, its desire that all employees presentation and with bring their cor.cerns regarding quality matters posters and paycheck to Licensees for resolution.

Toward that end, attachments. The various Licensees will seiterate for their employees aspects of this commitment and their contractors' employees the numerous ill continue to be stressed of ficial channels available to them for doing new employees arrive.

so.

These channels include:

a.

QA/QC inspectors; b.

QA/QC supervisors; c.

construction management; and d.

Texas Utilities Generating Company management.

Licensees will continue to emphasize to employees and their contractors' employees that they are required to bring quality assurance concerns to Licensees' attention and that no adverse conse-quence with respect to the terms and conditions of their employment will be tolerated due to their identification of problems.

Finally, employees will be advised that they are free, as always, to contact NRC regarding quality assurance matters.

4.

Licensees are initiating a program to The equipment has been encourage the immediate reporting of quality installed and is operational.

concerns.

Employees will be able to voice The program has been developed anonymously their concerns with quality at and implemented.

This will Comanche Peak via a telephone ccatact. The be a continuing program and telephone will be answered 24-hours a day by the commitment is considered designated individuals or by an automatic closed.

recorder.

Licensees' personnel with sufficient authority and resources to assure resolution of any matters affecting quality will review all concerns identified by this means.

Appropriate records will be maintained as to the disposition of concerns identified.

i 5.

Licensees will remind employees in writing of These paycheck attachments Licensees' commitment to quality at are presently being dis-Comanche Peak and of management's encourage-tributed and this action ment of prompt identification of concerns should be complete by mid-regarding quality. This written reminder December, 1983. Also, full will be given to Comanche Peak employees pa'ge newspaper ads have with their paycheck. Licensees are also been placed which emphasize considering other means of re-emphasizing to the entire public the to employees Licensees' commitment to Licensee's commitment to quality.

quality.

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Licensees will post new notices throughout This action has.been the plant encouraging employees to bring completed.

j to their attention any concerns regarding quality. These notices will reiterate the available means for doing so, as i

described above.

7.

Licensees will initiate a program to This program has been ensure that all QA/QC employees are given implemented and this i

the opport.anity to state concerns regarding action is considered quality prior to disassociation with the closed.

QA/QC department. Stated concerns will be evaluated and dispositioned by Licensees.

l 8.

Licensees will counsel selected QA/QC This action has been personnel on employee relations and the completed but will be a need to accommodate considerations of continuing program.

both labor law and atomic energy law, recognizing that the overall objective is construction and operation of a j

safe power reactor.

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Nove=.be r 29, 1983

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Mr. John T. Collins Adniniatraror U.S. Nuclear Regulatory Cocaission office of inspeerion and Enforcement. Ecgion'TV e

611 Byen Plaza Drive. Suite 2000 Arlington. Texas 76031 Dest Mr. Collins:

As you know. Mr. R. J. Gery cade eight cecenitments to the KRC in his Septe=ber 28,

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30E3 3etter of response to the Notice of Violation and Proposed Civil Pensity in Enforcement Action (EA) E3-64.

t h o se. cc=r:itr-en:s and their status.

Please find at.tached a list of lf ynit have any spiestinns, p1rane rin nnt hesitate tn call ne.

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$lacerely, -

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I, BRC:kb Attach =wnt c:

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  • r Neverber 14, 1963 5

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C0v.I~r3.TS PJ.DE To NRC IN R. J. CAEY ' S LETTE"r' OF F.T.5?ONSE TO R:TIICE OT VIOLATIDX AND pP.0?CSED CIVIL PD(ALTT IN EA lto. 8.b-64

'i DATED SEPIDGER 28, 1983 3

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i t':nen t 0:

1.

Licensees are developing an audiovisual-Tnis audievirusi presentation j

program to ree=phasize the coesitnent to has been co=pleted and is i

quality at Co,t.nche Peak.

The program ~

currently being abovu to all will s' tress that quality is the business personnel Essociated with the 8

of everyone at Oscacche Peak, that all cocenche Peak project, this QA/Qc parcemw2

. wla-J Lu.. p... t hM al tha* v411 Iw' red et a as.

l nutre enis esi mi ng. nul61vu,.mJ.t.m e,y

. We viewing of this presentatloa L

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in:crference (such as haraswawut) wlLL proper perforuance of QA/QC functions will centinue to be a requirement 4t C a nche Peak vill be tolerate 3.

for new e..ployees.

4 Individuals involved v_ith quality-i related work at ccamache Peak (including.

]

QC inspectors and craft) will be i

required to view this prosrau.

The

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1 progrem vill continue throughout'.the I

duration of constructien.

All current

.i-end futura enployees vill be required to view the progrem.

Licensees intend to ec=plete the establishment of the

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progrcra by December.

J 2.

Licenaces ' menatement has met s'nd will be The vice 'tresident, & clear I

meetinr, with selected personnel at has eet with the construction!

Ca ar.zhe De ah ta assykocino ite ce==itment cu pov=vi n nrn to cephaciso to quality, puring the rrw crings r Anage-rr.anagerw nr ' n a r rnng coe.witwent l

went will stress that it vill edntinuo to to quality.

He = tressed the ireplem.n t an ef fective QA/QC proEra:a at need to continue tsmintairdz:g Comanche Peak.

It will further re-emphasize quality as the highest priority.

that the quality of pleet construction has nese were intreductory ce=nents been and always will be of the highest to a viewing of the presentation i

priority, discussed above. Furthermore, t'ha Manager. Quality Assurance made the sacac presentation to the QA/QC Supervisora. This co.z:zitment is considered closed.

e e.

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Lice =rees' inanage ent will re-c=Fhssiee during nis c M s_:t'.is bei=s Il!

t these meetings, ce well as throu;h other maans met via the;e.udievisuci

'.3i described belev, its desire that all e=ployeen presentstien and with

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bring their conearns regarding quality matters posters and psycbeek

,i 1 to Licensees for resolution.

Toward that end.

e.t ta chmen t s.

The various

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Licensees will reiterste for their ecployees e spects of this ce==itme=t and their contracters' e=ployees the numerous vili centinue to ha streased I

official channels available to the= for doing as new e=pleyees errive.

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so.

These channels includa:

j a.

QA/QC inspectors; b.

QA/QC supervisors; construction managements and c.

d.

Texas Utilities Centrating Co=pany management.

Licensees will centinue to emphasize to employees and their contractors' e=ployees that they-are required to bring quality assurance concerns to Licensees' attention and that no adverse conse-quence with respect to the tarm.a and conditions of their e= ploy nent will-be tolerated due to their identification.of problems.

Finally, e=ployees will be advised ~tbat they arc free, as always, to contact NRC regarding quality ce=urance matters.

4.

Licensees are initiating a pregram to The equipser.t has been encoursEe the in: mediate reperting of quality installed cud is operational.

concerna.

En.ployees will be able to voice he program'has been developed anony:sously their concerns with quality at and implemented.

This will Cor.anche Peak via a telephone contact.

The be a continuing program and telephone vill be answered 24-hours a day by the coccLitment is considered desiEnated individuals or by an auto =atic closed.

recorder.

Licenseas' personnel with s6fficient authority and resources to assure resolution of any esttera affecting quality will review all concerns identified by this means.

Appropriate records vill be maintained as to the disposition of concerns identi fied.

j S.

Licensees vill remind e=ployees in writing of These paycheck attachments Licensees' coce:itment to quality at are presently being di,-

Comanche Peak and of management's encourage-tributed and this action ment of pro =pt identification of concerna should be complete b~y mid-regarding g r.lity.

This written reminder Leeember, 1983. Also, full vill be g' ven to Conanche peak e=ployees pa'ge newspaper ads have with their paycheck.

Licensees are also been placed which emphasir.e considering other means of re-en:phasizing to the entire public the to ceployees Licensees' co=mitzent to Licensee's ec.=mitment to quality.

quality.

ewe e.

I

=~

6.

Licensees will post'nev notices throughout This action hat..bcen the plant encouraging et=ployees to bring ce=picted..

to their attention any eencerns re;;;cedka:

quality.

These notices vill reiterate the svailable asses for doing so, as dcacribed abeve.

7.

7 icenne.e will initiate a. progrs= to This progr.m bag been annure that all QA/QC c=:picyses are given i=ple=ented and this the opportunity to state concerns regarding action it considere.d quality prier to disassociation with the closed.

QA/QC department.

stated concerns vill be.

cvaluated and dispositioned by 1.icenseen.

B.. Licensees will counsel selected QA/Q:

This action has been perennnel nn employee reistions and the' ce=pleted but will be a nr.ed to acce==odete considerations of continuing progre:a.

both labor law and atomic energy Irv, recognizing that the-overall objective is construction and Yperation of.

safe power reactor.

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(j3 December 12, 1983 I

COMMITMENTS MADE TO NRC IN R. J. GARY'S LETTER OF RESPONSE TO NOTICE OF VIOLATION AND PROPOSED CIVIL PENALTY IN EA NO. 83-64 DATED SEPTEMBER 28, 1983 Commitment 1.

Licensees are developing an audiovisual This audiovisual presentation program to reemphasize the commitment to has been completed and is quality at Comanche Peak.

The program currently being shown to all will stress that quality is the business personnel associated with the of everyone at Comanche Peak, that all Comanche Peak project. This QA/QC personnel are required to report initial phase will be complete nonconforming conditions, and that no by the end of December, 1983.

interference (such as harassment) with The viewing of this presentation proper performance of QA/QC functions will continue to be a requirement at Comanche Peak will be tolerated.

for new employees.

Individuals involved with quality-related work at Comanche Peak (including QC inspectors and craft) will be required to view this program.

The program will continue throughout the duration of construction.

All current and future employees will be required to view the program. Licensees intend to complete the establishment of the program by December.

2.

Licensees' management has met and will be The Vice President, Nuclear meeting with selected personnel at has met with the construction Comanche Peak to emphasize its commitment supervisors to emphasize to quality. During the meetings manage-management's strong commitment ment will stress that it will continue to to quality.

He stressed the implement an effective QA/QC program at need to continue maintaining Comanche Peak.

It will further re-emphasize quality as the highest priority.

that the quality of plant construction has These were introductory comments been and always will be of the highest to a viewing of the presentation priority.

discussed above.

Furthermore, I

the Manager, Quality Assurance made the same presentation to

{

the QA/QC Supervisors.

This commitment is considered closed.

4 G9 W

1 l

ls' i

2.

Licensees' canagement will re-emphasize during This co=niement is being these meetings, as well as through other means met via the audiovisual described below, its desire that all employees presentation and with bring their concerns regarding quality matters posters and paycheck to Licenseer for resolution.

Toward that end, attachments.

The various Licensees will reiterate for their employees aspects of this co==itment and their contractors' employees the numerous vill continue to be stressed official channels available to them for doing as new employees arrive.

so.

These channels-include:

~

a.

QA/QC inspectors; b.

QA/QC supervisors; c.

construction canagement; and d.

Texas Utilities Generating Company management.

Licensees will continue to emphasize to employees and their contractors' employees that they are required to bring quality assurance concerns to Licensees' attention and that no adverse conse-quence with respect to the terms and conditions of their employment vill be tolerated due to their identification of problems.

Finally, e=ployees will be advised that they are free, as always, to contact NRC regarding quality assurance matters.

L.

Licensees are initiating a program to The equipment has been encourage the immediate reporting of quality installed and is operational.

concerns.

E=ployees vill be able to voice The program has been developed anonymously their concerns with quality at and implemented.

This vill Co=anche peak via a telephone contact.

The be a continuing program and telephone vill be answered 24-hours a day by the com=itment is considered designated individuals or by an automatic closed.

recorder.

Licensees' personnel with sufficient authority and resources to assure resolution of any matters affecting quality will review all concerns identified by this means.

Appropriate records will be maintained as to the disposition of concerns identified.

5.

Licensees will remind employees in writing of These paycheck attachments -

Licensees' com=itment to quality at are presently being dis-Comanche Peak and of management's encourage-tributed and this action ment of pro =pt identification of concerns should be complete by mid-regarding ouality.

This written reminder De ceriber, 1983.

Also, full pa'e newspaper ads have vill be given to Comanche Peak employees g

with their' paycheck.

Licensees are also been placed which emphasize censidering other means of re-e=phasizing to the entire public the l

te e=ployees Licensees' com=itment to Licensee's cam =itment to quality.

quality.

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l 6.

Licenseer will post new notices throughout 8"xil" posters have been the plant encouraging employees to bring placed in various locations to their attention any concerns regarding around the. plant. Larger cuality.

These notices will reiterate and more permanent notices the available means for doing so, as are being made and should described above.

be in place by mid-January.

7.

Licensees will initiate a program to This program has been ensure that all QA/QC employees are given implemented and this action the opportunity to state concerns regarding is considered closed.

quality prior to disassociation with the QA/QC department.

Stated concerns will be evaluated and dispositioned by Licensees.

S.

Licensees will counsel selected QA/QC The Manager, Quality personnel on employee relations and the Assurance counseled all need to accommodate considerations of QA/QC supervisory personnel both labor law and atomic energy law, on these topics.

This recognizing that the overall objective action is considered closed is construction and operation of a but will be a continuing safe power reactor.

program.

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