ML20136B715
| ML20136B715 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/11/1983 |
| From: | Wisner C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20136B196 | List:
|
| References | |
| FOIA-84-779 PR-831011, NUDOCS 8511200271 | |
| Download: ML20136B715 (1) | |
Text
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"% UNITED STATES
![m 'g s NUCLEAR REGULATORY COMMISSION l
oAgg E OFFICE OF PUBLIC AFFAIRS, REGION IV
\> [ + 611 Ryan Plaza Drive, Suite 1000, Arlington, Texas 76012 i
RIV: 83-60 FOR IMMED,IATE REtEASE
Contact:
Clyde E. Wisner (Tuesdan October 11,1983)
Telephone: 817/860-8128 (Office)
~
817/571-9907(Home)
NRC RELEASES COMANCHE PEAK NUCLEAR PLANT INSPECTION REPORT 83-27 The Nuclear Regulatory Commission's latest report for the Texas Utilities Ger.erating Company's Comanche Peak nuclear plant, near Glen Rose, Texas, has been released to the public document rooms tocay according to John T. Collins, Regional Administrator of the NRC's Region IV office in Arlington, Texas.
The NRC report, numbered 83-27, details an inspection conducted at the 1 TUGC0 nuclear facility during the period of May 10 through July 1, and September 9-22, 1983. Areas examined during the inspection included a detailed review of seven alleged improper construction practices expressed by Robert L. Messerly and an allegation received from an individual, who requested confidentiality, that a former Brown & Root millwright had drilled holes through rebar without the required engineering approvals. All items involved in this inspection were the result of allegations made to the NRC. Within these areas, the inspection consisted of selective examination of procedures and representative records, interviews with licensee and contractor personnel, and observations by the inspector. Five of the seven allegations regarding improper construction practices expressed by Messerly were found to be unsubstantiated by the facts gathered by the inspector. The allegation about improper documentation was found to be substantiated, however, the error was properly corrected by the ;
licensee. The seventh allegation involving the posting of a required NRC form l cn prominently located bulletin boards could neither be refuted nor substantiated.
Within the scope of the inspection, no violations of or deviations from f NRC regulations were identified. '
In accordance with NRC regulations, a copy of the inspection report has been placed in the principal Comanche Peak NRC Public Document Room located in the Somervell Ccunty Public Library on the square in Glen Rose, Texas, and in 1 the mini-PCR located in the University of Texas at Arlington Library in Arlington, Texas.
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TEXAS UTILITIES GENERATING COMPAhT ns KYWAY TOWER
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January 23, 1984 TXX-4099 Mr. Richard C. DeYoung, Director
~ Office of Insoection & Enforcement U. S. Nuclear Regulatory Commission Docket Nos.: 50-445 Washington, DC 20555 50-446 RESPONSE TO NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY EA 83-132 FILE NO.: 10130 and 00897
Dear Mr. DeYoung:
On December 22, 1983, the NRC Staff (Region IV) issued a Notice of Violation and Proposed Imposition of Civil Penalty to Texas Utilities Generating Company, et al. (" Licensees") for an alleged violation of 10 C.F.R. Part 50, AppeFdiTB, Criterion I. Pursuant to 10 C.F.R. 5 2.201 ;
and 2.205, Licensees respond to the Notice of Violation and Proposed Imposition of Civil Penalty in the attachments hereto.
As set forth in the attached responses, Licensees deny the alleged violation and resDectfully request that the Notice of Violation and Proposed Imposition of Civil Penalty be withdrawn. Alternatively, Licensees submit.that the proposed civil penalty should be mitigated in its entirety. ,
Licensees regard this enforcement action as a matter of major concern, .
not just because of the seriousness of the allegations made by the NRC Staff but also because of the adverse and unfair impact the enforcement action has already had on the public perception of Licensees' commitment to quality. This is particularly troublesome because Licensees have always actively sought to ensure that all persons performing quality functions have sufficient organizational freedom to perform their jobs, as required by Appendix B, Criterion I.
Beyond this, Licensees have recently taken responsive actions within all levels of their organizations and their contractors' organizations at Comanche Peak to reaffirm their commitment to a strong quality assurance program. Tnese actions included development of an audiovisual program to reemahasize the commitment to quality at Comanche Peak, which -
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indivicuals involved with cuality relatec work (including QC inscactors and craft) are required to view; management meetings with selected personnel I to empnasize its commitment to quality; the establishment of a telephone .
" hot-line" in wnich employees are able to voice anonymously their concerns I with ouality at Comanche Peak; written and posted reminders encouraging employees to bring to the attention of Licensees any concerns regarding quality; and the counseling of selected QA/QC personnel on employee relations and the need to accommodate considerations of both labor law and atomic energy law, recognizing that the overall objective is the construction and operation of a safe power reactor.
These and other actions were initiated before the Notice of Violation and Proposed Imposition of Civil Penalty was issued in this proceeding, and NRC was advised of them in Licensees' Septemoer 28, 1983, Response to Notice of Violation and. Proposed Imposition of Civil Penalty in EA No. 83-64. Yet, tne instant enforcement action was apparently taken without any recognition of Licensees' earlier responsive actions.
Licensees also find the Notice of Violation and Proposed Imoosition of Civil Penalty troublesome because it was not issued in a timely manner. As revealed in the Report of Investigation prepared by the
- Office of Investigations Field Office, Region IV, the NRC inquiry into the alleged violation of Appendix B, Criterion I began on January 7, 1983, and ended on August 3, 1983. No action was taken on the matter for over four months thereafter. In sum, it took NRC almost one whole year to investigate the alleged violation 4;id to decide on the enforcement action it deemed to be appropriate. During the protracted investigation and lengthy deliberation within NRC, and orior to the Proposed Imposition of Civil Penalty, Licensees had already taken tiie responsible actions described above.
According to a recent presentation by the Staff to the Commission, it takes an average of about ten weeks from the date an alleged violation is discovered to process an enforcement action involving a civil penalty.
The underlying rationale for taking prompt enforcement action, as the Staff recognizes, is to assure that it will have the desired effects on both the licensee against which it is taken and on the industry as a whole. The NRC must cuestion whether the instant enforcement action, based on allecatic #
id and for which resconsive actions kM were tak , will n Finally, Licensees are perplexed that the Notice of Violation and Proposed Imposition of Civil Penalty, as well as the supporting Report of Investigation, do not provide Licensees with the underlying factual bases for this enforcement action. Such information is particularly important because of the critical role human nature and individual t perceptions play in evaluating the circumstances surrounding the alleged -
violation. Licensees have often discussed with the Staff the comolex ~
relationship between managers and employees and how there may oe instances of disagreement between them. Part of the complexity of this relationsnip involves the need to strike a delicate balance between assuring that QC supervisors receive sufficient management backing to enable them to supervise their subordinates while simultaneously assuring that those supenvisors do not adversely influence the organizational freedcm required by QC insoectors to do tneir jobs.
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The NRC Staff claims that Licensees improperly struck the balance in this case. For Licensees to respond to such claim, it is necessary for them to understand the underlying bases for it. This understanding is also essential if Licensees are to evaluate the effectiveness of the actions already taken to reemphasize that quality of construction is of
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$8fr Rather, it is a legal obligation rooted in due
' process' or t1e acministrative system which the NRC must fulfill. The Staff has not fulfilled that obligation here.
In spite of the Licensees' disagreements with the Staff concerning the Notice of Violation and Proposed Imposition of Civil Penalty, Licensees remain firmly committed to reemphasizing that quality in construction remains of foremost importance at Comanche Peak. As discussed above, we believe that our past efforts in this area evidence our total commitment to an effective quality assurance program, and we intend to retain th R total commitment throughout the construction and operation of Comanche r
Peak.
3 Sincerely, RJG:ln j -
cc: Mr. John T. Collins Regional Administrator, Region IV U. S. Nuclear Regulatory Commission Attachments: (1)' Licensees' Response to Notice of Violation (2) Licensees' Answer Protestir.g Civil Penalty .
I hereby swear that the above-stated information and the referenced ~
attachments are true and correct to the best of my knowledge and belief.
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R.(#. Gary
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Subscribed and sworn before me this 14 f day of Od. n u v# ,
1984.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of ) Docket Nos. 50-445 -
) 50-446 TEXAS UTILITIES GENERATING )
COMPANY, et al. ) Permit Nos. CPPR-126 '
1 CPPR-127 (Comanche Peak Steam )
Electric Station) ) EA No.83-132 LICENSEES' ANSWER PROTESTING CIVIL PENALTY On December 22, 1983, the NRC Staff (Region IV) proposed a S40,000 civil penalty in the captioned enforcement action against Texas Utilities Electric Company,1 et al. (" Licensees") for an-alleged violation of 10 C.F.R. Part 50, Appendix B, Criterion I. Pursuant to 10 C.F.R. $ 2.205 Licensees hereby respond to that Proposed Imposition of Civil Penalty.
I. Denial of Violation J For the reasons set forth in Section II of 8
" Licensees' Response to Notice of Violation" (incorporated herein by reference), Licensees deny the alleged violation and respectfully request that the proposed civil penalty be withdrawn in full. Alternatively, Licensees request that for the reasons set forth in Section III of 1 Please note that CPPR-126 and CPPR-127 were amended on December 30, 1983, to re flect the substitution of Texas Utilities Electric Company for Texas Utilities Generating Company as a licensee.
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" Licensees' Response to Notice of Violation" (also incorporated herein by reference), the proposed civil penalty be mitigated in full. )
1 II. Extenuating Circumstances The extenuating circumstances which Licensees believe warrant the withdrawal or complete mitigation of th'e proposed civil penalty are set forth in Section IV, below.
III. Error in the NOV Licensees submit that the Notice of Violation and -
Proposed Imposition of Civil Penalty ("NOV")-is incorrect.
2 First, contrary to the Atomic Energy Act and the NRC Rules of Practice, sped'LitrtyMTilirTdateyt'.raccshaAtar, f e Uf- eQh3t Ni~ts p h @ 4nsea ' - e diaX M Second, t +
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Because of these errors the proposed imposition of a civil penalty is inappropriate.
Failure to Disclose the Basis for the NOV. Section N
234(b) of the Atomic Energy Act provides that when NRC has reason to believe that a person has become subject to the imposition of a civil penalty, NRC must notify such person in writing " setting forth the date, facts, and nature of -
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. .2 This requirement is reflected in 10 C.F.R. 5 2.205(a). I In Radiation Technology, Inc.3 the Atomic Safetp and [
Licensing Appeal Board addressed the question of whether j the Staff provided a licensee with adequate notice of an -
. alleged violation as required by the Atomic Energy Act and NRC Rules of Practice when proposing a civil penalty. The Staff in Radiation Technology, Inc. alleged in the Notice of Violation and Proposed Imposition of Civil Penalty instances of excessive radiation at two specified locations and at several locations" not identified.4 The ,
licensee requested a hearing on the civil penalty, during which the Staff attempted to submit evidence relating to the areas of excessive radioactivity not specifically identified earlier. The presiding officer declined to i admit such evidence. The Appeal Board upheld his ruling on the grounds that a " licensee is entitled to notice of 2 42 U.S.C. i 2282(b). _
3 ALAB-567, 10 NRC 533 (1979).
4 Radiation Technology, Inc. ALJ-78-4, 8 NRC 655, 658 (1978), aff'd in part and rev'd in part, Radiation Technology, Inc. ALAS-567, supra, 10 NRC 533.
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specific violations before civil penalties may be imposed"
!!: and that a reference to excessive radiation at "several
- f locations" did not provide such notice.5
- Licensees submit that they have not received notice of -the specific violations for which the Staff proposes to *
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- , issue a civil penalty as required by Section 2.205. Among other things, the NOV fails to identify the QC inspectors who were not provided sufficient organizational freedom, the identity of the Oc supervisor allegedly intimidating personnel working for him, and when and under what ,
specific circumstances the alleged intimidation took
, place. -
The Report of Investigation 6 issued along with the j NOV is equally uninformative. It refers to two meetings scheduled by the " supervisor in question" but does not state where and when the meetings took place. The Report
- ) also notes the existence of " additional craft management -
complaints," yet fails to identify the content of any .
craft management complaints. Lastly, the Report states that one GC inspector did not report defects for fear of i
i Radiation Technology, Inc., ALAB-567, suora, 10 NRC at 5 -
549 n. 51.
6 Report of Investigation, Comanche Peak Steam Electric Station, Intimidation of Coatings OC Personnel, Case No. 4-83-001, August 24, 1983 (" Report of Investigation").
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4 s reprisals. However, the Report does not disclose either 0
the identity of the inspector or of the so-called defect allegedly not reported. ;
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N At bottom, just as in Radiation Technologv, Inc.,7
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here the Staff has not satisfied the requirements of law ,
, .because it has failed to provide Licensees with the factual basis for its claim that Appendix B, Criterion I was violated.8 For this re'ason, Licensees submit that the -
L NOV is erroneous and that the civil penalty in this j proceeding should be withdrawn.9
[;
e 7 ALAB-567, supra, 10 NRC 533.
8 In Connecticut Light and Power Company v. NRC, 673 F.2d
, 525, 530, cert. denied, 31 U.S.L.W. 3254 (1982), the 5 Court observed that "to allow an agency to play hunt
- the peanut'with technical information, hiding or disguising the information that it empleys, is to {(
n condone a practice in which the agency treats wha' '
l should be a genuine interchange as mere bureaucratic !
d' spo rt. " Although the observation was made in connection with the duty of NRC to disclose the technical basis for proposed rules, Licensees submit
.-j that it is equally (if not more) applicable here, where
' Licensees must respond to claims made by NRC or face a
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3 substantial civil penalty.
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- 9 While Licensees may have investigated the alleged incident of harassment, their inquiry did not focus on l
, the question of how NRC perceived the incident or on '
uncovering any information in the possession of NRC.
Therefore, Licensees' investigation does not change the -
e fact that it simply has no way of knowing the Staff's underlying factual bases for the instant enforcement action. Moreover, the fact that Licensees investigated the incident does not absolve NRC from its legal duty to disclose the underlying bases of this enforcement action.
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, One additional point should be noted regarding this deficiency in the NOV. Two goals of the Enforcement i
Policy are to obtain prompt corrective actions and to deter future violations of NRC requit mnents.10 The NOV t
cannot serve these goals if the licensee is not informed with specificity of the facts on which an alleged violation is based. A licensee cannot formulate its
' responsive actions and evaluate the effectiveness of those actions gnJssDWe"Yamn2%=Mwstneengeggiild ^
seN61 Dss- swiwW Similarly, future violations of NRC requirements cannot be deterred by enforcement actions unless the underlying bases of a violation are identified so that the licensee wit 1hrecisely-h,o,witsecondue4 a m, .. m ,. .1 --
pE$aQME'5-fRi4Djiatelyg Therefore, apart from the requirements of the Act and the Rules of practico requiring NRC to disclose with specificity the facts surrounding an alleged violation, sound enforcement policy also dictates that 7"9mifE=7Eh? Mas,,g.g that the promptness and extent to which a licensee takes -
corrective action, including actions to prevent recurrence, may be considered in modifying the civil -
10 10 C.F.R. Part 2, Appendix C $ I.
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7-penalty to be assessed.ll When applying this provision, j the Staff has in the past considered mitigation prior to proposing civil penalties formally. There have been .
approximately thirty-two Notices of Violation issued for I' Severity Level III violations Where no civil penalties 1
have been proposed.12 In at least some of them civil '
penalties were not proposed because of a licensee's prompt and extensive corrective action.13 Despite the provision in the Enforcement Policy allowing mitigation and the past practice of the Staff to consider mitigation prior to proposing a civil penalty, ., ,
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- there is no indication that the Staff at any time even t considered responsive actions taken by Licensees here before NRC issued the Proposed Imposition of Civil Penalty. On S.eptember 28, 1983, Licensees responded to the Notice of Violation and Proposed Imposition of Civil ;
Penalty in EA No. 83-64. In that response they set forth 4
numerous responsive actions, all of Which have been 11 10 C.F.R. Part 2, Appendix C, I IV.B.2. ,
12 SECY-83-487, " Revised General Statement of Policy and Procedure for Enforcement Actions," November 29, 1983,
'(SECY-83-487) at 3. -
13 See, e.a., January 6, 1984, letter from Thomas E.
Murley, Regional Administrator, Region I, U. S.
Nuclear. Regulatory Commission to Mr. J. J. Carey, Vice
-President, Nuclear Division, Duquesne Lighting Co.
regarding Enforcement Conference 50-334/83-27.
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-g-implemented.14 Licensees committed to these actions well
? before the instant enforcement action was initiated by l
- NRC. Indeed, because Licensees were aware in September, 1
! 1983, of the allegations involving harassment raised in I
this proceeding, they developed generic actions j specifically designed to address such issues.
Our concerns in this regard represent far more than a disagreement with the Staff over the correct procedures to be followed when proposing a civil penalty. Instead, they
} raise fundamental questions as to the basic fairness of this enforcement action. As the Staff is aware, most I
licensees believe that they are "tried and convicted in the press" when NRC proposes a civil penalty, and that even if the penalty is subsequently mitigated or remitted, the damage to their reputation has already been inflicted.15 Moreover, the Staff has conceded that it 2 l*
takes escalated enforcement actions in part because of the bad publicity they generate.16 l
14 These and other responsive actions ars set forth in
! Section II of Licensees' Response to Notice of l Violation in EA No.83-132, and are incorporated here by reference.
15 SECY-83-487 at 2.
16 During a January 4, 1984, briefing by the Staff on the _
Enforcement Policy, Commissioner Gilinsky asked the Director of Inspection and Enforcement whether the NRC was trying to deter future violations through the threat of bad publicity or through the actual imposition of civil penalties. The Director (footnote continued)
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l Accordingly, it is particularly unfortunate that the i
! Staff did not consider mitigation prior to proposing the civil penalty in this proceeding. The mere proposal of I
the civil penalty has already done considerable damage to the Licensees' reputation, and subsequent mitigation
] (which we obviously seek as an alternative to total
} withdrawal of the enforcement action) will not repair the
- damage. In short, it is difficult to understand what Lj valid regulatory policies were served by proposing a civil l penalty in this proceeding without first considering prior responsive actions initiated by Licensees.
Finally, Licensees again wish to emphasize that the responsive actions set forth in section II of its Response tokhgETMWhnot.,4gsigned merely to address
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erefore, given Lice Lon g we4.submi W Ttt m ed or w
(footnote continued from previous page) responded, "I think a combination. I think it's more the publicity than the amount of money." Transcript.
of January 4, 1984, Commission Meeting, " Discussion of l NRC Enforcement Policy" ("Jan. 4, 1984 Tr. ") at 10.
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Licensees believe that the was not taken in a timely manner. Because of this and the already committed, no valid regulatory policy will be furthered by imposing the proposed civil penalty.
Therefore, Licensees submit that it should be withdrawn.
During the January, 4, 1984, Commission' riesting on
! the Enforcement Policy, the Staff represented that it takes about ten weeks from the time an alleged violation is identified until a resulting enforcement action is commenced. However, the Staff added that in certain cases, such as where an investigation is involved, the period could ex h n w ksd7 When measured against these standards, the instant enforcement action is clearly not timely. The Report of
, Investigation indicates that the investigation into the matter took eight months. That inquiry.was closed on ;
August 3, 1983. The NOV was issued on December 22, 1983.
The Staff has recognized correctly that when enforcement actions are not taken on a timely basis, their effectiveness is limited. It has stated in this regard as follows: -
17 Jan. 4, 1984, Tr. at 36.
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- In the past, civil penalties have j frequently been proposed months after !
i a violation was identified and '
d corrective action taken. In these 1 cases, issuance of a civil penalty 1 probably had little remedial effect 3 and may have had a negative effect on
- . licensee morale.18 i The instant case is a model to illustrate this point.
- j Here the civil penalty was proposed nearly five months after a violation was finally identified and nearly four months after generic corrective actions were taken.
- ) Additionally, many of the individuals apparently involved M in the incident, including the Oc supervisor who allegedly intimidated QC personnel, are no longer employed at Comanche Peak. To impose a civil penalty under such conditions is inappropriate and unfair, could clearly undermine morale and has no valid policy justification.
Lastly, we note that on January 10, 1984, NRC Region L. II notified a licensee that the Commission decided not to propose a civil penalty for an alleged violation involving a material false statement. The violation was categorized as Severity Level III. The Commission declined to propose a penalty because the violation was over one year old and
$, substantive improvement had been made to prevent l
18 SECY-83-487 at 4. Commissioner Gilinsky stated recently that timely enforcement is needed because "as ,
we know, with children and pets and other such instances, if a penalty comes late, it can be down- l right harmful." Jan. 4, 1984, Tr. at 34. 1 1
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recurrence of the problem.19 It is difficult for Licensees in reviewing the results of that case to understand the reason for such disparate treatment here.
Therefore, because the instant enforcement action is not timely and in view of responsive actions already implemented, Licensees submit that the proposed civil penalty should be withdrawn.
V. Conclusion For the reasons set forth above, Licensees request that the proposed civil penalty be withdrawn or mitigated in full.
January 23, 1984 i
19 Janaury 10, 1984, letter from James P. O'Reilly, i
Regional Administrator, Region II, U. S. Nuclear Regulatory Commission to Mr. E. E. Utley, Executive Vice President, Carolina Power and Light, regarding Proposed Imposition of Civil Penalty in EA 83-88.
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