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Category:INTERNAL OR EXTERNAL MEMORANDUM
MONTHYEARML20211H4441999-08-27027 August 1999 Notification of Significant Meeting with Util on 990916 & 17 in Arlington,Tx to Improve Utility & NRC Understanding of Industry & Regulatory Perspectives on Current Issues ML20209G2421999-07-14014 July 1999 Notification of 990722 Meeting with License in Rockville, MD to Discuss Changes in EOI Licensing Organization Including Division of Responsibilities within New EOI Corporate Licensing Group ML20203J5931999-02-17017 February 1999 Notification of Significant Licensee Meeting with Util on 990329 Re NRC Plant Performance Review Summary Meeting ML20203A5081999-02-0505 February 1999 Notification of 980226 Meeting with Texas Utils Electric Co, Southern California Edison & NPPD Re Control of Hazard Barrier Tr, .Agenda Encl ML20195H9221998-11-17017 November 1998 Forwards Exam Repts 50-445/98-301 & 50-446/98-301 Conducted on 980619-26 with as Given Written Exams Encl,Designated for Distribution ML20153B0331998-09-18018 September 1998 Notification of 980929 Meeting with Texas Utilities Electric Co in Rockville,Md to Discuss Licensee Proposed App K Exemption Request & Topical Rept Submitted in Support of Exemption Request ML20236G8291998-07-0202 July 1998 Notification of 980720 Meeting W/Util in CPSES Nuclear Operations Support Facility Lab Annex to Discuss Midloop Operations During Last Refueling Outage ML20236F7611998-06-29029 June 1998 Notification of 980714 Meeting W/Util in Rockville,Md to Discuss Methods of ECCS Analyses & Licensing Submittals Required for Proposing Exemption to Appendix K & Power Uprate License Amend ML20217M9351998-04-0606 April 1998 Notification of Licensee Meeting W/Util on 980407 in Arlington,Tx Re Status of Licensee Actions in Response to GL 96-01 ML20202E6791997-12-0202 December 1997 Notification of 971209 Meeting W/Texas Utilities Electric Co in Rockville,Maryland to Discuss risk-informed Inservice Testing Request for Addl Info Responses, ML20202B1421997-11-26026 November 1997 Notification of 971115 Meeting W/Util in Arlington,Texas to Discuss Recent Unit 2 Refueling/Maint Outage at TU Electric Comanche Peak Plant ML20212G3921997-10-27027 October 1997 Notification of 971112 Meeting W/Util to Discuss Util 970228 Responses to Remaining Three Open Items Listed in NRC Safety Evaluation on Cable Functionality, .Reissued Due to Change of Cc:List ML20203C1181997-10-24024 October 1997 Discusses OI Rept 4-97-027 Re Falsification of Thermolag Matl Insp Records.Allegation Not Substantiated Therefore Enforcement Action Not Appropriate ML20212B7261997-10-16016 October 1997 Notification of 971031 Meeting W/Util in Arlington,Tx Re Predecisional Enforcement Conference ML20206E3401997-09-19019 September 1997 Requests That NRR Conduct Review of Licensee Backfit Claim to Determine of plant-specific Backfit Exists & Submits Recommended Actions to Be Taken If One Does Exists ML20217R1561997-08-28028 August 1997 Informs That GL 96-04 Did Not Require Response for Licensee That Did Not Have Boraflex in Sf Racks ML20237B9901997-07-0303 July 1997 Informs That on 970529-30,NRC Team Attended Severe Accident Mgt Implementation Demonstration at Comanche Peak Steam Electric Station,In Granbury,Tx ML20137C9201997-03-20020 March 1997 Forwards Documentation of Meeting Conducted in Region 4 Office on 970225 to Discuss NRC Enforcement Policy as Applied to Nonescalated Enforcement ML20134N2911996-11-22022 November 1996 Notification of 961205 Meeting W/Util in Arlington,Tx to Discuss Responses to Open Items Listed in NRCs Safety Evaluation on Cable Functionality at Plant, ML20134L9821996-11-19019 November 1996 Notification of Licensee Meeting W/Util on 961204 to Discuss Revision 25 to Emergency Plan ML20128P3011996-10-10010 October 1996 Forwards Analysis of Financial Qualifications & Antitrust Reviews & Input to SER on Proposal to NRC by Tuec for Tx Utilities Corp ML20129E9031996-10-0101 October 1996 Notification of 961002 Meeting W/Util in Rockville,Md Re License Amend Request 96-005,inverters & Battery Chargers Mod ML20135A2801996-04-10010 April 1996 Discusses Director'S Decision Re Actions Requested by Petitioners W/Regard to Use of Thermo-Lag by Reactor Licensees.Petitioners Requested Immediate Shutdown of Reactors Using Thermo-Lag ML20078H7831994-11-0707 November 1994 Forwards Rev 11 to CPSES ODCM & Receipt Acknowledgement Sheet ML20059K5261994-01-21021 January 1994 Notification of 940203 Meeting W/Util in Arlington,Tx to Discuss Realignment of Nuclear Overview Functions ML20059K4921994-01-21021 January 1994 Notification of 940204 Meeting W/Util in Glen Rose,Tx to Discuss Unit 1 Outage Related Activities ML20058C5451993-11-22022 November 1993 Notification of 931202 Enforcement Conference Re Reactor Coolant Spill Inside Containment on 931026 ML20058N1471993-10-0505 October 1993 Notification of 931006 Meeting W/Util in Rockville,Md to Discuss Implementation of Std TSs for Both Units ML20057C9801993-09-27027 September 1993 Discusses 930927 Press Conference Re J O'Connor Announcement That Util Settled Six Rate Matters & Appeals Before Illinois Courts & Commerce Commission by Agreeing to Refund Listed Amount to Customers Over Next 12 Months ML20057A8271993-09-13013 September 1993 Notification of 930920 Meeting W/Util in Rockville,Md to Discuss Fire Barrier Testing & Implementation on Unit 1 ML20056H2941993-09-0101 September 1993 Notification of 930916 Meeting W/Util in Comanche Peak Steam Electric Station to Discuss Safe Shutdown Risk & Other Issues Associated W/Scheduled Oct 1993 Refueling Outage ML20056E4571993-08-0505 August 1993 Forwards Technical Review Rept Re, Tardy Licensee Actions Initiated Because of Delayed Replacement of Batteries in Uninterruptible Power Supplies at Plant ML20128F3531993-02-0202 February 1993 Discusses Emergency Motion to Stay Issuance of low-power Ol.Motion Requested That Commission Issue Order Staying Issuance of Low Power License & Grant Petitioners Chance to Review Withheld Documentation Re Settlement Agreements ML20128D5741993-01-27027 January 1993 Forwards Sworn Joint Affidavit of I Barnes & Ft Grubelich ML20127L9121993-01-26026 January 1993 Forwards NRC Staff Reply to Cfur Request for Publication of Proposed Action Re Licensing of Unit 2.Sworn & Executed Affidavits of I Barnes & Ft Grubelich Will Be Filed as Soon as Possible ML20127H4811993-01-18018 January 1993 Notification of 930121 Meeting W/Util in Rockville,Md to Discuss Fire Protection issues,Thermo-lag Installation Issues & Test Reports ML20127D6951993-01-13013 January 1993 Notification of Significant Licensee Meeting W/Util on on 930122 to Discuss Results of ORAT Insp ML20127C4861993-01-11011 January 1993 Notification of 920115 Public Mgt Meeting W/Util in Region IV Ofc to Discuss CPSES Temporary Mod Program ML20126H3491992-12-29029 December 1992 Notification of Significant Licensee Meeting W/Util on 930107 to Discuss Plant Monthly Status of Const & Licensing Activities ML20126K7681992-12-24024 December 1992 Forwards Part of Earlier Submittal by TU Electric for Distribution as Was Done for Previous Submittal Re ME215 Sapcas Computer Code.Proprietary Abstract Also Encl.Abstract Withheld ML20126F4161992-12-18018 December 1992 Notification of 930107 Meeting W/Util in Rockville,Md to Discuss Design & Operability of Alternate Min Recirculation Path in Highhead Pressure Safety Injection Sys ML20126D9061992-12-14014 December 1992 Notification of 921217 Meeting W/Util in Rockville,Md to Discuss Fire Protection Issues at Plant ML20057C9921992-10-26026 October 1992 Partially Withheld Memo Discussing Rape Allegation at Plant ML20127F5051992-10-21021 October 1992 Discusses 921020 Telcon W/R Feldman of Thermal Science,Inc (TSI) Re 921018 Rept Made by Util That Less than 10 of 2,000 Conduit Sections Provided by TSI Showed Signs of Delamination & Some Had Occluded Porosity in Cross Sections IR 05000445/19920181992-07-0606 July 1992 Discusses Allegation RIV-92-A-0016 Reviewed During Insp Repts 50-445/92-18 & 50-446/92-18 Re Disposal of Radioactive Matl in Landfill Located on Licensee Property ML20057B4601992-05-15015 May 1992 Discusses Telcon W/Rm Dow Re Plant ML20057B1881991-04-18018 April 1991 Discusses 910405 Telcon W/Alleger Re Security Sys at Plant ML20029A4071991-02-13013 February 1991 Forwards Correspondence sign-off Sheet for LER 90-036-01. Suppl Acceptable for Submittal to NRC ML20057B1781991-02-0505 February 1991 Discusses Allegations Made by M Dow Re Scores of Security, Safety Violations & Allegation of Sexual Harassment at Plant ML20065K0251990-11-0707 November 1990 Forwards Amend 2 to Tech Specs,Modifying Tables 2.2-1 & 3.3-3 Re Neutron Flux Meter Setpoints 1999-08-27
[Table view] Category:MEMORANDUMS-CORRESPONDENCE
MONTHYEARML20211H4441999-08-27027 August 1999 Notification of Significant Meeting with Util on 990916 & 17 in Arlington,Tx to Improve Utility & NRC Understanding of Industry & Regulatory Perspectives on Current Issues ML20209G2421999-07-14014 July 1999 Notification of 990722 Meeting with License in Rockville, MD to Discuss Changes in EOI Licensing Organization Including Division of Responsibilities within New EOI Corporate Licensing Group ML20203J5931999-02-17017 February 1999 Notification of Significant Licensee Meeting with Util on 990329 Re NRC Plant Performance Review Summary Meeting ML20203A5081999-02-0505 February 1999 Notification of 980226 Meeting with Texas Utils Electric Co, Southern California Edison & NPPD Re Control of Hazard Barrier Tr, .Agenda Encl ML20195H9221998-11-17017 November 1998 Forwards Exam Repts 50-445/98-301 & 50-446/98-301 Conducted on 980619-26 with as Given Written Exams Encl,Designated for Distribution ML20153B0331998-09-18018 September 1998 Notification of 980929 Meeting with Texas Utilities Electric Co in Rockville,Md to Discuss Licensee Proposed App K Exemption Request & Topical Rept Submitted in Support of Exemption Request ML20236G8291998-07-0202 July 1998 Notification of 980720 Meeting W/Util in CPSES Nuclear Operations Support Facility Lab Annex to Discuss Midloop Operations During Last Refueling Outage ML20236F7611998-06-29029 June 1998 Notification of 980714 Meeting W/Util in Rockville,Md to Discuss Methods of ECCS Analyses & Licensing Submittals Required for Proposing Exemption to Appendix K & Power Uprate License Amend ML20217M9351998-04-0606 April 1998 Notification of Licensee Meeting W/Util on 980407 in Arlington,Tx Re Status of Licensee Actions in Response to GL 96-01 ML20202E6791997-12-0202 December 1997 Notification of 971209 Meeting W/Texas Utilities Electric Co in Rockville,Maryland to Discuss risk-informed Inservice Testing Request for Addl Info Responses, ML20202B1421997-11-26026 November 1997 Notification of 971115 Meeting W/Util in Arlington,Texas to Discuss Recent Unit 2 Refueling/Maint Outage at TU Electric Comanche Peak Plant ML20212G3921997-10-27027 October 1997 Notification of 971112 Meeting W/Util to Discuss Util 970228 Responses to Remaining Three Open Items Listed in NRC Safety Evaluation on Cable Functionality, .Reissued Due to Change of Cc:List ML20203C1181997-10-24024 October 1997 Discusses OI Rept 4-97-027 Re Falsification of Thermolag Matl Insp Records.Allegation Not Substantiated Therefore Enforcement Action Not Appropriate ML20212B7261997-10-16016 October 1997 Notification of 971031 Meeting W/Util in Arlington,Tx Re Predecisional Enforcement Conference ML20206E3401997-09-19019 September 1997 Requests That NRR Conduct Review of Licensee Backfit Claim to Determine of plant-specific Backfit Exists & Submits Recommended Actions to Be Taken If One Does Exists ML20217R1561997-08-28028 August 1997 Informs That GL 96-04 Did Not Require Response for Licensee That Did Not Have Boraflex in Sf Racks ML20237B9901997-07-0303 July 1997 Informs That on 970529-30,NRC Team Attended Severe Accident Mgt Implementation Demonstration at Comanche Peak Steam Electric Station,In Granbury,Tx ML20137C9201997-03-20020 March 1997 Forwards Documentation of Meeting Conducted in Region 4 Office on 970225 to Discuss NRC Enforcement Policy as Applied to Nonescalated Enforcement ML20134N2911996-11-22022 November 1996 Notification of 961205 Meeting W/Util in Arlington,Tx to Discuss Responses to Open Items Listed in NRCs Safety Evaluation on Cable Functionality at Plant, ML20134L9821996-11-19019 November 1996 Notification of Licensee Meeting W/Util on 961204 to Discuss Revision 25 to Emergency Plan ML20128P3011996-10-10010 October 1996 Forwards Analysis of Financial Qualifications & Antitrust Reviews & Input to SER on Proposal to NRC by Tuec for Tx Utilities Corp ML20129E9031996-10-0101 October 1996 Notification of 961002 Meeting W/Util in Rockville,Md Re License Amend Request 96-005,inverters & Battery Chargers Mod ML20135A2801996-04-10010 April 1996 Discusses Director'S Decision Re Actions Requested by Petitioners W/Regard to Use of Thermo-Lag by Reactor Licensees.Petitioners Requested Immediate Shutdown of Reactors Using Thermo-Lag ML20078H7831994-11-0707 November 1994 Forwards Rev 11 to CPSES ODCM & Receipt Acknowledgement Sheet ML20059K4921994-01-21021 January 1994 Notification of 940204 Meeting W/Util in Glen Rose,Tx to Discuss Unit 1 Outage Related Activities ML20059K5261994-01-21021 January 1994 Notification of 940203 Meeting W/Util in Arlington,Tx to Discuss Realignment of Nuclear Overview Functions ML20058C5451993-11-22022 November 1993 Notification of 931202 Enforcement Conference Re Reactor Coolant Spill Inside Containment on 931026 ML20058N1471993-10-0505 October 1993 Notification of 931006 Meeting W/Util in Rockville,Md to Discuss Implementation of Std TSs for Both Units ML20057C9801993-09-27027 September 1993 Discusses 930927 Press Conference Re J O'Connor Announcement That Util Settled Six Rate Matters & Appeals Before Illinois Courts & Commerce Commission by Agreeing to Refund Listed Amount to Customers Over Next 12 Months ML20057A8271993-09-13013 September 1993 Notification of 930920 Meeting W/Util in Rockville,Md to Discuss Fire Barrier Testing & Implementation on Unit 1 ML20056H2941993-09-0101 September 1993 Notification of 930916 Meeting W/Util in Comanche Peak Steam Electric Station to Discuss Safe Shutdown Risk & Other Issues Associated W/Scheduled Oct 1993 Refueling Outage ML20056E4571993-08-0505 August 1993 Forwards Technical Review Rept Re, Tardy Licensee Actions Initiated Because of Delayed Replacement of Batteries in Uninterruptible Power Supplies at Plant ML20128H2931993-02-10010 February 1993 Staff Requirements Memo Re Emergency Motion to Stay Issuance of low-power Operating License.Staff Issued Order Denying Motion ML20128E4301993-02-0505 February 1993 Staff Requirements Memo Re 930129 Affirmation/Discussion & Vote on SECY-93-016 Discussing FRN Concerning Proposed Issuance of OL ML20062J1941993-02-0303 February 1993 Board Notification 93-001:notifies of 930202 Emergency Motion to Stay Issuance of low-power OL Requesting Listed Items Including Issue Order Staying Issuance of License ML20128F3531993-02-0202 February 1993 Discusses Emergency Motion to Stay Issuance of low-power Ol.Motion Requested That Commission Issue Order Staying Issuance of Low Power License & Grant Petitioners Chance to Review Withheld Documentation Re Settlement Agreements ML20128D5741993-01-27027 January 1993 Forwards Sworn Joint Affidavit of I Barnes & Ft Grubelich ML20127L9121993-01-26026 January 1993 Forwards NRC Staff Reply to Cfur Request for Publication of Proposed Action Re Licensing of Unit 2.Sworn & Executed Affidavits of I Barnes & Ft Grubelich Will Be Filed as Soon as Possible ML20127H4811993-01-18018 January 1993 Notification of 930121 Meeting W/Util in Rockville,Md to Discuss Fire Protection issues,Thermo-lag Installation Issues & Test Reports ML20127D6951993-01-13013 January 1993 Notification of Significant Licensee Meeting W/Util on on 930122 to Discuss Results of ORAT Insp ML20127C4861993-01-11011 January 1993 Notification of 920115 Public Mgt Meeting W/Util in Region IV Ofc to Discuss CPSES Temporary Mod Program ML20126H3491992-12-29029 December 1992 Notification of Significant Licensee Meeting W/Util on 930107 to Discuss Plant Monthly Status of Const & Licensing Activities ML20126K7681992-12-24024 December 1992 Forwards Part of Earlier Submittal by TU Electric for Distribution as Was Done for Previous Submittal Re ME215 Sapcas Computer Code.Proprietary Abstract Also Encl.Abstract Withheld ML20126F4161992-12-18018 December 1992 Notification of 930107 Meeting W/Util in Rockville,Md to Discuss Design & Operability of Alternate Min Recirculation Path in Highhead Pressure Safety Injection Sys ML20126D9061992-12-14014 December 1992 Notification of 921217 Meeting W/Util in Rockville,Md to Discuss Fire Protection Issues at Plant ML20057C9921992-10-26026 October 1992 Partially Withheld Memo Discussing Rape Allegation at Plant ML20127F5051992-10-21021 October 1992 Discusses 921020 Telcon W/R Feldman of Thermal Science,Inc (TSI) Re 921018 Rept Made by Util That Less than 10 of 2,000 Conduit Sections Provided by TSI Showed Signs of Delamination & Some Had Occluded Porosity in Cross Sections IR 05000445/19920181992-07-0606 July 1992 Discusses Allegation RIV-92-A-0016 Reviewed During Insp Repts 50-445/92-18 & 50-446/92-18 Re Disposal of Radioactive Matl in Landfill Located on Licensee Property ML20057B4601992-05-15015 May 1992 Discusses Telcon W/Rm Dow Re Plant ML20057B1881991-04-18018 April 1991 Discusses 910405 Telcon W/Alleger Re Security Sys at Plant 1999-08-27
[Table view] |
See also: IR 05000445/1986008
Text
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March 18, 1987
Memorancum Fort George Gower
Senior St a f f Mernber
NRC Headquarters
F-om: Harry Shannon Fhillips
Senior Resident Inspector
Comanche Peak Construction
Subject: Inspection Report 445/06-08; 446/86-06
>.
Reference: (1) Memor andum, Spessard to Martin, 2/27/87
(2) Merno r andurn , Martin to Phi 11ips, 3/3/87
(3) Memorandum, Phi 11ips to Martin, 3/6/87
I transtaitted a report that I would sign and concur with as
requested by references 1 and 2. You responded to this revised
report transruitted by reference 3.
I have reviewed two suggested paragraphs that you propose for
the letter of transtaittal and paragraph 4.d of the subject report.
Your suggested paragraphs again omat two violations that vere in my
ortginal and latest version of report 86-08/06.
or facts are also not included and I believe this Supporting gives a false findings
impression to the public about these matters.
I .would like to better understand your reasoning for your
suggested paragraph 4.d. In attachment No. 1,I arn 1isting items
omitted, mabing statements, and asking questions. P1 ease provide
answ+rs.
s
<4-, w
,
Harry 1annon Phi 11ips
Enclosures
1. Attachment 1 - Comment s /Ouest i on's
2. MAC Letter 5/17/78
3. Exhibit 23
pg
s.
89032h.f.-
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2
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t he' i nspec t i on (84-32/11). As a result, the NRC inspector reviewed
the MAC report during the current inspection and found that MAC had
f ound TUGCo's audi t progr am de fic i ent . "
Coenmen t : This is similar1y an understatement. TU rnanagernent were
aware that I asked for alI consultant reports, audits, reviews, etc.,
to show that they had regularly reviewed the status and adequacy of
the QA program. I received a copy of the MAC Peport JPJ-471 dated
May 1978 in 1 ate 1995 or about a year a f ter tnspection 84-32/11. In
September 1986 I learned that TU managernent made a rnat er i al false
st atement as document ed in Board Noti fication No. 86-20. I r eal i :: ed
that they had also rnade a mat erial false st at ernent to toe when they
said they had no other consultant reports other then Lobbin which
they provided to me. ..
The withholding of the MAC report dignt ficantly altered the
direction
the report.
of inspection 84-32/11 and the en forc ernent recommended in
It al so al t er ed ray concl usi ons r el at i ve to fuel loading
which was proceeding in September 1984; i.e., it would have
n egat i vel y impacted the expedited hearing for fuel Icading. If I had
knowledge of this report I would have per f orrned a rnore comprehensive
and focused inspection.
Question 2: Why do you propose to drop this statement?
3.
"The Comanche Peak response Team (CPRT) evaluation of audits,
Pesults Report for Issue Speci fic Ac tion Plan (ISAP) VII a.4 dated
June 28, 1985, did not d1scuss the MAC report as TUGCo did not commit
to followup an thi's' audit in ISAP VII a.4. The results report ISAP
VII a.4, dated April 18, 1986, did not address the speci fic B&R audit
pr ogram de fic i enc i es, ident i fi ed by the NRC inspector during the
current inspection. In addition, TUGCo had issued no response to
Inspection Report 50-445/84-32; 50-446/84-11 to out1ine corrective
action.
Ccwnmen t : Considering 1 and 2 above this too is an understatement in
paragraph 4d. It simply supports the fact that they did not take
cc4npr ehensi ve and e f f ec t i ve cor r ec t i ve ac t i on conc erning the audi t
program f r orn 1978 until the present.
.
Question: Why do you propose to drop this statement?
4 "B&R management also f ail ed to take corrective action on MAC
atdit MAC-77-66, dated June 3, 1977 and as a r esul t their site audit
pr ogr am has r ernained de fic i ent since 1977 based on a review of B&R
audi t s CP-12 t hrough CP-16 (1978 - 1979). Finding nuraber 15 in the
sanagement surnma r y s t a t ed , 'The site audit prograro is ineffective.'"
Cuestion: Considering the fact that the B&R audit program has been
in continuous noncompliance f r orn 1977 until now, how can you justify
dr opping this violation?
.
_ _ _ _ _ - _ _ _ _ __
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3
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.
NOTE: The BLR QA manager said they did not perform all audits
b+cause TU would not pay them to per form the audi t s needed. This was
stated in front of witnesses.
5.
"TUGCo management, according to MAC (MAC-JPJ-471), were aware of
that
identi MAC fied had audited
program deBLR ficienci Houston
es. and Comanche Peak site and had
As a result of ineffective
corrective action concerning the MAC findings, the BLR audit program
was
4. b , de4.c ficient from 1980 through 1985 as described above in paragraphs
and 4.e."
Ccenment :
Bot.rd Not i f i c a t i on No. 86-20 Cont ains st atements that are
at best unclear and at worst are falsel Page 21 of Exhibit 23 states
that the President of Texas Utilities > Generating Company did not inow
that MAC audi
parageaph 1, 1ast ted sentenee
Brown & Rocc but the let ter to htm (Exhibit 1)
talks about t' hat audit. I discussed this
letter with MAC and they con firmed that TUGCo knew about the report.
i n vesI tbelieve i ga t i on this is adoes
report material false stthis.
not address at ernent but the
This is my finding until
someonw can show otherwise.
The statement is necessary to support a viofation; i e. , TUGCo
failure
p r og y at:. .
to followup and review the status and adequacy of thts QA
Question:
Why do you propose to drop the understated finding?
6. "At. the titue NRC Inspection R+rport 50-445/84-32; 50-446/84-11
was issued, the option was offered and accepted by your letter
TX X -4453 dated March 11, 1985, whereby you elected to respond to
vi olations centained in this report as part of the Comanche Peak
Pesponse Tearn P1 an. "
Comment: It never was an option concerning corrective action to be
taken only the option to respond; i.e., 84-32/11 NOV page 3 requires
cor r ec t i ve action taken and corrective steps to avoid further
violation.
Page 6 of the final report (86-08/06) that RIV and Hg. proposed
to i ssue states that the B&R audit p r og r ane, a part of the licensee's
audit program, was in viofat1on as a'udtt report CP-27 (1985) was a
part of the noncoropliance. This proves that they cont inued in
noncernpliance a f t er the 1984 violations in 84-22/11.
TU did not respond until February 2, 1987 and it does not
addr ess the de fic1 ent BbP audi t program.
Cuestion a: How does this justtfy continued nonc orop l i anc e for 21/2
years after the 84-32 violations were identi fi ed?
.
-n-, - .- - . - - - - - - - r-------n - , - - - - - - _ - ~ -- - - - . . - , - - - - _- . - - , - -
-, ,
- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _
.
. . 4
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.
Question b: How can anyone .just i f y a response to serious violations
taking 1'1/2 years while the audit program for Unit 2 construction
was
neccompliance?
indeterminate and finally identi fied by NRC to be in
7.
"It was our understanding the expectation that these violations,
together wi th r el at ed per t inent external source issue (e.g., TRT,
MAC) would be specifically included in the assessments per formed by
Issue Speci fic Ac tion Plans (ISAPs) VII.a.4 and VI.a.5, given the
sc op e of each. As a result of NRC review of the results reports for
these ISAPs, it is apparent that the r esul ts repor ts, in t h e rns e l ve s ,
do not explicitly ident i f y and describe the disposition of these
external source issues. This i s a roa t.t e r of concern when viewed in
the light of the findings noted i n t h i.'s, r ep or t regarding the BtR
audit prograrn and will be the subject o f separate corr espondence from
the NRC." /
Comment: This basically states they failed to tak e corrective
a: tion. This is an under st at ement as ISAP VI!.a.4 states that they
never intended t o t ake c ornpr ehensi ve c or r ec t i ve ac t ion. They only
looked to see if TU went through the rnotions not to assess audit
e f f ec t iveness which was the real issue. Apparently they did not even
see if B&R went through the rnotions.
In Sept ernber 1985 I spect fically asked C. Hal e, PIV Comanche
Peak Task Group, to look at B&R audit prograrn because I had seen
i ndi c at i ons o f pr obl erus. He ignored the *equest. He had no
int ent ion of pursuing the issues in the MAC report and was well aware
that TU made no comm1 t roent in the ISAP to addr ess the issues.
Questio'n How does this . justify not issuing violations whether in
86-08/06 or frorn the RIV CPTG r epor t ?
8.
"Criterion XVI of appendix B to 10 CFR Part 50, as irnplernent ed by
FSAR, Section 17.O, and TUGCo OAP, Section 16.O, Revi sion 0, dated
July 1, 1978, requires that conditions adverse to quality be promptly
identi fi ed, reported, and cor rec t ed.
Ee Liutt_t9_V itt x_G9ttestL90_91_ou_eudti_Deitsttuix
f
FSAR, Section 17.1.16, states that TUGCo r equi res rueasure be
established to assure that conditions adver se t o quali ty are prornpt 1y
1denti fied, reported, and corrected.'
! TUGCo pr oc edur e COI-C S-4. 6, Pevision 3, dat ed August 8, 1982, states
in part, 'Ver i fic at ion o f t rupl ernent a t i on o f cor r ec t i ve actions shall
be accornpli shed by appropr 1 at + means. '
Cont rary to the above, Audit De fic t ency No. 1 of TUGCo OA Audit
TC o-51 ( sep t ernb er 199"D was i rnpr oper l y c l osed out . That is, the
audttor did not veri fy the t rnp l ernen t a t i on of c ornr .1 t roen t s t o c or r ec t
the deficiency prior to closing the audit f i ndi ng. Pecords show that
in thi s case TUGCo had inttiated plans for r esol vi ng the audit
.
P
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5
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.
. deficiency
446/8606-V-08). through review of the oper at ion t ravelers (445/8608-V-06;
.
This is a Severity Level V violation. (Supplement II)"
Cornmen t : This violation was identi fied by a junior inspector who
submitted the viol ation to me without proper proc edural references
and being in the correct format.
at in the proper format as he hadI left obtained
site. the re f erences and wrote
The point is that this finding sailed through and was never
qwestioned but ray violations which identify fatture to take
corrective
vi ol at i onaction and per forrn
in compartson to theaudits h' ave been taken to task. This
CA prograne breakdowns is f ailure to tak e corrective action on
vi ol at ion and raine were dropped.insigni fi c ant ,, yet , this is an acceptable
p r e judic e is evident. This is not only incredible but the
C estion: How can you propose that this
c-opping two serious violations? violation be issued whtle
3.
Appendis C of 10CFR Part 2 states that the purpose of the NFC
e f orc ernent program is to promote and protect the health and safety
of
the public
obtaining by ensuring
prornpt cornpliance
correction of with NRC r egulations and by
violations and adverse quality
conditions which ar n af f ect safety and deterring future violations.
Cc rntnent :
This seetion of Tit 1e 10 says that +ach en f orc ement action
ts dependent on th'e' circumstances but no wher+ does it say that NRC
rn a n a g e r s , supervisors, and inspectors can arbitraryily decide not to
write up noncompliancec and notices of violattans. The only
justi fic at s on is if all the following are sattsifled the licensee
1 d errt i f i ed the problem, it is severity Ievel IV and V, it was
r+ ported tf required, at was or vi11 be corrected...within a
r+asonable ttrne, and it was not
a violation that could reasonably be
espected to have
for a previous violation.
been prevented by the l i c ensee's cor.r ec t i ve ac t i on
I cannot
3.e e t any of these conditions rouch less see all.
how the violations ! proposed
Question:
How can you justify not issuing the violations I proposed
as they do not meet any of the cri'eria for not writing a vi ol a t i on?
10. Appendix C of Part O Suppl ernent !! i s spec t fic about the failure
tc audit and corr ect deficienci es or t o t ak e p r ornp t corrective
a:t1.sn.
C : *,r n ent :
It believe I can rnal e a c ase for a e t ,tl penalty and a OA
ptrspection.
r :.g r arn brealdown c ortnec t ed to hardware but it will require rnore
I really prefer to have the licensee identify the
- .b l eras as a result of a Level IV viofation.
Question:
Why not 1ssue the proposed viof at1ons and Iet TU respond?
.
~
,' ..
_ _ . - -_
..
.
,v .',- ,
, -
Managemen..t Ann!} sis Catopnny hhh
11100 Roemde St Sea O!sgo. CA 92121
T14145213*1 -
,
l: L)2} T :E
f,y * 5 .,, ' . f ' 'Y , ,# .
?g
,
,
.
~ f
<*/ a 1. .
J g FMay TT,197E
~
'h MAC-JPJ-471
9
Mr. Perry Brittain
Prtsfdent y
Texas Utilities Generating Ccepany .~
200T Br
Callas.yan Tower
. TX 75201 >
Cear Mr. Brittain:.
Enciosed is the
for Texas Utflities report Ceepany.
Generating of the Managecent Quality Assurance Audit c
en ucted
The audit disclosed that, in general, the Quality Assurance activiti
effeettve, that there is good
the Architect / Engineer and the Constructor. tea.t spirit between TUGCO/iljSt
es were
F
_
perso
T
CffcationMome
Quality Assurance Planfaflures or cliiii75TR.t2 comely with requiatsrf recutrementsThe x the Wfa au
an Audit Report as Accendix A.
improved practice. These cef1clenctes are fcentified~fn C' '
and
t.e Comanchendix E ts thisTheseletter. are fdentified as Cbser<ations and Recom
ak.sile E Wyou knew, MAC particTMeMart audit of IM
,
~
s gnf ficant improvement is noted since that auditP
personnel con- // b cecp
I
Management Analysis C=pany received .
full
f"
general openness of persennel andaudit, their but frank discussion annot only c:
e
.
I
.
Thet i
of any deffcfencies,the conduct of the exemplifies.
n anced
ucive to correctiert DA $
attitude
Company and Texas Ut111 ties fervices
If there are any c:nnents or questions re
Inc. and hop
rating
so frr the future.
.
Mr. J. R. Norris or me at (714) 452-139T.garding thrts work, please centact
l
Sfnee S y,
- 7J
,f/
-
- .
!
/
John ?. Jackscn
JPJ:bew Principal Partner
Enclosurts: Appendix A
Appendix 3
.
._
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n
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.
'
,
.
.
.
1-
.
l . . .
.
already asked
.
2 -
you this, but jus
in case 2 naven't:
.
,
,
0 -i Are you aware of brown & Root
having hired MAC
4 their
to pertorm any re, views or audit of
implementation of
5
the QA Program at Comanche
,
Peak?
.
'
i .
6 A. '
l , No, I am not.
.
7
f C.
Or any r e p o r t.,a generated by them?
6 A. ..
'
.
No.
N
9 O. Oxay.
let me ask you an all
,
10 , question. encompassing
.
11-
Otner tnan what I nave already asxed yo2,
!
can you thinx 'ot --
Do you have
12 any xnowledge,
<
interoation from
{g I con ersations, meetings, dbcuments
Ig that
- L'L.} you ,have been privy to; anything that sheds any
, 14
.
15 +'
light on the origins of the f1AC report'of why it was
' withheld from sne Intervenor's request or how it was
4 16
-
17 produced in 1960 or why it was not produced earlier
that we have not discussed? '
. 18 h.
.
No, I have not.
19 Q.
t
You were interviewed by Mr.*Wooldridge here.
20 were:you not?
'
~
41 '
A.
'
I was. .
22 g. .
Was tnw information you gave Mr.
23 wooldridge
tne same information
- 2, you nave given me here tocay?
.
.
n. Yes.
.J '
.
25
,
I mean ne may not nave asxed exactly
\
t
t
.
tne same questions,
'
.
cut ene substance of it was
. , . . .,:-- -. L *
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. . . . . -
FEDE"RAL COUXT REPdRTERS _L
.
.e.. % .w.4.v+ w . H- _ ~ . . ~ . ~ . - ,;.- -
g. i
i [ %, UNITED STATES
3 ,, NUCLCAR REGULATORY COMMISSION
$ l
' *
, CEGION IV
611 RYAN PLAZA DRIVE. SUITE 1000
*4 !
, , ., ARLINGTON. TEX AS 76011
l
l
l
l
TRA!!SMITTAL SF.ET . REGION IV '
.
DATE: 3-19-87 ..
.
>
M.ESSAGE TO: GECRGE GCWER
TELECOPY NUM ER:
VERIFICATION NUM"ER:
.
NUMBER OF PAGES: B
PLUS INSTRUCTION SHEET
MESSAGE FROM: HARRY SHANNON PHILLIPS
CONTACT:
............................................................................
SPECIAL INSTTICTIONS: MExo Ano onsTIcNs cN REpon: 86 08/06
Fo% A-91- M
Ll1
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