ML20205L145
| ML20205L145 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak |
| Issue date: | 03/30/1987 |
| From: | Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| Shared Package | |
| ML20205L149 | List: |
| References | |
| NUDOCS 8704020124 | |
| Download: ML20205L145 (3) | |
See also: IR 05000445/1986008
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In Reply Refer To:
MAR 3016
Dockets: 50-445/86-08
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50-446/86-06
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Texas Utilities Generating Company -
ATTN: Mr. W. G. Counsil'
Executive Vice President
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400 North Olive, L.B. 81
Dallas, TX 75201
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Gentlemen:
This refers to the construction inspection conducted by Mr. H.'S. Phillips'and
other members of the Region IV Comanche Peak Group during the period April _1
through May 31, 1986, of activities authorized by NRC Construction
Permits CPPR-126 and CPPR-127_for the Comanche Peak-Steam Electric Station,
Units 1 and 2, and to the discussion of our findings with.you and other members
of your staff at the conclusion of the inspection.
Areas of construction examined during the inspection included plant status and
general construction inspections; Brown & Root (B&R) audits of site activities;
Unit 2 electrical cable, tray, and instrumentation installation;'and Unit 2
pipe supports / restraints. 'Within these areas, the inspection consisted of
selective examination of procedures and representative records, interviews with
personnel, and observations by the inspectors. The inspection findings are
documented in the enclcsed inspection report.
During this inspection, it was found that certain of your activities were in
violation of NRC requirements. Consequently, you are required to respond to
these violations, in writing, in accordance with the provisions of-
Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of-
Federal Regulations. Your response should be based on the specifics contained
in the Notice of Violation enclosed with this letter.
Also during this inspection, it was found.that certain of 'your activities
appeared to deviate from comitments made to the NRC. These items and
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references to the comitments are identified in the enclosed Notice of
Deviation. You are requested to respond to these deviations in writing. Your
response should be based on the specifics contained in the Notice of Deviation
enclosed with this letter.
Twounresolveditemsareidentifiedinparagraphs4.c(2)and4.c(3)ofthe
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enclosed inspection report.
-Your attention is directed to paragraph 4.d of the enclosed report, in which
the inspector presents an evaluation of items of noncompliance concerning your
contractor's performance in the area of QA audits and the similarity of these
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Texas Utilities Generating Company
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findings to other reported deficiencies observed in the past and that have
resulted in a previous Notice of Violation (84-32/11).
It is clear from this
evaluation, which refers to both reviews and audits conducted many years ago
along with recent findings, including those currently being addressed, that
your actions over time to correct and improve your overall audit function have
not been fully successful.
In this regard we request that you consider the
points raised in the evaluation, and the possible need to take further
corrective actions in connection with your continuing management reviews of
this area. Additionally, it was our understanding that these matters would be
explicitly addressed in the implementation of the Comanche Peak Response Team
Program Plan, Issue-Specific Action Plans (ISAPs) VII.a.4 and' VII.a.5, as
reflected in your response to the earlier Notice of. Violation (TXX-4453). The
absence of clear identification and disposition of pertinent external source
issues in the results reports for ISAPS VII.a.4 and VII.a.5 will be addressed
in separate correspondence.
We have also examined actions you have taken with regard to previously
identified inspection findings. The status of these items is identified in
paragraph 3 of the enclosed report.
The responses directed by this letter and the accompanying Notices are not
subject to the clearance procedures of the Office of Management and Budget as
required by the Paperwork Reduction Act of 1980, PL 96-511.
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should you have any questions concerning this inspection, we will be pleased to
discuss them with you.
Sincerely,
. Original Signed by:
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R.E.HALC
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E. H. Johnson, Director
Division of Reactor Safety and-
Projects
Enclosures:
1. Appendix A - Notice of Violation
2. Appendix B - Notice of Deviation
3. Appendix C - NRC Inspection Report
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50-445/86-08
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50-446/86-06
4. Appendix D - B&R Matrix of Annual
Audits
cc w/ enclosure:
(seenextpage)
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Juanita Ellis
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President - CASE
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1426 South-Polk Street
. Dallas, Texas' 75224
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Renea Hicks
Assistant Attorney General
Environmental Protection Division.
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P. O. Box 12548
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Administrative Judge Peter Bloch '
U.S. Nuclear Regulatory Commission
Washington, D. C.
20555
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Elizabeth B. Johnson
Administrative Judge _-
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Oak Ridge National Laboratory
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P. O. Box X, Building 3500
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' Oak Ridge Tennessee 37830
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Dr. Kenneth'A. McCollom
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1107 West Knapp
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Stillwater, Oklahoma '74075
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Dr. Walter H. Jordan
881 Outer Drive
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Oak Ridge. Tennessee 37830-
Anthony Roisman, Esq.
Executive Director
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Trial Lawyer.s for Public Justice
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2000 P. Street, N.W.' Suite 611
Washington, D. C.
20036
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Texas Radiation Control Program Director
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