ML20211D561

Forwards 1979 Trend Analysis Info,Per 800117 Request

ML20211D561
Person / Time
Site:	Comanche Peak
Issue date:	03/03/1980
From:	Hubacek W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Crossman W NRC
Shared Package
ML20211C348	List: IR 05000445/1981020 ML20211C341 ML20211C385 ML20211C402 ML20211C418 ML20211C452 ML20211C502 ML20211C508 ML20211C539 ML20211C565 ML20211C593 ML20211C608 ML20211D561
References
FOIA-85-312 NUDOCS 8606121026
Download: ML20211D561 (30)

Text

NRC Staff ExMbit l9Y UNITED sT ATEs

't NUCLE AR REGULATORY COMMISSION

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Harch 3, 1980

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MEMORANDUM TOR:

A. Crossman, Chief, Projects Section W. G. Hubacek, Reactor Inspector, Projects Section TROM:

SUBJECT:

TREND ANALYSIS - 1979 The attached information is provided in response to your memorandum, same subject, dated January 17, 1980.

The information, prepared by the assigned project inspectors, includes only those facilities that were in an active constructi0n status during calendar year 1979.

/

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V. G. Hub a c ek, Re?'..

petor Inspector Projects Section

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NRC Staff Exhibit lY Co=anche Peak, Units 1 & 2 DN 50-445; 50-446 b

TRIND ANALYSIS - 1979 P

y J

Number and Repetitiveness of Construction Deficiency Reports a.

Two items were officially categorized by the licensee as 50.55(e)

(1) items.

(2) The two items did not appear to be repetivie.

b.

Enforcement History (See attached sheet)

Responsiveness of Licensee to Enforcement Action c.

The licensee has generally been on time with his response to letters (1) and when he has not been able to do so, he has informed us promptly.

The response letters are generally adequate as forwarded to the office.

(2)

The licensee site QA personnel usually coordinate the answer with me prior to sending it to the office.

Any unsatisf actory answers given are not usually the licensee's fault, f

(3) but also not necessarily our fault either in terms of the way the noncompliance is written. It is primarily a matter of our wanting so=ething a bit stronger for the record.

My experience has been that the promised actions have been implemented (4) by the dates promised.

(5) The licensee has been generally responsive to our findings.

d.

Unresolved Items Unresolved items have gotten a bit out of hand since they are not being (1) worked off very rapidly. I have been promised increased attention will be paid to them.

The numbers of unresolved items are on the increase, but I view this as (2) this stage of construction since they are now well into every normal at aspect of the construction and this will naturally lead to more questions on our part that the licensee does not readily have available answers i

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Comanche Peak, Units 1 & 2 :

P (3) Nd.unresol.veditemswereescalatedtoenforcementitemsin1979.

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Corporate Management Involvement in Regulation Matters y

(1) The licensee always has senior site management available for the various interviews.

(2) The licensee sends all letters to us signed by the legally responsible co=pany officer.

(3) The site management appears very responsive to our inspection findings.

(4)

It is my i=pression, 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 effective:

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 Brown & 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-built condition.

If the engineer refuses, he is blamed for being to conser-vative and not responsive to the client's needs. Thus the driving force 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 inspected but terrible if they are not.

In a couple of cases, I have been able to show them that their i 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 U

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-j filling requirements.

In effect, the engineer has approved a noncon- _

forming installation in advance of QC being called. QC is then signing for the as-built condition and the underlying problem is not addressed.

.~...

Comanche Peak, Units 1 & 2,.

I'm not, at all sure that what CPSES is doing in this area is very e

different than what other utilities and/or engineers have done on other id projects but I don't like it.

I believe that much the same thing vent 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 I think he will take maximum advantage of part 50.55(e) and the past.

guidance to go through the necessary fonnalities 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.

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ATTACHMENT 2 l

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g NRC Staff Exhibit 180 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

{

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of TEXAS UTILITIES GENERATING COMPANY, )

Docket Nos. 50-445

_et _al.

)

50-446

)

(Comanche Peak Steam Electric

)

Station, Units 1 and 2)

)

SUPPLEMENTAL TESTIMONY OF WILLIAM A. CROSSMAN, ROBERT C. STEWART AND ROBERT G. TAYLOR REGARDING ANNUAL ASSESSMENTS OF APPLICANTS' PERFORMANCE (CONTENTION 5)

Q.1.

Mr. Crossman, in your direct testimony pre-filed on May 24, 1982, you stated (in answer to Question #12) that assessments of the Applicants' performance on an annual basis have determined that the Applicants have adequately developed and maintained a Quality Assurance / Quality Control ("QA/QC") program. Could you describe these " annual assessments" of the Applicants' performance?

A.1.

(Crossman) Yes. Starting in 1980, the NRC Staff initiated a

" Systematic Assessment of Licensee Performance" or "SALP" program.

The SALP program was implemented in accordance with the commitments of the " Action Plan for Implementing Recommendations of the President's Comission and Other Studies of the TMI-2 Accident."

The SALP is an integrated NRC Staff effort to collect available observations and data on an annual basis and to evaluate licensee performance utilizing such data and observations. The integrated systematic assessment is intended to be sufficiently diagnostic to

O.

provide a rational basis for allocating NRC resources and to pro-f

-vide meaningful guidance to licensee management.

The first "SALP" for Comanche Peak was conducted in 1980, covering the period August 1,1979 through July 31, 1980. That SALP involved evaluation of the licensee'sl/ performance during the appraisal period by a SALP " Review Board" consisting of Region IV management and inspectors as well as the NRC Office of Nuclear Reactor Regulation ("NRR") Project Manager for Comanche Peak. The SALP evaluated the licensee's performance in the following areas:

Enforcement history Status and Summary of Noncompliance Items Construction Deficiency Reports 4

Escalated Enforcement Action Licensee's Responsiveness and Ability to Take Meaningful Corrective Action Effectiveness and Attitudes of Licensee Personnel in Complying with NRC Requirements The SALP evaluation of licensee performance was discussed at a meeting with the TUGC0 corporate management. Inspection Report 80-25, November 12, 1980, (which is attached to this testimony as Staff Exhibit 181) documents that meeting and contains a

" Licensee Performance Evaluation." As indicated in Inspection

-1/

The Staff's testimony generally refers to Texas Utilities Generating Company, et al. ("TUGC0") as "the Applicants", since they have applied for TTeenses to operate Comanche Peak. However, since TUGCO, et al. have construction permits for Comanche Peak, Region IV docu-et al. as "the licensee." These ments may also refer to TUGCO, lii tWis testimony.

terms are used interchangeably

Report 80-25, that SALP concluded that the licensee's performance

(

was generally acceptable although continued improvement in certain areas would be desirable. On the basis of the evaluation, Region IV did not see a need to make any adjustments in the NRC inspection programs related to Comanche Peak.

The next SALP for Comanche Peak covered the period July 1, 1980 through June 30, 1981 and is documented in Inspection Report 81-20, April 27, 1982, (which is included as Exhibit 15 of the Staff's testimony pre-filed on May 24,1982). That report is the product of the revised NRC policy for the conduct of the SALP program.

That SALP evaluated the performance of the licensee in the following functional areas:

Piping Systems and Supports Safety-Related Components Support Systems Electrical Power Supply and Distribution Instrumentation and Control Systems Licensing Activities i

The SALP Board evaluation process consists of categorizing l

performance in each functional area. The three categories used are defined as follows:

Category 1.

A combination of attributes which demonstrates achievement of superior safety performance; i.e., licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are amply i

and effectively used such that a high level of performance with respect to operational safety or construction is being achieved. Reduced NRC attention may be appropriate.

l

Category 2.

A combination of attributes which demonstrates I

achievement of satisfactory safety performance; licensee management attention and involvement are evident and are con-cerned with r.uclear safety; licensee resources are adequate and are reasonably effective such that satisfactory performance with respect to operational safety or construction is being achieved. NRC attention should be maintained at normal levels.

Category 3.

A combination of attributes which demonstrates achievement of only minimally satisfactory safety performance; licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appear to be strained or not effectively used such that minimally satisfactory performance with respect to oper-ational safety or construction is being achieved. Both NRC and licensee attention should be increased.

The SALP documented in Inspection Report 81-20 concluded that the licensee demonstrated an overall combination of attributes exhibiting Category I performance during the appraisal period.

This evaluation was based upon the three primary areas where the construction efforts, and therefore, the NRC inspection effort, were directed; i.e., piping, electrical, and instrumentation installations.

In regard to the licensee's ongoing interactions with NRR, the consensus of the SALP Board was that the licensee managed these activities in a Category 2 mode.

Prior to the implementation of the SALP program in 1980, the NRC Region IV project inspectors prepared documents entitled " trend analyses" for Comanche Peak covering 1976, 1977, 1978 and 1979.

Copies of these analyses and related documents, are attached to this testimony as Staff Exhibits 182-195.

Q.2.

Why were such documents prepared?

A.2.

(Crossman) Starting in 1977, Mr. William C. Seidle, (then) Chief, Reactor Construction and Engineering Support Branch (Region IV),

requested by memo, that I, in my capacity as Chief, Projects Section, have the facilities inspectors prepare an analysis of the performance of each of their assigned licensees for the previous year. The specific areas to be considered included the following:

Number and repetitivene'ss of Construction Deficiency Reports.

Enforcement history, e.g., number and repetitiveness of non-compliance items.

Responsiveness of licensee to enforcement action Number of outstanding unresolved items - timeliness of resolution.

Corporate management involvement in regulatory matters.

Effectiveness of QA/QC programs.

Any other trends indicative of poor performance.

Since Mr. Robert C. Stewart was the Comanche Peak Project Inspector during the years 1976 and 1977, he analyzed Comanche Peak perfor-mance for 1976 and 1977.

In 1978 Mr. Robert G. Taylor became the Comanche Peak Resident Reactor Inspector and he did the analyses for Comanche Peak for 1978 and 1979.

Q.3.

Were such " trend analyses" official NRC inspections or audits 7 A.3.

(Crossman) No. All official activities related to a docket are l

documented in an inspection report and are made publicly available.

l The term " audit" does not appear within our procedures as a Staff activity where docket work is involved. Although the concept of

auditing as used in the nuclear industry and the Staff's concept of inspection are not significantly different, the tem "inspec-tion" is consistently used by the Staff. Also, inspection reports must be factual to the maximum extent and devoid of opinion as completely as possible.

In contrast, the analyses performed in response to Mr. Seidle's request consisted of both factual information, such as the number of Construction Deficiency Reports, and the opinions of the inspector on such items as repetitiveness, responsiveness, management involvement and effectiveness. I would point out that the analyses did not contain trends, but rather an assessment of the Applicants' perfomance for the pre-ceeding year. Those statements that might appear to be trends were, in reality, simply a sharpening of the inspector's perceptions of what usually were situations or conditions that had existed previously but were perhaps not apparent to him earlier.

Q.4 What was the purpose and use of the analyses?

A.4 (Crossman) The analyses were prepared to provide Mr. Seidle with infomation about licensee performance which would assist him in allocating the inspection resources available to him to achieve the I

greatest effectiveness. The analyses were prepared informally, were not transmitted to or otherwise made known to the Applicants, and were not made part of the official docket files.

Q.5.

Mr. Stewart, what did your 1976 analysis for Comanche Peak indicate?

e.

A.S.

(Stewart) The analysis indicated, with respect to " Responsiveness f

of Licensee to Enforcement Action," that although the licensee had been generally responsive to enforcement correspondence, I had, within that year, requested additional information in order to clarify corrective action taken by the licensee to preclude recur-rences. I indicated that although improvement was evident; at that time, an adequate level of confidence had not been fully achieved.

Concerning " Number of Unresolved Items - Timeliness Resolution;" it could not be demonstrated that items were cleared rapidly; however, the licensee had problems with Brown & Root ("B&R") in obtaining timely corrective measures, or adequate responsiveness to internal audit findings that generally affected the I&E unresolved matters.

With respect to " Corporate Management Involvement in Regulatory Matters," I noted that during the early part of 1976, it became apparent to me that the effectiveness of the licensee's QA/QC Program was in a state of degradation as a result of domineering and overpowering control by the contractor's site construction management.

Q.6.

Concerning your opinion about " Responsiveness of Licensee to Enforcement Action," has an adequate level of confidence ever been achieved?

A.6.

(Stewart) Yes. An adequate level of confidence was achieved in early 1977, based in part on the Applicants' change in senior

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management. The analyses for 1977, 1978 and 1979 evidence an pi

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. improvement in the responsiveness of the licensee to enforcement e

J ij action.

s Q.7.

Please explain what is meant by the phrases " state of degradation" a

and " domineering and overpowering control by the contractor's site construction management."

A.7.

(Stewart)

It wis my observation that the Brown & Root ("B&R")

construction management, from the foreman up through the site mariager, were demonstrating oppressive, domineering and intimidat-ing attitudes toward both TUGC0 QA and B&R QA/QC staff personnel.

At the time, there appeared to be no attempt to correct this unpleasant atmosphere by either TUGC0 or B&R corporate management; thus, my comment that "the licensee's QA/QC program is in a state of degradation."

Q.8, In view of the negative perceptions noted was any action taken by the NRC?

A.8.

(Stewart) On June 11, 1976, at the request of the Region IV staff, the President of Texas Utilities Generating Company / Texas Utilities Services, Inc. ("TUGCO/TUSI"), two Senior Vice-Presidents and the QA Manager met in conference at the NRC Region IV office in order to alert top management of the seriousness of the apparent breakdown in corporate management. Follow-on meetings were held July 30 and September 3,1976 (ref. Inspection Reports 76-08 and 76-09).

In addition, numerous informal discussions were held on and off-site

during the period September 1976 through January 1977. Later site t

inspections revealed sipns of a slow, but progressive, turn-around to a more effectual management control by the licensee; however, the matter remained an item of priority until a more satisfactory condition was demonstrated by the licensee. The licensee's corporate management agreed to additional meetings with members of the Region IV staff.

Q.9.

What transpired to reveal signs of a " slow, but progressive, turn-around to a more effectual management control by the licensee"?

A.9.

(Stewart) The following actions resulted in such a change:

1) The appointment of Mr. R. J. Gary, as Executive Vice-President and General Manager of TUGC0 on August 11, 1976;

2) A September 10, 1976 management change in Texas Utilities Services, Inc. ("TUSI") and TUGCO, in which new assignments were made in both the project and quality assurance areas.

3) The establishment of a TUSI Onsite Senior Staff Management Team in late 1976 and early 1977.

Q.10. Mr. Stewart, what did the 1977 analysis for Comanche Peak indicate?

A.10.(Stewart) Concerning the " Responsiveness of the Licensee to Enforcement Action," I noted that the licensee provided timely answers to our letters; that answers were not always adequate and that in certain instances we had to go back for more information; that any inadequate answers were not our fault; that corrective action was taken promptly and that the licensee was responsive.

4 With respect to " Unresolved Items," I noted that unresolved items were cleared rapidly; that neither the numbers of unresolved items nor the numbers of inspections were on the increase and that no unresolved items were escalated to enforcement items.

Regarding " Corporate Management Involvement In Regulation Matters,"

I believe that there was sufficient management representation at exit interviews; that the attitude of corporate management was receptive; that the signature on licensee letters was at the appropriate level, and that the Executive Vice-President and General Manager was personally involved in regulation matters.

Concerning the " Effectiveness of the QA/QC Program," it was my opinion that the contractor's QA/QC program was considered "too wieldy" in its structure and was undergoing progressive change by the licensee.

It was afso my opinion t' hat a significant organization and management change initiated January 3, 1978, would improve overall QA/QC program effectiveness.

I had no other perceptions indicative of poor performance.

Q.11. What did you mean by characterizing the contractor's QC program as "too wieldy" in its structure?

A.11.(Stewart) I meant that the contractor's QA/QC program procedure development resulted in the generation of too many procedures and instructions applicable to a particular construction activity which made it difficult for craf tsmen and inspectors to clearly understand and implement such procedures.

Q.12. What was the " progressive change by the licensee" to which you I'

referred?

A.12. (Stewart) I recall that a concerted effort by B&R was initiated to reduce the number of procedures (i.e., inspection, instruction and work procedures) by consolidation of procedures and instructions that improved the quality and adequacy of such procedures.

I believe that this change accounted in part for the fact that only three citations were issued to the Applicants in 1977.

Q.13. Describe the "significant organization and management change initiated January 3, 1978."

A.13.(Stewart) As indicated in the direct testimony pre-filed on May 24, 1982, during the first six (6) months of 1978, TUGC0 made a series of organizational changes which were considered to have a positive impact on the Comanche Peak QA program. At the same time, Texas Utilities Services, Inc. ("TUSI") implemented comparable changes to exercise greater control over engineering and construction. The active management of the B&R QA/QC staff was assumed by TUGC0 except I

for that work accomplished under the American Society of Mechanical Engineers ("ASME") code certification program. This reduced B&R headquarters QA involvement in on-site activities. Also, at that time, TUGC0 assumed management of the on-site soils and concrete 1

testing laboratory, formerly under a subcontract. A revised program description for QA during design and construction of Comanche Peak was submitted to the NRC on September 22, 1978, and accepted by the Office of Nuclear Reactor Regulation ("NRR") on

~

November 3, 1978. Region IV's audit of the Comanche Peak QA program was completed in December,1978 and the results are containedinNRCInspectionReport78-23(whichisincludedas Exhibit 14 of the St'aff's testimony pre-filed on May 24,1982).

i Q.14. Mr. Taylor, what did your 1978 analysis indicate?

A.14. (Taylor) With respect to " Responsiveness of the Licensee to Enforcement Action," I noted that the licensee had consistently met our date in its responses; that the licensee's responses were generally adequate, although we had to ask for additional informa-tion on two occasions.

(Inadequacies were for failure to provide a definitive commitment for action to prevent repetition); that no inadequate answers were the NRC's fault; that the licensee's corrective actions were in place on or before the dates committed to and that the licensee was fully responsive.

Concerning " Unresolved Items," I noted that unresolved items were generally cleared within one or two additional inspections, although some items took several months. It took several months to clear some items because I was unable to locate Westinghouse ("W")

l documentation on-site.

I also noted that " construction deficiency notices" were usually carried in the inspection reports issued prior to March or April,1980, as unresolved items for tracking i

purposes although other means of tracking were available and were i

utilized.

I didn't think that either the number of unresolved items or the number of inspections was on the increase. Also, I i

l l

noted that no unresolved items were converted to enforcement items

(

in 1978.

Insofar as " Corporate Management Involvement in Regulation Matters" was concerned, I noted that site management was always at the exit / management meetings; that site QA supervisory personnel were always prasent and construction personnel were usually represented by one or both of the Project General Managers and that it was not normal practice to have attendance from the Dallas office personnel.

I also stated my opinion that the attitude of corporate management toward regulatory matters was receptive and that the signature on licensee letters was at the appropriate level.

I also noted that the various levels of licensee management who should have been involved in the affairs of the project were involved. Also, I noted that the designated signatory for the licensee and the management person directly in charge of construction were well aware of problems and were helpful in correcting them on occasion.

Concerning the " Effectiveness of QA/QC Program," I stated my opinion

)

that the licensee's QA/QC program was generally effective.

I also t

stated my opinion that the QA/QC program was somewhat encumbered by too many procedures and occasionally by a lack of real talent to do the job correctly. I stated that instances of the latter were rare

}

but did show up occasionally in invalid Nonconformance Reports

("NCR") which in turn reflected that inspectors didn't really know what they were inspecting.

I also stated that in my particular l

l

situation, if I believed such inspectors were more than just a f

little ineffective, I would have been forced to attack the situation head-on.

I did not have any other negative perceptions indicative of poor performance.

Q.15. What did you mean by the statement that there was "a lack of-enough real talent to do the job correctly?"

A.15.(Taylor) I meant that some personnel who prepared procedures were somewhat inept in writing procedures. There was no documentation supporting my opinion.

In general, procedures containing only broad guidance are appropriate when the personnel using such proce-I dures are highly qualified. More specific procedures are required when the personnel using such procedures have lower qualifications.

Quality control personnel have been generally found to meet the requirements of the industry standard, N45.2.6., but would not necessarily be considered highly qualified.

It was my opinion that there was an imbalance between the degree of specificity in the QA/QC procedures and the level of qualifications of the personnel using such procedures. Had the imbalance between the degree of specificity in the procedures and the qualifications of personnel using such procedures been greater, the procedures would have been considered inadequate to meet Criterion V of 10 C.F.R. Part 50, Appendix B.

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=n Q.16. Mr. Taylor, what did your 1979 analysis indicate?

t A.16. With respect to the " Number and Repetitiveness of Construction Deficiency Reports," I noted that two items were officially t

categorized by the licensee as reportable pursuant to 10 C.F.R. 550.55(e)andthatthoseitemsdidnotappeartoberepetitive.

Concerning the " Responsiveness of the Licensee to Enforcement Action," I noted the following:

(1) The licensee was generally on time with responses to letters and when not able to do so, informed the NRC promptly; (2) The response letters were generally adequate as forwarded to the office. The licensee site QA personnel usually coordi-nated the answer with me prior to sending it to the office; (3) Any unsatisfactory answers given were not usually the licensee's fault, but also were not necessarily our fault either in terms of the way the noncompliance was written.

(It was primarily a matter of our wanting something a bit stronger for the record);

(4) My experience had been that the promised actions had been impleraented by the dates promised; (5) The licensee had been generally responsive to our findings.

I noted with respect to " Unresolved Items," that:

Unresolved Items (1) Unresolved items had gotten a bit out of hand since they were not being worked off very rapidly.

I had been promised increased attention would be paid to them.

(2) The numbers of unresolved items were on the increase, but I viewed this as normal at that stage of construction since they were now well into every aspect of construction and this would naturally lead to more questions on our part for which the licensee did not readily have available answers.

(3)Nounresolveditemswereescalatedtoenforcementitemsin 1979.

_ =

Insofar as " Corporate Management Involvement in Regulation Matters" t

was concerned, I stated that (1) The licensee always had senior site management available for the various interviews; (2) The licensee sent all letters to us signed by the legally responsible company officer; (3) The site management appeared very responsive to.our inspection findings; (4) It was my impression, based on discussions with the licensee's two Executive Vice-Presidents most involved with the construc-tion phase, that they were very involved and knowledgeable of our inspection findings.

I addressed the " Effectiveness of the QA/QC Program" in two parts.

In the first part, I discussed the overall theory of Quality Assurance as a management tool.

In this area, I stated that I believed that the licensee had been led down a poor path by Brown

& Root during past years.

It appeared to me that Brown & Root had, in many instances, pruvided construction procedures to fulfill I

10 C.F.R. Part 50, Appendix B that provided a minimum amount of direction to the construction force and yet cortplied with the words, if not the spirit, of Appendix B.

This would not be too bad if the construction force was really a competent group but would lead to some pretty bad things if that was not the case.

What I had begun to see, but had difficulty proving, was that the Brown & Root construction philosophy was to build something any way they wanted to and then leave it up to the engineer to document and approve the as-built condition.

If the engineer refused, he was blamed for being too conservative and not responsive to the client's

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i 17 needs. Thus, the driving force behind my request for a special I

engineering audit of site operations.

Secondly, I addressed Quality Control. I stated that only recently had 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 pro-cedures wer'e frequently pretty general, again, not too bad if the inspectors are knowledgeable in the subject being inspected, but terrible if. they are not.

In a couple of cases, I had been able to show them that their people were essentially incompetent even though they had been through the site training and had been certi-fied as competent. I saw a desire on the part of the licensee to turn this situation around in the important areas of electrical and piping installation. However, too often an installation was clearly constructed other than as originally designed and had been approved by the licensee's on-site engineering arm as fulfilling requirements.

In effect, the engineer had approved a nonconfoming installation in advance of QC being called. QC was then signing for the as-built condition and the underlying problem was not I

addressed.

l I stated that I wasn't at all sure that what CPSES was doing in this area was very different from what other utilities and/or engineers had done on other projects, but I didn't like it.

I l

l

e believed that much the same thing went on in Bechtel at Arkansas i

Nuclear One, Unit 2, but it wasn't as obvious nor was I there as much.

Finally, I noted that I didn't see any other problems not discussed above except possibly a future development in the public relations arena.

It seemed likely to me that the licensee would use its full powers to be less open with us in the area of identi-fied construction deficiencies than it had in the past.

I thought it would take maximum advantage of 10 C.F.R. 6 50.55(e) and the guidance to go through the necessary formalities but avoid, if at all possible, having to report to us.

I further stated that it was, of course, premature to really get into this arena until we proved a case.

Q.17. Mr. Taylor, you stated, with respect to " Responsiveness of Licensee to Enforcement Action," that "any unsatisfactory answers were not usually the licensee's fault, but also were not necessarily our fault either in terms of the way the noncompliance was written.

(It was primarily a matter of our wanting something a bit stronger for the record)." Please explain what you meant by the statement, "but also not necessarily our fault either in terms of the way the noncompliance was written."

A.17. I meant that because of the specificity required by 10 C.F.R.

l 2.201, a less than completely satisfactory response was obtained from the Applicants.

t Q.18. What did you mean by stating, "It was primarily a matter of our I

'wanting something a bit stronger for the record"?

A.18. I meant that occasionally, the Applicants' response was not capable of being audited and therefore, was not strong enough. However, 10 C,F.R. 5 2.201 does not impose any requirements for auditing.

Q.19. In discussing the "Effectivcness of QA/QC Program," you stated that you requested a "special engineering audit of site operations."

Was such an audit ever conducted?

A.19. Yes. Based on my recommendation, R. H. Brickley, of the Reactor Systems Section of the Vendor Program Branch, Region IV, was selected to do the audit, or more specifically, the inspection.

That inspection was made in early February 1980, and was docu-mented in NRC Inspection Report 80-04 (which is attached to this testimony as Staff Exhibit 196).

l Q.20. What was the purpose and result of that inspection?

A.20. The purpose of the inspection was to examine activities involving field instituted design changes. No items of noncompliance were identified.

Q.21. Concerning your perceptions regarding the " Effectiveness of the r

QA/QC Program," you stated, "In a couple of cases, I had been able to show them that their people were essentially incompetent even though they had been through the site training and had been certi-fied as ccmpetent." Who did "them" and "their" people refer to?

,_,,__m m

A.21. All official NP.C Actions are with the licensee (Applicants or TUGCO),

and may include their ager.ts, of which Brown & Root is one. In this specific instance, both the Applicants and Brcwn & Root were involved. Thus, I was referring to personnel employed by either the Applicants (TUGCO) or 3rown atd Root, Q.22. What personnel did you refer to when you stattd "they had been through site training..."?

A.22. I was referring to both "line itispectors" and their first tier of supervision.

0.23. Was this perception documented es an inspection finding?

A.23. Yes, AsindicatedinItemA,57.c.(p.65)oftheStaff'sdirect testimony, pre-filed on May 24,1982, NRC Inspection Report 79-18 contains this inspection finding. That inspection report is included as Staff Exhibit 70 to that testimony.

Q.24.'Did the Applicants take any action when you showed them that "their pecole were essentially incompetent..."?

A.24. The Applicepts interytewed, at length, the personnel involved and reviewed their respective backgrounds to order to gain a batter insight into trainifig needs, Additional training wps developed and provided by the Applicants' Quality Engineering grcup. The inspection procedures used by the QC persennel were substantially revised to provide more specificity. First tier supervision was enhanced by the selection of personnel with the background to

. appropriately guide the line personnel.

(The Applicants' correc-t tive actions, as well as the Staff's follow-up inspections, are discussed in detail in the Staff's direct testimony, pre-filed on May 24, 1982, Item A.58.c. (p. 89) and Item A.59.c. (pp. 94-95).

Q 25. You also stated, in discussing " Effectiveness of QA/QC Program,"

that "I saw a real desire on the part of the Licensee to turn this situation around in the important areas of electrical and piping

. installation." What specific actions of the licensee indicated this desire on the part of the licensee?

A.25. The statement " turn this situation around" was in reference to the imbalance between the levels of instructional detail in the inspec-tion procedures within the inspection force. The corrective actions described in A.24. above, indicated the desire on the part of the licensee "to turn this situation around."

Q.26. Was there a lack of desire on the part of the licensee "to turn this situation around" in activities other than electrical and piping installation?

A.26. No. The particular wording was chosen since the persons utilizing the analyses were aware that in 1979, piping and electrical instal-latiuns were just getting underway although some piping work had been done in 1978. The other principal activity, civil type con-struction, had been underway since 1975 and was much more refined.

. Q.27. Did the NRC approve the practice you perceived whereby it would be t

lef t up to an engineer to document and approve of the as-built condition of construction?

q A.27. The NRC neither specifically approves nor disapproves that practice. It is allowed by the last paragraph of Criterion III of Appendix B to 10 C.F.R. Part 50, subject to the requirement that the design changes be reviewed and approved in the same manner as was the original design.

Q.28. What was the concern expressed in the final sectjen of your 1979 analysis, relating to "the public relations arena"?

A.28. I was concerned that the Applicants would become reluctant to follow NRC guidance relative to reporting " potential" construction deficiencies, as described in 10 C.F.R. t 50.55(e). Such "poten-f tially" reportable items were recorded in the inspection reports.

I There were instances, which I can no longer specifically recall, when newspapers in the Dallas / Fort Worth area carried articles discussing these incidents.

Q.29. Did your prediction that the Applicants would be "less open" with the NRC "in the area of identified construction deficiencies" j

P i

develop?

I A.29. Yes. Two instances of " failure to report" were the subject of Notices of Violation included in NRC Inspection Reports 80-03/80-18 l

I (Staff Exhibits 54 and 112, respectively, to the Staff's pre-filed direct testimony of May 24,1982). Inspection Report 80-08, as t

well as the Applicants' corrective action and the NRC Staff's

follow-up inspection are discussed in the Staff's direct testimony pre-filed on May 24, 1982 on pp. 24, 28 and 33 respectively.

Inspection Rer M 19-18 is discussed in the Staff's direct testi-mony pre-filed on May 24, 1982, on pp. 54 and 59.

0.30. Gentlemen, your testimony documents fomal assessments of Applicants' performance (the "SALP" reports) as well as perceptions contained in the analyses made before the fomal assessments began.

Could you describe how Applicants' performance changed during this entire period?

A.30,(Crossman,StewartandTaylor) At the beginning of the analysis period, there was some question as to whether B&R was exercising domineering and overpcwering control over both TUGC0 QA and B&R QA/QC personnel. However, changes were made by the Applicants, the most important of which was the significant organization and management change initiated January 3, 1978 by which TUGC0 assumed active management of the Brown and Root ("B&R") QA/QC staff (except for work accomplished under the ASME code certification program). While some later weaknesses, as discussed herein, were noted, there was progressive improvement in the effectiveness of the QA/QC program as construction advanced.

Our cenclusions regarding the quality of construction have been summarized in the Staff's direct testimony pre-filed on May 2jr 1982, in Section V.

In reaching those conclusions, we considered the perceptions in the " trend analyses" as well as the later assessments documented in the "SALP" reports.

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U%iTE3 STATES

~I NUCLEAR REGULATORY COMMISSION

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/f sit RYAN PLAZA DRIVE. Suits tooo NRC Staff Exhibit III s

'S ARLINGTON. TEXAS N011 S,

November 12, 1980 l

In Reply Refer To:

4 g

RIV Docket No. 50-445/Rpt. 80-25 50-446/Rpt. 80-25 r

Texas Utilities Generating Company ATTN: Mr. R. J. Gary, Executive Vice President and General Manager 2001 Bryan Tower Dallai, Texas 75201 Gentlemen:

This refers to the meeting held by Messrs. K. V. Seyfrit, W. C. Seidle, W. A. Crossman and R. G. Taylor with you and other members of your staff on October 30, 1980, at your offices in Dallas, Texas, in regard to the regional evaluation of your performance as an NRC licensee.

In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room.

If the report contains any infomation that you believe to be proprietary, it is necessary that you submit a written application to this office, within 20 days of the date of this letter, requesting that such information be withheld from public disclosure. The application must include a full statement of the reasons why it is claimed that the infomation is proprietary.

The application should be prepared so that any proprietary information identified is contained in an enclosure to the application, since the application without the enclosure will also be placed in the Public Document Room.

If we do not hear from you in this j

regard within the specified period, the report will be placed in the Public l

Document Room.

l Should you have any questions concerning this inspection, we will be pleased to discuss them with you.

Sincerely,

[

g W. C. Seidle, Chief

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Reactor C6nstruction and Engineering Support Branch i

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Texas Utilities Generating J

Company Novemoer 12, 1980 h

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Enclosure:

IE Inspection Report No. 50-445/80-25 50-446/80-25 cc: w/ enclosure Texas Utilities Generating Company ATTN: Mr. H. C. Schmidt, Project Manager 2001 Bryan Tower Dallas, Texas 75201 i

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O. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT

~ REGIO, IV g

N Report No. 50-445/80-25; 50-446/80-25 Docket No. 50-445; 50-446 Category A2 Licensee: Texas Utilities Generating Company 2001 Bryan Tower Dallas, Texas 75201 Facility Name: ' Comanche Peak, Units 1 & 2 Meeting at: Dallas, Texas (October 30,1980)

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/t k A~1 NRC

Participants:

t K.

V'. Seyf rit, Direc egi'on IV Date r+

awn W. C. Seidle.[Cpief, Reactor Construction and Da'te' Engineering Wupport Branch

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W. A. Crossman, Chief, Projects Section Date

// 5l80 R. G. Taylor, Resident Reactor Inspector, Comanche Date Peak Station

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Ir//o/yn Date p S. B. BUrwell, Licensing Project Manager, NRR a;

1. /f!/tf Approved:

-W. A. Crossman, Chief, Projects Section Datb.

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Meeting Sum. mary:

Meeting on October 30, 1980 (Report No. 50-445/80-25;50-446/80-25)

Meeting Topics:

Announced meeting with TUGC0 corporate management concerning N

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Region IV's~(valuation of the licensee's performance.

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DETAILS 1.

Persons Attending Meeting k

Licensee-Participants g

R. J. Gary, Executive Vice President and General Manager, TUGC0 L. F. Fikar, Executive Vice President and General Manager, TUSI B. R. Clements, Vice President, Nuclear Operations, TUGC0 J. B. George, Vice President and Project General Manager, TUSI D. N. Chapman, Quality Assurance Manager, TUGC0 R. G. Tolson, Site Quality Assurance Super /isor, TUGC0 NRC Participants K. V. Seyfrit, Director, Region IV Office of Inspection and Enforcement W. C. Seidle, Chief, Reactor Construction and Engineering Support Branch W. A. Crossman, Chief, Projects Section R. G. Taylor, Resident Reactor Inspector, Comanche Peak Station S. B. Burwell, Project Manager, licensing Branch 2, NRR 2.

Meeting With Texas Utilities Generating Company Management a.

Purpose of Meeting The purpose of this meeting was to describe the regional evaluation under the Systematic Assessment of Licensee Performance program.

This evaluation is an intergal part of the Systematic Assessment Performance (SALP) program which is being implemented in accordance with the commitments of the " Action Plan for Implementing Recommen-dations of the President's Commission 'and Other Studies of the TMI-2 Accident." The attached Appendix B is the performance evaluation for the Comanche Peak facilities for the period August 1,1979, through July 31, 1980, compiled by the NRC participants and a Regional Review Board.

To begin the meeting, the Regional Director outlined the following objectives for the Systematic Assessment of Licensee Perfomance l

program:

Identify exceptional or unacceptable licensee performance Improve licensee performance Improve the IE inspection program l

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Provide and achieve a means of regional consistency in evaluating.

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- licensee perfomance I

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b.

Enforcement History The enforcement history for the Comanche Peak facilities was reviewed.,

Thg-following noncompliances, during the above stated review period, g wer,e identified by Region IV IE inspectors:

9e Personnel not properly trained and indoctrinated Failure to follow procedures for verification of the performance of automatic welding machines Failure to follow nonconformance procedures for electrical cable Failure to follow procedures for hoisting safety-related components Failure to update procedures Failure to provide appropriate instructions for installation of Class IE equipment Failure to follow welding procedures Failure to provide instructions and procedures appropriate to c

installation of Class IE battery chargers j

Failure to follow procedures for cable pulling Failure to follow procedures for reporting and repair of damaged electrical cable Failure to follow welding procedures Failure to follow electrical inspection procedures Failure to establish quality assurance program for Class 5 pipe support systems Failure to follow inspection procedure for returning inspection stamps Failure to follow inspection procedure to initial and date operations traveler Failure to report a significant construction deficiency (50.55(e))

- Failure to follow construction procedures required by drawings

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c.

Status and Summary of Noncomoliance Items The NRC participants stated that as of this time all of the above items have been closed out by subsequent inspections. The item in regard to the QA program for Class 5 pipe supports will be followed y

clo,sely during future on-going inspections since it involves a

's substantial backfit inspection effort on the part of the licensee.

J.

The NRC participants stated that 1689 NRC inspector-hours were consumed in 26 routine inspections at the Comanche Peak site. Based on the 17 items of noncompliance identified, this indicated about 100 inspector-hours were expended per noncompliance which is typical of an acceptable construction QA program but could not be rated as exceptional performance.

d.

Construction Deficiency Reports - 50.55(e)

The following construction deficiencies were reported by the licensee during the evaluation period in accordance with the requirements of 10 CFR 50.55(e):

Spacing of Concrete Anchor Bolts QA of Welded Conduit Supports QA of Seismic I (NNR) Pipe Supports Honeycomb of Unit 2 Containment Interior Walls Anchorage of Main Control Boards Material in Service Water System Valves The NRC participants indicated that it appeared that the licensee's threshold for reporting significant construction deficiencies to the NRC was appropriate and timely, particularly since the management meeting discussed in Inspection Report No. 50-445/80-12; 50-446/80-12.

e.

Escalated Enforcement Action An Imediate Action Letter was issued on September 7,1979, confirming a licensee decision to not place concrete in the wall to dome transition area of the Unit 2 Containment Building until such time as a proper engineering evaluation could be made of the omission and subsequent addition in another location of a group of reinforcing steel shear ties.

f.

Licensee's Responsiveness and Ability to Take Meaninoful Corrective Action The NRC participants indicated the following positions in regard to the licensee's response to various levels of NRC identified problems:

Bulletins and Circulars - The responses to this class has been i.,

adequate although much work still remains to be accomplished in ;

. regard to Bulletins 79-01 (Class IE Equipment Qualification) and L 79-02 (Pipe Support Systems). The licensee stated that they recognized that much work in these areas must be done and that

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they would fulfill requirements as construction progresses.,

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Enforcement Action Responses - The NRC personnel indicated that the licensee's responses have been concise, effective i

and to the point.

g.

Effectiveness and Attitudes of Licensee Personnel in Complying wi_th NRC Requirements Licensee Quality Assurance Personnel - The NRC personnel stated that the overall impression was that the licensee had upgraded

{

the quality of their personnel at all levels during the past 1

two years.

Licensee Construction and Engineering Management - The NRC personnel stated that it appears there is a continuing tendency to engineer away construction problems rather than enforce compliance to drawings and specifications. The licensee stated that he is taking several management actions with the engineering and construction personnel to alleviate this situation. The NRC personnel stated that there was no specific regulatory concern since safety does not appear to have been compromised as yet but could possibly be sometime in the future if appropriate actions were not taken as indicated above.

Brown and Root Quality Assurance - The NRC personnel stated that overall abilities of the Brown and Root QA personnel appeared to have been improved during the past year, in part because of much improved procedural direction being given to them.

Brown and Root Construction Supervision and Labor Force - The NRC participants indicated that their impression of this area indicated that there is a need to make this group more aware of nuclear power plant construction requirements. That there is a considerable difference to those of a conventional fossil plant. The licensee responded that he has issued instructions to Brown and Root to reduce the labor crew size reporting to foremen and the number of crews reporting to general foremen. The licensee stated that it is expected that this will provide increased control over the quality affecting actions of the. labor force.

3.

Sumary of Licensee Perfomance The Region IV Director, at the conclusion of the meeting, emphasized that the licensee has the principal and legal responsibility for all matters regarding the construction and operations of a nuclear power plant as specified in the law and in the Regulations.

Corporate management is essential in all phases of the project to assure appropriate execution of the licensee's responsibilities.

The licensee responded that he is aware i.

of his responsibilitie.s and that in response to these responsibilities, y

he continuously increased his involvement in the project during the past e

three years until he is now essentially in complete control of the project '

The licensee except for the imediate line supervision of the labor force.

indicated that as new or additional involvement becomes necessary, he will i

respond accordingly.

j i

The Director stated that the region's evaluation of the licensee per-fomance is that it is generally acceptable although continued improve-ment in certain areas, already discussed, would certainly be desirable.

k The Dire.ctor stated that, on the basis of the evaluation, Region IV does 5

not currently see a need to make any adjustments in the IE inspection 1

program as it relates to the Comanche Peak facilities.

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APPENDIX B k

LICENSEE PER'IORMANCE EVALUATION (CONSTRUCTION)

Facility:

Comanche Peak Steam Electric Station Licensee:

Texas Utilities Generating Company I

Unit Identification:

Occket No.

CP No.'/Date of Issuance Unit No.

50-445 CPPR-126/ December 19, 1974 1

50-446 CPPR-127/ December 19, 1974 2

i Reactor Information:

Unit 1 Unit 2 Unit 3 NSSS Westinghouse Westinghouse MWe 3411 3411 Appraisal Period:

August 1,1979, through July 31, 1980 Aopraisal Comotetion Date:

October 2, 1980 Review Board Memeers:

L W. C. Seidle, Chief, Reactor Construction & Engineering Supeort Branch, RI$

W. A. Crassman, Chief, Projects Section, RIV u

R. E. Hall, Chief Engineering Support Section, RIV R. G. Taylor, Senior Resident Reactor Inspector (CPSES), RIV R. C. Stewart, Reactor Inspector, Projects Section, RIV

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S. B. Burwell, Project Manager,, NRR'

'.NRR Project Manager was contacted in regard to panel review, but did not have

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3 APPENDIX B 2-k A

Number _and Nature of Noncemoliance Items 4

NoncompIiance Category:

Unit 1 Unit 2 Unit 3

• 0 0

Violations 13 8

Infractions Deficiencies 3-4 Areas of Noncompliance:

Unit 1 Unit 2 Unit 3 (List Areas as Required)

(Points)

(Points)

(Points) 20 10 QA/ Management 52 42 Piping and Hangers Electrical Equipment 24 4

Electrical Cable / Tray 40 30 2

Reporting Total Points 136 88 i

B.

Numcer and Nature of Deficiency Recerts

1. Spacing of Concrete Anchor Bolts

2. QA of Welded Conduit Supports

3. QA of Seismic I (NNR) Pipe Supports

4. Honeycomb of Unit 2 Containment Interior Walls

5. Anchorage of Main Control Boards

6. Material in Service Water System Valves C.

Escalated Enforcement Actions l

Civil Penalties None Orcers None

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Immediate Acticn Letten_

September 7, 1979: Omission of Unit 2 Containment. Shear Ties

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APPENDIX B

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IF S

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Management Conferences Held During Past Twelve Months h

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April - 8,1980:

Discuss 50.55(e) Reporting Requirements s

E.

Justification of Evaluations of Functional Areas Categorized as Recuiring an increase in Inscection Frecuency/Scoce (see evaluation sneet)

The review board considered an Increased Inspection Frequency and/or Scope for Items 6 (Piping & Hangers) and 9 (Electrical - Tray & Wire) since they represented the most dominate problem areas encountered during the past year.

The board reviewed the IE inspection history and determined that most of the enforcement actions in these areas had occurred relatively early in the review period and that the licensee's actions appeared to have been effective.

On this basis, the board detennined that an increase of inspection and/or scope was not warranted at this time.

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f APPENDIX B 4

(

Inspection g

Frecuency and/or Scoce J

FUNCTIONAL AREA INCREASE NO. CHANGE DECREASE 1.

Quality Assurance, Management & Trainin9 X

(complete) 2.

Substructure & Foundations 1

3.

Concrete X

4.

Liner (Containment & Others)

(complete) 5.

Safety-Related Structures X

6.

Piping & Hangers (Reactor Coolant

& Others)

X*

7.

Safety-Related Components (Vessel, f

Internals & HVAC)

X 8.

Electrical Equipment X

9.

Electrical (Tray & Wire)

X*

10.

Instrumentation X

11.

Fire Protection X

12.

Preservice Inspection X

13.

Reporting X

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• See Item E for discussion of these items

NRC Staff Exhibit /96r 3- -,- ;

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" rna r.-:.:=wn.s.: r i:r R.r.s eN.trxu nm Tabruary 29, 1980 In Reply Refer To:

RIV Docket No. 50-445/Rpt 80-04 50-446/Rpt 80-04 Texas Utilities Generating Company ATTN: Mr. R. J. Gary, Executive Vice President and General Manager 2001 Bryan Tower Dallas, Texas 75201 Gentlemen:

This refers to the inspection conducted by R. R. Brickley of our staff on Tebruary 11-15, 1980, of activities authorized by NRC Construction Permits No. CPPR-126 and 127 for the Comanche Peak facility, Units No.1 and 2, and to the discussion of our findings with Mr. R. G. Tolson and other members of your staff at the conclusion of the inspection.

Areas ev= mined during the inspection and our findings-are discussed in the Within these areas, the inspection consisted l

enclosed inspection report.

of selective examination of procedures and representative records, inter-l views with personnel, and observations by the inspector.

l Within the scope of the inspection, no items of noncompliance were identi-I fied.

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In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's.Public Document If the report contains any information that you believe to be pro-prietary. it is necessary that you submit a written application to this Room.

office, within 20 days of the date of this letter, requesting that such The application utst information be withheld from public disclosure.

include a full statement of the reasons why it is claimed that the informa-The application should be prepared so that any tion is proprietary.

proprietary information identified is contained in an enclosure to the application, since the application without the enclosure will also be If we do not hear from you in this placed in the Public Document Room.

regard within the specified period, the report will be placed in the Public Document Room.

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February 29, 1980 Should you have any questions concerning this inspection, we will be pleased to discuss them with you.

Sincerely, N/ /[

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W. C. Seidl Chief Rasctor Co tion and Engineering Support Branch

Enclosure:

IE Inspection Report No. 50-445/80-04 50-446/80-04 cc: v/ enclosure Texas Utilities Generating Company ATIN: Mr. H. C. Schmidt, Project Manager 2001 Bryan Tower Dallas, Texas 75201 o

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U. S. NUCLEAR REGULATORY C0!9 FISSION OFFICE OF INSPECTION AND ENFORCE!!ENT REGION IV I

Report No. 50-445/80-04; 50-446/80-04 Docket No.- 50-445; 50-446 Category A2 Licensee: Texas Utilities Generating Company 2001 Bryan Tower Dallas, Texas 75202 Facility Name: Comanche Peak, Units 1 and 2 Inspection at: Glen Rose Texas, Comanche Peak Site Inspection conducted: February 11-15, 1980 1

~bb Inspector:

Date R. H.'Bt'ickley, Pridei' pal Inspector Vendor Inspection Branch 2*88' 8 Other Date Accompaning D. G. Breaux, Intern Inspector Personnel Vendor Inspection Branch

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Approved:

d Date C. J. Hal'e, Chief, Pr6 gram Evaluation Section Vendor Inspection Branch l

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' Date W. A. Crossman, Chief, Projects Section, RC & ESB Inspection Susanary Inspection on February 11-15, 1980 (Report No. 50-445/80-04; 50-446/80-04) j Areas Inspected: Routine, unannounced inspection of activities involving field instituted design changes. The inspection involved thirty-two inspector-hours on site by one NRC inspector.

Results: No items of noncompliance were identified.

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l DETAILS SECTION A.

Persons Contacted J. L. Ainsworth, Supervisor, Quality Engineering (TUGCO)

G. R. Hiler, Area Mechanical Engineer (BER)

R. E. Holloway, Technical Services Supervisor (GEH)

B. J. Hurray, Project Mechanical Engineer (TUSI)

J. K. Saltarelli, Piping Engineer (B&R)

D. G. Sutton, Civil Engineer (B&R)

• R. G. Tolson, Site QA/QC Supervisor (TUGCO)

A. Vega, Senior Engineer, QA Division (TUGCO)

R. B. Williams, Project Civil Engineer (TUSI)

• Denotes presence at the exit interview.

B.

Design Change Control 1.

Objectives The objectives of this area of the inspection were to verify that:

Procedures have been established and implemented for con-a.

trolling changes to approved design documents.

b.

Design changes are:

(1) reviewed for the impact of the change (2) documentedastotheactiontaken,and (3) transmitted to all affected persons and organizations.

The design changes are justified and subjected to review and c.

approval by the same groups or organizations as for the original design (see d. below for exceptions).

d.

When respo'nsibility has been changed, the designated organiza-tion shall have access to the pertinent information, com-petence in the specific area of design, and an understanding l

of the requirements and intent of the original design.

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Method of Accomplishment The preceding objectives were accomplished by an examination of:

Chapter 17.1 of the Texas Utilities Services Inc. (TUSI),

a.

Comanche Peak Steam Electric Station (CPSES), FSAR to determine programmatic requirements.

b.

The following procedures from the project procedures manual:

(1) CP-EP-30 (Comanche Peak Project Engineering Organization)

Rev. 0 (2) CP-EP-4.0 (Design Control General Requirements) Rev. 1 l

(3) CP-EP-4.1 (Design Planning) Rev. 1 (4) CP-EI-4.1-1 (Field Support Design Group Design Control l

Instruction) Rev. 1 l

(5) CP-EP-4.2 (Design Interface Control) Rev. 1 1-(6) CP-EP-4.3 (Design Input) Rev.1 I

(7) CP-EP-4.5 (Design Verification) Rev. 0 CP-EI-4.5-1 (Technical Services Instruction for Perforn-(8) ing Engineering Analysis of As Built Hanger Baseplates)

Rev. 0 (9) CP-EI-4.5-2 (On Site Hanger Design Group Engineering Instruction) Rev. 0 (10) CP-EI-4.5-3 (Field Support Design Group Review Instruction for Field Analyzed Piping and Supports) Rev. 0 (l'1) CP-EP-4.6 (Field Design Change Control Procedure) Rev. 2 1

(12) CP-EI-4.6-1 (Field Design Change Control Instruction) l Rev. I and Rev. 2 r

(13) CP-EI-4.6-2 (Application of the CMC Fors to Pipe Hanger Base Plates) Rev. 0 (14) CP-EP-13 (Field Support Design Group Document Control Procedure) Rev. 0 l

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3 (15) CP-EP-16.3 (Design on Hanger Design, Fabrication and Installation Activities) Rev. O Texas Utilities Generating Co. (TUGCO) Procedure CP-QP-16.0 c.

(Nonconformances and Deficiencies) Rev. 2 d.

Brown & Root Procedures CP-CPM-6.10 (Inspected Ites Removal Notice) Rev. 1, and CP-QAP-16.1 (Control of Nonconforming Items) Rev. O TUGC0 QA Audit Report TCP-6 (Audit of Site Engineering e.

Activities) f.

The following Design Change / Design Deviation Authorizations (DC/DDA):

(1) No. 2437 for drawing 2323-El-0601-01-S Rev. 2 dated April 13, 1978.

(2) No. 2432 dated August 30, 1978, for specification 2323-MS-84 Rev. O dated August 5, 1978, stating that the required seismic calculations were needed for daspers CPI-VADPCK-01-04, CP2-VADPCK-01-04, and CPX-VADPCK-01-04. The in-spector verfied that the required calculations were supplied to TUGC0 by Gibbs & Hill Inc., Dallas via letters No. DAL-582 dated January 9, 1979, and DAL-769 dated May 25, 1979.

(3) No. 4445 Rev. I for drawing 2323-SI-0630 Rev. 2 (4) No. 4483 Rev. 2 dated January 10, 1980, for drawing 2323-M1-0506-01 Rev. 11, 2323-M1-0507 Rev. 12, 2323-M2-0506-1 Rev. 3, and 2323-M2-0507 Rev. 3.

The inspector verfied that GER had reviewed and approved the DC/DDA via their Design /

Engineering / Change / Deviation Request (DECD) No. 5-1421 Rev. 1.

(5) No. 4495 dated April 30, 1979, for drawing 2323-51-0535 regarding rebar anchorage deficiencies. The inspector verified that G&H had provided, per letter No. GTN-21908 dated October 18, 1977, a procedure for determining the quantity and length of the additional reinforcing steel needed to supplement rebars with inadequate anchorage.

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i (6) No. 4471 dated April 26, 1979, for drawing 2323-51-0624 The inspector verified that G&H had reviewed Rev. 21.

and approved this DC/DDA and documented their actions via TWX-11004 and DAX-862.

(7) No. 4428 dated April 23, 1979, for drawings 2323-5-0718 and 2323-S-0720. The DC/DDA Mast'er Index indicated that G&H had reviewed and approved this DC/DDA and documented their actions via their DECD No. N-10537 dated June 22, 1979. A copy of the DECD was not in the TUGC0 files.

(8) No. 4424 dated April 23, 1979, for drawing 2323-5-0744 The DC/DDA Master Index indicated that Rev. 2.

G&H had reviewed and approved this DC/DDA and documented their actions via their DECD No. S-11798 dated June 25, 1979. A copy of the DECD was not in the TUGC0 files.

(9) No. 4420 dated April 23, 1979, for drawing 2323-52-0549 The DC/DDA Master Index indicated that Rev. 2.

G&H had reviewed and approved this DC/DDA and documented their actions via their DECD No. S-12799 dated June 25, 1979. A copy of this DECD.was_not.in.the TUGC0 files.

The DC/DDA Master Index issued by GGH showing the status 3

or completion of G&H design review action.

The following Component Modification Cards.(CMC):

h.

(1) No. 12921 Rev. O dated January 25, 1980, for drawing SW-1-027-007-J03R.

(2) No. 13138 Rev. O dated January 22, 1980, for drawing l'

CS-1-250-003-553.

(3) No. 13149 Rev. O dated January 19, 1980, fer drawing CH-1-226-002-S43R.

(4) No. 13183 Rev. O dated January 28, 1980, for drawing DD-1-016-018-533K.

(5) No. 10812 Rev. O dated October 31, 1979, for drawing BRP-SW-1-DG.

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(6) No. 10832 Rev. O dated November 19, 1979, Rev. I dated December 7, 1979, and Rev. 2 dated February 1, 1980, for drawing BRP-CC-ISB-004 Rev. 7.

(7) No. 10843 Rev. O dated December 3, 1979, and Rev. I dated January 16, 1980, for drawing RRP-RH-1-SB-04 Rev. 0 (8) No. 10857 Rev. O dated November 12, 1979, Rev. I dated November 16, 1979, and Rev. 2 dated November 20, 1979, for drawing RRP-SFX-TB-003B Rev. 3.

(9) 'No. 13877 Rev. O dated November 20, 1979, through Rev. 4 dated January 14, 1980, for' drawing BRP-CH-X-FB-005 Rev. 2.

(10) No. 10920 Rev. O dated October 31, 1979, through Rev. 4 dated November 26, 1979, for drawings 2323-M1-0233 Rev. 5, 2323-M1-1103 Rev. 11, and BRP-SW-1-SI-005 Rev. 13.

(11) No.13508 pated January 26, 1980, for drawing CC-X-013-002-A43R.

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TUSI semorandum (CMC Sign-Off Authorization) dated November 28, 1979, and other such memorandum to verify.that authorized personnel had. approved the CMCs_ listed under paragraph.hJahnve..__. _. _

j.

The following Nonconformance Reports (NCR):

(1) No. E-1497 (Cable Tray Hanger) dated June 18, 1979.

l (2) No. H-1681 (Pipe Spool No. 6; dervice Water) dated October 26, 1979.

(3) No. 5-1857 (Piping, C&VCS) dated December 7,1979.

(4) No. 5-1874 (Piping, C&VCS) dated December 10, 1979.

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G&H letter No. GTN-20096 dated July 18, 1977, GTN-29770 dated August 31, 1978, and GTN-31475 dated November 13, 1978, authorizing G&H field personnel to approve nonconformances i

prior to their review and approval by the G&H Engineering Department.

1.

A draft copy of an engineering instruction (Procedure for Transmitting CMCs/DCAs for Design Review by Respective Original Design Organizations) dated February 5,1980.

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Findings a.

General l

The examination of the report (paragraph B.2.e. above)

(1) of a TUGCO audit conducted early this year revealed that a thorough audit had been conducted of field design activities. A comparison of NRC identified procedural weaknesses with the audit findings revealed that they had been identified by the TUGCO auditors. Management representatives stated that they were aware of the audit findings and were actively revising their procedures to eliminate the identified deficiencies. A schedule for completion of these activities had not been established at the time of this inspection.

(2) The examination of the DC/DDAs and CMCs revealed that these two documents are being used for the following:

(a) Design changes initiated by the original design organization.

(b) Field design changes resulting from interference problems.

(c) Design changes resulting from Nonconformance Reports (NCR) issued as a result of a construction error, i

an error in a vendor supplied item, construction damage, etc.

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(3) The inspector was unable to determine from the DC/DDA and CMC forms that changes resulted from an NCR. The 4

NCRs presented to the inspector for examination did indicate that the disposition was via a particular DC/DDA.

With respect to NCRs, manage. ment representatives stated The that a trend analysis program is under development.

initial areas to be covered are welding and records with additional areas to be identified later.

(4) Personnel approving DC/DDAs and CMCs had been properly authorized.

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f (5) Although approved by authorized field personnel, CNCs No. 12921, 13138, 13149, 13183, and 13508 had not been design reviewed by the original design organization at the time of this inspection. Time did not permit the i

verification of original design organization review for CMCs No. 10812, 10832, 10843, 10857, 10877, and 10929.

b.

Noncompliances None identified Deviations and Unresolved Items c.

None identified d.

Follow-Up Items A reinspection of the design change control activities shall be scheduled at a future time dependent upon completion of procedural revisions and their implementation.

C.

Management Interview An exit interview was held by the RRI with management representatives (denoted in paragraph A) on February 19, 1980. The RRI suonarized the Comments were generally for scope and findings of the inspection.

clarification only, or acknowledgement of the statements by the inspector.

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ATTACHMENT 3 l

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l AFR 2 71982 In Reply Refer To:

Dockats: 50 445/81-20 50-446/81-20 Texas Utilities Generating Company ATU:

R. J. Gazy, Executive Vica President and Genersi Manager 2001 Bryan Tower callas, Texas 75201 Gentlemen:

This refers to the Systamatic Assessment of Licansee Per#cr=anca (SALP) Board Recort of the Ccmanene Peak Facility, Units 1 and 2, Construction Femits CPOR-125 and CPcR-127. The SALP Board met on Septacter 1,1981, to evaluata the perfor:anca of the subject facility for the period July 1,1980, through Jur.e 30,1981. The perfceancs analyses and resulting evaluation are doc:mented in the enclosed SALP Eoard Report. These analyses and eval-uation wrw discussed with you at your of*ica in Dallas, Texas, on October 9, 1981.

The per ermance of ycur facility was evaluated in the following functional d

Piping Systams and Supeorts; Safety-Related Cca:conents; Support Systams; areas:

ElectMesi Power Supply and Distribution; Instrzentation and Control Sys ams; and Licensing Activities.

The SALo Board evaluation process consists of catagorizing per omance in each d

I furetional area. The estagoMas which we have used to evaluata the er#omanca of your facility are defined in Section II of the enclosed SAL? Scart Report.

As you are aware, the NRC has changed the policy for the conduct of the SALP program based on our exceMences and the recently imolementaa recrgani:ation which emenasi:ss the regionali:atien of the NRC staf". This report is the product cf the revised policy.

On AoH1 1, 1982, you were recuestad to provide corments concarning our eval-uatien of your facility. In that 20 days have passed, and no coments have been recaived, the SALP Board Report is being issued as an NRC Repcrt.

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Should you have any questions concerning this letter, we will be pleased to discuss them with you.

5inearely, C:1." -~'

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John T. Collins Regional Administntor

Enclosure:

Accendix - NRC Report 50 445/81-20 50 446/81-20 cc:

Texas Utilities Generating Ca::pany ATTN: li. C. Senmidt, Project Manager 20013ryan Tcwer Dallas, Texas 75201 bc: to CMB (IE01):

BC FM AECD ELD IE FILE IE/CRRRI/RPRI3 NRR/0HF3 NRR/CHF5/0L3 NRR/CL3/RAB RE5 L?OR PCR:HO NSIC NTIS bec distrib. by RI'l:

R. Taylor, RRI Juanita Ellis, CASE 0 ).elley, RRI Cavid Preistar, Asst. At::r.ey Genersl IAT. A. Crossman, RFS-B Ricnard Fouke J. T. Collins, RA C. Wisner, PA0 Info Systams RFB2 7:3 Texas Stata Cect. Heal n J. M. Tayler, 0/R9

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