ML20212K663
| ML20212K663 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/21/1987 |
| From: | Ellis J Citizens Association for Sound Energy |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#187-2312 OL, NUDOCS 8701290146 | |
| Download: ML20212K663 (44) | |
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2 3/ z-UNITED STATES OF AMERICA NUCLEAR REGULATORY COPHISSION 1/21/87 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In t6a Matter of Docket Nos. 50-445' CC and 50-446-o4 TEXAS UTILITIES ELECTRIC COMPANY, ~et al.
(Applicationforan
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(Comanche Peak Steam Electric Operating License)
Station, Units 1 and 2)
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h c8 CASE'S MOTION TO COMPEL NRC STAFF TO SUPPLEMENT -
Sg RESPONSES TO QUESTION 1 0F CASE'S 2/10/82 M
M4 FIRST SET OF INTERROGATORIES AND o
REQUESTS TO PRODUCE TO NRC STAFF
]
S BACKGROUlm On February 10, 1982, CASE filed its First Set of Interrogatories and Requests to Produce to NRC Staff. We now find it necessary to request the Board's assi' stance in securing responses to interrogatories and documents which we believe clearly should have already been provided to CASE by the Staff. We are setting forth the background leading to this Motion in some detail, since it occurred during the time when the Licensing Board was constituted differently from its current members except for Dr. McCollom.
Included in our First Set of interrogatories was the following question:
"1.
(Quoted 10 CFR, Part 50, Appendix B,Section XVIII, AUDITS)...
please answer the following:
"(a) Has the NRC conducted any audits to detect trends that may be detrimental to safe station operation at CPSES?
"(b) If the answer to (a) above is yes, supply for copying and inspection all such audits, or advise how CASE can obtain them through the Public Document Room.
If the audits themselves are not provided, please provide a list of the specific documents so that we can obtain them from the PDR.
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"(c) If the answer to (a) above is no, has the NRC conducted any unofficial audits (i.e., perhaps not actual audits but efforts to detect such trends) for this purpose?
"(d) If the answer to (c) above is yes, supply for copying and inspection all such documents, or advise how CASE can obtain them through the PDR.
If the documents themselves are not provided, please provide a list of the specific documents so that we can obtain them from the PDR."
The Staff agreed to file written answers to all of CASE's interrogatories to which the Staff did not object ft/. The Staff did not object to Interrogatory 1 of CASE's First Set, and the following sworn answers were provided to Interrogatories 1(a), 1(c), and 1(d) by Robert G.
Taylor, then-NRC Resident Inspector at Comanche Peak /2,/.
"l(a)
"This interrogatory asks whether the NRC Staff conducted any
' audits' to detect trends that may be detrimental to safe station operation at CPSES (Comanche Peak Steam Electric Station, Units 1 and 2).
"The provisions of 10 CFR Part 50, Appendix B, Section XVIII, apply to the Applicants' Quality Assuranco/0uality Control program and do not impose any requirements on the NRC Staff. The Staff does carry out a comprehensive program of documented inspections at the site, through the Resident Inspector and the Region IV Staff.
In addition, the Staff makes a ' Systematic Assessment of Licensee Performance' ('SALP') which is also documented. The last documented 'SALP' was conducted at Comanche Peak on October 30, 1980 and is documented in Report Nos. '50-445/Rpt. 80-25' and '50-446/Rpt. 80-25', November 12, 1980. The most recent 'SALP' at Comanche Peak covera the period from mid-1980 to mid-1981 and will be documented in Report 81-20.
/ lf See MRC staff's 3/10/82 Answers to CASE's First and Second Sets of Interrogatories on Contention 5 and NRC Staff Motion for a Protective Order, hereinafter referred to as " Staff's 1/10/82 Answers," at page 4.
fj/ Seo NRC Staff's 3/10/82 Answers, first and second pages of NRC Staff Answers folicwing 8 page legal brief. An unsigned affidavit by Mr.
Taylor was submitted with the Staf f's 3/10/82 Answers, and a copy of Mr.
Taylor's sworn signed, notarized affidavit was sont to the Board and Service List under cover letter dated March 16, 1982. We assume that Interrogatory 1(b) w1s provided by the NRC Staf f counsel.
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"1(b)
"This interrogatory requests that all ' audits' be provided for copying and that the Staff advise CASE how CASE may obtain such
' audits' from the Public Document Room (PDR).
"NRC Staff inspections are documented in inspection reports which are issued by the Staff and made available to the public in the Commission's Public Document Room (PDR) and Local Public Document Room (LPDR). The 'SALP' reports issued by the Staff are-also made available in the PDR and LPDR (Footnote 1 omitted.]
Thus, these documents are available to CASE, as well as the members of the public, at the PDR, LPDR and ' mini-LPDR.'
In addition, CASE's representative (Mrs. Ellis) is also on (NRC)
Region IV office's distribution list for inspection reports and any 'SALP' reports and is personally sent copies of such reports by Region IV.
"l(c)
"This interrogatory inquires whether the NRC Staff has conducted any ' unofficial audits (i.e., perhaps not actual audits but efforts to detect such trends)'..."
"The Staff has not conducted any ' unofficial audits' at Comanche Peak.
"l(d)
No answer to this interrogatory is necessary, since it applies only if the answer to (c) above is yes."
In CASE's 3/22/82 Motion to Compel NRC Staff to Provide Complete Answers to CASE's First and Second Set of Interrogatories and Requests to Produce and Answer to NRC Staff's Motion For a Protective Order, CASE stated (page 10):
" CASE had always been under the impression that the Staff or NRC personnel inside the Region IV office were doing trending to detect trends that may be detrimental to safe station operation at CPSES. Our Interrogatory If (sic -- should be 1) of our 2/10/82 First Set to NRC Staff dealt specifically with this, and we specifically explained that we did not mean just audits (or paper trails) but any trending about construction at Comanche Peak --
about concrete, welding, or any other trending. This was made specifically clear during our conference call with the NRC 2/18/82 ar.d again when the writer talked by phone to (NRC Staff Counsell Ms. Rothschild 2/23/82." (Emphasis in the original.)
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"The Staff's answer to our Interrogatory 1 Indicates that the I&E Reports and the ' Systematic Assessment of Licensee i
Performance' ('SALP') are the only documented efforts the NRC Staff has made in this regard, and that the type of trending CASE had believed was being done at the Region IV office was not being done...."
l It was not until April 13, 1982 (following the first day of the April 13-15 NRC Caseload Forecast Panel meeting, sur3ary of which was sent to the Service List under cover letter of July 7, 1982) that NRC Staff counsel Ms.
Rothschild handed CASE's Mrs. Ellis copies of documents prepared by NRC Region IV which contained precisely the kind of trending information which CASE had believed was being done at Region IV and which we had been seeking when we originally filed our First Set of Interrogatories on February 10, 1982.
Those documents (which were called " Trend Analysis") contained extremely damaging information, which presented a far different picture of Applicants and their QANC program at Comanche Peak than had ever been indicated by the NRC Etaff -- and certainly far dif ferent from anything which was indicated in the Staff's profiled testimony for the then-upcoming hearings. The Staff sisbsequently filed Supplemental Testimony to their profiled testimony for the June 1982 hearings, and introduced the trending documents into evidence as part of that testimony M/. The trending documents provided to CASE following the April 1982 Caseload 1
f_3/ Hearings continued in July 1982: seet 7/27/82 Tr. 2320 et seq.; and NRC Supplemental Testimony of William A. Crossman, Robert C. Stewart, and Robert G. Taylor Regarding the Annual Assessments of the Applicants' Performance (Contentior. 5), NRC Staff Exhibit No. 180, and attachments thereto, Exhibits 181 through 196.
4
o f
M Forecast Panel meeting were included as NRC Staff Exhibits 182 through 195; we are attaching copies of those exhibits for the convenience of the Board l_4 /.
Those trend analyses covered the years 1976 through 1979, and were prepared by NRC Staff Witnesses Robert C. Stewart (NRC Resident Inspector at Comanche Peak during 1976-1977) and Robert G. Taylor (NRC Resident Inspector at Comanche Peak during 1978-1979 and throughout most the hearings in these proceedings)15/.
Included in the damaging statements made in those trend analyses were the following:
From 1976 Trend Analysis, NRC Staff Exhibit 184, page 1:
"During the early part of 1976, it became apparent to the Principal Inspector that the effectiveness of the licensee's OA/0C Program was in a state of degradation as a result of a domineering and overpowering control by the contractor's site construction management.
"On June 11, 1976, at the request of the Region IV staff, the President of TUCCO/TUSI, two Senior Vice Presidents and the OA Manager met in conference at the NRC regional 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. IE Inspection Reports 76-08 & 76-09).
In addition, numerous informal discussions Were held on and of f site during the period September 1976 thru 1977...."
d/ CASE also requested from the Staff and received additional responses regarding the trending documents received in April 1982; noe CASE's 4/20/82 Third Set of Interrogatories and Requests To Produce To NRC Staf f, 5/4/82 Letter f rom NRC Staf f Counsel Harjorie U. Rothschild To CASE's Mrs. Ellis, and NRC Staff's 5/7/82 Additional Answers to CASE's Third Set of Interrogatories on Contention 5.
15/
Soe_Tr. 2358/1-12.
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a From 1979 Trend Analysis, NRC Exhibit 195, Items f and g, pages 2 and 3:
"f.
Effectiveness of 0A/0C 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 pro /ide a minimum amount of direction to the contruction 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 too conservative and not responsive to the client's needs. Thun the driving force behind my request for a special sngineering audit of site operations.
"The second part of the addressment is to that phase called OC.
Only recently has there been a real effort on the part of the licensee itself, or on the part of Brown & Root, to writo 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 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 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 licensen's on-site engineering arm as fulfilling requirements.
In effect, the engineer has approved a nonconforming installation in advance of OC being called. OC is then signing for the as-built condition and the underlying problem is not addressed.
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s "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 u= in the area of identified construction deficiencies than he has in the past.
I think he will take maximum advantage of part 50.55(e) and the guidance to go through the necessary formalities 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."
It was difficult for CASE to accept the explanation given for the withholding of the trending analyses, and as demonstrated by the following portions of the transcript of the 7/27/82 hearings, it appears clear that then-Licensing Board Chairman Miller also had trouble with the explanation given by Mr. Taylor.
See especially Tr. 2364/24-2373/23, et seq.; quoting from the transcript, after Mr. Taylor had repeated CASE's interrogatory 1(c) for the record (Tr. 2367/14-2368/14):
"BY MS. ELLIS:
"Q.
... And in a telephone conference discussion with the NRC Statf and myself, wasn't it made clear that what we had in mind was any sort of trending that had been done by the NRC Staf f ?
"BY WITNESS TAYLOR:
l "A.
Again semantics, sorry.
I realize that the documents that were prepared for -- by me, by Mr. Stewart, during the period of 1976 to -
'75, '76, '77, '78, were labeled as trend analyses.
They were in fact not trend analyses.
"Mr. Seidle's choice of the label for that particular document was his choice. The questions he asked, that we reponded (sic) to, were his questions, but they do not develop trends.
"Now, by the time you asked the interrogatory about two years had gone by, and we simply had forgotten them.
"Q.
But the title of the document is trend analysis?
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a "BY WITNESS TAYLORt "A.
Trend analysis, I agree, ma'am.
"MS. ROTHSCHILD:
Mr. Chairman?
" JUDGE MILLER:
Yes.
"MS. ROTHSCHILD:
I would like to object to further questioning along these lines.
" JUDGE MILLER: The objection will be overruled.
I'll save you the trouble. We do find this question of semantics to be troubleacme. We think that the Staff, whoever is responsible, should have certainly gone beyond the form, and if you're talking about trend analyses by anyone we think the informa: ion should have been produced."
CASE has gone into this much detail so that the Board has a clear picture of exactly how the matter of trending or trend analyses by NRC Region IV developed, and to emphasize the importance CASE obviously placed on such analyses.
It was also our understanding, from everything we had been told and which is in the record of these proceedings, that such trending or trend analyses (i.e., any efforts by NRC Region IV to detect trends that may be detrimental to safe station operation at CPSES) were no longer being portormed by NRC Retton IV except as contained in NRC Region IV Inspection Reports or SALP Reports.
It never occurred to CASE that we should specifically request supplementation of the Staff's response to interrogatory 1 of our First Set of Interrogatories under the Board's 1/31/84 Memorandum and Order (Continuing obligation to Update Interrogatories); had
>.a had any idea that there was the possibility that such trending was again being po-formed, we certainly would have done so.
8
r MOTION TO COMPEL CASE was very disturbed by the withholding by NRC Region IV of the trend analyses, as discussed in the preceeding; to say the least, it did little to inspire confidence in the NRC or its regional office. Additional loss of confidence by CASE in NRC Region IV occurred because of other testimony on these proceedings during the hearings on design issues f6/.
It is especially disturbing to learn that withholding of information specifically requested in previous interrogatories was still occurring at least as recently as the time of preparation of Inspection Report 85-07/85-05 in 1985 and early 1986; we are again very disturbed to find that apparently the regional office has performed similar trend analyses regarding Comanche Peak, and that they have again withheld this information.
In the OIA Report recently sent to the Board and Survice List, in the REPORT OF INVESTICATION -- Allegations of !!!sconduct by Region IV Management With
,RespecttotheComanchePeakSteamElectricStation/7/,onpage4,bottam j
of page, continued on page 5, it is stated:
" Inspection Report 50-445/85-07: 50-446/85-05 (85-07/05) j
"(Blacked out) told OIA he was directed to drop a trend analysis of the NRC inspection program at CPSES from inspection report 85-f6/ See in particular pages VII-21 through VII-23 and XXVII-30 through XXVII-51 of CASE's 8/22/83 Proposed Findings of Fact and Conclusions of Law (Walsh/Doylo Allegations) regarding testimony of NRC Staff Witness Taylor about the amount of reinforcing steel which was left out of concrete at Comanche Peak.
/ 7,/ Board Notification No. 86-24 Report of Investigation by the Office of Inspector and Auditor, sent to the Board and Service List under cover letter 12/11/86 from NRC Staff's Mr. Noonan.
9 i
e 07/05.
(Blacked out) was asked by (blacked out) to do a trend analysis of the NRC inspection program at CPSES to include violations and unresolved items.
(Blacked out) said (blacked out) wanted to review unresolved items at CPSES that had been documented during Region IV inspections to determine if any of them should have been violations.
(Blacked out) believed (blacked out) wanted this information because (blacked out) suspected violations were reported as unresolved items so TUGC0 would not inve to formally document corrective action and would not be required to determine the cause of the deficiency or take corrective action.
(31acked out) believed this could allow an inadequate QA program to go undetected.
(Blacked out) stated his trend analysis revealed adverse trends which should have been identif*.e4 osring NRC inspections.
He added that these trends were comparable to the problems with the TUCCO OA program, which were later identified by NRC Construction Assessment Team (CAT) inspection repset 83-18/12 and the NRC TRT.
It appeared to (blacked out) that many inspection violations had been handled as unresolved items.
"The regults of the trend analysis performed by (blacked'out) weru documented in a January 13, 1986, memorandum f rom (blacked out)
(Attachment E).
(Blacked out) also included the results of the trend analysis as item lH in a draf t of inspection report 85-07/05 (Attachment F).
(Blacked out) said (blacked out) directed him to delete the paragraph on the trend analysis f rom inspection report 85-07/05 because the analysis would subject the NRC to embarrassing questions.
Because the paragraph did not contain any violations or unresolved items, (blacked out) dropped the paragraph. However, (blacked out) later learned (blacked out) did this without (blacked out) concurrence.
(Blacked out) thought (blacked out) wanted the results of the analysis in inspection report 85-07/05, and (blacked out) also thought the results should be documented in the report because the work was done during the inspection period (Attachment B, pages 37-40, and 76-85)."
(Emphases added.)
It appears obvious that this trend analysis (and any other similar analyses) should have been provided to CASE in reponse to our previous interrogatories filed in 1982.
Based upon the record of these proceedings 10 u
s and the information contained in the recent OIA Report, it is now CASE's belief that the following constitute material false statements:
(1) the withholding of the 1976-1979 Trend Analyses; (2) the misinformation that such trending was no longer being performed other than as set forth in NRC Inspection Reports or SALP Reports; (3) the withholding of the trending recently identified in the OIA Report; and (4) the testimony of the NRC Staff witness discussed at page VII-22 and XXVII-44 through XXVII-48 of CASE's 8/22/83 Proposed Findings regarding the amount of reinforcing steel left out of the concrete at Comanche Peak. We request that the Board ask the NRC's Office of Investigations to make a determination of whether or not these do indeed legally constitute material false statements.
We also move that the board order the NRC Staff to immediately [8/
supply CASE with all trend analyses (by whatever name) similar to those discussed 'n the recent OIA Report, along with all internal memoranda, handwritten notes (identified as to the writer's name, title, etc.), and any other relevant documents regarding such trend analyses (including, but not limited to, the January 13, 1986 Memorandum from (blacked out) Attachment E, and draft inspection report 85-07/05 (Attachment F), which were mentioned specifically in the first full paragraph on page 5 of the OIA report).
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It is our understanding that af forts are now underway to get all of the recent DIA Report (hopefully uncensored), including all of the back-up information which is part of the entire report, into the hands of the Board and parties. llowever, CASE maintains that there is no valid reason for the trending documents to have been withheld f rom CASE in the first place, and no valid reason for further delay in supplying them to CASE.
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7 In addition, we move that the board order the NRC Staff to respond anew to the following portions of CASE's questions 1(a) through (d), insofar as they pertain to documents and information not already provided to CASE:
"1.
. please answer the following:
"(a) Has the NRC conducted any audits to detect trends that may be detrimental to safe station operation at CPSES?
"(b) If the answer to (a) above is yes, supply for copying and inspection all such audits... If the audits themselves are not provided, please provide a list of the specific documents so that we can obtain them from the PDR.
"(c) If the answer to (a) above is no, has the NRC conducted any unofficial audits (i.e., perhaps not actual audits but efforts to detect such trends) for this purpose?
"(d) If the answer to (c) above is yes, supply for copying and inspection all such documents... If the documents themselves are not provided, please provide a list of the specific documents so that we can obtain them from the PDR."
CASE can then ascertain whether or not there have been additional trend analyses performed but withheld (not specifically identified in the OTA Report), and obtain them and related relevant documents.
Respectfully submitted, b A n., i E
($ ^-
Utre.) Juanita Ellig, President
/ CASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 i
214/946-9446 12 l
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DOCKETED UiNPC
'87 JAN 27 P3 :25 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
[
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
}{
}{
TEXAS UTILITIES ELECTRIC
}{
Docket Nos. 50-445 COMPANY, et, al.
}{
and 50-446 (Comanche Peak Steam Electric
}{
Station, Units 1 and 2)
}{
CERTIFICATE OF SERVICE By my signature below, I hereby certify that true and correct copies of CASE's Motion to Compel NRC Staff to Supplement Responses to Question 1 of CASE's 2/10/82 First Set of Interrogatories and Requests to Produce to NRC Staff 21st 7
have been sent to the names listed below this day of January
,g9g""",
by: Express Hall where Indicated by
- and First Class Hall elsewhere.
Administrative Judge Peter B. Bloch Nicholas S. Reynolds, Esq.
U. S. Nuclear Regulatory Commlaslon Bishop, Liberman, Cook, Purcell Atomic Safety & Licensing Board
& Reynolds Washington, D. C.
20555 1200 - 17th St., N. W.
Washington, D.C.
20036 Judge Elizabeth B. Johnson Oak Ridge National Laboratory Geary S. Mizuno Esq.
P. O. Box X, Building 3500 office of Executive Legal Oak Ridge, Tennessee 37830 Director U. S. Nuclest Regulatory Dr. Kenneth A. McCollom Commission 1107 West Knapp Street Washington, D. C.
20555 Stillwater, Oklahoma 74075 Dr. Walter H. Jordan Chairman, Atomic Safety and Licensing Carib Terrace Board Panel 552 North Ocean Doulevard U. S. Nuclear Regulatory Commission Pompano Beach, Florida 33062 Washington, D. C.
20555 1
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Chairman Renea Hicks, Esq.
Atomic Safety and Licensing Appeal Assistant Attorney General Board Panel Environmental Protection Division U. S. Nuclear Regulatory Commission Supreme Court Building Washington, D. C.
20555 Austin, Texas 78711 Mr. Robert Martin Anthony Z. Roisman, Esq.
Regional Administrator, Region IV Trial Lawyers for Public Justice U. S. Nuclear Regulatory Commission 2000 P Street, N. W., Suite 611 611 Ryan Plaza Dr., Suite 1000 Washington, D. C.
20036 Arlington, Texas 76011 Mr. Herman Alderman Lanny A. Sinkin Staff Engineer Christic Institute Advisory Committee for Reactor 1324 North Capitol Street Safeguards (MS H-1016)
Washington, D. C.
20002 U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Dr. David H. Boltz 2012 S. Polk Dallas, Texas 75224 Robert A. Wooldridge, Esq.
Worsham, Forsythe, Sampels William Counsil, Vice President
& Wooldridge Texas Utilities Generating Company 2001 Bryan Tower, Suite 3200 Skyway Tower Dallas, Texas 75201 400 North Olive St., L.B. 81 Dallas, Texas 75201 Thomas G. Dignan, Jr., Esq.
Ropes & Gray Docketing and Service Section 225 Franklin Street (3 copies)
Boston, Massachusetts 02110 Office of the Secretary U. S. Nuclear Regulatory Commission Ms. Nancy H. Williams Washington, D. C.
20555 Project Manager Cygna Energy Services Ms. Billie P. Garde 101 California Street, Suite 1000 Government Accountability Project San Francisco, California Midwest Office 94111-5894 3424 N. Marcos Lane Appleton, Wisconsin 54911 Mark D. Nozette, Counselor at Law Roy P. Lessy, Jr., Esq.
Heron, Burchette, Ruckert & Rothwell Wright & Talisman, P. C.
1025 Thomas Jefferson Street, N. W.,
1050 Seventeenth St., N.W.
Suite 700 Washington, D. C.
20036-5566 Washington, D. C.
20007 k*/L
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r-(Mrs.) Juanita Ellis, President CA'SE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 2
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t NRC Staff Exhibit II1 4
1 UNITED tTATES NUCLE AR REGULATORY CoMMIS$10N v'
QFPICE OF INSPECTION AND ENFORCEMENT REGION IV
$11 RYAN PL AZA DRIVE sulTE 1000 ARLINGTON, TE X A1 76012 January 4, 1977 f
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W. /.. Cross =an, Chief, Projects Section IRE S A: tai
- ISIS - 1976 The start of a new year is a good time to step back and take a look at the perfor=ance of our assigned licensees during the past year.
if, in our evaluation, we detect negative trends, then we should promptly arrange through regional supervision to discuss these findings with corporate management.
~
Please re:;uest your Facilities Inspectors to conduct a trend analysis 6f the perfor=ance of each of their assigned " active" licensees during calendar year 1976.
Specific areas to be considered should include:
- Nu=ber and repetitiveness of Construction Deficiency Reports.
- Enforcement history, e.g., number and repetitiveness of non-compliance ite=s.
- Responsiveness' of licenses to enforcement action.
- Nu=her of outstanding unresolved items - timeliness of resolution.
- Corporate management involvement in regulatory matters.
- Iffectiveness of QA/QC programs.
- Any other trends indicative of poor perfor. ance.
Please forward ycur writtan evaluations to me be COB January 28, 1977.
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W. C. SeidleT Chief Reactor Construction and 4
Engineering Support Branch I
cc:
R. E. Hall W. E. Vetter
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NRC Staff Exhibit II3 I
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UNITED ST 8.TE:
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NUCLE A34 A(GU6 ATOMY cov'.18SSION jf'.k.T'['Y "
$11 RYAN PLAZA D48VE. SUITE 1000 a
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?~w,~ /f T,.y.,* ** p January 14, 1977 n
W. G. Hubacek R. G. Taylor R. C. Stewart C. R. Oberg,,-
FROM:
W. A. Crossman, Chief, Projects Section
SUBJECT:
TRIND ANALYSIS - 1976 Enclosed is a memo from Bill Seidle concerning licensee performance trend analysis.
To answer his questions please provide the following CY 76 information.
a.
Number and Repetiveness of Construction Deficiency Reports (I have this information already) b.
Enforcement History For each facility list:
(1)
Inspection Report Number (2)
Dates of Inspection (3)
Number of Violation (4)
Number of Infractions (5) Number of Deficiencies (6)
Number of Deviations (7) Mandays involved (for that inspection)
(4)
Re= arks (indicate if repeat from 1976 and 1975)
(b)
Number of outstanding unresolved itees c.
Responsiveness of Licensee to Enforcement Action p,.
(1)
Is licensee on time with answer to our letter?
(2)
Are answers adequate? Do we have to go back for more information?
(3)
Is corrective action done promptly?
(4) Are any inadequate answers our fault?
i-(5)
Is the licensee responsive in your opinion? Why?
c'
?
.f
, 1 d.
3:urberofUnresolvedIte=s-TirelinessResolution Et
~il)
- unbers are given in b.(9) above.
I (2)
Are unresolved items cleared rapidly?
(3)
Average time to clear, j
(4)
Are nu=bers/ inspection on the increase? Why?
e.
Corocra:e Management Involvement in Reculation Matters (1)
Sufficient management representation of exits?
(2)
Attitude receptive?
(3)
Signature on licensee letters appropriate level?
(4)
Is management involved?
(indicate, basis for answer) f.
Effectiveness of QA/QC Program This is a very subjective matter.
I desire your own opinion and what you base your opinion on.
If too early in construction phase to state, indicate this. Also indicate what you believe we can do to have them improve their program.
B.
Anv Other Trends Indicative of Poor Performance List and discuss any other indications that may point out poor /
good performance.
As a last item, give me your general reco=mendation on advisability of holding a periodic management meeting with all licensees to discuss past performance and identify possible problems for the licensee to avoid.
As indicated in the enclosure, this is to be your assessment of your
" active" facilities.
Please have your information to me by CO3 on January 25, 1977.
= = = :- z w W. A. Crossman, Chief Projects Section
- r.
Enclosure:
As stated I
cc:
W. C. Seidle i
.m.
.r.
NRC Staff Exhibit /fot TREND ANALYSIS COMANCHE PEAK, UNITS 1 & 2 b.
Eiforcement History u
See attachment c.
Responsiveness of Licensee to Enforcement Action Although the licensee has been generally responsive to enforcement correspondence, the Principal Inspector has, within the past year, requested additional information in order to clarify corrective action taken in order to preclude recurrences.
In addition, informal dis-cussions were held with the cognizant licensee representatives in order to have the licensee improve a general weakness in providing a reply that is fully responsive to each of the three basic questions contained in the notice. An improvement has been evident; however, an adequate level of confidence has not been fully achieved.
d.
Number of Unresolved Items - Timeliness Resolution The IE inspection reports indicate sixteen (16) unresolved items iden-tified during the past twelve (12) months.
It can not be demonstrated that items are cleared rapidly; however, the licensee has had problems with their contractor (Brown & Root) in obtaining timely corrective measures, or adequate responsiveness to internal audit findings that generally impact on IE unresolved matters.
(see paragraph f below) e,f&g.
Corocrate Manacement Involvement in Reculatory Matters During the early part of 1976, it became apparent to the Principal Inspector that the effectiveness of the licensee's QA/QC Program was in a state of degradation as a result of a domineering and overpowering control by the contractor's site construction management.
On June 11, 1976, at the request of the Region IV staff, the President of TUGC0/TUSI, two Senior Vice Presidents and the QA Manager met in conference at the NRC regional 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. IE Inspection Reports 76-08 & 76-09).
In addition, numerous informal i
discussions were held on and off site during the period September 1976 thru January 1977.
Recent site inspections have revealed signs of a slow, but progressive, turn-around to a more effectual management control by the licensee; however, the matter remains an item of priority 1
I. _ _
until a more satisfactory condition is demonstrated by the licensee.
Additional meetings with the licensee corporate management have been mutually agreed to. The next meeting is tentatively scheduled for the second week in February 1977.
tt P~riodic management type meetings with licensees are always useful; e
A however, they should be tied to specific problems if possible since the utility top management's time is valuable.
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CONSTRUCTION DEFICIENCY REPORTS 1976-t u
4 e
ANO 4/28 6/29 10/27 Waterford 3 7/6 8/18 Comanche Peak 1 4/9 9/20 Comanche Peak 2 9/20 South Texas 1 South Texas 2 River Bend 1 10/4 River Bend 2 Wolf Creek 1 Ft. Calhoun 2 Black Fox 1 Black Fox 2 Allens Creek 1 Blue Hills 1 Blue Hills 2 l
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.y wucLt AR necutArony covwssics NRC Staff Eihibit 185-
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REGION IV E, ')?'[
- g 511 RYAN PL AZA DRIVE.SutTE 10'30
- I[- [ % [;f A R LINGT oN, TEX AS 76011 Janua y 6,1978
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-1 14EP.0RANDUM FOR:
W. G. Hubacek R. G. Taylor R. C. Stewart C. R. Oberg FROM:
W. A. Crossman, Chief, Projects Section
SUBJECT:
TREND ANALYSIS - 1977 Please perform a trend analysis of the performance o'f each of your assigned
" active" licensees for the calendar year 1977.
In cases where responsibility for licensees is being reassigned, the inspector who was responsible for the-licensee in calendar year 1977 will prepare the analysis.
Your analysis should incluce the following information:
a.
Number and Recetiveness of Construction Deficiency Reports b.
Enforcerent History For each facility list:
(1)
Inspection Report Number (2)
Dates of Inspection (3)
Nurter of Violations (4)
Nurser of Infractions (5)
Hu ser of Deficiencies (6)
Nunber of Deviations (7)
P.andays involved (for that inspection)
(8)
Renarks (indicate if repeat from 1977 and 1976)
(9)
Nurber of unresolved items c.
Resoonsiveness of Licensee to Enforcement Action (1)
Is licensee on time with answer to our letter?
(2) Are answers adequate?
Do we have to go back for more information?
(3) Are any inadequate answers our fault?
(4) 15 corrective action done promptly?
4 (5)
Is the licensee responsive?
?
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7
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Irspectors - Projects Section January 6,1978 d.
Unresolved Items hg
'd '
s (1)
Are unresolved items cleared rapidly?
1 Are numbers / inspection on the increase?
Why?r riumber of unresolved items escalated to enforcement items.
e.
Corporate Management Involvement in Reculation Matters (1) Sufficient management representation at exit interviews?
(2) Attitude receptive?
(3)
Signature on licensee letters appropriate level?
(4)
Is management involved?
(Indicate basis for answer) f.
Effectiveness of OA/0C Procram This is a very subjective matter.
I desire your own opinion and basis for your opinion. -If too early in construction phase to state, indicate this.
Also indicate what you believe we can do to have them improve their program. This information should not be included in the documented analysis, but you should be prepared to discuss it_with Mr. Seidle.
g.
Any Other Trends Indicative of Poor Performance List and discuss any other indications that may point out poor / good performance.
Please have your information to me by CC3 on January 31, 1978.
//M W. A. Crossman, Chief Projects Section cc:
W. C. Seidle b
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UNITE D 51 AT EL
.t NUCLE AR REGVL atony COWILSIOP.
REGION IV i
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sii RYAN plaza ORivE. suite iooo NRC Staff Exhibit II6
.4
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MEMORANDUM FOR:
K. V. Seyfrit. Director FROM:
W. C. Seidle, Chief RC&ES Branch
SUBJECT:
USE OF LICENSEE PERFORMANCE EVALUATION INFORMATION, MEMO 10/3/78, DAVIS TO SEYFRIT In response to the subject memorandum, the attached Trend Analysis in-formation generated for those facilities assigned to the RC&ES Branch during the year 1976 and 1977 is provided for your information.
I initiated this on-going analysis in ntv memorandum to W. A. Crossman dated January 4,1977, a copy of which is attached.
You will note in Crossman's implementation memorandum of January 6,1978, page 2, para-graph f (copy attached) that I discuss each facility with the assigned project inspector.
If you have any specific questions regarding this matter, I would be pleased to discuss them with you.
,/
/
M(WL W. C. Seidl Chief Reactor Construction and Engineering Support Branch i
Attachments:
1 Memo dated 1/4/77. W. C. Seidle to W. A. Crossman Memo dated 1/6/78, W. A. Crossman to Project Inspectors Trend Analysis Book - 1976 and 1977 1
T
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4 NRC Staff Exhibit IIT Comanche Peak, Units 1 & 2 TREND ANALYSIS - 1977 a.
Number and Repetiveness of Construction Deficiency ~ Reports El Y
None reported.
E b.
Enforcement History (Seeattachedsheet) c.
Responsiveness of Licensee to Enforcement Action (1)
Yes.
(2) Yes.and No.
(3) No.
(4)
Yes.
(5) Yes, d.
Unresolved Items (1) Yes.
(2) No.
(3) None.
e.
Corporate Management Involvement in Reculation Matters (1) Yes.
(2).Yes.
(3) Yes.
(4)
Yes, Executive Vice President & General Manager is personally involved.
f.
Effectiveness of QA/0C Program j
The. contractors QA/QC Program is considered to be "too wieldy" in its 4 structure and is undergoing progressive chance by the licensee.
A 3
significant organization and management change initiated January 3, r
1978, should improve overall QA/QC Program effectiveness.
g.
Any Other Trends Indicative of Poor Performance None.
r' f
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T Comanche Peak, Units 1 & 2 Enforcement h1 Report}
Dates V_
I_
D_
D M/D U
Remarks
{
77-01 1/18-21 & 2/2-4 0
0 0
0 13.5 1
77-02 3/01-04 0
2 0
1
- 9. 6 1
Investigation 77-03 3/15-18 0
0 0
0 11.3 0
77-04 4/26-28 0
0 0
0 3.6 1
77-05 4/26-27 0
0 0
0
- 1. 6 1
77-06 5/10, 11, & 13 0
0 0
0 6.9 0
77-07 6/07-09 0
0 0
0 6.1 0
77-08 7/05-08
.0 0
0 0
7.1 1
77-09 8/16-19 0
0 0
0 10.8 2
77-10 9/27-30 0
1 1
0 3.5 2
77-11 10/11-14 0
0 0
0 6.8 3
77-12
.11/07 0 0
0 0
- 3. 8 0
77-13 11/28-12/2 0
0 0
0 17.4 1
77-14 12/15 & 16 0
0 0
0
- 3. 0 0
Investigation TOTALS
.0 3
1 1
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NRC Staff Exhibit II9 February 2,1979 4
a, HEMORANDUM-FOR:
W. G. Hubacek R. C. Stewart h
q R. G. Taylor C. R. Oberg ji FROM:
W. A. Crossman, Chief. Projects Section
SUBJECT:
TREND ANALYSIS - 1978 Please. perform a trend analysis of the perfonmance ef aach of your asslyned '. active" Jicenseas for the calendar yaar1978. -In cases where responsib115ty for11censees is.being ruas. signed; the inspector who was responsible Tor the licensee in~;malandar, year 1978 erill tre-4G pare the analysis. xTour analysis shoG1d.4nclude"the following infor-mation:
24
- +ij
.! ra. /. lumber and :Repet'iveness af tonstruction' Deficiency Reports
.b..Anforcement Mistory 3
?.
li for ancl. facility list:
f
- 1) Inspection Report haber 4
- 2) Dates of Inspection
..'y F *Q
- 3) -Wumber af Violations d
4 Emnbar af infractions
.D 15 9(wi>er.af Deficiencies J6
-*taberaf Seviations
'g
'h 47 *andays involved (for that inspection) 18 'Ramarks (indicate if repeat Trte 1978 and 1977) 1 1
J3kanber of.amresolved items j
c.
Responsiveness of Licensee to Enforcement Action y.,
D (1) -is licensee en time with answer to our letter?
- ..Y
- 12).Are answers. adequate? Do we have to go back for more infor -
U
-mationT
^ j " 4)
Are arty inadequate answers ourfault?
As corrective eetion done Srunptly7 111e the licensee responsive?
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February 2,1979
, Inspectors - Projects Section
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d.
- Unreso.1ved itecs_
, j 'd d rapidly?
-[he unresolved items cleare ilhy?
L Are ntsnbers/inspectf on or, the increase? Numb (1
i
(
Corporate Management Involvement in Regulation Natters _
it interviews?
e.
. Sufficient managunent representation at ex (1
Attitude receptive? Signature on licensee letters app (2
(3 Is management involved?
i (4
- 1.,..Effactiveness of CA/QC Program J
i ion -and 3 bis-is -a very.aubjective matter. 2 desire you
.].
.t can do
. stateiindicate this. Hiso indicate what you believe we c.
j This information should not d
to have 1. hem deprove their program.
- included in the documented analysis, but you should be p
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3 ato discuss 1tarith Mr. Seidle.
- r..
Anyttkr T.s.ds Indicative of Poor Perfonnance l
.. z _-
/ ood
' List snd.*fiscuss any ether indications that any point out po
.3 performance.
28, 1979.
-flease have your infonnation to me by COB on Tebruary
~
tm' so-=a e,y w. A c-Al A. Crossman, Chief frejects Section
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NRC Staff Exhibit 190 UNITED sT ATEs
'c, NUCLE AR REGULATORY COMMISSION y,,,., *< *g RE GION IV 611 RY AN PL AZ A DRIVE. 5UIT E 1000 V
a
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ARLINGTON, T E x A5 76012 as,o*
October 19,1979 Pi;i
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MEMORANDUMFOR:fW. A. Crossman, Chief, Projects Section R. C. Stewart, Reactor Inspector, Projects Section FROM:
TREND ANALYSIS - 1978
SUBJECT:
The attached infortnation is provided you in response to your memorandum, same The information, prepared by each of the subject, dated February 2, 1979. assigned project inspectors, include active construction status durine CY 1978.
0
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i R. C. Stew
, Reactor Inspector Projects Section m
3 b
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NRC Staff Exhibit 19 1 Con.anche Feak Units 1 & 2, ON 50 a45; 50-446 TREND ANALYSIS P:P
~
Number 6f itepetitiveness of Construction Deficiency Reoorts g >d a.
The licensee reported a total of six potential construction deficienciesTh (50.55(e)) items during calendar year 1978.
I do not consider that any of these items to be fully reportable CDNs.
any of these items to have been of repetitive nature.
b.
Enforcement History (See attached sheet)
Responsiveness of Licensee to Enforcement Action _
c.
The licensee has consistently met our date in his responses.
(1)
The licensee's responses are generally adequate, although we have ha Inadequacies were (2) to ask for additional information on two occasions.for failu repetition.
a (3)
No The licensee's corrective actions have been in place on or before the (4) dates committed to.
On subjective basis, I would consider the licensee to be fully (5) responsive.
d.
Unresolved Items Unresolved items have generally been cleared within one or two ad These are inspections although some items have taken several months.
(1) generally as a result of being unable to locate W documentation Also note that CONS are usually carried in the reports as unresolved items for tracking purposes.
Without the benefit of last years report on Comanche Peak and without a good deal of research, I cannot be sure but I don't think that th (2) is the case.
No_ unresolved items have been converted to enforc (3) i i
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, Comanche Peak e
Corporate _Manacement Involvement in Reaulation Matters e.
- U j
Site QA y3 Sit.e management is always at the exit / management meetings.
(1) supervision is always present and construction i.s usually represented J s It has not been by one or both of the Project General Managers.
normal practice to have attendance from the Dallas office personnel.
(2)
Yes (3) Yes 5
The various levels of licensee management who should be involved in (4) the affairs of the project have been. The designated signatory licensee (Gary) and the management person directly in charge of con-struction appear to be very well aware of problems and have been helpful in correcting them on occasion.
1 f.
Effectiveness of 0A/0C Procram It is The licensee's QA/QC program is generally effective in my opinion.
somewhat encumbered by too many procedures and occasionally by not having Instances of the latter seem enough real talent to do the job correctly.
l rare but do show up occasionally in invalid NCRs which in turn reflect that the inspectors don't really know what they are inspecting.
In my particular situation, if I believed that they were more than just a little ineffective, I would be forced to attack the situation head-on.
Any Other Trends Indicative of Poor Performance g.
None 5
?
z
Co:r.anche Peak Units 1 & 2, DN 50-445; 50-446 ENFORCEMENT HISTORY 5
b Report
-f No.
Dates V_
J, D
D_
U M/D Remarks
)
78-01 1/03-13 0
0 0
0 2
10.6 78-02 1/30-2/2 0
0 0
0 0
9.9 78-03 2/08-10 0
0 0
0 0
3.0 78-04 2/28-3/3 0
0 0
0 1
9.0 78-05 3/21-24 0
1 0
0 1
3.8 78-06 3/21 0
0 0
0 0
.5 Ward /Huback off-site investigation 78-07 4/11-21 0
0 0
1 2
12.8 78-08 4/26-28 0
0 0
0 2
2.6 Environmental 78-09 5/16-19 0
0 0
0 1
7.2 78-10 5/30-6/1 0
0 0
0 0
4.1 78-11 6/20-23 0
1 0
0 0
3.6 78-12 8/22-25 0
2 0
0 2
7.0 78-13 8/01-31 0
2 0
0 1
15.8 RRI 78-14 9/14 0
0 0
0 0
4.0 Glen Rcse Meeting 78-15 9/05-15 0
0 0
0 0
7.0 RRI 78-16 10/02-31 0
0 1
1 1
13.5 RRI 78-17 10/04-12 0
0 0
0 0
2.0 Investigation 78-18 10/10-13 0
1 0
0 1
6.4 78-19 10731-11/03 0
0 0
0 0
4.2 4
1 11/01-30 0
0 0
1*
0 13.8 RRI
- Deviatig 78-20 noted withdrawn i
Cor.anchb Peak,
Report No.
- Dates V
I D_
D U
M/D Remarks g;
f 78-21 11/20-22 0
0 0
0 0
2.2
~
78-22 12/01-31 0
0 0
0 0
7.8 RRI 78-23 12/18-20 0
0 0
0 0
5.6 e
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UNITED ST ATES NRC Staff Exhibit 19 1 8, 3,,. j )f NUCLEAR REGULATORY COMMISSION r
REGION IV
/,
611 RY AN PLAZA oRIVE. SUITE 1000 s, '.s 0(
"'s, c'
ARLINGTON. TE XAS 76012 January 4, 1980 t-
}
MEMORANDUM FOR:
W. A. Crossman, Chief, Projects Section FROM:
W. C. Seidle, Chief, RC&ES Branch
SUBJECT:
TREND ANALYSIS - 1979 Please request your project inspectors to conduct a trend analysis of the perfor=ance of each of their assigned facilities during calendar year 1979.
The analysis should be consistent with the considerations identified in my memorandu= to you dated January 4, 1977 (copy attached).
1 Please provide me with the analyses by COB February 15, 1980.
~
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W. C. Sei e, Chief Reactor C 'struction and Engineering Support Branch cc:
K. V. Seyfrit R. E. Hall l
W. E. Vetter i
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(tNIT E D 51 ATE!
c.
NUCLE AR REGULATORY COMMISSION 9
i;,;
[a REGION IV t, 'eg!:.f f sii avan eta: A onivt. suitt 1000 g gg g gg g
AR LINGToN, TE X As 76012 January 17, 1980 MEMORANDUM.IOR:
W. G. Hubacek
[
R. C. Stewart
'J R. G. Taylor C. R. Oberg E. S. Phillips FROM:
W. A. Crossman, Chief, Proj ects Section SU5 JECT:
TREND ANALYSIS - 1979 Please perform a trend analysis of the performance of each of your assigned " active" licensees for the calendar year 1979.
Your analysis should include the following infermation:
I a.
Number and Repetitiveness of Construction Deficiency Reoorts b.
Enforcement History For each facility list:
(1)
Inspection Report Number (2) Dates of Inspection (3) Nu=ber of Violations (4) Number of Infractions (5) Number of Deficiencies (6)
Number of Deviations (7) Mandays involved (for that inspection)
(8) Remarks (indicate if nepeat from 1978 and 1979)
(9) Number of unresolved items c.
Responsiveness of Licensee to Enforcement Action (1)
Is licensee on time with answer to our letter?
(2) Are answers adequate?
Do we have to go back for more information?
(3) Are any inadequate answers our fault?
(4)
Is corrective action done promptly?
(5)
Is the licensee responsive?
d.
Unresolved Items l
l (1) Are unresolved items cleared rapidly?
k (2) Are numbers / inspection on the increase? Why?
(3) Nu:iber of unresolved items escalated to enforcement items.
~
s
' Inspectors - Proj ects Section January 17, 1980 e.
Corporate Manage =ent Involvement in Regulation Matters t-(1)
Su.fficient management representation at exit interviews?
(2) Attitude receptive?
J (3)
Signature on licensee letters appropriate levelt (4)
Is management involved?
(Indicate basis for answer) f.
Effectiveness of QA/QC Program This is a very subjective matter.
I desire your own opinion and basis for your opinion.
If too early in construction phase to state, indicate this.
Also indicate what you believe we can do to have them improve their program.
This information should not be included in the documented analysis, but you should be prepared to discuss it with Mr. Seidle.
g.
Any Other Trends Indicative of Poor Performance List and discuss any other indications that may point out poor / good performance.
Please have your information to me by COB on February 15, 1980.
&h?
g W. A. Crossman, Chief Projects Section cc:
W. C. Seidle l
l l
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NRC Staff Exhibit 19Y
' 'g UtilTE D ST ATES
. [ -[,,...,[ j NUCLEAR REGULATORY COMMISSION v
f REGION IV
- .g.sl, s //
611 RYAN PL AZ A DRIVE,sulTE 1000 S,.t;4 [
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'g AR LINGToN, T1 X AS 76012 March 3, 1980
[
J W
MEMORANDUM FOR:
A. Crossman, Chief, Projects Sec' tion FROM:
W. G. Hubacek, Reactor Inspector, Projects Section
SUBJECT:
TREND ANALYSIS - 1979 The attached information is provided in response to your memorandum, same subject, dated January 17, 1980.
The informatiota, prepared by the assigned project inspectors, includes only those facilities that were in an active construction status during calendar year 1979.
f'..
W. G. Hubacek, Riiictor Inspector
/
Projects Section t*
cc:
Project Inspectors i
NRC Staff Exhibit lY Comanche Peak, Units 1 & 2 DN 50-445; 50-446 TREND ANALYSIS - 1979 t
~:
a.
Number and Repetitiveness of Construction Deficiency Reports d
(1) Two items were officially categorized by the licensee as 50.55(e) items.
(2) The two items did not appear to be repetivie.
b.
Enforcement History (See attached sheet) c.
Responsiveness of Licensee to Enforcement Action (1)
The licensee has generally been on time with his response to letters and when he has not been able to do so, he has informed us promptly.
(2) The response letters are generally adequate as forwarded to the office.
The licensee site QA personnel usually coordinate the answer with me prior to sending it to the office.
(3) Any unsatisfactory answers given are not usually the licensee's fault, but also not necessarily our fault either in terms of the way the a
noncompliance is written.
It is primarily a matter of our wanting something a bit stronger for the record.
(4) My experience has been that the promised actions have been implemented by the dates promised.
(5) The licensee has been generally responsive to our findings.
d.
Unresolved Items (1) Unresolved items have gotten a bit out of hand since they are not being worked off very rapidly.
I have been promised increased attention will be paid to them.
(2) The numbers of unresolved items are on the increase, but I view this as normal at this stage of construction since they are now well into every aspect of the construction and this will naturally lead to more questions on our part that the licensee does not readily have available answers for.
I
['
1 i
0 Comanche Peak, Units 1 & 2 :
t (3) No[.unresolveditemswereescalatedtoenforcementitemsin1979.
4 e.
Corporate Management Involvement in Regulation Matters (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 company of ficer.
(3) The site management appears very responsive to our inspection findings.
(4)
It is my impression, 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 ar.y way they want to and then put it up to the engineer to document and approve the as-beilt condition.
If the engineer refuses, he is blamed for being to cinser-vative and not responsive to the client's needs.
Thus the driviag 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 j people are essentially incompetent even though they had been through
,3 the site training and had been certified as competent.
Iseeadesir(,
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-I 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.
, e Comanche Peak, Units 1 & 2.
I'm not at all sure that what CPSES is doing in this area is very P
differ 6nt than what other utilities and/or engineers have done on other tj projects but I don't like it.
I believe that much the same thing went 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 past.
I think he will take maximum advantage of part 50.55(e) and the guidance to go through the necessary formalities 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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