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- y 4 NUCLEAR REGULATORY COMMISSICN i 5 .- 1 R$oloN IV tti RYAN PLAZA DRIVE. SUIT 11GB
, ARUNoToN. TEXAS Nett JAN 13195 1
MEMORANDW FOR:' E. H. Johnson, Acting Director, DRSP l FROM:
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SUBJECT:
NRC'IN3PECTION PROGRAM AT COMANCHE PEAK STEAM ELECTRIC STA MON l (CPSES) g k l The CPSES group performed a quick review of the CPSES inspection program status including, implementation (Enclosure 1), inspection regarding QA between 1974-84 i l (Enclosure 2), general review of the inspection program documentation i (Enclosure 3), and a general review of the historical unresolvedcand - e" i noncompliance items (Enclosure 4). The details of the general program review
.. (Enclosure 5) and the review of the histor cal unresolved and-noncompliance items,(Enclosure 6) are enclosed. <
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The reviews identified a number of items ich should be given cons'ideration by l management \regardingtheinspectionprogram taplementation at CPSES.'QA I inspection at CPSES, inspection program docjanentation, and the handling 8f i unresolved!1taas at CPSES. The enclosed information represents' a number of hours work and was performed fn order to better understand thefCPSES QA and technical problems, the inspection program documentation and status, and the general handling and status of mm previously identified findings. The informatten is being provided solely fors.. . your infomation and conside. ration and includes some recommendations. , Consideration should be given to utilizing the enc 1o' sed information during the I continuing inspections of the CPSES facility (TNT followup and. routine inspection program). Consideration should aise be given to evaluatir.g the Information re'ative to the IE inspection program and program fuplementation at CPSES to determine if IE program changes may be necassary to strengthon'eur inspection ap followup of safety issues.
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1 Memo for E. H. Johnson . If you have further questions, please contact H. S. Phillips (CPSES SRI-C at (817) 897-2201 orme(FTS 728-8103). N' p ..;. .. ., . .?.'
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. ENCLOSURE 1 NRC INSPECTION PROGRAM AT CPSES 1 - IMPLEMENTATION l
A quick review of the NRC inspection program at CPSES relative to the activity ; implementing procedures and records revealed the possible need to address ] certain areas during the final inspections of CPSES 1. j NOTE: Also the review revealed the need to commence the required inspections cf CPSES 2 expeditiously in ordar to adequately coinplete the required ] inspection program. 1 The following areas may require additional emphasis regarding CPSES 1:
- Structural Steel Supports (480638 - report documentation weak) 1 1
I Safety Related Components (500738 - additional inspection needed) {
*. Instrumentation Components / Systems (520548 - report documentation weak)
Containment Structural Steel (550638 - additional inspection needed) Reactor Vessel (50055 - additional inspection needed)- S'afety - 'Related Structural Steel Welding (55065 - additional inspection needed)' Electrical Components and Systems (51055B - additional inspection needed) i i i 1 8 l W 9 8 6
q I ENCLOSURE 2 1 NRC INSPECTION PROGRAM AT CPSES 1 & 2 REGARDING OVERALL QA BETWEEN 1974-84 i The quick review of the NRC inspection program implemented at CPSES 1 & 2 regarding QA revealed that between 1974 and 1984 the RIV QA inspections were weak at best. The following attributes did not appear to be adequately addressed in the routine inspection program: i Initial Corporate Office QA Program and Implementation (Once - 1984)
- Mid-QA Inspection -{36 hours) l
- Vendor QA Program' (completed prerequisites only in 1978, but the '
inspection was not performed) Annual Construction QA Review Meeting (Once - 1980) l c Routine Review of QA Program Implementation and Effectiveness - Design, l Procurement, and Construction (Once - 1984) i Audit of Site QA/QC Work Activities (Once - 1983, CAT) ! Annual Procurement, Receiving and Storage (Once - 1983, CAT) Review of Contractor QA Manuals Notwithstanding, supplemental and additional NRC inspections were performed at ! CPSES which provided some assurance that the licensee's QA Program was ' acceptable, including the CAT in 1983, the SRT in 1984, the RIV inspection in 1984, and the TRT in 1984. These inspections did not identify an overall breakdown in the CPSES QA Prngram; and the specific areas of concern identified appear to be salvageable - at this time. The final word on QA should evolve from the full implementation of the CPRT Program Plan and other special inspection activities. The QA Program inspections need to be performed, at this time, for CPSES 2 to ensure continuing acceptable QA practic.es. c
f - 1 ENCL'0SURE 3 l-GENERAL REVIEW OF THE 0'RC INSPECTION PROGRAM IMPLEMENTED AT CPSES
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i In general, review of the NRC inspection program implemented at CPSES revealed some apparent problems which may need review by management to provide inspection program improvements. The following matters were noted during the review of inspection reports and data:
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- In many instances, report documentation was not adequate to demonstrate that the inspection procedure (line items as a minimum) were inspected.
The percentage complete determination, in some instances, vras not fully supported by the report documentation. Additionally, the use of unresolved and open items, when deviations or 1 violations should have/could have been utilized, degraded the NRC program to i some degree. The NRC - and utility - management do not routinely evaluate unresolved and open items; and therefore, are not aware of " findings" handled at that level. Further, the corrective action taken by the licensee were generally specific to the identified issue, rather than generic to identify the cause and prevent recurrence of the problem. . NOTE: The NRC does not generally consider unresolved and open items in SALP evaluations. i l L
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4 l ENCLOSURE 4 H f GENERIC TREND OF CPSES UNRESOLVED ITEMS AND VIOLATIONS - l A very general trend of the frequency of violations arid unresolved items as g ' they relate to Appendix 8 to 10 CFR 50 was performad by the CPSES project to 4 identify any areas where additional inspection effort might be warranted. The attached trend identified two areas which are presently included in the CPRT ; Program Plan - 1) Design / Design Control (Criterion III), and 2) Inspection { (Criterion X). The third area the trend identified was Furchasing I (Criterion VII), and this area may need to be given additional consideration by the project to provide additional inspection effort. S l ' It is noteworthy that a large number of issues were identified as unresolved in } the area of purchasing and only a few findings were cited as violations. This ! practice may indi6 ate ineffective corrective actions in the area by the i licensee. I The general trend also included a cursory review of the items to note whether j the unresolved item was probably a violation. Based on available information '
. it was concluded that without a significant amount of additional' effort it I could not be determined which items were definitely violations. Those assigned to the project determined that the additional effort was not justified at this time, and also the data was not absolutely essential for the inspection of CPSES.
The rriview, both unresolved items and violations, revealed findings in the areas of design / design control, procedures, purchasing, special processes, inspections, and records. However, a, definite lack of findings 'was noted in the areas 'of procurement control, document control, material trac'eability, l corrective actions, and audits. This matter, both in the areas where findings I were identified and areas where findings were not identified, may be very j important when the findings of the TRT are considered and may need evaluation and consideration. i h e e 9 h
ENCLOSURE 5 l GENERAL INSPECTION PROGRAM REVIEW ! l i
- 1. The NRC inspection program at Comanche Peak relative to quality assurance between 1974 and 1984 was weak. That is the IE inspection program to inspect the applicant's QA program was less than adequate based on the following:
- a. After the construction permit was issued in December 1974, no comprehensive inspection of the corporate management was performed until August 1984. As a result, there was no evalestion at corporate offices to determine how effectively the Comanche Peak QA P.rogram has been implemented. Also, the applicant's QA Program and QA Audit Program, which was implemented by corporate auditors only, were in noncompliance with their commitments and Criterion XVIII (failure to audit) and Criterion II (failure to assess the status and adequacy of the QA Program) from 1974-84, respectively.
- b. The mid-QA inspection, as required by Manual Chapter (MC) 2512 and Inspection Procedure 352008 was neither comprehensive nor in sufficient depth to properly evaluate whether or not the applicant's program was effectively implemented (when construction is about 50-60% completed).
Usually, this inspection is performed by the project inspector and three discipline inspectors over several weeks (2 weeks preparation, j one week inspection at site, followed by a final week of inspection j at the corporate QA offices). The mid-QA inspection at Comanche Peak ' was conducted by two NRC inspectors during the period December 18-20, 1978, and 36 inspector hours were recorded under IP 352008. Less than a manweek was expended versus the usual l 5-8 manweeks; and further, it appears that the electrical discipline l was not inspected adequately. '
- c. Audit of Applicant's Surveillance of Contractor QA/QC !
Activities 350208 - As a result of Vendor Branch IE Inspection 1 Report 9990524/78-01 (which stated that the applicant's QA Program concerning vendor control activities appearedto be breaking down), i l an inspection was conducted and documented in IR-78-07 by the ' resident inspector. l Other than reviewing a list of vendors and status of vendors' QA ! l program and manufacturing (documented in IR 78-09), no further inspection occurred to assure that the applicant's control of vendors j fully complied with Appendix 8 requirements. 4 I I l ! l
i i In 1984 two NRC inspections identified potential, and subsequently upgraded, violations concerning control of vendors. The applicant's l control of vendors has remained in question since 1978. The Region IV inspection did not acertain whether the applicant's QA Program relating to surveillance of contractors assured proper control of vendor and corrective action concerning an apparent QA program breakdown. ,
- d. Management Meeting - Construction Quality Review IP 300518 - This I annual requirement to discuss: (1) quality of construction, (2) QA program implementation, (3) QA/QC staffing, (4) preplanning for complex work activities was held in October 1980; however, it was not
{ done and/or documented in 1981, 1982, 1983, and 1984. I
- e. Audit of the Applicant's management of the QA Program 350608 - This inspection of the applicant's management was required every 18 months since August 1980. The purpose of inspection was to evaluate the effectiveness in implementing the corporate QA Program for ongoing '
activities of design, procurement, and construction. I This inspection should have been performed twice between August 1980 and June 1983, but was not performed until August 1984 when the RIV l Task Force performed the inspection. { l
'f. Audit of Site Work Activity and the QA/QC Program 350618 - This annual inspection of site work activity and the QA/QC program was to assure that safei.y related work was properly controlled. This l inspection should have been accomplished in 1981, 1982, 1983, and 1984. The NRC CAT Team accomplished the equivalent of 30% in 1983 ,
l and the Region IV Task Force performed this inspection in mid-1984, l but there was very little work in progress on Unit No. 1. Unit No. 2 ' was not inspected. The inspection of as built drawings versus plant configuration in one electrical and naechanical area identified violations; i.e. , drawings did not match configuration and inspection did not identify these departures from drawings and specified tolerances.
- g. Procurement, Receiving, and Storage 350658 - This inspection (required by MC 2512 annually since 1980) of site procurement,
' receiving, and storage was not inspected underethe routine program in 1980-81, 1981-82, 1982-83, or 1983-84. The CAT team inspection in 1983 covered 30% of the required inspection and the Comanche Peak Special Review Team inspection may be counted toward the 1983-84 inspection of procurement.
- h. Review of QA Manuals 351008 - This inspection procedure requires that each ccntractor's QA/QC Manual be reviewed and evaluated once in
i conjunction with NRC review of civil, electrical, and mechanical procedures which control work activities. IE inspection reports document such reviews for all contractors,on site except Bahnson (reviewed selectively).
- The above paragraphs describe inspections that were missed for Unit No. 1 and the opportunity to inspect is lost; however, the following special inspections have occurred and provide assurance that these or similar ;
inspections were performed to assure that the applicant's QA program was l and is adequate or identify deficiencies. Special Inspection Construction Assessment IP 35061 - 30% per IE letter dated April 27, 1983 i Team - January 24 through ID 35065 - 80% same letter February 4, 1983 NOTE: Not in 766 data
- Comanche Peak Special This report dated July 13, 1984, documents an Review Team Report extensive review of QA/QC activities relating to April 3-13, 1984 design, procurement, and construction. The line items of IP 350618 and 350658 were inspected during i this comprehensive inspection.
NOTE: Not recorded in 766 data I l Region IV Task Force Inspection Report 84-22/07 documents the inspect 1on Inspection - July 9 of IP 350618. Also, a number of QA manuals were through Mid-October 1984 reviewed. IR 84-32/11 documents the inspection of IP 35060B and 350208. The scope of 350208 was limited to site construction. NRC Technical Review This inspection by over 100 engineers and technical Team - July 9 through specialist thoroughly covered the QA/QC function and Mid-October 1984 may be counted toward and satisfy IP 30051B, 35061B, 350658, and 35100B inspection requirements for present and past work.
- 2. Manual Chapter 2512 Inspection Program of Site Work Activities - This program requires NRC inspections to: (1) review specific QA/QC implementing procedures, (2) observe current /past work, and (3) review of records pertaining to civil, electrical, and mechanical work activities on !
site. The program accepts the premise that all inspection procedures may not be completed. The 766 data run dated October 1984 was used to ' evaluate the inspection procedure line items inspected and documented in inspection reports. The following are the results:
- a. RIV inspection reports document the review of inspection procedures such as safety related piping (330618) and other similar procedures; however, the.following procedures reviewed'were either not recorded
in the 766 data system or were not completely inspected and/or I documented in inspection reports: (1) The October 1984 datd run for 766 information did not include inspection procedures 450618, 460518, 470518, and 550518 but, reports were found indicating these inspections were performed but were not recorded on a 766 form or in one case the data group failed to enter the item. (2) The following review of procedures were either not complated or documented in inspection reports: 450518, 50051B, 500618, 500718 and 550818. Procedures 50051, 50061, and 50071B were reported 100% inspection of line items, but reports document inspection of 50% of line item procedures.
- b. .RIV inspection reports document the observation of work activity on site for the following areas as follows:
(1) Site preparation - 766 data form, IR 78-04 reports 80% completed but the report does not document observed work. Only procedures and records inspected. I (2) Lakes, dams - inspection completed (IC) (3) Foundations - IC. (4) Concrete - 766 data run shows no entries for 470538, yet, IR 76-06 shows 766 form -'100% and plant progress 11.7% Unit 1 and 1.5% Unit 2. 1 Also found documentation of inspection in RPT 75-12,-75-11, 75-10, but not in 766 data. 470548 - IC - (5) Containment Steel - IC (6) Structural Steel supports 480638 - Report 766 form reports 100% but reports document 20%. 480648 - IC (7) Reactor Coolant Pressure Boundary Piping 490538 - TR 82-11 , reports 100%, but all line items were not complete / documented in the report. IR 79-25 showed 90% 490548 - IR 80-19 and 82-11 report 30%. (8) Safety Related Piping - 490638 - IR 80-26 reports 100% but supports documents 80%. I L _-_ _ - - - - - _ - - - _ - _ - - - - - - - - - - - .- - - - - - - - - "
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l l I NOTE: Considering all resident inspection may consider 100%. l (9) Safety Related Piping Welding - IC (10) Reactor Coolant Pressure Boundary Pipe We1 ding 550738 - IC j 550745 - 90% completed (11) Reactor Vessel - IC 1 (12) Reactor Vessel Internals - IC (13) Safety Related Components 500738 - 60% completed l 50074B - Approximately 80% completed
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(14) Pipe Supports - IC (15) Fuel Storage Racks 1 500958 - 60% but understand D. Hunnicutt recently completed. (16) Containment Penetrations - IC (17) Containment Penetrations - IC (18) Containment Structural Steel Welding 550638 - 100% reported but reports support document 20%. 550648 - Ditto above 100% vs. 70% completed / documented. I l (19) Electrical Components / Systems 510538 - 70% completed. ' 510548 - 90% reported - 50% documented..- (20) Electrical Cables / Terminations - IC (21) Instrumentation (Components / Systems) 520538 - IC l 520548 - 90% reported 766 - 50% documented. (22) Instrumentation Cables - IC (23) Preservice Inspection - IC
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- 3. The overall observation of work appears to be adequate with a few .
exceptions. Not all of the inspection procedure line items were 100% inspected and completed;' however, the Manual Chapter recognizes and allows that all procedures may not be completed. . . Considering this allowance the following percentage completed appears to be-too low: (1) structural steel supports - 20%; (2) reactor coolant i pressure boundary piping (490548) - 30%; (3) containment structural steel (550638) - 20%.
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The major problems found during this review were as follows: l
- a. Reports in many instances failed to document the inspection to demonstrate that inspection procedure line items were inspected.
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- b. The percentage complete determination requires some judgement; j however, some judgements appear to have less basis than needed. j i
NOTE: This is also true of review of procedures and records. These slight weaknesses appear to be well compensated for by work observed and documented in the special inspections previously ' referenced in paragraph 1 above,
- c. RIV inspection reports document the NRC review of QA records. The review of records for all discipline procedures was completed and adequate except as follows:
(1) The 766 data shows 0% complete for 450558. l (2) For concrete 47055B,.the 766 reports 100% but the reports do not document the inspection of line items. The same is true of 470568 f.e., the last accurate report was 70% but 79-04 report i of 100% was not documented. (3) Containcient Steel - 100% inspection of line items reported - 70% I documentation > (4) Structural Stee) Supports - 100% reported .10% documented. ' (5) Reactor Coolant Pressure Boundary (55075) - 100% reported - line item on nonconformances only 10 of 14 nonconformances reported. (6) Reactor Vessel 50055 - 100% reported - 60% documented (7) Safety Related Structural Steel Welding - 100% reported - 20% of I line items inspected documented for 550658. 100% reported on 550668 - 70% documented. Nonconformances and audits line item not completed and/or documented.
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(8) Electrical Components and Systems - 100% reported - 20% l documented for 510558. j l 90% reported - 20% documented for inspection of line items of l 510568. ' I l The records review and review of procedures appear to be the weakest ares l 1.e., NRC review of procedures, observation of work, and review of QA ! records. l l 1 l 1 l 1-1 l ! j l l l l I 4
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' in Reply Refer To: -
i I Dockets: 50-445/85-07 MB 0 3 E 50-446/85-05
- Texas utilities Electric Company l ATTN: W. G. Counsil
, Skyway Tower I t
, 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Gentlemen:
This refers to the inspection conducted under the Resident Insper. tion Program l by Messrs. J. E. Cummins and H. S. Phillips and others during the period April 1, 1985, through June 21, 1985, of activities authorized by NRC Construc-tion Permits CPPR-125 and CPPR-126 of the Comanche Peak facility, Units 1 and 2,
- - and to the discussion of our findings with Mr. J. T. Merritt, and other members of ,
I your staff at the conclusion of the inspection. ,
- Areas examined during the inspection included plant status, action on previous NRC inspection findings, action on applicant identified design construction deficiencies (10 CFR Part 50.55(e) reports) and plant tours. Within these .
i' areas., the inspection consisted of selective examination of procedures and representative records, interviews with personnel, and observations by the inspectors. ! These findings are documented in the enclosed inspection report. . l i During this inspection, it was found that certain of your activities were in I violation of NRC requirements. Consequently, you are required to respond to l this violation, in writing, in accordance with the provision of Section 2.201 j of the NRC's " Rules of Practice," Part 2. Title 10, Code of Federal ' i Regulations. Your response should be based on the_soec Hire enntained in th Notice of Violation enclosed with this letter. Since B&R Procedure 35- -CCP-10 i
- ( has oeen revised to W ovice accumentea ection of truck mixer blades, there 1
i i was no abnormal blade wear identified as a result of blade inspection, and there i have been consistent concrete strength and uniformity tests, no reply to violation 2.c is required. l l .- l i RSB b RSB HSPh1111ps/dc DMHunnicutt q h CPT G TFWesterman DRSP EHJohnson NPR VNoonan a i/w/86 l /p/86 / /W/86- l /g/g 7 sr/86
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I Texas Utilities Electric Company 2 Should you have any questions c~oncerning this inspection, we will be pleased l to discuss them with you. -
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Sincerely, d BV 00d# :3 g, 8. - E. H. Johnson, Acting Director 1 Division of Reactor Safety and
' Projects i
Enclosures:
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- 1. Appendix A - Notice of Violation
- 2. Appendix B - NRC Inspection Report 50-445/85-07
., 50-446/85-05 I
t cc w/ehslosure:
,__ Texas Ltilities Electric Company i
ATTN: .,. W. Beck, Manager,
- Licensing !
Skyway Tower 400 North Olive Street Lock Box B1 Dallas, Texas 75201
'duanita Ellis President - CASE 1426 South Polk Street ,
Dallas, Texas 75224 Renea Hicks Assistant Attorney General Environmental Protection Division P. O. Box 12548 l Austin, Texas 76711 Texas Radiation Control Program Director . bec to DMB (IE01) bec distrib. by RIV:
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- MIS System
*RRI-OPS *RSTS Operator
*RRI-CONST *R&SPB
*T. F. Westerman, CPTG DRSP V. Noonan, NRR R. Martin, RA S. Treby, ELD *RSB
*RIV File J. Taylor, IE
*D. Weiss,LFMB(AR-2015) R. Heishman, IE
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- APPENDIX A ?
NOTICE OF VIOLATION . Texas Utilities Electric Company Docket: 50-445/85-07 Comanche Peak Steam Electric Station 50-446/85-05 Unit: I and 2 Permit: CPPR-126 CPPR-127 During an NRC inspection conducted on April 1 through June 21, 1985, violations of HRC requirements were identified. In accordance with the " General Statement of Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985), the violations are listed below:
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- 1. Failure to Promptly Correct an Identified Problem with RTE - Delta
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Potential Transformer Tiltout Subassemblies -
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i , 10 CFR 50, Appendix B, Criterian XVI, as implemented by Texas Utilities Generating Company (TUGCO) Quality Assurance Plan (QAP), Section 16.0, Revision 0, requires that measures shall be established to assure that j conditiens adverse to quality, such as failures, malfunctions, deficien-cies deviations, defective material and equipment, and nonconformances are { promptly identified and corrected. j Contrary to the above, a potential problem with' RTE - Delta potential transformer tiltout subassemblies, which are used in the emergency diesel generator control panels, was identified to the applicant via a letter, dated June 15, 1983, from Transamerica D'elaval Inc. This letter also ' provided instructions for correcting the potential problem. However, the
- - applicant did not take the corrective action. The NRC initially reported this item as unresolved in NRC Inspection Report 50-445/84-40. ~
This is a Severity Level IV violation. (Supplement II.E) (445/8507-01 446/8505-01).
- 2. Failure To Follow Procedures 10 CFR Part 50, Appendix B, Criterion V, as implemented by the TUGC0 QAP, Section 5.0, Revision 2 requires that activities affecting quality shall
! be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accor-dance with these instructions, procedures, or drawings. a. Drawing 2323-51-0550, Revision 4, Section 6-6 specified the use of Class E" concrete for the Unit i reactor coolant pump and steam generator supports. I l 9&Garm32ff- -
i I Contrary to the above, comercial nonshrink grou't was used.to grout the Unit 1 reactor coolant pump and steam generator supports in lieu of Class "E" concrete. (445/8507-02) This is a Severity Level V violation (Supplement II.E). (N) g l b. Brown and Root Procedure QI-QAP-7.2-8, " Receiving of Westinghouse Y Safety Related Equipment," Section 3.1.d.1, requires a QC inspector to verify that the Westinghouse Quality Release (QR) document checklist items be filled out completely and accurately. * { Contrary to the above, the voltage recorded on Westinghouse QR 41424 j checklist, attachment 1, step 4.1, was outside the specified i tolerance, but the QC receipt inspector accepted QR as satisfactory. (445/8507-03) l 1
, _ , This is a Severity Level IV violation.
' l 1 c.
Brown & Root Procedure 35-1195-CCP-10. Revision 5, dated December 4,. 1978, requires that central and truck mixer blades be checked / quarterly to assure that mixer blade wear does not exceed a loss of 10% of original blade height. j Contrary to the above, on May 31, 1985, the NRC inspector determined j that there was no objective evidence (records) that the mixing blades :
had been inspected quarterly since the trucks were placed in service I in 1977. (445/8507-04;446/8505-02)
This is a Sever.ity Level V violation (Supplement II.E) i d. Brown & Root Procedure CP-QAP-15.1, " Field Control of Nonconforming i
- ~ Item, " states that nonconforming conditions shall be documented in a i Deficiency and Disposition Report (DDR). Procedure CP-QCP-1.3, " Tool Equipment Calibration and Control," dated July 14, 1975, states that i
i out-of-calibration equipment shall be identified on a DDR. {
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Contrary to the above, on May 31, 1985, the NRC inspector reviewed / l the calibration file for scale (MTE 779) used for weighidg cement and I found that a 24-48 pound deviation from the required accuracy was ! encountered with the water and cement scales during a 1975 calibration 1 of the backup plant scales, however, no DDR was issued to identify this condition any) produced. and require disposition of the scale and concrete (if I (445/8507-06;446/8505-04). j This is a Severity Level IV violation (Supplement II.E). I i unummmmmer I
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Pursuant to the provisions of 10 CFR 2.201, Texas Utilities Electrje Company is hereby required to submit to this office within 30 days of the date of the letter transmitting including this Notice, a written statement or explanation .in reply, for each violation: (1) the reason for the violations if admitted, the corrective steps which have been taken and the results achieved, the corrective steps which will be taken to avoid further violations, and the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending the response time. l Dated at Arlington, Texas, this 3rd day of February,1986 O ,
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