ML20205L145

Forwards Const Insp Repts 50-445/86-08 & 50-446/86-06 on 860401-0531 & Notices of Violation & Deviation.Actions to Correct Overall QA Audit Function Not Completely Successful

ML20205L145
Person / Time
Site:	Comanche Peak
Issue date:	03/30/1987
From:	Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
Shared Package
ML20205L149	List: ML20205L145 ML20205L212 ML20205L235 ML20209A367
References
NUDOCS 8704020124
Download: ML20205L145 (3)

See also: IR 05000445/1986008

Text

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In Reply Refer To: MAR 3016

Dockets: 50-445/86-08 '

50-446/86-06 ,

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Texas Utilities Generating Company - l

ATTN: Mr. W. G. Counsil' l

Executive Vice President ,

400 North Olive, L.B. 81

Dallas, TX 75201 ~

Gentlemen:

This refers to the construction inspection conducted by Mr. H.'S. Phillips'and

other members of the Region IV Comanche Peak Group during the period April _1

through May 31, 1986, of activities authorized by NRC Construction

Permits CPPR-126 and CPPR-127_for the Comanche Peak-Steam Electric Station,

Units 1 and 2, and to the discussion of our findings with.you and other members

of your staff at the conclusion of the inspection.

Areas of construction examined during the inspection included plant status and

general construction inspections; Brown & Root (B&R) audits of site activities;

Unit 2 electrical cable, tray, and instrumentation installation;'and Unit 2

pipe supports / restraints. 'Within these areas, the inspection consisted of

selective examination of procedures and representative records, interviews with

personnel, and observations by the inspectors. The inspection findings are

documented in the enclcsed inspection report.

During this inspection, it was found that certain of your activities were in

violation of NRC requirements. Consequently, you are required to respond to

these violations, in writing, in accordance with the provisions of-

Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of-

Federal Regulations. Your response should be based on the specifics contained

in the Notice of Violation enclosed with this letter. I

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Also during this inspection, it was found.that certain of 'your activities l

appeared to deviate from comitments made to the NRC. These items and

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references to the comitments are identified in the enclosed Notice of

Deviation. You are requested to respond to these deviations in writing. Your

response should be based on the specifics contained in the Notice of Deviation

enclosed with this letter.

Twounresolveditemsareidentifiedinparagraphs4.c(2)and4.c(3)ofthe

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enclosed inspection report.

-Your attention is directed to paragraph 4.d of the enclosed report, in which

the inspector presents an evaluation of items of noncompliance concerning your

contractor's performance in the area of QA audits and the similarity of these

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findings to other reported deficiencies observed in the past and that have

resulted in a previous Notice of Violation (84-32/11). It is clear from this

evaluation, which refers to both reviews and audits conducted many years ago

along with recent findings, including those currently being addressed, that

your actions over time to correct and improve your overall audit function have

not been fully successful. In this regard we request that you consider the

points raised in the evaluation, and the possible need to take further

corrective actions in connection with your continuing management reviews of

this area. Additionally, it was our understanding that these matters would be

explicitly addressed in the implementation of the Comanche Peak Response Team

Program Plan, Issue-Specific Action Plans (ISAPs) VII.a.4 and' VII.a.5, as

reflected in your response to the earlier Notice of. Violation (TXX-4453). The

absence of clear identification and disposition of pertinent external source

issues in the results reports for ISAPS VII.a.4 and VII.a.5 will be addressed

in separate correspondence.

We have also examined actions you have taken with regard to previously

identified inspection findings. The status of these items is identified in

paragraph 3 of the enclosed report.

The responses directed by this letter and the accompanying Notices are not

subject to the clearance procedures of the Office of Management and Budget as

,

required by the Paperwork Reduction Act of 1980, PL 96-511.

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should you have any questions concerning this inspection, we will be pleased to

discuss them with you.

!

Sincerely,  !

\

. Original Signed by:

R.E.HALC -

.

E. H. Johnson, Director

Division of Reactor Safety and-

Projects l

l

Enclosures: 1

1. Appendix A - Notice of Violation l

2. Appendix B - Notice of Deviation

3. Appendix C - NRC Inspection Report j

50-445/86-08 '

50-446/86-06

4. Appendix D - B&R Matrix of Annual

Audits

cc w/ enclosure: (seenextpage)

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Juanita Ellis f

, President - CASE

1426 South-Polk Street

- . Dallas, Texas' 75224

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I Renea Hicks

Assistant Attorney General

Environmental Protection Division. '

'

P. O. Box 12548

,

Austin,' Texas 78711-2548'

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Administrative Judge Peter Bloch '

U.S. Nuclear Regulatory Commission

Washington, D. C. 20555

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Elizabeth B. Johnson

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Administrative Judge _-

Oak Ridge National Laboratory

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P. O. Box X, Building 3500

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' Oak Ridge Tennessee 37830 ,

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Dr. Kenneth'A. McCollom _

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4 1107 West Knapp

! Stillwater, Oklahoma '74075

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i Dr. Walter H. Jordan i

881 Outer Drive ' '

i Oak Ridge. Tennessee 37830-

Anthony Roisman, Esq.

Executive Director

i Trial Lawyer.s for Public Justice '

j 2000 P. Street, N.W.' Suite 611

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Washington, D. C. 20036

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Texas Radiation Control Program Director

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