ML19270G265

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Suppl to Petition to Intervene.Adds Contentions Re Const of Plant.Affidavits & Certificate of Svc Encl
ML19270G265
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 05/07/1979
From: Fouke R, Jacobson N
CITIZENS FOR FAIR UTILITY REGULATION
To:
References
NUDOCS 7906050236
Download: ML19270G265 (25)
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Text

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NRC PUBLIC DOCDENT ROOM ,.

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NCW 07.'.'.S Oiti: ens for Fair Utility Regulation (OF7R) and files *his its Sueelement to Petition for Leave to Interrene cursuant to 100r"2, Rules of P-actice for Comestic licensing Proceedings.

OPA's list cf contentions is as fellows. Sene are based upen the application of irfemtion frem the scientific and/or nuclear ect.. unity to reecific conditi:ns at OPSIS as reflected in the PSAR and/cr the FSAR.

Cther c:ntentiens are based upon an analysis of NPO Inseection Re erts.

Still otners are based utan allegatiens which have eene to OP2's attention enly since the April 19 pre.hearir.g meeting with N?.0 staff (the source ef the allegati:ns is net identified and "FOR dees not knew if CP2 can substantiate the allegations, but the persen who passed the ir.femation to OP;R is trustworthy and of sufficient stature 'n the Tarrant County : :nunity *. hat CP3 decided the preeer eeurse of action is to ir. fem the N?:"). All cententiens shew good cause for a full and thorough hearing into the aeplicant's qualificatiens to ecerate 0? SIS in acceMance with the regulatiens, ir. eluding sworn testimeny and cress-examinatten, as well as the need fer additional recerts by the applicant eencernine -

% safety asee:ts of emeratien. CP3's cententions furthur denens . "*Ae need for special operating restrictions to be elaced en the a:elicant in the rient that an operating license is granted.

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07ANC:E FEAK Fl?al, SAFI*! A'31!S!S Fi? ORT 3! 'nTS!!':0ECCSI IN

!!IU CF P? IPA?A*!ON AC ZENSI ST T:G AF?!!".A:C i.xhibit H et the Texas Utilities Westingneuse agrecnent specified that Wes*inghouse would previde the effort for the pn;aratien and defense of a pertien of the Cenanche 7e44 Final Safety Analysis Report in accordance with Regulatory "uide 1."C, " Standard Femat and Centent of Jaf ety Analysis Reecrts for Nuclear ?cwor ?lants', Revisi:n C.

1 :n Sectember,197'5, Westingneuse informed Texas '.tilities that Westing .ouse was not goi g to honor a :entract requiring Westingh use te deliter a; rexisately 2.9 r.1111:n cou.nds :f urar.iun "yelloweace- for the :u::ese of er:vidi .g f:e1 for the ir.itial : ore :12s the first rel:ad f:r *:nanc..e ?ea< 1 a .c

  • at a pri:e acer-A .ating 311 eer pourd. . Octeber,1975, Texas *.*ti'ities sued We stirg-heuse in nga:-d to *.his -a*.t er. On Oeeen'rer 07, 1977 Texas .tilities and Westingneuse sig=.ed an out-of-::urt settlement vni:n .--quire: We: ting .e2se to delt rer a realler a-:unt of 2rantun at a s:-ownat nig .or :rt:e as well as to provide a .un:er et unrelate: =ie:es :f :r per-/, .4 cufactu ed gecds and s o .= e e.

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  • he principal purpose of the pre,4 ration and defense of the Final Safety Analysis Report (MAR) is to enable the O missien to detemine whether Conanche Peak can be eperated without undue risk to the health and safety of the public. *he FSAR is the princioal document for the acclicant to provide the h. asis for the Oerrtissi n to decide whether the facility will cperate in cortf ormity with the Act and whether the acclicant is technically qualified to engage in the activities to to autherized by the operating lies se.
  • he manner and way in wttich the ?:E0 staff has reviewed the TSAR to date does not preclude the :essibility that the apelicant has relied en a separate party to prepare the FSAR. Nor do the written rvquests for additional informatien preclude the possibility that the apolicant has forwarded these requests to ancther party for defense. In view cf the terns of the settlement and *.he manner in which the TASR has been nviewed, there has been no infor .ation supplied to assun the Comissica that the applicant is technically qualified to operate Oceanche Peak (100FRfC.57.a.4).'

It is OT'!R's centention that the only preper course cf action available under the circunstances is to requin the applicant to undergo extensive direct questions to asrare the Ocmission and the public that the applicant knows what he has beught, is aware of the limitations of the device he has acquired and is aware cf the extent cf the assunptiens made in evaluating accident sequences as well as the va-ious actiens assumed to have been taken to prevent a more serious accident sequence from taxir.g place.

Such extensive oral examination can enly be ac:ceplished under the ferr.at of a full hearing.

C. 3ASICTT OF 00M7:*IR ?'OCMMS OTICZID 3 "YI 00 MAD 2 PEA % FSAR TO S000ES3M1C $*F01A*E TIE 3EMA'.70R 07 "".-2 STS*D4 *t 3.*.% A000E';*

SE0'2'CES .

C.A. Ocmeuter Codes 7tilited 'ahich Have Nci 3een Ter ially Acceeted For Use in %ter-Lini-e- the Censecuences of Accident Se::e-ces.

Certain connuter codes have been utilized in the 0=-anche Peak ?SAR wr.ich an based on reports which have not as yet been fer . ally acce:ted fer use in deterning the censequences of accident sequences to ver'fy t:at. e.

lease of radicactive natorial in effluents do net exceed the require =ents of 10 OTR 50. A " .a. A list of these re;crts follows:

1. " Overpressure Protection for *a*estingheuse Pas". '4".A? '*/69
2. ";0M?M Oode Oescription". C?-79C7
7. " TACT 3AE--A Tertran-r/ Cede f:r *her-al Transients in a OC2 'l E d~'

' C P-79CS 4 "T2:'t-T/. An *.n=reved > eg-an for *he:- al-Hydraulie Analysis of Rod Bundle : ores".

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5. "Calculati:nal Model for : ore asfi:eding Af ter a 1 CA", WP-317
6. "'E. ASH. A 7:rtran-7/ : recte.- Pregran for Si=ulatten of Transients in a Multi-1:e: ?O." . *=CA ?-2000

. *1:07A-Tl ?r: gram 100A Transient A-alysis". WP 2310

a. *1A!A:4-r/ Pr:grsm a =renenstve Jea:e *ine 0*pe .de .t Analysis of ;*0A".

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9. "Centainment Pressure Analysis Code (0:c0)", '40AP-8307 10."'4estingnouse A7/ Analysis",'4 CAP-3300 11.*4estingneuse 2005 Ivaluatien Medel-A Sumary", ' CAP-S$30 12.*4estiegneuse ICOS Plant Sensitivity Studies", '4 CAP-GO 13."'4estinghcuse 2003 Ivaluatien Model Sensitivity Studies". ' CAP-51 14."An Ivaluation of icss of ?!:w Accidents Oaused by Poder System T.-equency Transients in 'destinghcuse .WRs",'4 CAP
  • C 15.*4esti .shcuse m:$ Ivaluation Model--Suple-entary :nfer,4tien". '4 J ?-%71 16."'4estir.ghcuse COS Ivaluation Model-Modified 0:ticer 19 5 'tersten", VJp-9168 0?*JR centends that all infernation relied upon to constract ec-cuter codes should be verified and formally accepted before ineciperati n into the Oemanche Peak FSAR.

II.S. Inee-elete .Cemeuter Orde Ae tde-t Secuences.

'ahenever and wherever pcssible, a cenpater cede saould be detemined to te valid by comparir.g the predicted tchavior of the code to that actually exnerienced in real life. The *hree-Mile-!sland incident aff:rds us *ust that ecportunity.

The frequency of the Three-M.ile-!sland incident is nuch greater than one in a million and veuld be categorized as a credible accident af either the infrequent variety or the limiting f ault variety. *ho two accident sequences analysed in the Cemanche Peak FSAR which nest closely resemble

+2e start of the *hre,-Mile-Island sequence are the Loss of Nor-'ai Feedwater Flow sequence and/or the Feedvater Systen Pipe Break sequence; these sequences utilize the 10F ?AN FAO*?AN and TCC ce' cuter codes.

Tet, ner.e of these codes centain the capability of deterninir.g the ar.eunt cf hydrogen generated during the accident sequence. 0:nceivably, the results of these cedes ceuld be used as i put for IOOS : des, but the ECOS : odes do not contain the espability for determining the anoant of hyiiregen in the cooling systems and/or the centaiment.

OP.'R contends that the cceputer codes should be tested to see if they realistically predict the tehavior experienced at Three vile-Island w.en the paraneters vs.ich existed at Three-Mile sland are a;clied to the conputer codes. All modifications necessary to obtain realistie predicti:ns shculd te iacorporated prior to apereved usage cf the cer:cter codes to predict behavier at Ocma .che Peak.

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~~.A. T. ass -Accidents The Cor-anche ?sa< ?!A?. includes .cne of the pestulated Class 9 Accidents - even these addressed h ?r: fess:r No--an ?.as-ussen in $ LASE-14C O .

Since tne issuance :t WASE-1*CO, tne ::nficence li .its :f the estimated precabilities cf occurrence have been dete-.ined to be quite large--sn'ficent-17 large to :ause tne T?.0 to disavew the :enelustens rea: .ed 1. 'iASH-1-00.

  • f it is :ensidered necessary that f:r an a::ident seque .ce te te -edible,
  • he pr-cability f ec urence (wi*.hin a reasona:1, :entidence level; mus*

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be gnater *han one in a sillion, then some et the a: idents estegorized as Class 9 by ?.as .ussen clearly teceme ensible. To be conservative, in the absence of any reliable data, all of the a:etdants in WASE-14CC :=uld to :en-sidered credible.

OPJR cor.tends that the censequerces of the mostulated 01 ass 9 Accider.ts snould be calculated even though the =robabilities cf occurnnee cf the accidents ca f.et to accurately determined at this ti .e.

!!!.3. Pedreeen Exclssien A hydrogen exnicsten could :enceivably sever both nor-al and e=ergency core cooling as well as cause the integrity of the contalment st-acture to be violated if the hydregen were to ex: lode. *his 11.ni*irg catastrophic event was not adequately addnssed in WASX-1bCC. l'et, it is clear freci the Three-Mile-island incident that the possibility of sufficient aceunulation of hydro-gen in either the reacter and/or the contaiment for an explosien to cecur is gnator than heretofor imagined.

OT;R centends that the above hydrogen exilesion sheuld te added to the list of class 9 A::idents fer which consequences vill be detemined fer 0? SIS, T(. TERI *a'il. 3E A Nt M3ER CF 00NTIN":CNS T!AT F011CW 00NCE7;.7NG Pl**EF.S E03*AE A ES"!.* CF TEI .wANER AC u! IN 'a3103 00N3*?.;;;1:N HAs TAKIX F*A0E.

T/. A. Iaev of trra*.izatien, Ouality A s sura e;es , testrn co-trel, M e-ure-ent 6

Occument Cc . trol, Instr :etiens,Procedu -es, and Orawines. Occ ments I

I C e a.t--1. C :nt el e f Pu rc h a s e d waterial, E: 1: ment and 3c-vt:es,

! Identifiestien and Oertn1 et v toriala s Pa-tr.,_a_nd ",e. enents,

_Centrol_cf

~ .S.r.e_ cia.l Preces ses, !=sueetien, Te st Centrol, Centrol of Measurt-r a-d Test Ecui:=ent, as Eeouired br law. .

AcceMing to 10 tyR fo, Accendix 2, tr.. law clearly r=quins that. "*he a=plicant snail be restensible for the establis;.nent ar:d execution of +.he 3 pregre . *he a:pli: ant may delegate to thers ru:h as ::ntractors, agents or eensultants the werx cf establishing and executing tr.e 3 er sup:ert there-of, but snail retain respensibility therefer."

Ac:ording to parag-aph 17.1.1.2 ef 77CC"'s ?SAR, the Oerporathru.? egram and the "? sis .A Plan are the pri=ary de .: ents by whien T;0: assuns effective centrol of all project quality-nlated actie. ties. That the Corp 3 hegram

ecifies tne quality requirements te vai:n OPSIS U Flan will : :1y and transfern into stetific procedures, rethods and teenniques and vtil creytte detailed 1..f ormati:n in the f:rn of precedu-es to assun ter.pliance by all involved indie. duals.

Hewever, CTOF has found t.at then is eved.ely.img decu:-entsd er.5nce frert E0 *ns:ection 3epor*s dati g fre- :eeeter,19"), tr.at a :ensis* ant disngard for 3 by *he acclicant .as existed *hreng .eut 0:manene ?eac plant life fr n ince= tion to t e :rese-t ti;-e at eve:-r :riti:a1 s* age -f devel-

me r.t . in clear violation :f ine law. Act:rding to an '*EO .steeti:n Ee cr*

dated Oeee-cer 3,1973, an ins eeter dete:-.ined t .at Oe-*4in A!! -'<! 1re-e .t3 and rat:ance .ad teen ::-ittec fre=. tne ~.A Occu:-e .t s . *ha* *he authert*y and i,

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U.A. lack of Orranization. evt.

cuties of CS: staff 3 engineers and MS: engineers worxing under PSES pr>-

ject engineers were not clearly understood nor delineated in writing even though-toth grouns had been and were engaged in design review and precure-ent doeurents. *his was a violati n of the law. N?f Reports shcwed that the OA program indicated that meascre had been established to assure that dec monts would be utilizied at the 1: cations when "A worx or activities were being perfor .ed-;, however, the 3rRian did not centain a preeecure to ir.=lement tne rNuirement, even thcagh worx was On-g:ing. The require .ent that activities affecting quality hall be accomolisned under suitably controlled :enditiens was not addressed by either the ? eg-am er the Flan even thecgh w:rk was en-going. In additien, neither the Pregram nor the Flan clearly required cen-pliance with AEC nquire-ents or raidance for design controls er changes in procurer.ent dece-ents, nor did it include see ific instractiens to infom the responsitie eviewing engineer hew er by what guidlines he was *o detem.ine the adequacy of the basic provisions cf A33: 95.2, pp5, res requiring ee. trac-ters to prrtide a 3 er: gram.

In the sar.e 270 Eeport dated reeember 3,1973 it was fcund that no procedure in the 3 Flan gave raidance to persens cenducting CA reviews of design and pr curement documents and even thcugh the Pr gram said that T*:S had established measures te reqaire coneliance with Criterien '.*, the Finn did not have a precedure for it te be accenclished.

The 270 Espert shewed that the 3 P egram a .d Plan had no written prxedures er instrJettens established at a tine censistant with the senedule for acecmplishing design procure-ent and ?SAR develcement activities, even though the ;A Pr: gram had been apereved by MS!'s president and e pies had been distributed te personnel. Precedures "not included er inadequate

  • in the 3 Progran and Flan in:1:ded the nininun jeb qualifications of CSI persennel perfor-ing quality related werx, Further, there were no instructiens as to how management vo21d ngularly review tne status and adaquacy cf the part of OA they are responsible to execute wni: . =anage ent is rMuired to ece ty' law. (10 075 30, Apc 2).

Another WO re:ert durtrg the same tine eriod identified viciatie .e res ;uality Surv6111ance, Cesign,wni:n was net being carried out a:eerding to written :olicies in the PSAR and 3 manuals even thcugh design and ero-curement werx was in pregnss. For exan=le, althouga MS: e:nsultant I"S Nuclear had enumerated 19 general and 200 s=,cific ecments regarding the

  • hne prine centractors, '4es*inghouse, Citts and E111 and 3rewn and Rect, the :or=ents of IOS Nuclear had not been discussed with the thne :entracters.

In19%, U.0 ins ecti:n recorts identified problems in' p 6dedural p

centr:1 with suo-centractors *0endu:t of Audits" teing :tserepant in several anas, addi*ier.a1 ;C procecures equir-d f:r sut-cont-seters en-site testir.g. inconsistancies in the delinea*ien :f nstensittlit7 to-ween tne suo-cent:20ters of Me IS ~a9, vni:n r*;uired nvist:n of te suo-contitetsrs 3. SC precedures. 3r:xn a .d Ecot's en-site : .stra:tien procecures ".at et been fully tevel:tet f0r *he SS! 249 oven in:ugn Ve N e

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17. A. lac'< ef 0?ranisat* en. cont, was in pregnss, seecific rarreillance activities for e nstr : tion of the SS! Cam was inadequate in the OPSIS OA 71an. later in the year the sub-centractor was s*.111 devele:irg a procedure for inroecti:n and testing to accommany the S$! Shutdevn Can inseectien and test senedule. Again in ic7t* 3rewn and Rect LC srocecuns were f:und to be inadequately centrolled.

Three pree,dures reviewd by the inspec*.or -en the SafeShutdown *: :oundment an,. were found to be either in er-cr, incorrectly referenced

  • to work which was to 'ce .acconclished'in a::ordance with a different precedure, or were not revised in accordance with the rNuire-tects of'3rewn and Rocts 01 preceduns.

The ins =ector e phasised that these' errors were indicative et a defaciency in the SAR control of. changes to and issuance of OA/00 procedures. In 197N-'.

other sub-contractors testing and inspection procedures were not fully develoeed for the SSI Cam and things such as " indefinite statements" were found in proceduns nutive to deter.in; :orrective actiens especially in regard to time of recertir.g such an action.

Other proedural deficiencies were found in'that 3rown.4n6Ecot4nspectien proced:res for the excavation for the reactor centairrent strzeture of OTSES, Unit 1 and 2, did net entst. There follewed rock cverbreak in both excavattens with " nit 1 beirg worse than Unit 2. Proce+ ral deficiencies were found in changes initiated for eenerete testing and insee:tica for excavations of Catagery I ste ctuns as well as censtraction procedures for blactig for plant str:ctu n of SS! *.,an.

In 1975, the rown and Rcot progran nar;;al did not centain nferences to other 3&R OA Co.. trol vanuals in use nor was it " clear as to the v.anuals faneticr,a1 application to the Comanche Pea < Project." Since 3rewn and Root's OA nanual was not functienally applicatie to Cenanche Feas in 1975, a ye.r into construction, then any npresen*.ation that a OA Pregran was in plses is false. And further, serious questions as to the safety and sound-ness of *he constr:ction nust to answered. :t was found, even af ter nvisiens were made, that S&R r.anuals 'ased in the field were cut-dated. That year, it was found that 3&R site organaation, individual. tties and respen-eitili*ies wen not calari.fied,

  • hat the T"S! site surreillance staff's
uties and nreensittlities were not :larified, tnat the T"S! site surieillance

".A Flan di:.n set sufficiently describe rec.uireents f or timely fcilew-ups to correct deficiencies identified during site constr ;ien.

The applicant

  • was found to te in non-ccec11ance with N?O Regulatices Oriteria ! and ~!,10 OTR 50. Aco. 3, when centrary to the lawNenstr:etten de art .ent perscer.el won perf er**.rg 00 ins:ecti:n and acce=tance activities which were not desig .ated factions of the ::nstr :*i:n de:ar*=ent, i'. e . , they ,

fpersennel f e-t eenstr :ti:n) ven tving used as S.eceiving 00 insreeters f:r conente. witheut any tnining :r qualificati:ns f:r

  • hat jeb. OT*7 has fcund and will snow in :ententiens w ten fellew, that eensistantly. ::retiens relating to :enente hare occured.
  • n 10 5, it was found that a fer-al ;;/0A =r:gran .ad not teen re rel::e:
  • o verify field -sasurt-ents Serf :- ed --i **.S! pers:r_.el or anal"ti:a1 re-suits revided tr ince:ers:ent lateratories -e: tne e-vtr:rre .tal =r:grs :.

Enviterrten*al inste tien re c *s :id net i..cluce ce--ents as to :u--ent or lan.ed ::nstr:etien acttvities inat ::uld result in adverse effects. ~his 6

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IV.A. ' sex of Creanizatien, etc., cent. .

was found in June of 1975 and was not resolved until Jan, of 1976, seven months later. :n 1973, *.he cresent enviremental insteetier n: orts did nct include cements *o ensure the requir*-ents of the Tinal Invirennental State-ment, ar.d n1sted to the conditions for burning er burfing waste vegetation material. A *03: spokseman said that the item had been " inadvertently em-itted".

n Asril of 1975, 5% Inscoction Resorts snow that contrary to 10 :TR 30 a:p. 3, Oriterien 7, 2&R 00 inspection procedures and instructions were not available that would verify confermance with SAR OP-;:-la. *0cnerete Insce tien and Testing. Again, centrar/ to 10 05 50, aeo. 3. Orit. I, 00 ins eetien activities were conducted by individuals nporting to an organization whose functional autheri*y is not independent of unda influence and responsibilities for schedules and costs, in violation of the law, and again had to do with cenente ins:ection and testing.

In Januar/,1976, an NPO inspection found that the envirements! control pregra:n did not srevide adequate i..fomatien to show how centrol measures would be crevided to prevent enviremental occurances. In July of 1976, SE Resorts shew that a subcentractor did not have fully ec pleted forms for several pieces of liner plate for the Unit centaiment and sumo penetrations.

Also in 1976 another violation of 10 CB 50, app 3. Crit 7, occured when an inspection fcund that a su5centractor'encerpassed engineering functions beyend that which is described in the CPST.3 OA Pregram manual. In July of 1976, a re-port showed that contrar/ to the require =ents of the law, dccument centrol was being violated in that revisions to drawings were not distributed to and used at the locatiens where the prescribed activity was taking place. Ouring this ins ection forty findirgs identified problens concer.ing docment centrol.

Also in July of 1976 the Sie, pipe fa'erications pregram included, a plan to initiate fabrication fren unaccreved drawings supelled by a subcentractor, contrary to the CPSIS PSAR, maragraph 17,1.3.3.

In August of 1976, an h% Report stated that 34R 00 had started using a different system for develocing CCR trends whi:h- identified deficiency type, but the data had not yet been recorted in the monthly reecrt or used to ecuee *1.e frequency of :R's. In that sano neert, it was f:und that calibrations sorrices purchased by the suNeentractors had not been ;cr-chased f rem a:ereved su liers and that OA was net a requirement of the purchase orders. *he pro'clen was found in August of 1976 and was not re-solved until A=ril of 1977 wnen tne instector conducted a walk-inreugh of the calibratien facilities. '): ring thi: time, najer revisions had to be nade to the Censt::e*.1:n, LC *ns:ection and ;A Surveillance procecures.

Further, in August of 1976 WO 3stection necr s snewed tnat 3rewn and Reotnad tu-enased -atedal with inadequata decrentati:n even thougn pur: nase ords,rs steeified seecific deementatien -ecuirements.

  • he innd tr.aly:is in. mugs August 3,1976 snewed tnat 3]$ : R's ud teen written. ja were f:r lacs ef or ince.-miete toementatien en -eetist of material: anc equi: ment: 26 :enes-se agg , gate: 20 eencored ::-ente and 8 an tren sue-centracters activi*ies.
  • he sa-o Fr neert stated that letters ee-:-enti g e -e-risiens of 2325 153

7/.A. La < of Ortanizatien. etc. , cent.

Gibbs and Hill soecifications won dated after the purchase erder rapple.

ments whien 1. cle-ented the nvisions. Also in 1976, 7JGC0 eur:nased material was nesived with it. adequate decu .entation. Nrther investigstien revealed that the documentation =reblem had been addnssed as early as August of 1973.

In September of 1976. an NRC Report showed that a revisten to Sites and Hill Specification 232'MS-*3A had arrived en site two nontas af ter the vendor had accepted the supolement to the purehase ercer wht:h in-plenented the revision. *he time lag in israing the revisien to the site caused material to arrive en site without the necessary procunment decu-ments available as requind.

On September 20, 1976 the licensee infor ed the Regien T/ staff that gradatien problens with filter *A" r.aterial may have the potential of being a c:nstraction deficioney within the meaning of 10 CE 30.jj(e). It was detemined that large sandstenes in filter "A" material had been f:und en August 19,1976 and were cut of the grain site distribution s:ecified, and required 9 feet of previcusly place material to be ramoved. :n nyiewir.g a letter fren 3rown and 'oot to TJSI, the inr:ector said that the letter effered "infermation en 3 row. and Rect OA rarveillance and status of material suppliers's OA program implementatien" which found that the rapplier, General Portland was not conducting monthly raw material reports, material was not being checked. daily checklists were not eenpleted en row material goir.g into the durp hepper and net all material was being screened and washed as required by purchase order. This cer.straction deficiency nsulted in a step-work crder.

Orawing control problems feu .d in eee .ber of 1976, snewed that at the " nit 1 Centeiment and Auxiliary Suilding anas drawings ven being used for constraction while marked "Not for OenstractienM whien 3r:wn and Root explained didn't nean *nct for eenstraction" at all but senething else. *he Catch-22 explainatien was that the s*mp en a drsving apelied enly to the latest revision and werx may preceed with the drawing in areas net affected by the latest revisien. Hewever, during the it.steeti:n i* was discevered that a irsving marked'"' lot for Censtnetien' was being used whe-o the last two revisiens t 'd not yet been 4:oreved by !"0!, *he ins;eetien neert n-ained unresolved until S&?. preceduns von nvised to F:larify the allesatie use of drawing stanped in various ways.*

Sectien 3.3.1.2.1 sf the CPSIS PSAR contains the cemitnent to the 1.T Section ::!. Division 2, Oode. In the ::de, under :ersenr.el qualift:stiens.

^

it states that a candidaIe for :enere*e.inste:tien perserr.el' te qualified in ace:rdance with Aepencix 7!!. "ncer the .eading "le rel !* it states that nquin-ents include *: m letien of 8th grade plus 2 years :f er erienee plus satisfacto:y eceuleti:n of a training ::urse an exa insti n." ;cntrs y to that rMuire-ent, in Mar:n of 19~7. 2.'4 .ran* , a eenc rete testing su:-:en-tracter was founc to havo negated inat Muir= .ent during an '.~." i.. :ec*ien.

R.4 Runt was hiring reecie witneut no 2 years ex:e-tence --cuireent. *' i s deviation zit. ns: alt in a se-tous violation wnen a *.evel : insrect:r wt*neut any Orrrtous exterience, falsified :enents :ocuments. (07"e. will : ver that later in these :ententiens.

a Mshn ,

~

A 2325 154

%md" a @s-

IV.A. !ac< of Orranizatien, etc. cont.

Nring the sane NRC insteetion re ort of Maren.19"*.it was found that there was procedural discarity in 3rewn and S. cot ".A crocedure No.15.1 and the 3&R OA Manual, section 15.6.and were niated to the falsification ef eenente recoreds. Nrther in the March,1977 re ort it was found that the e..W. Hunt Oor:any had failed to nport the employee's alleged falsifi:ation of cenerete neords, in direct violation of the law. A precedural infreetien, ni certifi.

cation /documentatien of ins ectors was written against R. ~4. : 2nt at the same time because the sub-contractor had allowed the level ins ector to perfom eenerete cylinder cem=ression breat tests and aggregate sieve ansylsis without evidence of demenstrated pr:ficiency in accordance with '.he sub-contractor's procedure requirenents and in violation of 10 0?2 50. A:e.3 Crit.V.

In a November,1977 NRO Secort lack of quality ree rds were f:und ni the steel support structuns for the Resetor Coolant and Stean Oenerater.The foms, selected at randen during a routine intrection, did net :entain- signa-tures and dates, nor any nference to eight ee penents sup: lied witheut dec-unentation. A subsequent review of an A/I centract draung f:und a weldir.g design change without authorization by the 34R shcp ins:ector.

OF*JR eentends that in the absense of OA, there is no cer.fiderce that CPSIS will perform satisfactorily in service and therefere detailed testir. ny with the eption of cross-examinatien, is absolutely ir:erative to convince the Connissien and the public that OPSIS is safe and n11able enougn to cen-cones pre-operational testing. -

17.3 . Weldine There is a substantial amcunt of documented evidence in the U.0 Irsteetien re erts that shew weldirg in vary areas of CPSIS has not e.et requirements of the law. !n seme esses, while investigating nen-cenferning welds, precedural errers von also found. :n sene, the total nen-existence of required precedures was diseevered. In ethers, a systematic failure to follew procedures was discovered. In atany of these instances. : rnetive nessuns were taken which affetted verx fren that point :n but no acti:n was taken to discover the exte .t of defects already embedded in eene-ete.

  • 4elding crchlems a e.ar in the Ins =ection Re=erts at least tren Januan 1976. P ecedures Mquired by law (10 0F2 50. Accendix 3. Crite-ica 7) wen f:urd to be lacking for insta!!ation cf ten =craq attachments to the react:r sure ;dpe restraints or for examination and -e: air. In a related -atter, it was discovered that the neair precedun being used per.itted detectatie 4 e.

laminations to remain 7he plate, centra y to the ACMI Code wr.ica the :entracter was sucrosedly ustr4 T"* s nspense was to not accept the W.0 eriti:iss but to hire a third ear *y to test tne weld s.

Also in January. '"f. precec res equired ty law (10 072 jC; A: . 3. .

Orit. 7) f:r ;0 surveilla .:e :f *.ne :entaiment 52ilding stesi liner installa*1:n von dis:: vend t: net exist. This infracti:n was dise:ve-ed while r*:st-re erds were toi g -aviewed :encerning sene nen-: nf::-ti :g we;ds, (a general veld review was also g:ing :n at tne ti-e.) S.e nen-cenf o- .ing walds in-velved ens wita u-a::ectatie : r:sity fren-::nfe:.:ty =5) an :ne .ith a 52- -

thrt:C3 ( en-:ent:--ity =10 S.e earti:ular =recedures we-e in re-art?i:n at *he time, altheuen the installation f *he :entait-ent 5;ildtrg steel liner 2325 155

7. 3. WeMire, cent.

had been taking : lace for five menths. *henfore, it is OF'.T s cententien that the centractor's clain of innecence a:eears sus:ect and the infracti:n a: pears to have been a deliterate avoidance of the requinnents of law.

Also in January, '76, during a routine review it was fou..d that appreved design changes involving liner plate welding reteirements which had teen sent *o the contra:ter and sub-contractors by **.*3: in July had not been in-

rporated yet into document.e ased on site, ever a period of six enths.
  • his was an infraction of the law.

In July,1976, an infraction was found in that there was a total la:k of procedure as required by law (IC CFR 50, acp. 3, crit.7) for centrol or insteetion of incertant parameters involved in welding of safety-related cers penents in the centractor's Miscellaneous Steel Fabrication Shep.

In Aurast,1976, it was discovend that argen flew-regulaters used fer welding were net in the calibratien pregram and were not being calibrated.

Cver a period of at least five months, no corrective action was taken, al-though work with the meters centinued.

In May,1977, insteetion revealed extensive dis =entinuities in the weld-ments of certain braca:ets. In November,1977, the licensee n:cr*ed that certain "S" series Cadweld sleeves ven welded to steel plate e .bedments in nverse crientation. 7his item is unres olved because of ether =essible si:r.1,.

Iar cenditiens.

In Ceteber,1976, an auter.atic welder in safety-related work was fcund to be traveling at 2.5 inches per ninute, whereas the travel s:eed required was h.6 inenes ;er ninute, which affects the heat and therefore the strength of the weld.

Most serious of all, in Ceteter.1978 a particular cadweld splice came a: art while positier.ing an attached length of robar. In the course of in-vestigatien, i* was docusented that the licensee had failed te prenstly re.

pert *.he incident. (a violatiens of ICCFR JC.j$ (e) (2)). It was further dee:-

mented that then had been a habitual mede ef coeration in viciatien of the FSAR and NEC Rer21 story Guide 1.10, whenin ::s:ualified and inadequately su:errised s:11:er hel:ers were doing all pre aratien of the s=liess u: to tne :cint of loading and firing seretimes in peer lighting and hazar:icus tenditions.-11so6 in : art due to the sa .e peer :=nditi:ns and in :a-t due

to the lack
f adequate records, no one was sure who had done what w:rx r

! wnen, and several 'other visually detectable defects had passed ins ecti:n.

. as well as the one vnich came a: art.

3eme 675 other s:lices made by the sane s:11:er were not available for insteeti:n. including 3 ef *he 4 selices he apparently rado that ..ignt.

Furthe- ere. to 07'?'s cowledge, there nas never :een any !ns=eetien Ee:cri stating that 10 CFTs 50. Aepe . dix 3. Criterien ** ("A:tivtties aff ecting quality 3:all te a:::-=11sned u=. der suita:17 ::r.tr:lled :enciti:ns." was violated by *.he verring conditi ns :!sse-1:ed t=. ths *nsteetien Reperts, altr.euga it is :t rteus

  • hat sue . :enditiens wen a -ost likely cause :f
  • he :sfeetive welds and ins:ec*ien.

OTP :entends *.r.at .c na*ter now canffly the persennel an tratned, if *.ney have to =a<e ineir way around ninfereir.g steel 130' a: eve g eurd

-V 2325 156 W(%

J i L u.

w' a Wl; J

e x y l.teim

e. ,

we iyd s -

~:o y ya

U.S. 'a'eldine, cent.

with no scaffolding, at night with the aid of flashlignts and if insteetions must be made in the sa-e conditions, h ality Assurance as inte-ded in the law is im=essible. *here is no assuranes the welds unavailatie for insee:tien were any better. OF.*R eentends that the law with reseect to working ::n.

ditions was violated and that cornetive action should have been ordered.

Further, an allegaticn of fraudulant practices due to poer weric an- -

ship has been made by an unidentified sour:e. pertaining to cadwelds. One of the accented ways an insmector tests a =adweld is to use a thin metal rod _wh_i.ch he eckes into the weld to see that it__ doe _s.n't go all the way .

through, thus deternining the integrity of the veld. The allegatien has been made that it was the practice of seme of the helpers to stuff cetten or nud into the ana cf the veld h keep, the red fr:m ' going all the way through.

i fCC*to ICC0 cadwelds are made a day.

{,

OPJR center.ds that the abcre excerpts of documented evidence fren G.0 reports and the allegation of bad wor:c.anship raise sericus questiens as to the safety and scuadr.ess of constraction completed and in-pr:gress wherever wel!ing was and is taking place and should be addressed so that a through analysis of the censequences of these and other safety-related welding prob-less can be deter ined.

U.C. Steel More docu-ented evidence fren N?O hspectier. Reports shcw that a nur.ber of roblems regarding steel used in the cectairrent str2: tun and ether safety related verk have occured which do net meet the requirements of the law. In sere cases the problets found deve-tali with the pecblems found in welding ir. fractions with the same precedural =reblensa errors. failure to follow preceduns and non-existant crecedures. As in the abeve.ccrrective nessures eften only affected work from that point en or proceduns were changed to nate the procedure fit the problem.

For example, in one NFO re= ort it was stated that the licensee's contracter was installing centaircent buildings seismi: catagery Class I =1:e restraints esteds withcut crescribed documented instructions er worx proceduns. In addition to that deficiency tne same re:crt stated that the ins:ector fcund that installation f the contairrent building drain s;:no pipe nstraints were being installed withect benefit of instalia-tion procedures. :entra y to 10 CFR 50. Acce :diz 3. Criterion 7. and een-trut/ to the Gibbs and Hill seecification entitled Miscellaneous Ste41 and dated Tetr2ary 28 1975. The date of the found : oblen was Januarf *-9,1976 f

and raises a serious questien as to the integ-ity of the installation of steel in *he entire year ereceeding.

In Januar/ cf 17/". an '70 ree:-t stated that during an indecencent review f str2:tursi emeeds it was found that while the reactor : elant puans and steam generat:r rerti:a1 su:= ort e tecs were f abri:ated and being installed tne detailed design in t..e !?!!3 FSAh figure 3.8-1* vas su:-

stantially different The detail in -he S R snowec tne em:ed a.: crate asse.bly extsncing *eugn the fi:er liner : ate into the :entai rent :sse

-:s t . *he "as-tuilt" :ercition tid not :enetrste the : a ,s. A *:esig .

enange* was

  • hen instituted a .d a:preved by the licensee "af ter the fact *.

= 2325 157

1".*. 0. 3 t eel . :en t.

In Octe'cer of 1975, a liner plate anenor stud pull-cut was caused by a lanination in the steel piste installed in the reaeter vessel". avity in the contai.raent base nat. A"..11e 3rown and Rect did not censider the stoelen sufficient to recort it as a non-conformance, it was learned by the Z insee ter that Brown and ocet and *"S! vers :ene.--ad hetween themselves that other liner plates night have siniliar lanisations. Neverthe.

, less, Brown and ?. cot and *1'S1's :crnetive acti n stated only that the matter would be *nviewed". No further action was taken to deterdne the extent of defects in s'e41 already installed.

Fo11 ewing an inseeciten of the 3rown and Root Fabricatien Shep an N30 inspector found that the CA Supervisor had not issued a stoo-werk order as required by law, even thougn he was aware that there wen no in-process controls in the shop while safety-related werk was and had been going on, also as r*quind by law. The step-worx crder was issued only af ter the NPO inspector found the deviation. drawing an uravoidable conclusion that safety-related w:rx in the fabrication shep weuld have conti.ued ad-infinitum without in-process cer.trols to guirantee the safety and quality of *.he work.

  • here were no stems taken to nyiew the safety and q ality of verk that had been on-going previcus to the N?O inspectores finding.

In reviewing testing records an N?O inspecter found that contrary to Mown and Root's evn written procedure requir.ing_ indecendent laboratory testing of all supoliers, a procedure approved by the licensee, a supplier, Bethlehen Steel Ocr=cration was conducting its ewn 11 tests en steel supolied to 3rown and Rect. 'dhen this was repor*ed to the NRO, 3rewn and Reot c:r.

rected the probe . by re-writing the crecedure a11 ewing suroliers *o test their ewn products. a questienable practice at best and ene not desig-ed to assure qcality centr:1 or assurance. Further, an arrega.t disregard for the law, as shewn by 3rewn and Ecot's decisica to rewrite a procecure so that it

, fits a problen, there;y negati g the probles, is disquieting.

.Nrther, it has been alleged by an unidentified scurce, that the re.-

inforcing steel arocnd panetratiens has breken when werxersr atten;ted to bend it, indicating the quality =f the steel is in questi:n.

0.Q =entends that these questiens and allegatiens nga-ding the in-tegrity cf the steel already in place in the plant,as well as *. hat which is to be used in the futun, nust be addressed.

17.3. Oreundvater '41thdrawal--

I.x:essive g;;u . water withdrawal rates ven necr*ed as a rielation in *I *nsteetien Re crt No. JCAfM/7f-Ci!. Cen*ra y to the :enet: acti:n earnit, the at=li: ant ex:eeded the s ecified -axinun withcrawal rate of 250 g;n. Ocr-ective actien was taken to ensun that daily f1:w rates ex.

ending an average of 250 gpm would not te ex:eedec.

N ring the ::nsty::tien pernit .--view, the a:cli: ant :lainec that there veeld be no ac erse 1-:aet as a result =f g cun: water usage. In :arti: ;ar, tr.e a:plicant statec *nat adverse effects suen as excessive drawcewn sculd not ec:ur. Yet, tne grouncwater level has art: ped since ::astr;eti:n activit-/

star *ed at the sits.

up. a mvma u# - -

y Ah e . 2325 158 J h h_ h h+b hL 3

7. "l. -~Mvo. *r N--val, cent.

ZlR eentends *. hat a thorcugh analysis df the censequences of ecatined crawdown of the groundwater at the OP site te initiated. In additien. *.he effects of the reduced water level should be deter .ined along wt*h a deter-mination of =cssible ecrrective actiens to alleviate any hardshic incesed en other earties.

7.I . ;-- ~ t.

here is an everwhel i .g ancunt cf evidence fics % *nt ection re'xrts that :-2sta=tul ==rers cf pr:blems with ::nrete have ::cu ed dring "?;IS censtruction in progress: prcble=2 th.t di c:ti relate to safety ani questien the integ-ity cf e-itical structr:es in the Catacery clus a. well as raise questions z.s to cerr.ittment to 11 by the applicant.

Ter exa=ple, in a yet-cary,1976 EO Repert, eering s==;1es were taken

.% the Unit : Ocntalment hilding base =at, (Octagery : Otr ture), shew-ing evidence of a a to 6 inch layer of heneye:r.b stratifi:atien. *he cen-ditien had the potential cf tecening a sigraficent eenstra:tien deficiecey.

"'he problen areas were fou:xi to be in a eas of high cen:entretiens of ecteds and were identified as voids, lack of ceneclidaths atxi inadequate werkir4 of cencrete arouni e=teis, a:d were located in the cuter wall a ec. 24 cere sa=ples were taken later aM chewed two scperate deficient areas in the peri-noter wall cf the mat. Cer ective acasces taken appeared to be cencerned with how to preclude the cecurt.nce freer happe..ir4 at Unit 2 c xi if the valve isclati:n erbed=ents wculd perfc= their s:.fety-related fcnetien after repairs.

It was decided that there wculd be for pcurs ade c.t hit 2 rather then the one peur that had occured at Unit 1 as specified. There was no idicati:n that the Unit I tase :.at w:uld te repered to assee ite safety and 1.-terity.

Instead gr:cting was d:nc a:xi repa. irs were made. Sis raises a serieus questi:n as to the strergih of the cencrete where voids hrte been filled w-ith new sterial and may cr : 7 not af.ere to the cid cc . crete er r.ay er =ay net even fill all the veids espe: icily since the veids were disectered in Tet :ry of 1976 a.:xi the repairs appear not to have teen ecepleted until August of 1976, six =cnths later. Se questien cf the valve isciatien erbedne .ts perfer=ir4 their safety-related fun:tiens was never addressed. C::;1sted ccrrective action was inspected by observation only.

?rther, in Never:ber cf 1976 an 30 * .spectica re;crt stated that durir4 a reutine inspection, expaMed metal mesh used as a fe= f:r a previcus concrete placement was feu:ri to te seperated .% the adjacent placenents by as =uch as 3/41.n:h in an area greater than 200 ft. aM left in ;1 ace at the Octstracticn joint vnile ancther pla:enent was teir4 ; cured at the hit : Oc=:ai=e.-t tase =at. *te unbourded =etal mash was not re=:ved a:xi the irspecter acted that there was no special e=phasis er eff=; t.r the :en-

=ste rew to vibrate the ecnerste next to the ve-ti:a1 c:nstraction joi.-ts cence.ned. It was disecvered that Oibbs ani 3111 had evaluated the fe.sa-tility cf usi 4 the metal =esh sexi lear _ng it in pla:e ht had n:t ::nsidered the ccediti:n wnere the resh =ignt te:c .e r.becied. Also there were no inspecti:n require-ents in MR *,0 cencer .i.4 the terri c nditien cf the net:.1 mesh ;-ict to subsequent pc.=-ings. he repcrt iM icated that the cnly cc rective actions taken vere the pressi 4 of the mesh tack agai.ct the previous place =e.t and the vtring :gether of the =esh in the areas wnere

" 2325 159

21. E. C m -a*a. eent. - - -

it everlapped er was founi to te lecre. Espection requirenents were re-written to allev no =.benied :nesh in constraction joints fer futre place..ents.

Se checking cf previcus placerents was apparently not censidered.

3 another Inspecticn re;c-t,a constractica infracti:n oce: ed due to lack of adherence to preced=e regirtr.ents as required by 10 :2 t 30, App.3, Orit. *I, resulti 4 in inec q lete censelidatien of cenerete at the nit 1 centaircent 'ing base r.at. Se ine: glete censolidatien cf cencrete oce=ed between two adjacent ccncrete lifts cauring a concrete vertical

' cold 'cint' en the west side of the tetten of the reaeter vessel cavity ani a step-weric or er was initiated. P.a infraction was caused by tine delays ber.veen the pours stich exceeded the prescribed 7?, of the ti=e of initial concrete set. ~his infractien, acceriing to the 20 R:;crt of J21716-18, 1973, had 'the potential f:r causing er centributira to an oce=ance related to health sni safety.'

Prewn and Rcot fourd it necessary.fellevir4 this serious infrc.etien, to hold additienal classroca trainir4 to instruct craftenen and supervisers on the correct manner to place cen=ete in acccrdance with specifications ani procedures and to assign adiitional cupervisers to large can=ete place-r.ents in the futre. C:ccrete craftsnen ani supervisers by definitics shculd 'c.cv the eer e:t anner in st.ich to place cencrete, hev to read specificatiens ani unierstani preced=es, in perticular those hired fer the ecnstruction of a !!uclear ;cver plant and the fact that they had to have edditienal clastrem traini 4 fer this functica raises sericus questi:ns as to the qualifications of ?dP. persennel. "his fact also raises an even nere se-ious questien as to the safety and reliability of all previcus cencrete

curs at the C7335 site. Ani further, this is net the only reference (TJL has fcuni in 20 inspectica reperts where untrained persennel were.used in critical phases of constracti n resulting in serious safety viciaticcs, a.s we ;cint out in other cententiens.

D=ing an 20 inspecticn in 7.ove:her ani *ece=ter,1973,, concrete aggregate problems were f: uni to te of such =ag .itude that a ' step werk' crder was initiated on the centi:raed place =ent cf Class : cc. crete. ~he ins;e:ter pcirtai eut that there was no evidence that 'le apprcx5ately 6000 c hi:

yards Of Class cen=ete previcusly pla:ed in centai==ent f unisti:n base

=ats is of =.ifer cencrete. *n the sa:ne repert, the 3 ins;=eter expressed cencern that the 2AR ';A staff "f: uni it necessa:y to initiate ecce tive actica of an i..trasive natre agai .st '2e ccnstreetien activities to obtai.'

res;cnsive 1:tien.' "he ;Mblen was cenridered an iten cf n:nec=;11ance, c=ctr=7 to 10 3 50, App. 3, 0:iteri:n :"T , and a;; eared that 'le licensee 's established neasres f:r 1.itiati 4 eerectire acti:n had not resulted in prec;t cerective acti:n ner 111 the :neasce ;recl*.:de repetitien.

S July cf 1975 an infracti:n was identified as centrary to 10 3 30, a:p. 3, W. 7 tecuse water va.s added to *2e cenette in '2e transit _.'.x tracks curir4 cen=ste place =ent Of the " nit i Contair: ent t"" 4 base nat,

n sin d'fferent occasiens vi'Acut the t.pr evt.1 ef the testing 1 J:crat: y

- =esentative. "he infractien, again, ha.1 the ;ctential f:r caus=4 er cectribu.ir4 to an :ccur en:e related to health ani safety, a::crdir4 to the 7.0 hs;cetien ?.epc-t. Once again W. had to ::cduct a ::neste place--nt e*

q T M M F 1. m i

2325 160

17. I . ---.* * . eent. ._

ecese f r :enstraction perscerel ani ailed asilitienal ;erserrel fee large cencrete placenents as well as militienal inspectors.

In July of 1976, it was f:urd that e-tra eenerete cylisiers were :st cast f.r all batches of ec . crete batched withcut ice as repired f:r the renairing Iceds placed and extra thernce n:ples to be ededded in the plc.ce-sent to reniter the heat cf hsW:tice. Se heat of h;tr. tion peaked at alcut 136D. ard the rep =rt stated that temeratres sicve !!5* t:uld have teen cance for conce n# Se repcrt fetier said that the eencrete ec=pressive strength test reccrds inii ated that tw eylirders h:d treken fren batches where the placing te perat=e was in en:ess cf 7CD. A*.though the two cylinders brcke at peater than 400C PSI, there was no evidence cf the cylir.ier strer4th tests for the other thirteen tetches of ::nerete which had poccibly exceeded 7C*? because they also ecetai ed ::o ice. 21s pretien was net reselved, to the satisfactien of the 20, f:r fcur :enths.

In Jaraary cf 1977, the appli:ar.t, deing a reutine site revci' lance founi that cenrete crir4 surfa:e terperatres were telest specific:.tien li=1ts. ?=ther investigati:n eculd rat identify a doce.ented ;ce plan in the placenent reecris whid night have c:ncerned itatif V.th the i. penii.4 coLi reather. The concrete curir4 d.ich was telew spe:1ft:sti:cs was fcr the ar.::'"'s y b"'"'at ani serri:e vatar intake stra:tre arerJ. Se inspecter foual this as a licensee identified pr:blen of appr:zinately ene year tefere, 1..an the reface te=peratees were tel:v 200 7 en the cring cencrete of pla:e-ment 2.101-20CC-C01 on both Cecenber 30 ani 31,197C. Sis see repcrt said that there was no pla:enent plan in the 3 9. 3 doe:.nent vault to reet regirar.ents of Ker21atery Guide 1.f5 and the ;ro'est 70r.. A site sereil-lance repert dated January 7,1977 shcwed an identic 1 ccediti:n, " fro:en' cenerste drir4 :rir4 et the Cnit **c.1 Safeguards P"" g 7.at. Cnce again 33 revised their precedres fer r:cnitorir4 the ec.'rc s=f a:e terperat=es for " fates" placements.

T.othing was done abcut the cenerete pered during freezir4 veather in the tw winters re;crted; V.nters whi:h had had long perieds of extremely ecid weather with freezing te=peratres cer=:en. *here is no way the centracter can plead igncrance of the weather, ner can the applicant. So, was ": cst ani schedule" the reascn cecrete was peced, rather than safety?

Tifty-five O' ancher belts were f:end to hace been ec:itted fren the reactcr centain=ent t"d' 4 Tc.; cenersta placenent, in a re ztine revisu by the 20 in 1;ril cf 1977. Ca e again, 22 tock ccrrective acticn in the fern Of trainir4 sessiens and e=hed detail drawing devel:p=ent to " preclude a sr" ' s - ecerance' a=i by a.ssic. ira a full tiae civil ',0 inspectcr to dec=.ent a:xi verify eencrete placenent enheds.

One of the nest serious ex2=ples cf cencern to C*2. in reger'i to the cura'l safety of all Ocnce*e Occstneti:n Lxi to the parti:n of :==ithnt to 3 i. in the 20 2epe . 77-C2 which reperts the investigatice in:c the falsifacatice Of :enrete air-entrair:=ent test reecrds in ihch of 1977.

he incident ecerei dring initial ceneste placener:: in a Oct nery :

St ::true when a level : eencrete inspecter verkire f:r ?. . Ir_t, :cre.n:1;-

falsified an air-entrainnent test erding at a nit k.fer:aris 'r"* d' _g flect slab.

u 2325 161

7. 7 . * ~~-
  • a , cc-. . .

"he fa'.sifacation cecesi en fa: ary *0, l'?;7. It a.s ..ot repcrted to the :7.0 until Teercary 25,1977 and then en17 after a reutine review by ~'000/

G3 "J staff me-ler of 3GL's 2.'s, :ne of W.ich nede a reference to the te5:~.L.atien of a 3'3 e=picAe fer falsif 71ng hi8 reFCit.

2.e te: .it.ated pe-sen was a f avel I Sspectcr assigned by :.2 to inspect eene ete a:xi to cenicct sta.dard lab tests on site. Perscnnel files shewed that the persen was hired en 'anuary 12,1976 and ter-deated en Tet: Ary 8, 197/. ~e was certifiai as a cen=ete inspecter en Jrxa:/ 19, 1976, seven days after being hired. &vever, his recced shewed +2at ha hei had ne pre-vieus experience in concrete testing er inspectien, ner did he gadue.te frem high school. Cther recenis revealed tha.t this sane persen had ecrsiueted cylinier cct prehensive strength tests, AS Y. -117 ani 0-1*4 gah.ti:n tects ani A3"Y".;-566 ::cistre aggegates tests, with:ut evidence of training.

CZCR cente:is that ass =a. cess of safety cart.ct he r.ade .until a full analysis of the consequences cf the safety-related ;-etiens fcund ever ord over again in the cencrete construction of - .C c:n te deternined, t..at in fact, f.ctmon threcds run through the :2a inspectian Re;crts d = 2g the constructica p.ase ef CG from procedures required t/ law fcurri to be totally ncn-exister.t to the hiring of untrained, =4:211?ied perscer.el for safety-related jets, with an "I'll fix it if p:u catch, rs' attitude prevelant and a censistant disreg::.rd fer the re;airerents of the lau, brMgirg into question every phase of c nst:acetien.

p. . _r s ~ '_ -- M

An allegatica has been made arr'. treucht to the attentien of C that the en snsien ac int between the au-ille.ry ? ' .g ard Centa.i.r.ent Unit 2, (L vall ani '.a wall); centdns a st: 2ct::ral defect in that the e.v=.sica

'cint did n:t verk, that steel was sutnituted to ::rrect the ;rchles and that cencrete was poured over the cavity.

C'T.'.l has so way of verifyi.::g this allegatien tut te11 eves the na.tter

. is of a sufficiently sericus natre to v:rrant an investigatten and ccrrective actica, if necesst./.

n ; . M at-- -" '--a== h B:hitit 3 cf the aceenent between "Jestice.cuse atxi *exs.s "tilities specifies that 'ies 14 hcuse vi'.1 pe-f:r= the fractre teugt.ess testir4 en the reacter ves:els staan generatcrs ani pressri:ers f:r E " nit i ani s.a.s. 2.*

M trings into c:estien the p@ety of the supplier of the nest critical accrenents of the pl: t testi g th:Je sane ce=;;:nents that s .id supplier, (*estin;n:usc), is seli h g '.) the applicant. " hen in fact, in a less critical area, hevn ani ?. cot's ,A vas calicd into pesti:n by the

30 Repc- 75-06 . ten it was f: uni tha'. reint:::irg steel nata'.1=gi.:.1 testa vere net :crdur.ed bf an irde;c.-dent te:ter, es regirti by hevu .-d ?. ::'s proceire Of-119f ?.07-3.
r. telieves that assrance :r estety : art.ct te :atistasterily ;i en t7 tha tyyli: ant tithcut 8:x>enicn . *.esting Of sud .ritical : r;:nents a.s the rea..cr vessci.M s*.ean generaters ani - ess...:ers. iven the crea-2325 162

..m.  ;;

s, ; .

i it I. l- 51 lt ' fik hQs: hbUblIO L23

17.3. S- . + --. ~ *-. . . . .+ 1- , ec et .

to life 8:11 health that could occur frcet an accident at 73C , it is in cu:her.t u; n the c.licant to act :nly 5 cer~.itted to ,nality Asr.:rence, but to te alert to ary hint of chi:.r.ery where the health aM safety of the public night be b questi:=.'

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The detailed acceunt of the eer.striction pr.ase of 073 3 shows petless in every area of que.lity assurance. Icc.e of the ;nblens vere due to hadequacies directly attributable to sub-ecetra:ters; hcwever, a.s specifici by Appendix 3 of 10 CF. 30, -E0 is respcnsitio f:r the establistrent , executi:n and all other pcrts of the M Pre pan. al* lough -~0"O can delegate ver:c to others, the ultinate res;cnsibility re= tins with ~~%CO. In particul e the 1e:dership neccesary fer the peper operati:n cf all ; cases of a well-r.:n 3 Frc.ran

=ust cene fren *2e entity with the ultir. ate recpensibility.

Tet the persister.ce cf each type cf ;r:blem ever the total constructi:n to date, iMicates that so overall s:1uti:n cf a.y of the ;retiens has been instituted. .ilth: ugh each pretic= is a' dressed after it has been idectified, the size type poblen pe;s up shcrtly thereafter. Tc.is is clearly a rArage-zent p:cles ard in11:Ates that a pattern of itisse:-ft. ire exists en the pa-t cf -"300 6 : tar as G is cence ned. This is :entr:ry to Its.r.:ed c;erating precotro ad is dro centrary to the require:ents of the law. :*o s2-:cer-tracter is g:hc to narch to the drun of the ?. een they are getting pild by a seperr.te part;--!U" RCD, (so 10..g as they :an stay out cf *sil).

"his situatien makte it i= perative ths.t a mere ac.gessire stani on the part of the goverrrect is necesscry to caere that ""0:0 establishes aM aze:ut.ss a.n effective G prepte: during the cperati:n phase of 70C, (in the event an c; err. ting license is at:ted). CF"J. eente-Zs that two arst.s t.re of prine cencern: Einir.isation cf incider s wherein halvertant releases cf uncentrolisi r:t.'istice 'akes place aM the pre entic: cf e.ccidents.

C7*'t's reccer.cnittien to avcid in:idents is to dedies.te a ;;rti:n :f the cuter peri: ster of the 735 site to the ; eductica cf all iMigen us editie plant ani aninal (= eat and dairy herds) life sexi require that Squaw Orcek Reservier te stecked 4th all irrligen :.s edibic fish. Fr:m these aM '2 sir products, one free r.eal fer each shift of empleynes sha.11 te prepared en s'te and a rester kept iniicating which e ployees voluntarily partake of the zeals. In additien, a cer=1ttnent shculd to cttained fre= !"'300 top r.ansg (as well as 7J tcp zanagenset) to visit the site weekly ani partake of a zaal.

A rester of these meals also should te kept. Inese liv hg t.'.ings also rep-resent the ultinate zea.sring devi:e in '2e event 'lat ez:essive. radiatien is released.

":n::1's receraeMati n to preve=t accidents is to require that the ten-sequences :f lass : A :idents be r =inently displa:mi at 'le plant site ani in :crperate headrut.rters :f "**"/0. -n any ;reperly r:r. 3 "repan, the pessible ec . sequences Of a gect-on =ust te repeatedly told to the t==1:7-ees. *fet, the .1. clear prep:n see:s to have to:::4 veri; e:4 ssed in ie-littling the :ensequences of large accide::: to c unter ;csstbit anti-nuclet-preeagania. Erever,this acti:n has als: 511ttled the:e :ensequences in the =inis of the nuclear ;1:e.t esti:yees ar.1 their su;<rviscrs. I'* 1 :entenis 2325 163

M ..T. "**4 f-- % .., h"-- e.aa,a^"*. C ., 0:nt.

that the epicsite ap' cach is ^- * *cl7 preger app.cach to a sound, realistic

,d FT 4~ L' to assure safe operatien.

(Note *n

. the above ::nte".tiens. m blems a.a.aly:ed ty n d e 4 *y,, g,,...g.,

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pha.se of c?3s vet

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  • spec +.icn ae;crt s C-C thro;p M,)

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V. OCEST**N OF OAFA3111*! CF SFI:C T.T! CT0FXI A?I.A TO C 55 A*:0 00fe:A:cis

!t is s*a*ed in 1; crR 30, A:eer. dix A, Oriterien 2 that structures, includirg the Spent Fuel Storage Area, "shall be designed to withstand the effects of natural phonenena such as... tor-adoes...vithout loss et escability to perfers their safety functices. *he design bases for these structares...shall refleett (1) Aperceriate censideration of the most severe cf the natural =henerena that have been historically n:orted fer the site and surieunding area, vita suf-ficient margin for the limited accuracy, quantity, and peried of ti.-e in nich the historical data have been accuriulated, (2) a=orceriate earteinstiens of tne effects of normal and accident eceditions with the effects cf tne natural phe-nomena, and (3) the importance of the safety functicns to be performed." *dith regard to the CFSIS/FSAR suttaitted by TOGC0 for licensing purposes. OF7. con-tends that the above criteria have not been sufficiently and nsponsibly net, with cur.cbjectiens falling into three bread :stegories: 1. lack cf accepta-bility cf the analyses leading to the derivatien of the Cesign 3 asis Tornado (37), 2. lack of a:centability Of the 3* icading analyses, and 3. use of less.

than conservative design basis paraneters without justificatien. A nors de-tailed explication of these objectiens follews.

V.1 lack of Aeeeetability of Pre Aralvses Instead of centucting its evn. independent probability and noteorelegical studies in order to deter .ine the 3T for a nuclear pewer plant in'a relative-ly high-ris< tornado area, !;GC0 has relied uoon previous studies whose relia-bilities are severely questi:ned by OnR. More succifically, c'efectien 7.1 concerns the validity and appreeriateness of probability calculati:ns and et-served ternado data used to establish paraneters for a 3* with an adequate level of cceservatis:n. Contentiens made in this regard are as fo11cvs.

V.I.A CT3 objects to the prenise that "the pretability of ce urrence of a tornado that ex eets the 3* shculd be en the oder of 10*7 per year per nu-

- elear power plant." (*4A3E-13CC, p.11) The exclusien of any ter.ade that has been " historically re:crted for the site and surreursding area" violates the legal requirenents cf :riterien (1) above, a fact that nakes the 2se el prfea-bility thee.y at all cpen to serious question. Furthernere, even if prota-bility :alculatiens an dee-ed acceptable, the figure of 10" is ascertainec by On'R as tee icw be:ause Of the pctentially estastro= hie ard highly un=re-dictable consequences of a ter . ado ecturrence at a nuclear :lant site, and as too arbitrary because these at risk (the area residents } had no vel:e in the deter .ination of an accectable degree of probability.

7.1.3 O n~5 sert:usly questi:ns the validity of erobability :al:ulatiens and data used in the *? SIS /?SAR t: derive a "S* whese pre:abt11ty is en the :Mer

..-7 becaust:

c.a .s 7.1.5.1 ine ter-aco strike procacility f or-ula (derived by Then in 106]) is itself :f deurtful niia:111ty since (a) it is aines* entirely de-tved from torr. ace data limited ts *.he state f *:wa f this is estecially t-2e f *he deri-vation of the -ean :sta a-sa constant), (b) i* is de-tved frm data -ni:n is fem 17 to 26 cars :1:. (:) it is derived frem cata ::11ec*sd :aring a perte:

'9-(1C3?-1: 21 a.r s-i: . obse-ad en: ,f

  • a-a m e s w a -, often ursvete-ati: and v.

2325 165

accurate. (d) it is based on numerous assuretions which were ma:e for mathe-natical reascas but which, in light of *.he uncertainty of the data in the first place, night decrease its over-all n11 ability, (e) its curnnt use in the 0?!!3/

TSAR assues that the mean annual path area of tornadoes has not changed in 17 years, and finally (f) its current 2se depends on the accuracy and relia:ility of re orted tornado observations in any ana for which the erobattlity is being calculated, seeething whien is not always possible, esiecially in "smarsely =ee-ulated anas such as the Southwestern Tnited States", where "there are uncoutt-edly nany ter .adees each year that an not observed or reported." (*a3X-13CO. ;.1) 7.'t.3.2 the Paut: "one-degree square" ternado occurrence da*.a (Tig. 2, '4Agg-1300) used to calculate tne probability of a tornado hitting a point is fr:n 12 to 24 years old and therefore does not include any tornado data for the last 12 years, a fact that OT TR censiders cr2cially sig=.ificant.

V.1.3.3 the hjita-Pearsen tornado seale (y??) used in OPSIS/?SA?. has by no means been universally accepted as the most reliable method for *he classifica-tion of tornado intensity characteristics. This fact is undersecred in '4ASM-1300:

"Or.e of the obstacles to accurr21ating reliatie quantitative in.formatien has been the lack of widely accepted methods for measuring and re:crting tornado data...

If this system (Njita-Pearson) proves successful and is adopted for general use, reliable quantitative data eeuld bete-e available within a few years, at whien time more detailed analyses tan be undertaken." ('4A32-1300, p. 2, e chasis added)

This statement is also indicative of the marked clinate of uncertainty that per-vades WA53-1300, uten which is based the over-all CPSIS/ TSAR nothod for estab-lishing a CST. This is discussed further in 7.1.3.l*.

7.1.3.4 although '4 ASH-13CC is intended to serve as a "te:hnical basis for in-terian regional tor-ado criteria", it is as :-uch a corr.ent en the uncertain, an-proximate, nebulous natun of =urrent ternade knowledge as anythin.g else. The following quotations, all taken fres '45H-13C0, will sene to illustrate this cracial points

- "M:vever, there are still too few obserrations a..J too few trained observers to secure the data necessary for dete:-:ination of exact ter-ade intensity charse.

  • eristics.* (p. 1)
  • in many of tsose anas waere few or no ter .adoes vers n=erted futun increases in peculation density may be ace:meanied by an increase in the nunter n:orted."

(p. 2)

"Tnfortunately, censistent and systemati: etse:-rations of the winsd:eed asseeta-ted with ter-adoes is li-tited." (p. 9)

  • !ince the ter-ado windsteed data ettair.ed 1 sing the prebattlity -ethed an based en :nly a two-year seriod of neer:, vni:M nay or .ay ne* to a n:rese-tative sa-ele, a*. least :=.e inde:endent method (dew:oi .t ::rnlation) shculd be used *o verify the results so *.ha* ngicnal ter . ado :riteria can be devel:eed " (p. ib)

"Owing *o tne 140.< of actual vind -easu n .ents, tne -axir m vir.cssoed asse:iated with ter .adees has been :ete:--i".ed :y exarc.-atten :f da-are a .d dis = laced ::je:ts, by meti:n ti-*u n re:ce:s w.en availatie. Or ' f tnooretical es*i.ates,* (:.' 6)

Mile rariati:ns vitain sa:c. Ngi:n an anti:.:ated. One :urre .t data do n.ct :er-ni* defini*ien f ere *han three general regi ns at *.is tine. Vnen sufficient

a.a :eeene availa:1e. tnese egi:ns e.11 te exami-ed.' ':. 20 7'1 feels t at tne :ncee:irg quotations fur *.her a :lify the 2.ce- atn -atun W

t

of the data and nothodoloc u=en which the CPSIS/T!AR is based, and that the cracial 1.portance of the 2* calculatians to the health and safety of the pub.

lie naos it imperative tha*, before licensing 0FST3, sait :alculati:ns to ther-ous .ly reassessed.

In concluding 7.1, CT.*R reiterates the requirement stated in 1* 072 30 thar the design bases for st.2ctures, including the feent .Nel Storage Area, 'shall re-flect...secreeriate eensideration of the most severe of the ,e natural eneto-ora that have been re:orted for the site and surrounding area (er.chasis added). *T'3 interprets this to nean that all nethods, calculations, and data e-eleyed to de-rive something as crJeial as the 2*, should be, above all else, -eanterful, 3 -

Itable, gd current. Mowever, !"GCC's consistent reliance on old, uncertain, and incer:nlete data and formulae, and on unproven scecifiesti n techniques, is characteris*ic of a cavalier and perfenetary a=: reach to analyses which have a direct bearing on the safety and health of I';GCO's rate:ayers, and which must te carefully, thougntfally, and independently recensidered befers licensing of CPSES.

v.2 lack of Acceetability of tot leadine Analyses In light of the cententiens discussed in 7.1, CT3 has 11scovered two unaccept-able probless in the CPSIS/ TSAR Icading analyses.

7.2.A Since the methods, calculatiens, fornulae, and data leading to the deri-vation of the 27 have been shown to be ef doubtfc1 reliability OT3 questions the acceptability of apolying the 02FAPI cer: pater code to prestare leadings as differentials created by the 2*. OT*,*R does not believe T' GCC knows enough about the 3T to use it in Ahi leading calculatiens.

Y.2.3 0F"R obie:ts to the lack of discussion regarding the loadirg and other censequences caused by the encounter between a t:rnade-generated r.issile and an opening left by a vented blewout panel. OP3 clains that the crtission of such a discussion is a clear violation of 10 OTR 50.11.b.2 which stater "~he descrie-tion shall be rafficient to mornit the ".ederstanding of the systen desips and

- their relationship to safety evaluations."

7.2.0 CT3 feels that the assig' ation of a load factor of 1.0 for load ce .:1-nation equations incorporating tornado Icadings in certtination with "nor al and ac:ident cenditions" is a violation of the spirit if net the letter of 10 CTR 50, Appendix A, Oriterion 2. OT2 clains that the *ustifiestions for the 1.0 Icad cenbination factor cited in 3.3.0.2 et 073I1/ TEAR are no longer acceptable in ligns of OT3's arsments in 7.1 (lack cf a::eptatility of pn-27 analyses).

In concluding 7.2, OT3 e-chasises the need for **3:0 to develen an accreeriate evaluation -odel which realistically incer: crates the findings of ths recen-sidered 3* derivation suggested in 7.1 a .d. fur *her, to recalculate all 27 loadings ace:rdi . gly, as wel* to subni* a thereugn a-alysts :f centingency 7.2.3 ateve, before licensing of MI3 is accreved.

  • u s* t fir s* ten 7.3 g g less-that-e-ese-rati re :est ra ?a st s ?are-eters vita.eut it should te noted *. hat M?; ?.er;1a .o y :: tee 1.NO,2 e enasizes tnat any fe rt-ation frem tne 27 earar eters listed in 'aASM 1:00 v .ien results in -1,ss :enserra-tive* values nust te Ocmtletely ,*ustifi M ty an atta:7 ent exclatning "no :na-ge.
n section 3.2.2.1 :f the 275IS/?2A?.. *.*0C0 assert:es the "desip tor-sco" as having a :eri: eral tangential velocity ,f 200 :n. a tra .s:atien velocity :. 62 r = ., . .. a ,,es su,e mo f :-= s.s 3 s. -e s. :r2 :la1-s i m a = . m ese

= 2325 14

desiCn enaracteristi=s differs from *he WA3H.;**C 03T in all three asce:ts.

Altnougs *.ne velocities in teth 037's pid the sano Maxis.n Wind !;eed (surt of translation and tangential velocities). *r.ey do differ incividually, and no ex.

clanation is offered. More irpertantly, the 7.csi/3 see pressure drep ef the

ET used in 3.3.2.1 yields an effective pressure dron of 1.;st/see, a firare less censervative than WA331200 by a facter et 2 OTS telieves that this is a clear centradi:tien of the 22C =esition in :E 1.76 and, until a tnerougs and i: mediate justification for the deviati:n is fortheeming, licensing of 0? SIS snould not be a;creved.

Y. C"IRIX0A7A!!C:3 Evidence of reek *overbreak" around the perheter of the excavati:ns fer the contat.vtent buildings due to blasting was re erted as a deficiency in I. I. *r.steetien Reecrt 75 03. The T!AR indientes t'.at eenerete grout was used to repair the fissures in the soil as well as an area identified enly as a niner evenxeavatice adja:ent to the centai':nent stracture of Unit 1.

It is suecified in 1C0D.100 Ac=endix A that ene of the required investigatiens is to determine the static ar4 dynamic preperties of the materials urderlying the site to determine the charseteristics of the ur.derlying material in transnitting earthquake.irduced P.otiens to the foundations of the plant. It is furthur specified that the maxirran vibratory accelerati:n ef the Safe Shutdown Earthquake at each of the various fcundation 1 cations of the Category : stractures shall be deter.ined . tacing into account the characteristics ef the undcrlyir.g .

soil material b transmittug the ear *.hquake induced motions (3*TE31279).

It is furthur ::ecified that areas ef actual or =ctential rarface or subsurfa:e subsidence, uplift or collapse nru1*.ing from man's activities shall be evaluated (28T331279).

In view of the above.refenneed requirements of the law, it is Or'3's cententi:n that additier.a1 testing and reperts sheuld te made in erder to deternine if the evenx avati:n and/er a .y r2bseque.t ecen:tive .

ac*iens have joecarcised the ability of any and all Oategory I str;: tuns to withstand seismic disturbances.

C. *"!STICY

. CT Swsi..O.O OT A0710N TAKI' W"*H E A?* TO TECS A?JAS

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  • he ac 11: ant str.ted in *.he TSAR inat ne ha-dwan redificati:ns are equind to mitigate the ::r. sequences of A*'45. Eat *J.is allegs*i:n was :lained :ased :n two :ut:ated Westingneuse studies. hs "20 indi:sted at the :enstr.eti:n 11: ente stage inat they were re.riewt.g .
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five years later, the a=plicant is subnitting tast: ally the same reecrts and the U.0 is still reviewing the situatien.

071**. centends that the publi: should not have to suffer for the te-erity of *he W" and that the apolicant sheuld be teund to whatever generi: decisien is finally made ceneer .ing Westing .euse reacters of the Conanche ?,ak category - even if hirdware nodificatiens are s=ecified and i.f the Oormissica grants an exe ption to applicants for e=eratir.g li:enses submitted in this specific time frame, v!!.3 Additional Generi Problems the AORS exmressed its concern re6 arcing generic problems rela *ed to C?SES and reeer.-e .ded that tnese problems te dealt with appropriately.

OFUR has been ur.a'cle to discern any treatnent of unreselved safety issues in *.he FSAR. For this reasen. OTUR requests that this rabject be adected as an issue to allow the fellewing areas to be exelered in the hearing process:

1) '<!ater Ha rier
2) Asy netrie 31ewdewn leads en the Reacter Occlant Systen
3) ?'u Stean Generator *ube :ntegrity
4) Resetor Vessel Materials Toughness
5) Fracture Toughness and Iamellar Tearir.g of Stean Generater and/or Reactor Ocelant ? : s Susports
6) Systems Interactiens
7) Enviremental "ualificati n of Safety-Related Equipment
8) Reacter Vessel Pressure Transient
9) Residual Heat Re-eval Shutdewn Requir e ents
10) Oentrol of Leads Near Spent Tuel
11) Seismic esign Criteria
12) Centainment I..ergency S e p Reliability
13) Station Blackout

'a*CREFCRE. ?*EM!3ES 0053::E7D. 0?* R prays that the Atenic Safety and Licensing Board will erder a full and epen hearing and that OF7R ,

accepted as an Intervener with all cf its cententions accepted as issues.

Res:ectfully subr'tt" ll

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Q384i~ . .orecy :ertiry that a t.2e and ce" - N es*f of this 07;**.'s 3uccle-ent to ?etiti:n f:r leave to E * ? s wat tailed en this the 7th of May, ic"? 'y '.* nit +d S m s' e .estage paid, to the fol'owing: Se:retary sf f.e . :.41s3 , ;et3. .....s 7.S. ::uelear Rer21%srf : r:-issM  ;,3, ,2:1,37 3e 7g.:3 7.j :=,

'elasning en 2. O. 20f33 ,,g;7ggen,  ;, ;, ;;$33 Attni >c<eting and 3e-vi:e 3rsnen

M:nclas 3. Reynolds. Isq. gh
eeexcise & Lite--an 1000 1*'th 5t set. !!. W.

Wasai.gten. 2. ; 200~6 23

TEI STr3 CF TFRS CCUICT CF T.G.R.C EIFCRE TEI U'Di?. SIC-HID AUrECRITT en this day personally appeared MIC?.AEL 7AILIA.'E ".IZFIEC", who, having been placed under oath by ne, did depose as fo11cws:

"(1) My nane is Michael Valliant Re:nikoff. I a= cf legal age and a resident of Fcrest F', in Tarrant County, Texas. My m .g ad& ess is 6001 Forest F4 Drive, Fcrt 'Jorth, Texas 76119. At that same address I co-own, with my wife Priscilla Prin'< Re:nikoff, real property consisting cf land arxi personal residence. This property is within approxd tely 35

=iles of Cocanche Peak Steam nectric Station Units 1 arxi 2."

"(2)Whereas, the health, safety and value of property a-d livelihood .

and health of family may be affected by either routine cperatien of Cc=anche Peak Steam nectric Station or by any accident involving release of radioactive ele =ents, therefore, we, ne=bers of Citizens for Fair Utty Regulation,

_(CFUR),have a direct and proper interest in the attached 3:pple.ent to CFf's e

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. Petition fer leave to Intervene." /

C ,tr I b>fbff, y \

Fichael Valliant Re:rikoff /

SU3SCRISE A'D SWCR3 TO 3IFCRE H5 by the said Michael 7alliant Rezni'<cff on this 3 'iay of May, 1977. s e O C_u L v1 p' , D

' eta y ?iclic in and fer

/\ TarranT, Ccun.7, Texas s

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"'HE 3"'.C CF TEXAS CCU'CY CF TARRA'C 3EFCRE T:-2 UIOT.SIG:C AUTHCRI"'? cn this day perscnally appeared

~3.ICHARD L. FCU12, who, having been placed under oath by ne, did depose as follCws:

"(1) My nane is Richard L. Fouke. I a= of legal age and a resident of Arlington, Tarrant County, Texas. Fy mning address is 1662-3 Carter Drive, Arlington, Texas 76010 (2-) I an one of the fourdling seven nenbers of Citi:: ens for Fair Utility Regulation (CFUR) and an presently a =ceber in gcod standiag. The nenbers of CF3 have been constlted and they have authoriced ne to represent the= in any Nuclear Regulatory Cornission proceedin; ccccernia.;: Application of Texas Utilities Generatirg Ccepcry, et al, for an Cperatir4 License for Conanche Feak Stean Electric Station Units 1 a.M 2.

(3) I have reviewed the representations centained in the Attached Supplement to CF G 's Petition for Leave to Intervene and such representations are true arxi accurate to the best of my knowledge. "

/?A&F w L Richard L. Fcuke SU3SCRI3EJ A!O 3;U.U TO 3IFCRE ME by the said Richard L. Fouke en this c

2' ._ day of May, IC79.

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,'otary hblic in and for 0" \ ry Tarrant Ccunty, Texas

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y, 3 My cen=ission expi-es Ax e !.

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