ML19323G762
| ML19323G762 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/12/1980 |
| From: | Fouke R CITIZENS FOR FAIR UTILITY REGULATION |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8006090001 | |
| Download: ML19323G762 (4) | |
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.~nm, MAY 161980 > V.g 5/12/80 4-D' hflic of the S&cretary UNITED STATES 0: AMERICA
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deting & Senice I
j NUCLEAR REGULATORY COMMISSION BEMRE THE ATCHIC SAFETY AND LICENSING. BOARD IU atter of
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l TEXAS UTILITIES GENERATING COMPANY, ET AL.
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Docket Nos. 50 h45 i
50 h46 (Comanche Peak Steam Electric Station.
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Units 1 and 2)
I CFUR POSITIOP ON CONTENTION 4.A The Atomic Safety and Licensing Board (Board), subsequent to the May 22, 1979 prehearing conference, stipulated the wording of a QA/QC contention encompassing a portion of the QA/QC concerns of all petitioners and admitted all three petitioners as intervenors. This contention has been designated CFUR Contention 4.A and is woztied as follows:
"The Applicants have failed to establish and er, cute a quality assurance / quality control program which adheres to the criteria in 10CFR50 Appendix B."
CRIR argues in support of the present wording of this contention. At the same time, CFUR wishes to emphasize the necessity of including CFUR Contention 4.3, which is prospective in nature and contains special operating requirements exceeding those of 10CFR50 Appendix B, as a subject matter in these proceedings.
Quality assurance / quality control is an "across-the-board" type of function. Although assurance that special processes (e.g.--welding) are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable requirements of 10CFR50, Appendix B, Criterion IX is a necessary part of QA/QC, it is by no means an all encompassing part. Additional aspects of QA/QC are adequately documented in 10CFR50 Appendix B and represent aspects of QA/QC which are just as important as Criterion IX.
Failure to execute any one aspect of these
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requirements properly would be just as inimical to the common defense and security or to the health and safety of the public as would any of I
the requirements.
The Applicants proposed wording would limit QA/QC to concrete work, welding, inspection, materials used and craft labor qualifications.
CFUR's basis is by no means limited to these areas. Lack of organization:
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-2 design controls procurement document controls instmetions, procedures and drawings document controls control of purchased material, equipment and services identification and control of materials, parts and components:
control of special processes inspections. test controls control of measuring and test equipment were all identified and discussed in IV.A of " Supplement to Petition For Leave To Intervene By Citizens For Fair Utility Regulation (CFUR)", dated May 7,1979 as can be detemined simply from the title of IV.A.
A closer examination of the contents of IV shows that additional criteria are addressed in at least the following locations:
- 1) 4A Program - page 6, line 38
- 2) Audits - page 5, line 41
- 3) Corrective Action -- page.14, line 40
- 6) 10CFR50.55 - page 10, line 29
- 7) PSAR - page 5, line 35
- 8) QA Program and Plan -- page 5, line 23
- 4) Quality Assurance Records -- page 9, line 13
- 5) Nonconforming Materials, Parts or Components - page 8, line 20 The Applicants proposed language is unduly restrictive when compared to CFUR's basis and would serve to limit discovery to such a degree that only partial records would be available.
It would be encumbent upon the Applicant to produce the applicable documents - many of which would be intemixed with documents that could be argued were not applicable.
1 Additional QA/QC problems and/or allegations have occurrad since CFUR's basis was submitted: including the misorientation of the reactor pressure vessel in Unit 2, the omission of rebar in the containment of Unit 2 and the mishandling of containers with radioactive identifications.
CFUR contends that the woniing of this QA/QC contention should be sufficiently broad to enable these concerns to be addressed as well -- but the Applicants proposed language would not accomplish this.
A special investigation of the South Texas Project conducted between November 10, 1979 and February 7,1980 identified 22 itens of noncompliance.
Brown and Root (B&R) is both the A/E as well as the constructor at South Texas. However, B&R personnel have been transferred between South Texas
3 and Comanche Peak on more than one occasion. It is not unreasonable to suspect that similar problems have existed at Comanche Peak. At the very least, it is appropriate to incorporate wording broad enough to allow these subjects to be addressed in this hearing.
In addition, the Applicants proposed language overstates CFUR's position.
CFUR contends in Contention 4.A that the Apolicants have failed to establish and execute a QA/QC program. CFUR further certtends in Contention 4.B.
that in view of the laxness of the Applicant's QA/QC program - special' operating conditions should be required of the Applicant.
In the event that the lax QA/QC program can be shown to have caused construction deficiencies of sufficient magnitude so that corrective actions are required prior to operation to protect the health and safety of the public. CFUR expects that these corrective actions will be required by the Board before an operating license is issued.
If the corrective actions required are of such economic magnitude to cause the Applicant to reconsider the Comanche Peak project, theri so be it.
But that is not CFUR's contention.
The Board has requested altemate language for this contention. CFUR sutaits the following:
"The Applicants have failed to establish and execute a quality assurance / quality control program which adheres to 10CFR50 Appendix B. Criteria I through IIII, Criteria XV through XVIII, the Construction Pemits for Units 1 and 2, the PSAR, the FSAR, the QA Program and Plan, and/or10CFR50.55."
Respectfully submitted.
Richard L. Fouke CFUR Dated at Arlington, Texas this 12th day of May, 1980
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CERTIFICATE OF SERVICE I hereby certify that copies of "CFUR POSITION ON CONTENTION 4.A" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, this 12th day of May,1980.
Elizabeth S. Bowers, Esq., Chaiman Mr. Geoffrey M. Gay Atomic Safety and Licensing Board
. West Texas Legal Services U.S. Nuclear Regulatory Commission 100 Main Street (Lawyers Bldg.)
Washington, DC 20555 Fort Worth, TX 76102 Dr. Forrest J. Remick, Member David J. Preister, Esq.
Atomic Safety and Licensing Board Assistant Attorney General U.S. Nuclear Regulatory Commission Environmental Protection Division Washington, DC 20555
.P. O. Box 12548, Capitol Station Austin, Texas 78711 Richard Cole, Esq., Member Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Atonic Safety and Licensing Board Panel Washington, DC 20555 U.S. Nuclear Regulatory Commission Washington, DC 20555
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Marjorie Ulman Rothschild, Esq.
Office of Executive Legal Director Atomic Safety and Licensing Appeal Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Conmission Washington, D. C.
20555 Washington, DC 20555 Nicholas S. Reynolds, Esq.
Docketing and Service Section Debevois & Libeman Office of the Secretary 1200 17th Street, N.W.
U.S. Nuclear Regulatory Comnission Washington, DC 20036 Washington, DC 20555 Mrs. Juanita Ellis N
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President, CASE 1426 South Polk Street Dallas, TX 7522h
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Richard L. Fouke CFUR i
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