ML19344F267

Offer of Proof in Support of Intervenor 800701 Motion for Reconsideration of Qa/Qc Contention.Urges Admission to Modify Contention 5 to Include Issues Raised in Encl Insp Repts.Certificate of Svc Encl

ML19344F267
Person / Time
Site:	Comanche Peak
Issue date:	08/29/1980
From:	Gay G ASSOCIATION OF COMMUNITY ORGANIZATIONS FOR REFORM, WEST TEXAS LEGAL SERVICES
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML19344F268	List: ML19344F267
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ISSUANCES-OL, NUDOCS 8009150045
Download: ML19344F267 (6)

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LNITED STATES OF AMERICAN y _.

NUCLEAR REGUIRORY COMISSION 19% g BEFORE THE ATQEC SAFE 1Y AND LICENSING BOARD '$[ fe

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TEXAS UrILITIES GENERATING CGiPANY, Er AL. S Docket Nos. 50-445 50-446 (Comanche Peak Steam Electric Station, S Units 1 and 2)

S ACORN'S Unt.R OF PROOF IN SUPPORT OF IIS ,

FUTION WR REQ]NSIDERATION OF 'IHE QA-QC CONIENTION

. On July 1,1980, ACORN urged in its Motion for Reconsideration that the Board utilize the wording proposed by ACORN for the QA-QC contention. This offer of proof consists of the following I & E Reports: 73-02 Stumary of Violations /1-2.g, 73-02/3.b, 74-02/VII A,B, 74-03/B, 74-03/D, 74-04/1, 75-05/A.3.a., 75-06/A.2.b.,

75-12/III,2, 01/I.A.2.a(3), 76-08/I.A.2.b. , 77-02/A.2.2. , 78-05/4, 78-07/5, 78/07/8, 78-11, 79-04/5.

This offer docunents fSdamental problems in the QA/QC program with regard to lack of conpliance, failure to report itens of non-coupliance, lack of methods of identification and control of nonconformance, program surveillance, procedural de-ficiencies, storage of electrical conponents, failure to follow pipe fabrication procedures, failure to follow equipment maintenance, and possible damage to the pressurizer. A stnmary of the I & E Reports on these items is included as Attach-ment A. The actual I & E Reports are included as Attachment B.

The present wording of the QA-QC contention unnecessarily limits development.

of issues which are in the public interest. ACORN has continuously argued that specific defects itemized in the bases of previous offerings docunented and reasonably supported broad contentions and inquiry into the QA-QC program. Specific itens are synptoms of prevasive flaws in methodology, control, and maintenance. ACORN requests that this offer of proof be accepted and that the board reconsider and nudify the ,

wording of the QA-QC contention to include inquiry into the concerns raised in the attached I & E Reports. ACORN requests that the Board accept the wording of con-tention 5 offered by ACORN.

Respectfully submitted, JCk r GL GEORKEY M.'GAi / ,(,}3f/

West Texas In Services Lawyers Building 100 Main Street Fort Worth, TX 76102 go09150 M % (817) 336-3943 ATIORNEY FOR INIERVENOR, ACORN i

'e OFFER OF PROOF, Appendix A QA Program -

Lack of Caupliance I & E Report 73-02, Smmary of Violations /1.-2.g. Documents eleven separate violations of AEC Regulations pertaining to quality assurance aspects of.CPSES design and procurement activities. The inspector reported specific violations of Criteria I, II, III, IV, V, VI, VII, and XVII of Appendix B to 10 CFR 50.

I & E Report 74-01 recognizes corrective action taken by the licenses to coup 1v with design and procurement procedures pursuant to appendix B to 10 CFR 50. According to the report three (3) specific violations of criteria II, VI, and VII of appendix B to CFR 50 remained uncorrected.

I & E Report 74-02/VII A, B, notes that neither the architect / engineer's quality assurance policies and procedures nor the Gibbs & Hill (G&H) quality assurance documents are adequate for the status of the project. Based upon the inspectors' findings that:

1. The PSAR and the "GE Project Guide" are not consistent in the definition of the approved QA Policy and Procedures.

• 2. The GE QA Policy and Procedures decuments do not carnit GM to the ANSI standards contained in the "AEC Guidance."

3. The requirements of the ANSI standards have not been addressed in the G M QA procedures.

I & E Report 74-03/B notes that "more specific delineation of interface ectivities and responsibilities will require revision of QA and QC procedures." Specifically, the inspector's review of section 6.0 of Freese & Nichol's (F&N's) Quality Assurance Program revealed "several inconsistencies in light of nere specific delineation of responsibilities and interfacing activities of F6N, Mason-Johnson Associates (tilA), and Brown & Root (B&R) "

QA Program -

Surveillance I & E Report 73-02/3.b. indicates that following an inspection and examination of the nukeup and operation of the quality surveillance ccmnittees, the inspector detennined that inasnuch as no meetings of the quality surveillance cmmittee-design had taken place as of the date of the inspection (Decmber 3-6, 1973) and design and procurement work was in progress, there was a lack of inplenentation of TUSI's Quality Assurance Program in '

contravention uith Appendix B to 10 CFR 50, Criterion II. ~

I & E Report 74-03/D identif es an unresolved item relating to TUSI's expansion of the CPSES QA plan to include specific surveillance activities for construction of the safe shutdown ' s~midment (SSI) dam. Specifically, according to the IE inspector "Freese

& Nichols @6N) will perfonn QC of their own activities and a second level surveillance function of inspection and testing. TUSI will audit F6N design activities in accordance with Section 3.0 of the CPSES QA Plan, Project Construction Surveillance."

I & E Report 76-01/I.A.2.a(3) identifies an item of non-compliance in that Brown &

Root (B&R) was discovered to be conducting QC surveillance of the containment building steel liner installation without prescribed docmented instructions or procedures in con-travention with Appendix B to 10 CFR 50, Criterion V.

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0FFER OF PROOF, Appendix A Page 2 I & E Report 76-08/I. A.2.b. identifies an item of nonempliance relating to the failure of the Texas Utilities Services, Inc. CIUSI) site surveillance inspector to docment an item of nonconformance as prescribed in the 'IUSI QA Plan. According to the I&E inspector, said item of ncnomformance was associated wit' the Freese & Nichols (F6N)

QA manager's duties and responsibilities enempassing engineering functions beyond that which is described in the CPSES QA Proy Manual, in contravention with Appendix B to 10 CFR 50, Criterion V.

QA/QC PROCEDURAL DEFICIENCIES Accordin; to I & E Report 74-04/1 the inspector discovered the following deficiency:

" Brown & Root (B&R) quality control procedures are not being adequately controlled. 'Ihree procedures reviewed by the inspector contained either error QCP-33, incorrect reference to work which is to be accanplished in accordance with a different procedure, QCP-12, or were not revised, QCP-4, in accordance with the requirements c,f QAP-7 and QAP-8."

I & E Report 75-05/A.3.a. cites a QA/QC procedural deficiency relating to Brown &

Root's (B5R,'s) failure to develop and inplement an inspection procedure for activities related to the excavation for the reactor containment structures of CPSES, mits 1 and 2, in accordance with B5R Procedure CP-QCP-12. Said deficiency was identified by the inspector as being contrary to 10 CFR 50, Appendix B, Criterion V.

According to I & F " port 75-06/A.2.b. , the IE inspector discovered that inplenenting Brown & Root (B5R) QC ins,. action procedures, or instructions, were not available that would verify conformance with the requi.rements prescribed in BSR CP-QC-14, Concrete Inspection

& Testing, dated March 6,1975. 'Ihe matter was identified as an item' of noncompliance with Appendix B to 10 CFR 50, Criteria II and V.

MEIHOD OF IDENTIFICATION AND CONIROL OF NCNCONFORMANCE I & E Report 75-12/III.2 references an unresolved item relating to the lack of a method for identification and control of nonconformance. The IE inspector cites Chicago Brider & Ironworks (CB & I) site QC documnts identifying an anchor stud pull-out on one of the reactor vessel cavity liner plates (MK-20-17). 'Ihe inspector further notes that the cause of the anchor stud pull-out (lamination in the liner plate) was identified by CB&I as an item of nonconformance, however, it was not clear to the inspector that Brown

& Root was handling the matter as an item of nonconformance. Based on the foregoing the ,

inspector made the following evaluation"...The CB&I noncoiformance control list does not provide a clear basis for the conconformance, nor is it clear as to the manner in which B&R identifies, re.icss, accepts / rejects and documents itms of nonconformance identified by subcontractors."

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f,.a OFFER OF PROOF, Appendix A Page 3 SUB00NIRACIORS' FAILURE TO REPORT ITEMS OF NONCWPLIANCE According to I & E Report 77-02/A.2.2 the licensee was cited with an infr action for a subcontractor's (R.W. Hunt Co.) failure to inmediately report a matter relat.ve to an enplayee's alleged falsification of test records, in contravention with Appeniix B to 10 CFR 50, Criterion V. A subsequent investigation of the alleged falsification of test records is discussed in I & E Report 78-07/8.

STORAGE OF ELECIRICAL COMPONENTS I & E Report 78-07/5 identifies an unresolved item associated with the licensee's and/or various contractors' failure to incorporate kNSD reconmendations for recording ancient air and winding tmperatures into storage and maintenance requirement documents for safety injection pum notors and failing to incorporate tesnufacturer's reconmendations for sealing of openings in diesel / generator sets into the respective storage and main-tenance requirenunt documents. The IE inspector further notes that he discovered four (4) such openings in a stored deisel generator.

FAILURE TO FOLwW PIPE FABRICATION PROCEDURES I & E Report 78-05 references a notice of violation issued April 6,1978, based upon the licensee's apparent failure to follow pipe fabrication procedures. According to said report, the IE inspector observed on March 23, 1978, a number of pipe sections and one acqted weld joint (CS-1-RB-24-QZ-NZ) with counterbore transition slopes greater t.han 300 to the plane of the pipe wall contrary to construction procedure 35-1195-MCP and representing noncmpliance with the requirements in criterion V of Appendix B to 10 CFR 50.

POTENITAL CONSTRUCTION DEFICIENCY REGARDING POSSIBLE DAMAGE TO LNIT I PRESSURIZER According to I&E Report 78-05/4 the IE inspector was infonned of an accident in-volving the Unit I Pressurizer. The accident reportedly occurred in railroad yards near Tallahassee, Flcrida when a wheel of the rail car transporting the pressurizer broke causing the car to derail. A subsequent discussion of the potential construction deficiency is referenced in I & E Report 78.11.

FAILURE TO FOIlDW EQUIPMENT MAINTENANCE INSIRUCTIONS I & E Report 79-04/5 references a notice of violation issued as a result of Brown

& Root's (B&R's) failure to follow cquipment maintenance instructions. Contrary to storage spector found that B&R had failed to rotate the shaft on the control room venti-lation fan as required by unintenance procedures and had neglected to maintain the surface of the positive displacement charging punp with proper application of preservative.

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.t UNITED STATES OF AMERICA NUCLEAR REGUIKIORY C0tilSSION BEFORE THE A1IMIC SAFETY AND LICENSING BOARD In the Matter of S TEXAS UTILITIES GENERATIE CCMPANY, ET AL. 5 Docket Nos. 50-445 50-446 (Cmanche Peak Stean Electric Station, S Units 1 and 2)

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atumCATE OF SERVICE I hereby certify that copies of the foregoing " ACORN'S OFFER OF PROOF IN SUPPORT OF ITS FDTION FOR RECONSIDERATION OF THE QA-QC CONIENTION" and appendices in the captioned matter were served upon the following persons by deposit in the United States mail, Certified, Return Receipt Requested this 29th day of August, -1980:

Valentine B. Deale, Esq. Chairman, Atomic Safety Chairman, Atomic Safety and and Licensing Boa"d Panel Licensing Board ',

U.S. Nuclear Regulatory 1001 Connecticut Avenue, N.W. Cmnission Washington, D.C. 20036 Washington, D.C. 20555 Elizabeth S. Bowers, Esq. Chairman, Atomic Safety and Chairman, Atmic Safety and Licensing Appeal Panel Licensing Poard U.S. Nuclear Regulatory U.S.-Nuclear Regulatory -

Cmnission Cmndssion Washington, D.C. 20555 Washington,- D.C. 20555 Dr. Forrest J. Remick, bkraber Marjorie Ulman Rothschild, Esq.

Atmic Safety & Licensing Board Office of the Executive Ingal Director 305 East Hamilton Avenue U.S. Nuclear Regulatory Cmnission State College, Pennsylvania 16801- Washington,~D.C. 20555 ,

Dr. Richard Cole,- Maber David J. Preister, Esq.

Atmic Safety & Licensing Board Assistant Attorney General U.S. Nuclear Regulatory Candssion Environmental Protection Division Washington, D.C. 20555 P. O.-Box 12548 Capitol Station Austin, TX 78711 Mr. Richard L. Fouke Mrs. Juanita Ellis CFUR . President, CASE 1668B Carter Drive 1426 South Polk Street Arlington,' Texas 76010_ Dallas, Teris 75224 e

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s e - .:e W-Arch C. McColl,' III, Esq. Jeffery L. Hart, Esq.

701 Camerce Street - 4021 Prescott Avenue Suite 302 Dallas, Texas 75219 Dallas, Texas - 75202-

.Mr. Gase R.~ Stephens.

Docketing & Service Branch -

.U.S. Nuclear Regulatory Comnission Washington, D.C. 20555 Nicholas S. Reynolds, Esq.

Debevoise & Libennan 1200 17th St. N.W. d .P l. {6, l. at Washington, D.C. 20555 GEOFFREYEfGAY \

- West Texas Legbl Services 4 f6).

4 Lawyers Building 100 Main Street

. . Fort Worth, 'IX 76102

, (817) 336-3943 ATIORNEY FOR INIERVENOR, ACORN m

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