ML20004F450

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Supplemental Answers to Applicants' First Set of Interrogatories,Per ASLB 810413 Memorandum & Order.Listed Insp Repts Are Evidence of Applicant Failure to Adhere to CP Provisions.W/Certificate of Svc.Related Correspondence
ML20004F450
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 04/30/1981
From: Gay G
ASSOCIATION OF COMMUNITY ORGANIZATIONS FOR REFORM, GAY, G.M.
To:
Atomic Safety and Licensing Board Panel
References
NUDOCS 8106180366
Download: ML20004F450 (6)
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of S TEXAS UTILITIES GENERATING COMPANY, ET AL. S Docket Nos. 50-445 50-446

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(Comanche Peak Steam Electric Station, Unit:s 1 and 2) S

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  • b SUPPLEMENT TO ACORN'S ANSWERS TO "*" E uY APPLICANTS' FIRST SET OF INTERROGATORIES ' oj M TO ACORN AND REQUESTS _TO PRODUCE 4 &

as ACORN files this its supplement to Answers to Applicants' First Set of Interrogatories to ACORN and Requests to Produce as ordered by the Board's April 13, 1981 Memorandum and Order granting Applicants' modified motions to compel ACORN to respond to and also to supplement responses to Applicants' First Set of Interrogatories to ACOPS and Requests to Produce.

Further, in compliance with the Board's Order of April 13, 19 81, ACORN will respond to or supplement responses to the following interrogatories in Applicants' first set of interr-ogatories to ACORN and requests to produce, namely, 2, 3, 6, 12,

  1. 1 13, 14b, 15, 16, 18-25, 30, 32, 40, 43, 47-50, 52-70,80-100, '

103, 110-124, 126-127, 130-141, 195, 199, 200 and 203-213, as soon as the information requested is developed or obtained.

SUPPLEMENTARY ANSWERS The following supplementary answers are identified oy the corresponding interrogatory set forth in Applicants' First 3106180 % 5d/

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Set of Interrogatories to ACORN and Requests to Produce.  !

Question'10. Yes.

a. ACORN would refer to the following inspection and Enforcement reports as evidence of Applicants' failure to adhere to the provisions of their construction permit as well as 10 CFR Part 50.

Excessive Rate of Goundwater Withdrawal During Construction -

I&E Report Regarding Inspection Conducted June 6 and June 10, 1975.

Failure to Adhere to F 5 9cedure Requirements Regarding Concrete Transit liix - I&E Report 75-10.

1 Failure to Adhere to Procedure Requirements Regarding I Concrete Placement - I&E Report 75-10.

Failure to Implement Prompt Corrective Action and Provide Adequate Measures to Preclude Repetition Regarding Concrete Aggregates - I&E Report 75-13.

Failure to Provide Documented Inst' ructions or Procedures As Prescribed Regarding Examination and Repair Activities on Seismic Category Class I Components - I&E Report 76-01.

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Failure to Incorporate Approved Design Changes into Applicable Design Specification and Work Procedures -

I&E Report 76-01.

Failure to Provide Prescribed Documented Instructions or Procedures for Conducting QC Surveillance of the Containment Building Steel Liner Installation - I&E Report 76-01.

Failure to Provide QC Surveillance Procedures Regarding Containment Building Seismic Category Class I Embeds Installations - I&E Report 76-01.

Failure to Provide Prescribed Documented Instructions or Work Procedures RegardinJ Installation of Containment Building or Seismic Category Class I Pipe Restraint Embeds - I&E Report 7.6-01.

Failure of QA Supervisor to Exercise Delegated Stop-Work Authority Regarding Welding of Safety Related Components -

I&E. Report 76-07.

Failure to Follow Procedures for Welding of Safety Related Components - I&E Report 76-07.

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E Failure to Follow Procedures for QA Documentation of Surveillance Activities - I&E Report 76-08.

Failure to Maintain Document Control - I&E Report 76-08.

Failure to Follow Procedures for Certification / Document-ation of Inspectors - I&E Report 77-02.

Failure to Provide Welding Proce ures at the Location Where the Prescribed Accivity is Performed - I&E Report 77-10.

Failure to Remove Weld Surface Defect Prior to Final Acceptance.- I&E Report 77-10.

Failure to Follow Pipe Fabrication Procedures - I&E Report 78-05. -

Failure to Follow Concrete Testing Procedures - I&E Report 78-07. .

Failure to Maintain Proper Flow in Lower Squaw Creek -

I&E Reparr 78-08.

Failure to Follow Piping Installa1: ion Procedures -

I&E Report 78-11. ,

Failure to Adequately Control and Tag Nonconforming Items - I&E Report 78-12.

Failure to Follow Welding Procedure - I&E Report 78-12.

Failure to Follow' Concrete Testing Procedures - 1&E Report 78-13.

Failure to Promptly Report a Significant Deficiency -

I&E Report 78-16.

Failure to Follow Welding Procedures - I&E Report 78-18.

Failure to Achieve Adequate Radiographic Sensitivity -

I&E Report 78-20.

Failure to Adequately Control and Tag Nonconforming

'tems - I&E Report, NRC Inspections on August 21-25, 78.

.ailure to Follow Weld Monitoring Procedures - I&E Report, NRC Inspections on August 21-25, 1978.

' Failure to Follow Concrete Placement Procedure - I&E Report 79-03.

0 Failure to Follow Equipment Maintenance Instructions -

I&E Report 79-04.

Failure to Follow' Inspection Procedure for Inspection of Class IE Cable Tray Supports - I&E Report 79-06.

Failure to Implement the Quality Assurance Program for Civil Construction - I&E Report 79-11.

Failure to Follow Procedures for Cable Pulling - I&E ,

Report 80-03.

Failure to Report a Significant Construction Deficiency -

I&E Report 80-0 8.

Failure to Follow Procedures for Reporting and Repair of Damaged Electrical Cable - I&E Report 80-08.

Excdssive Rate of Groundwater Withdrawal During Con-struction - I&E Report 80-09. ,

Failure to Follow Piping Installation Prccedures -

I&E Report 80-11.

Failure to Follow Welding Procedure - I&E Report 80-13.

Failure to Follow Electrical Inspection Procedures -

I&E Report 80-13.

Failure to Establish Quality Assurance Program For Class 5 Pipe Support Systems - I&E Report 80-15.

Failure to Follow Construction Procedures - I&E Report 80-15.

Failure to Follow Weld Preparation Procedures - I&E .

Report 80-17.

Failure to Report a Significant Construction Def,iciency - ,

I&E Report 80-18.

b. See Answer to 10 a. above.
c. See Answer to 10 a. above. [

Question 129. A disturbance of nhe atmosphere marked by temper-atures below 32 degrees Farenheit, high winds and a heavy d -

charge of sleet and/or snow.

Respectfully submitted, f.:bi ., l'b Q  %, 1 Geoffrey M. Gay [ .

Attorney for ACOR1'L,

CERTIFICATION .

I I, Geoffrey M. Gay, Attorney for ACORN, am authorized by them to certify, and I do now declare and certify, that thc foregoing Supplement to ACORN's Enswers to Applicants' First Set of Interrogatories to ACORN and Requests to Produce +

is true and correct to the best of my knowledge and belief.

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EXECUTED this N/. _ day of April, 1981.

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GEOFFREY M. GAY

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. Attorney for' ACORN .  !

West ' Texas Legal fiervi<fes .,

Lawyers Building I 100 Main Street l Fort Worth, Texas 76102 (817) 336-3943 -

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. - g CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Supplement to ACORN's Answers to Applicants' First Set of Interrogatories to ACORN and Requests to Produce in the captioned matter were served upon the following persons by deposit in the United States Mail, _first class postage prepaid, on this -

52J77, day of April,19 91:

w Valentine B. Deale, Esq. Richard Fouke Chairman, Atomic Safety and 1668-B Carter Dr.

Licensing Board Arlington, Texas 76010 1001 Connecticut Avenue, N.W.

Washington, D.C. 20036 Chairman, Atomic Safety and

- Licensing Board Panel Dr. Forrest J. Remick, Member U.S. Nuclear Regulatory Comm.

Atomic Safety and Licensing Board ,

Washington, D.C. 20555 305 E. Hamilton Avenue State College, PA. 16801 Chase R. Stephens Docketing & Service Branch Dr. Richard Cole, Member U.S. Nuclear Regulatory Comm.

Atomic Safety and Licensing Board Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington,"D.C. 20555

  • Juanita Ellis, President CASE Nicholas S. Reynolds 1426 South Polk Street Debevoise & Liberman Dallas, Texas 75224 1200 Seventeenth St. , N.W.

Washington, D.C. Chairman, Atomic Safety and Licensing Appeal Panel David J.-Preister U.S. Nuclear Regulatory Comm.

Assistant Attorney Gener:1 Washington, D.C. 20555 Environmental Protection Division P.O. Cox 12548, Capitol Station Jeffery L. Hart Austin, Texas 78711 4021 Prescott Avenue Dallas, Texas. 75219 Marjorie Ulman Rothchild Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555

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  1. GEOFFREY /14 GAY y

Attorney ' for ACORN '%

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