ML20011E129

Responds to Concerns Raised by Citizens for Fair Util Regulation in 891016 Request for stay, & 891207 Meeting Re Allegation OSP 89-A-0089.Issues Raised Do Not Adversely Affect Viability of LWRs

ML20011E129
Person / Time
Site:	Comanche Peak
Issue date:	01/30/1990
From:	Lyons J Office of Nuclear Reactor Regulation
To:	Brink B CITIZENS FOR FAIR UTILITY REGULATION
References
NUDOCS 9002080102
Download: ML20011E129 (24)

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January 30, 1990

. Docket Nos. 50-445 and 50-446-

.Mrs. Betty Brink, Board Member Citizens for Fair Utility Regulation 7600 Anglin Drive Fort Worth, Texas 76140

SUBJECT:

. ALLEGATION OSP 89-A-0089 j

This:is in res>onse to the concerns raised by the Citizens for Fair Utility Regulation (CFJR)-in the Request for Stay, dated October 16 1989,yourLletter.

of November 8,1989 and our meeting of December 7,1989. AlthoughtheCommission's Order'of October 19, 1989.only-addresses the technical concerns and settlement agreement issues raised in the Request for Stay, the NRC staff has endeavored to evaluate all of CFUR's concerns. The purpose of this letter is to describe the basis for the NRC staff's resolution of those concerns.

The-enclosure to this. letter presents the NRC staff's conclusions regarding

-the fundamental technical issues. CFUR has not raised any issues not already considered by the staff.

However, we recognize your desire for a further-

' explanation;of the resolution of those issues.

In addition to the specific issues addressed ~in the-enclosure, CFUR-has also raised several philosophical-issues which'we should explain so as-to provide a context for our conclusions regarding the more specific technical issues.

First, several CFUR representatives have suggested that we should consider-your concerns with respect to the viability of-light-water reactor. technology.

The NRC's responsibilities and authority are predicated on the-Atomic Energy Act and the Energy Reorganization. Act which, in conjunction with. applicable case law, establish the fundamental premise that light-water reactor technology can.be-used'as an energy source so long as an a)plicant for a license-satisfies the applicable Federal regulations for that tecinology.- The Final Environmental'-

j Statement for Comanche Peak.(NUREG-0775, September 1981) addresses alternative enery sources in accordance with the National Environmental Policy Act and 4

conc uded that the addition of the two units to TU Electric's system is expected 1

.to result in significant savings in system production costs, decreased dependence y

on fuel supplies of uncertain availability and increased system reliability.

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None of the issues raised by CFUR adversely affect the viability of light water j

reactors.

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r 2-January 30, 1990 Mrs. Betty Brink l

Second, CFUR has suggested that all of the issues associated with Comanche Peak should be considered collectively as representing a trend or pattern of unacceptable behavior by TV Electric. As a result, you have concluded that the TU Electric organization is incapable of operating Comanche Peak safely.

i Similarly, you asked whether there is a threshold nunber of violations or errors which would cause the NRC to deny a license. The applicable Federal l

regulations, NRC enforcement policy and underlying quality assurance principles are intended to preclude mistakes, but all recognize that mistakes will be made, particularly for a venture as massive and complex as the construction of a nuclear power plant, and there are means to correct those mistakes.

Further, even when mistakes are repetitive the NRC's enforcement policy provides for civilpenaltiestoemphasizetheImportanceofeffectivecorrectiveactions:.

Our enforcement policy also provides the means to suspend, modify, or revol:e a license when we are concerned that repetitive mistakes might jeopardize put lic safety.

NRC inspection and preoperational testing of plants are intended to identify construction related problems. Rarely are construction mlated problems so great that they cannot be corrected. Even progrannatic breakdcwns during construction have been corrected. Consequently, the NRC does not have a " threshold" of violations which would cause the deniel of a license.

Nevertheless, we have attempted to evcluste the collective significance of CFUR's concerns at:d their relationship to past construction errors.

In this i

evaluation, we have relied on the results of our review of the independent Comanche Peak Response Team (CPRT) findings, as is described in Supplement 20 to the Safety Evaluation Report for Comanche Peak (NUREG-0797) which was issued in November 1988. Such an evaluation of collective significance involves a long period of time, a large number of people, a wide variety of constraction activities, and a judgment of the significance of the construction deficiencies that were identified by both the HRC and TU Electric.

Based on l

(2) the relative significance of the enforcement history for Comanche Peak)

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l to correct these deficiencies, and (3) the nature and evolution of the accepted industry practices for the design and construction of nuclear power plants over the time that Comanche Peak has been under construction, we conclude that, while TU Electric could have done some things better as is reflected in the CPRT findings, Comanche Peak deficiencies have been corrected and there is r<ow no discernable trend or pattern that would raise a serious safety concern or provide a basis for denial of an operating license.

Although the NRC has taken a number of enforcement actions and continues to identify violations related to TU Electric's activities, these actions are not unusual nor, in our view, are they so significant as to raise a concern about the ability of TV Electric's organization to safely operate the plant.

Moreover enforcement action may be necessary in the future to ensure TU I

l Electric s continued vigilance so that weaknesses are corrected.

In a related matter, CFUR has also expressed concern about the significance oftheAugmentedInspectionTeam(AIT) findings (50-445/446-89-30/30) following the check valve failures during hot functioh I testing.

The staff's concernti regarding those findings are described in the subsequent enforcement action 1

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l (EA-89219)whichwasissuedonJanuary 25, 1990. However, we consider these findings to be related to TU Electric's transition from construction activities to an operational endronment.

In that regard, we will rely on the staff's ongoing inspection program as well as the NRC's Operational Readiness Assessment Team to assess whether TV Electric's corrective actions, in response to the AIT findings, have been effective.

Third, CFUR has expressed a broad concern about TV Electric's management, primarily with respect to attitudes and implied policies. CFUR has characterized TU Electric's management as " arrogant" and alleged that they have misled the NRC and the public. The NRC staff has determined that TV Electric's management has appropriate commercial nuclear experience and written policies related to nuclear safety.

Based on the NRC staff's dealings with TV Electric management and the results of several investigations, including an NRC panel review of intimidation and harassment issues in 1985, we conclude that TU Electric has not demonstrated a pervasive behavior that would be detrimental to safe operation of the plant. Moreover, while the NRC panel concluded in 1985 that a number of i

TU Electric's past management practices may have generated mistrust and suspicion so as to contribute to a lack of management credibility, more recent experience has demonstrated that TU Electric's performance has substantially improved in i

f this regard, particularly as evidenced by the low number and significance of employee concerns over time.

Finally, CFUR has alleged that concerns expressed by a fomer NRC inspector at Comanche Peak and a group of " Anonymous NRC Inspectors" constitute an attempt I

by the NRC to " whitewash" Comanche Peak issues. On the contrary, the NRC established a process for differing professional opinions to encourage its employees to express their individual views so that potential safety issues l

would not be overlooked.

The existence of differing professional opinions and l

individuals' concerns does not, in and of itself, constitute a safety issue.

l NRC management still has an obligation and responsibility to mke decisions based on staff opinions.

In this case, a Differing Profession 1 Opinion canal was directed to review the concerns of the anonymous inspectors.

The panti has completed its review and the resulting recomendations are currently being reviewed by senior NRC management.

After action is taken on those recom-L mundations, the results of the panel's review and related records will be made publically available. Similarly, the former NRC inspector's concerns, along will with the results of the investigation that stemmed from those concerns,ld also be released to the public when the final reports are complete.

It shou f

be noted that these staff opinions were considered in the staff's planning for l

the inspections related to operational readiness.

We recognize that CFUR's members are concerned about the safety of the Comanche Peak Steam Electric Station. While it is apparent that we do not agree on the significance or resolution of some issues, we have attempted to further l

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Mrs. Betty Brink January 30, 1990 j

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explain the basis for our resolution of your concerns in the hope that with that j

knowledge, you will understand how the NRC has discharged its responsibility to l

protect the public health and safety.

Sincerely, (original signed by) l

' James E. Lyons,' Chairman l

Allegation Review Coomittee Comanche Peak Project Division

Enclosure:

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h....r D$}Efp/pg,,,,,,j}{pff,,,,,i:}{p[pg,,,,,j}(,[9g,,,,,${p/gg,,,,,,g,,,,,,,,,,,,j,,,,,,,-,, OFFICIAL RECORD COPY Document Name: BRINK LETTER 6

t + Mrs.' Betty Brink January 30, 1990 l l i ccw/ enclosure (w/oattachments): t Mr. Robert F. Warnick Jack R. Newman, Esq. Assistant Director Newman & Holtzinger for Inspection Programs 1615 L Street, NW Comanche Peak Project Division Suite 1000 U. S. Nuclear Regulatory Comission Washington, D.C. 20036 P. O. Box 1029 Granbury, Texas 76048 Chief, Texas Bureau of Radiation Control Texas Department of Health Regional Administrator, Region IV 1100 West 49th Street U. S. Nuclear Regulatory Commission Austin, Texas 78756 l 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 Honorable George Crump County Judge Ms. Billie Pirner Garde Esq. Glen Rose Texas 76043 Robinson, Robinson, et al. i 103 East College Avenue Mr. William J. Cahill, Jr. Appleton, Wisconsin 54911 Executive Vice President TU Electric t Mrs. Juanita Ellis, President 400 North Olive Street, Lock Box 81 Citiz6ns Association for Sound Energy Dallas, Texas 75201 1426 South Polk Dallas, Texas 75224 s E. F. Ottney P. O. Box 1777 Glen Rose, Texas 76043 l Mr. Roger D. Walker Manager, Nuclear Licensing Texas Utilities Electric Company 400 North Olive Street, L. B. 81 Dallas, Texas 75201 Texas Utilities Electric Company c/o Bethesda Licensing 3 Metro Center, Suite 610 Bethesda, Maryland 20814 William A. Burchette Esq. CounselforTex-LaElectric Cooperative of Texas Heron, Burchette, Ruckert & Rothwell 1025 Thomas Jefferson Street, NW j Washington, D.C. 20007 GDS ASSOCIATES, INC. L Suite 720 1850 Parkway Place Marietta, Georgia 30067-8237

l y CFUR. ISSUES l 1. M ~ The risk of low power operation is exemplified by problems (including release of radioactive gases) at Ft. St. Vrain, which was also regulated by R-IV. Now,10 years after startup, it is shutdown forever. Evaluation } The NRC will not issue any license, not even a low power license, without reasonable assurance that there is adequate protection of the public health and safety. Nevertheless, there are special considerations to low-power operation. Most importantly, the possible consequences of an accident during low-power operation are limited to a very small fraction of those l possible at full power. l.ow-power operation would generate less than one-twentieth of the radioactive fission products which would be generated at full power. This decrease in fission products also' dramatically reduces the amount of decay heat availeble to damage the core as compared to full power operation. Therefore, accidents at ow-power operation l would evolve over longer periods than at full-power operation and could be contained by equipment designed to cope with accidents occurring at full power. CFUR's concern appears to stem from an 0IA investigation of Region IV I management in 1986 which raised issues related to the inspection activities at Ft. St. Vrain, in addition to Comanche Peak, CFUR implies that i inspection policies during the construction of these plants had allowed inherent flaws to go undetected. The concerns raised by OIA Report 86-10 were reviewed extensively by an NRC staff panel, referred to as the Comanche Peak Report Review Group (CPRRG), and subsequently in an independent investigation by David Williams, then with the Government Accounting Office and now the NRC's inspector General. The results of those investigations, which were released to the public, concluded that the issues were primarily administrative and did not have any direct adverse impact on plant safety. Those issues were also investigated by Senator Glenn's comittee. The corrective actions that resulted from the CPRRG review, as described in the published report NUREG-1257, included several followup inspections which were assigned to the Comanche Peak Project Division when the Office of Special Projects assumed responsibility for the inspection activities at Comanche Peak in early 1987. The results of those followup inspections i similarly did not reveal any evidence that any safety-significant deficien-cies have gone undetected. Moreover, a comprehensive review of the design and construction of Comanche Peak has been conducted in conjunction with the Comanche Peak Response Team (CPRT) and Corrective Action Program since 1986. Based on extensive review and inspections, the staff concluded that 4 the CPRT had adequately implemented its investigative activities related to the design, construction, construction quality assurance / quality control,

l 2 c. e ) I and testing at CPSES. The staff further concluded that the CPRT evaluation i of the results of its investigation was thorough and complete and its i recomendations for corrective actions were sufficient to resolve i identified deficiencies. The staff subsequently concluded in a variety j of inspection reports that TU Electric had adequately implemented the hardware validation and final reconciliation portions of their Corrective [ Action Prngram. J Ft. St. Vrain is a high-tem >erature gas-cooled reactor (HTGR). Any difficulties that plant migit have had during its startup are more likely due to the uniqueness of the HTGR technology than to NRC inspection practices. ft. St. Vrain is the only commercial power HTGR in the United States. The decision by Public Service Company of Colorado to decommission-Ft. St. Vrain is primarily due to the economics of the HTGR technology and has no bearing on the viability of Comanche Peak or any other light-t water reactor as a safe energy source. More generally, the potential for difficulties during the startup of a nuclear power reactor largely depend o,1 the amount of effort the utility puts into preparedness for plant operation. Considerable attantion has been focused on operational readiness because of the Augmented Inspection l Team findings. The 0)erational Readiness Assessment Team inspection will be conducted during tie period from January 22 through February 2,1990 for the purpose of assessing whether Comanche Peak and TU Electric are adequately prepared for plant operation. 2. Issue The potential for spent fuel accidents is more severe than previously thought, based on a study by BNL dated 2/5/87: BEYOND DESIGN-BASIS ACCIDENTS IN SPENT FUEL P0OLS (GI-82). The lack of a high level waste i repository will require long term storage of spent fuel at Comanche Peak. Evaluation Since the Brookhaven study was issued, the staff and its consultants have performed a more complete analysis of the risks of potential accidents in spent fuel pools and has concluded that the risks are acceptably small. In NUREG-1353, " Regulatory Analysis for the Resolution of Generic Issue 82, Beyond Design Basis Accidents in Spent Fuel Pools," (April 1989), the NRC staff determined that the risks of accidents from spent fuel storage are dominated by seismic impacts on the. ructural integrity of the spent fuel pool, that the risks and consequences of such accidents appear to meet the Comission's Safety Goal Policy Statement, and that the risks are no greater than associatea with the risks from core damage accidents. The NRC staff also concluded that the alternative measures for reducing the risks were not warranted in light of the costs of the alternatives and the large inherent safety margins in the design and i construction of spent fuel pools.

I L l L The risk that the CPSES spent fuel pools will not have sufficient storage l capacity is an economic risk only, not a safety risk. The CPSES spent fuel pools meet the minimum design capacity guidelines for a dual shared facility of one full core discharge plus two normal fuel discharge cycles j (322 fuel assemblies for CPSES) as set forth in ANS 57.2. The CPSES Technical Specifications, which will be a part of the license, limit the storage capacity to no more than 1166 fuel assemblies as is currently designed. Any future changes to the storage capacity will require a i license amendment and the attendant opportunity for a hearing. However, it should be noted that the Commission has determined that spent fuel pool { modifications using previously approved methods involve a no significant i hazard consideration as defined in 10 CFR 50.92 and, therefore, do not require that a hearing be held prior to issuance of the amendment. The Consission addressed the issue of long term storege of spent fuel in its August 31, 1984 Weste Confidence Decision. Currently, 10 CFR 51.23 states in part: The Commission has made a generic determination that for at least 30 years beyond the expiration of reactor operating l licenses no significant environmental impacts will result from the storage of spent fuel in reactor facility storage . pools or independent spent fuel storage installations located at reactor or away-from-reactor sites. The background discussion from the review and proposed revision of the ) Waste Confidence Decision and a conforming amendment to 10 CFR Part 51, which was published in the Federal Register on September 28, 1989, (Attachment 1) describes the actions taken to date by the Consission. The proposed revision to the Waste Confidence Decision reaffirms and supplements the 1984 findings and the environmental analyses supporting them. l 3. Issue Check valve failures that occurred during hot functional testing in April and May'1989 were critical and would have contaminated systems outside containment. TV Electric's response to the check valve failures was inadequate, according to the NRC's July 10, 1989 report. Additional Borg-Warner check valve problems have been identified by the NRC since initial failures in April and May. Eve 3uation As stated in the December 7,1989 neeting, CFUR's concerns were derived from the findings in the NRC's Augmented Inspection Team's (AIT) report and subsequent NRC inspection reports and letters regarding the check valve failures. The NRC review of Borg-Warner check valve issues is still in progress. Previous inspections related to this topic are documented

i 4-i in NRC Inspection Reports 50-445/89-30, 50-446/89-30; 50-445/89-52, l 50-446/89-52; 50-445/89-64, 50-446/89-64; 50-445/89-71, 50-446/89-71; 50-445/89-73, 50-446/89-73; 50-445/89-84, 50-446/89-84; and 50-445/89-88, 50-446/89-88. t i i The NRC staff has concluded that the applicant's corrective action program to reset and control the bonnet elevation of Borg-Warner check valves will effectively prevent the previously observed phencrenon where the valve disk jammed under the seat ring. Although some problems have been i' encountered in the implementation of these corrective actions, the applicant's conmitment to conduct a functional backflow test and/or i radiographic examination for each valve will provide reasonable assurance that all Borg-Warner check valves are capable of performing their design function. In NRC Inspection Report 50-445/89-73,50-446/89-73(Attachment 2),the NRC identified 14 open items regarding various issues steaming from the AFW backflow events. To date, two of these open items have been closed as documentsd in NRC Inspection Reports 50-445/89-84, 50-446/89-84 and 50-445/89-88, 50-446/89-88 (Attachments 3 and 4). All open items will be closed out prior to licensing and the closeouts will be documented in j ' NRC Inspection Report 50-445/90-03,50-446/90-03 and subsequent reports. i In addition to the open items, the NRC has issued an enforcement action, EA-89-219 dated January 25,1990(Attachment 5). That action is being r taken to emphasize the importance of the lessons learned from the check valve failure events. l l An issue not raised in the Stay Request, but in CFUR's subsequent November 8, 1989 letter to the NRC, was that the NRC had identified l additional Borg-Warner check valve problems since the initial failures in April and May. TV Electric reported the failure of a swing arm in a i l. Borg-Warner check valve installed in the service water system. As the result of discovering the failed swing arm, the NRC staff is reviewing the service suitability of the Borg-Warner check valve swing arms. The l-applicant, along with its consultant, Aptech, conducted an extensive series of nondestructive tests on the swing arms to identify and replace L the discrepant swing arms. An extensive engineering analysis was performed to demonstrate the acceptability of those swing arms which were not replaced. That analysis is now under review and the NRC will ensure that ( the check valves operate properly prior to making a decision on a Unit 1 l feel load license. l: The AIT report indicated that, during the check valve failure events operationspersonnelfailedtoeffectivelyrecognizeandactoncondItions l adverse to quality. The staff's concerns regarding those findings are i described in the subsequent enforcement action (EA-89-219). However, we consider the significance of these findings related to TU Electric's transition from construction activities to an operational environment. l 4 ,.-w,... _,, ~ -. - -.,, ~., -... - w .c

l i i In that regard, we will rely on the NRC's Operational Readiness Assessment Team to assess whether TU Electric's corrective actions, in response to i the AIT findings, have been effective. 4. ggg Counterfeit bolts have been used throughout the plant. Substandard material may also have been procured from the Meredith Company. CFUR requested information regarding Meredith Company. Evaluation As discussed in the December 7, 1989 meeting, CFUR's concerns were derived from the findings in NRC inspection reports and letters on counterfeit materials. The NRC has taken a number of generic short-term and long-term measures to provide assurance that NRC licensees do not install counterfeit equipment and materials in their plants. In May 1989, the NRC issued Generic Letter 89-02, Actions to Improve the Detection of Counterfeit and i Fraudulently Marketed Products, which described to the nuclear industry, those characteristics of effective procurement and dedication programs. Generic Letter 89-02 provided NRC's conditional endorsement of an industry 4 standard for dedication programs which evaluate the suitability of commercial grade products for use in safety-related applications. Also in March 1989, the NRC issued an Advance Notice of Proposed Rulemakitig soliciting public comment on whether or how NRC regulations should be revised to provide increased assurance that counterfeit or misrepresented vendor products are not installed in nuclear plants. Over 60 commenters provided responses to the NRC on the proposed rulemaking and the staff is currently evaluating the public coments. Inaeditiontotheshort-termmeasure(GenericLetter)andthelong-term measure (rulemaking), the NRC inspection and investigative staff have l been very aggressive in pursuing instances of suspected counterfeit cr misrepresentation by vendors. These efforts are directed to keep the industry fully informed so that appropriate licensee corrective actions can be taken and to assure that appropriate enforcement and investigative actions against the vendors are also taken. During the past two years, the NRC has issued over 25 Bulletins Information Notices and Supplements to alert the nuclear industry of suspected misrepresentation by vendors and the staff has provided support to the Department of Justice's review of-vendors suspected of wrongdoing, The NRC recognizes that vendor misrepresentation is not a problem unique to the nuclear industry in that counterfeiting and fraud can and do occur I in other industries. To assure that other Federal agencies are informed of-instances of vendor misrepresentation identified by the NRC, copies of NRC's Bulletins and Information Notices are forwarded to other l l \\ ---,-,m

' ) -agencies such as DOE, D00, FAA and NASA. In addition, NRC staff have aeveloped staff contacts in these other agencies to facilitate the t exchange of this type of information, The following is a listing of counterfeit equipment / material issues and related generic communications. Misrepresented Veeder Product.3ssues Generic.communicatten i Fittina and Flanges Bulletin'88-05 and two supplements Fastenars Bulletin 87-02 and two supplements l Molded Case Circuit Breakers Bulletin 88-10 and one supplement Information Notice (IN) 88-46 and four supplenents Valys Parts IN 88-97 and one supplesent Valves IN 88-48 and two supplements Fastevers IN 89-59 and one supplement IN 89-22 Materials IN 89-56 and one supplesent Electrical Equipment IN 88-19 and IN 89-45 and two supplements RelatedMatters(e.g., criminal IN 89-70, IN 89-35. IN 89-18 prosecution for misrep+ssentation, Generic Letter 89-02, March 1989 indicaticns of misrepresentation, ANPR, March 1989 guidance for procurement and dedicationprograms) Where applicable to CP5ES, TU Electric has addressed NRC generic communi-cations relating to questionable certifications or other questions relating to the adequacy of procured materials. Flanges supplied by Piping Supplies. Inc. of Folsom, New Jersey and West Jersey Manufacturing Company of Willian:stown, New Jersey were addressed in Bulletin 88-05. TU Electric tested 240 Unit 1 flanges, all of which were found to be acceptable. The results were reported in TV Electric's letter dat;d January 11, 1989. NRC L Inspection Reports 50-445/89-20, 50-446/89-20 and 50-445/89-37, 50-446/89-37 address the applicant's response to Bulletin 88-05. InTormation Notice 89-56 notified licensees of possible problems with certification of material furnished by Meredith Corporation / Pressure Vessel Nuclear (PVN) and Alloy & Carbon Steel Comoany, Inc. TV Electric issued a corrective action request (CAR-89-014) regarding steel purchased from PVN, which was closed out on the basis of either satisfactory con-firmation of certifications from the original vendor or laboratory testing i of steel samples. TU notified the NRC of this condition in a significant deficiency analysis report, SDAR-CP-89-026, and later determined that the condition was not reportable in a letter dated November 1,1989. CARS and SDARs are internal TU Electric documents available on site for NRC inspection.

1 ) Bulletin 87-02 required that a general sample of fasteners from warehouse stock be tested. As required by the bulletin, TU Electric had the fasteners tested by a laboratory they had qualified to perform this type of testing. The tests were performed in accordance with the requirements of the applicable fastener's specification, grade, and class. TU Electric all of the fastentrs tested were acceptable for use. CAR-88-36 addressed ~ responded by letters dated July 22 and January 11, 1988, and found that the generic adequacy of fasteners other than fasteners supplied by Aircom. i It was concluded that no genaric problem existed based for the most part j on the results of testing to support IE Bulletin'87-02. In addition, the NRC concluded in NUREG-1349 (a sunmary of utility test data responding to IE8 87-02) that the test results generally "did not indicate a safety 1 concern relating to the use of mismarked or counterfeit fastaners in the nuclear industry." NRC Inspection Reports 50-445/88-56, 50-446/88-52; 50-446/89-03; 50-445/89-18, 50-446/89-18; and 50 445/89-78, i 50-445/89-03,(Attachments 6 through 9) addressed Supplements 1 and 2 to 50-446/89-78 1 NRC Bulletin 87-02 as well as other matters related to counterfeit parts. As documented in the NRC inspection reports referenced above and TU Electric corrective action report (CAR) numbers 88-34, 35, and 36, in response to NRC Bulletin 87-02, a significant nunter of safety related and non-safety related fastenters of questionable quality and quality documentation were purchased from Aircom Fasteners, Inc., a fastener distribution company. As a result, TU Electric tested 96 of the fasteners from Aircom which had not been installed in tre plant for conformance to specification require-ments. As docunented in the TU Electric and NRC documents referenced i above, only very minor deviations from specification requirements for chemical and physical properties were noted. Thereby TU Electric i demonstrated that this sample of 96 Aircom fasteners selected for test would be acceptable for use had they been installed. Subsequently, after review of the foregoing information by the NRC staff and in response to questioning, Tb Electric selected a representative sample of 200 of the subject Aircom fasteners installed in electrical 4 cable tray support systems. These 200 fasteners were removed and subjected to the same physical and chemical testing as were the initial 96 fasteners noted above to determine if they met the purchase order and specification requirements. As a result of chemical and physical testing of this sample of 200 previously installed fasteners supplied by Aircom, the NRC is satisfied that these tasteners met the requirements of the specification or, in those few cases where they departed from the specification, the deviations did not affect the structural capability of the fasteners. Thus, they are adequate for the intended service. In addition to the NRC activities discussed above, NRC representatives l witnessed the testing of these 200 Aircom fasteners at South Western Laboratories on October 30 and November 1,1989 and observed that all I

~ ) ' l E testing was in accordance with standard industry practices and procedures. TU Electric addressed this issue in a comprehensive engineering report I describing their investigation of suspected substandard fasteners. That report includes analyses of bounding conditions for the bolting applica-tions, inclucing those associated with Aircom; those analyses were used i in the assessment of the significance of the test results. t Moreover, during the installation of cable tray end support fasteners, the " turn-of-the-nut" method of fastener tensioning was specified and v used. The bolt tensioning imparts a loading condition comparable to or greater than the design loading condition so that, if there were substandard materials of significance, they would have most likely failed during tensioning. To the staff's knowledge, no such failures occurred. i During TU Electric's examination of this matter, lated application, carbon as reviewed by hRC, it was determined that in a limited nonsafety-re j. steel fasteners were used where stainless steel fasteners were specified, 4 and in several very limited applications, Aircom fasteners were used in installations governed by the ASME Code. For each of these cases the corrective actton required the removal of the Aircom fasteners ana replacement with fasteners in accordance with the specified design requirements. The results of all these tests and analyses have adequately demunstrated that there is reasonable assurance the installed fasteners can withstand the design loading conditions, including any potentially misrepresented fasteners supplied by Aircom or other suppliers of similar fasteners. f 5. Issue Shannon Phillips, a retired NRC inspector and forner resident inspector at CPSES, wrote a memo to Conmiission which raised issues regarding (1) that TU Electric had misled the Commission about construction l problems at CPSES (2) TU Electric exerted pressure on top NRC management todowngradehisfindingsrelatedtorepairsontheservicewatersystem, and (3) an internal TV Electric memo showed a pattern of shoddy inspection techniques by TU Electric. There was inadequate resolution of the damaged service water piping identified in the S. Phillips memo. A QA inspector at the site was told all of the SWS piping would be replaced, but only 60 ft. were replaced. Evaluation The Office of Investigations has investigated the allegation that TU Electric misled the NRC about construction problems at CPSES. While the final report documenting the investigation is not yet complete, OI has informed the staff that their investigation did not reveal any evidence that TV Electric intentionally misled the NRC. The investigator did note that there were some disagreements about the interpretation of the information provided.

j ' 1 Inspection Report 50-445/09-23,50-446/89-23, issued on January 26, 1990 (Attachment 11), documents the review of TU Electric's response to enforce-ment action EA 88-310, which was the subject of the OI investigation. This reportwasissuedaswrittenbyMr.Phillips$withanaddendumupdatingthe status of the enforcement action. Additiona potential' violations regarding the TU Electric Code V procurements are identified in the inspection report. An enforcement conference will be held prior to licensing so that the staff can determine if the applicant's response provides an adequate basis for i licensing, or if additional actions are required. j An issue not raised in the Stay Request, but in the staff's December 7,ld 1989 meeting with CFUR, was that a QA inspector at the site.had been to by his supervisor that all of the service water piping would be replaced, i but only 60 feet of piping were replaced. As stated in the meeting, the responsibility for determining the appropriate corrective actions lies with TV's engineering department, not their QA organization. The staff's evaluation of the decision to replace only 60 ft, of SWS p(iping isAttachment12) reflected in Inspection Report 50-445/89-76, 50-446/89-76 relative to closing Violation 445/8847-V-01c. This indicates that the section containing the 1/2-inch hole was replaced, as were the three 20-foot spoolpieces which contained the most extensive and significant indications of. damage. QC evaluation of the removed 20-foot spoolpieces was used to calibrate the review proc 6ss for the remainder of the 10-inch i piping. The NRC staff determined that the applicant's actions to address j l the hardware concerns associated with the SSWS 10-inch piping were satisfactory and appropriate. Even assuming that TU did change its mind about the decision to replace the entire section of piping, we find no l engineering reason that it could not have made such a decision. J 3 We are satisfied that the piping has been properly repaired and procedural improvements have been effective, as demonstrated by TV Electric's performance in subsequent, similar repairs to the Unit 2 piping. 6. Issue A group of NRC staff inspectors informed the Comission that the pending i SALP report "is neither accurate nor complete." Factual information had been deliberately withheld, and the utility should receive a below average rating for its past year's performance. The inspectors stated the plant is at least 6 months away from fuel loading. Copies of both versions of SALP report should be released. L Evaluatico 1 i In response to the unsigned memorandum from "NRC Staff Inspectors" to L Chairman Carr of October 4,1989, a panel was established to review the l: issues and make a recommendation to the Director of the Office of Nuclear l 4

i 1 4 .c -Reactor Regulation. The panel has completed their review of the SALP 1 process at Comanche Peak including the CFUR concerns. The panel thoroughly reviewed the development of the SALP report, and conducted interviews with selected SALP Board members. As a separate initiative. the staff members involved with the Comanche Peak inspection program J were requested to provide any comments they might have on the SALP report-e and were told that their comments could be provided anonymously. The results of the survey were also reviewed by the panel. The panel has completed its review and the resulting recommendations are currently being - reviewed by senior NRC management. After action is taken on those recommendations, the results of the panel's review and related records will be made publicly available. A decision on the issuance of an operating license is separate from the SALP process and will not be made until the necessary Special Projects i licensing and inspection efforts are completed, and the ORAT inspection l previcusly discussed is completed. Although the insights derived from the SALP report provide a subjective adjunct to the formal findings submitted to NRC management with a licensing reconsnendation, the formal findings provide a much stronger and more accurate basis for the licensing decision. The SALP process is retrospective and, therefore the performance i L summary provided to the utility in the SALP report is to a large extent historical in nature. l L The anonymous memorandum also asserted that NRC inspection reports and i other documents had been edited to create an inaccurate characterization of the utility's performance. This assertion could imply inappropriate action on the part of NRC supervisors and managars, so this concern was referred to the Office of Inspector General for any action they deem necessary. 7. Issue CASE settled with TU Electric because of the significant economic interest in settling the whistleblower claims and the settlement of these claims was contingent on CASE withdrawing. The individual settlement agreements have not been reviewed by the NRC or made public. The settlement was not based on the resolution of safety issues. Evaluation The settlement of the Comanche Peak proceedings was based on a Joint Stipulation signed by case TU Electric Company, and the NRC staff. The parties submitted the Joint Stipulation to the Licensing Board for its approval. The Licensing Board reviewed this Joint Stipulation before l dismissing the proceedings. In addition, the settlement involved a l separate agreement between Case and TV Electric Company. As part of its consideration of whether to dismiss the proceedings, the Licensing Board also reviewed the Case-TV agreement. Both of these agreements are attached to the Licensing Board's order of July 13, 1988. (28NRC103) e These agreements are public documents. l

l. ,4 i ? j l-1 (. As part of the Case and TV Electric agreement, TV Electric agreed to continue in good faith to negotiate settlenents of outstanding employment discrimination claints against TU Electric and its contractors at the time of signing the agreement. TU Electric also agreed to negotiate in good faith settlenents with persons identified by CASE, who had assisted IASE in the CPSES licensing process. A sample of the release which was to be signed if these negotiations were successful was attached as an exhibit to ~ the Licensing Board's order. As a result of these negotiations TU reached agreements with three groups of individuals. First, TU reached an agreement settling a lawsuit involving a number of former employees, known as the Atchison plaintiffs. This was a suit pending at the time in the Texas state courts. Second, TU negotiated settlement agreements resolving three of four pending Department i of Labor complaints. These agreements are not, to the staff's knowledge, public documents. CFUR's concerns, as clarified below, appear to relate to these agreements. Third, pursuant to the settlement agreement with CASE. TV reached agreement with most of those persons designated by CASE as having assisted it during the licensing process. In its stay request, CFUR alleged that (1) TU Electric conditioned the settlement of individual claims on the dismissal of the hearings and the withdrawal of CASE, (2) the Settlement agreements have not been reviewed by the staff and have not been made public, and (3) that the settlement was not based on the resolution of safety issues. - During the meeting which took place on December 7,1989 CFUR clarified its concerns. CFUR stated its main concern was with the individual Department of Labor agreements. CFUR believes that these individual agreements should be reviewed by the staff to ottermine if the agreenents contain restrictive clauses similar to those found in two settlements of De)artment of Labor complaints involving two former employees at the Comancie Peak site, Mr. Polizzi and Mr. Macktal. Neither of those agreements were in any way related to the settlement of the proceeding in 1988. CFUR believes that s the CASE agreenents should also be reviewed to determine whether the language of the agreements could be construed as adversely affacting the willingness of the signers to bring safety concerns to the NRC. To address CFUR's concerns as clarified in the December 7 meeting, the staff took several steps. First, the staff reviewed the responses of TU Electric and its contractors to a generic letter issued to all licensees, applicants, and principal vendors on April 27, 1$89. This letter requested that licensees and their contractors identify settlement agreements they executed which contained clauses precluding the signer from bringing safety concerns to the NRC. The staff determined that in response to t1at letter, TU Electric had not identified any of the agreements which were executed around the time of the Comanche Peak settlenent as having restrictive clauses. In addition, representatives of the Comanche Peak Project Division and the Office of the General Counsel reviewed all of the releases signed by the Atchison plaintiffs in settlement of their lawsuit, and all of the

i settlement agreements and releases signed in settlement of the Department of Labor Complaints pending at the time of the Comanche Peak settlement. The staff's review indicated that none of these settlement agreements and releases involve restrictive clauses of the type which were found in previous settlement agreements. In fact, the agreements settling the Department of Labor complaints, contained explicit language which informed the former employee that he/she was free to take any safety concerns to the f NRC. The releases signed by the Atchison plaintiffs did not have any specific language concerning the right of the individual to bring safety concerns to the NRC. However, there were no restrictive clauses which precluded the individuals from doing so. In addition, the Atchison plaintiffs were informed by their counsel of their continuing ability to bring their safety concerns to the NRC. The staff also reviewed a sample l n of the release signed by those receiving compensation for their assistance i to CASE. These releases do not contain any restrictive clauses and it was TU Electric's practice that when the individuals presented the signed releases, they were informed of their continuing ability to bring their safety concerns to the NRC. In acdition, it is the staff's understanding that CASE did not designate these individuals until mid-1989 and that accordingly, these releases were not executed until long after the settlement of the Comanche Peak proceedings. 1 The Atchison plaintiffs were mainly people who had already appeared before the Licensing Board as witnesses during the Harassment and Intimidation hearings. There has been no indication that these individuals have any safety concerns which were not already brought to the attention of the staff. As far as the Department of Labor Complainants are concerned, as i discussed above, there is specific language in the settlement agreements which they signed that informs them of their right to continue to bring safety concerns to the NRC. In fact, one of these individuals has engaged in a continuing dialogue with the staff since he signed the agreement. Thus, there is no evidence that CFUR's concerns raise any safety issues l with respect to the settlements with individuals entered into around the i time of the settlement of the Comanche Peak proceeding. The staff has not found any evidence of an intent, either express or implied, to keep those who signed individual agreements from presenting their safety concerns to the NRC. Therefore, the mere fact of a link between the negotiation of L individual settlements and the general settlement of the Comanche Peak L proceedings did not result in stopping the flow of safety information to the NRC and, thus, does not raise a safety issue. With respect to the general settlement agreement between the parties to j the proceeding, as required by the agreement, CASE has been given and has taken an active part in monitoring the activities at the Comanche Peak site. CASE has made both TU Electric and the NRC aware of issues which l are of concern to CASE. Therefore, the settlement has, in fact, resulted in the continuing resolution of safety issues presented by CASE, and CFUR's allegation in this area is without merit, j

l ) v The NRC has issued a proposed rule to make it clear that any restrictive i clauses in settlement agreements, even language that might be perceived l as restrictive, is not permitted. A final rule which considered public comments is before the Commission. All of the agreements 6ssociated with the CASE settlement are consistent with the proposed rule. In summary, the staff finds that the agreements are not restrictive, and events which have taken place since the signing of those individual i agreements indicate that the individuals who signed the agreements do not consider themselves precluded from bringing safety concerns to the NRC. Therefore, the staff has determined in response to the Commission's Order of October 19, ISM, that there are no safety issues raised by CFUR's allegations with respect to the settlement of the Comanche Peak proceedings. 8. Issue Kapton wiring. Although TU spokesmen have repeatedly denied Kapton problems in any safety related installations, and have stated that all i Kapton has been properly installed, on 9/28/89, a flashover occurred which destroyed several wires as a result of Kapton insulation. A March 1989 inspection report states that certain allegations regarding Kapton "will remain open." CFUR wants to know where Kapton is used, and why it is acceptable. Evaluation i Kapton is a trade name for aromatic polyimide, poly p, p', diphenyloxide, i As documented in i pyrome111timide, manufactured by the DuPont Compan50-445/89-04;50-446/89-0 NRC Inspection Report utilized in Class 1E applications in the following equipment at Comanche J Peak: Electrical Conductor Seal Asse2 11es Containment Electrical Penetrations I i: Gannametric Neuton Flux Monitoring System Cables 1 Borg Warner Feedwater Isolation Valve Solenoids l l Electric Hydrogen Recombiner Incore Thermocouples ] The acceptability of Kaptor insulated conductors is based primarily on L the component environmental qualification sackages. These documents, ) which are maintained by the applicant at tie plant site, typically refer J to both the type of testing which was used to simulate accident conditions and the applicability of unique plant component configurations which incorporate Kapton to the design basis accident conditions. Additionally, the reliability of,Kapton-insulated conductors in commercial nuclear power applications hat been established based on extensive operational experience under normal and transient plant conditions. j a

4 P Several NRC Inspection Reports have addressed the specific installation i issues identified at CPSES. Those NRC Inspection Reports are: 50-445/83-73, 50-446/89-73 (Attachment 2, pages 9-11) and 50-445/89-84, 50-446/89-84 (Attechnent 14). As identified in Inspection Report 50-445/89-73, l 50-446/89-73, several Kapton insulated conductors associated with a containment penetration were potentially damaged when they were i inadvertently grounded to a cross brace in a junction box. Subsequent evaluations performed by TU Electric in conjunction with the supplier (Conax) on the removed sections of the five effected conductors revealed that only one conductor had experienced a breakdown of the Kapton i insulation and that an adjacent conductor had received a minor spark burn on the outer layer of Kapton from the arcing process. The remaining adjacent conductors were determined to have a carbon char residue which was easily removed from the apparently undamaged outer layer of insulation. Testing performed by TV Electric revealed that the four conductors adjacent to the damaged wire would have performed satisfactorily. However all ) l - fiveconductorshavebeenremovedandthecorrespondingfieldcableshave been respliced. TU Electric's analysis concluded that the phenomenon associated with Kapton insulated conductors utilized in aircraft which is characterized as " arc tracking" or "flashover" did not occur in this incident. The staff agrees with TU Electric's assessment. The reports J listed above cocument the inspection activities which determined that the applicant's corrective and preventive actions were adequate to address l the identified concerns for Unit 16nd counon equipnent. Based on a review of the: epplicant's records, the staff determined tnat the applications of Kapton insulated conductors at CPSES were limited to the six areas identified above. Accordingly the concern re arding theuseofKaptoninnonsafety-relatedapplicatons(whichcoul interact I with safety-related equipment) is limited to selected Unit I containment f penetrations which are classified as nonsafety-related. The applicant's ) recently completed cable inspection program included equivalent evaluations 1 for both safety-related and nonsafety-related penetration teratination configurations. Thus, the same levels of protection, preservation, and L separation were provided for both safety-related and nonsafety-related l penetrations.- These measures provide reasonable assurance that the Kapton-insulated conductors will not present a safety hazard, 9. Issue I i-Cold Hydrostatic Testing. Serious questions remain from inspection reports of 1988 and the response of the NRC to CASE consultant's report this year i as to the adequacy of TU's previous tests. Evaluation CFUR did not provide any new information which would cause the staff to reevaluate its position regarding the adequacy of the cold hydrostatic test. The staff's position accepting the adequacy of the cold hydrostatic 1 ~.

>i. j 15 - ) I test is clearly stated in its August 18 1989 response to Mrs. Ellis and Mr. Counsil regarding the CASE dispute filed in this matter (Attachment 15). 10. Issue ) Inspection report 50-445-446/89-73,10/30/89. CFUR was made aware of the allegations of welding problems contained in.the report and those allegations have been substantiated and amplified by another unnamed whistleblower to CFUR board members. l l CFUR provided a tape of a conversation with an alleger and is concerned there may be broader welding problem. Evaluation The staff reviewed the tape provided by CFUR at the December 7,1989 1 meeting. The allegations made by the welder on the tape had been provided to the NRC in July 1969, by a third party present during the taped conversation. The third party informed the NRC of the existence of the tape in a conversation in October 1989. This allegation preciattated i the staff's review of the HVAC welding process and documentation whici 15,1989(Attachment 1650-445/8) 1ed to the issuance of the violations in Inspection Report 50-446/89-73. TU Electric letter dated December addressed these violations including causes, corrective actions, and gencrid oncerns. An NRC letter dated December 21, 1989 concluded that TU $ dt W e's actions were responsive to the concerns raised in the Notice of N !et' son. The staff ir.tenas to review implementation of the corrective -actiou before fuel load to determine that full compliance has been l achieved and will be maintained. In the brvader sense, welding problems have been identified in the l pst in lut inspecticn reports and the staff has monitored the resulting ccrrective actions. Generally, the welds can be accepted based on a design analysis and/or sample non-destructive examination (NDE) testing. Both techniques have been used to resolve a wide variety of welding concerns. In* addition, independent evaluations by the Comanche Peak l Response Team (CPRT), as described in Supplement 20 to the Comanche Peak Safety Evaluation Report, found that, although there were minor anomalies in the records, the quahty ano control of site welding activities were generally very good. This finding was substantiated by independent examination of selected welds by the NRC's mobile NDE laboratory. 11. Issue Lost calibration records. Recent allegations to CFUR board members i indicate that critical calibration records for automatic welding machines used on the fuel liner have been lost or have disappeared.

~

l. l Calibration records were lost for Dimetrics Gold Track II automatic weld machines. These machines were also used in the service water, I

main steam coolin water systems and in general sho) welding. As indicatedInCAR-8-029,thereisalsoaconcernwit1torquewrench calibration. Evaluaties ] The NRC staff contacted the person identified by CFUR. The alleger stated i that he had participated in, and fonnally documented, the calibrations of the Dimetrics Gold Track II welding machines. Later, when he tried to locate the records he was unsuccessful. His concerns regarding the calibration laboratory are addressed in CAR-88-029. n The historical site procedures do not have any requirements for retaining 4 i the calibration records for the Dimetrics Gold Track II welding machines as quality records because the welding machines are not considered to i 6 i-be " automatic welding machines" as defined by the AWS and ASME codes. An automatic welding machine is one which performs the welding operation without adjustment of the controls by a welding operator; whereas a welding machine is one which performs the welding operation under the i L constant observation and control of a welding operator. For this reason CPSES procedure WCP-6, " Electronic Alignment, Performance Verification and. Maintenance of Dimetric Gold Track II Automatic Welding System," dated November 23, 1977, Revision 0. states that "the Dimetrics Welding System will not be considered a calibrated item." Notwithstanding the issue of calibration, the adequacy of the welds per-formed using the Dimetric Gold Track 11 welding machine were confirmed by the normal cuality control inspection process which included radiography, nondestructive examination, and visual inspections in accordance with the applicable class of weld, j CAR-88-029 was issued on August 10, 1988 and dealt with the maintenance and test equipment (M&TE) program / equipment deficiencies (like torque wrenches). A subscquent QA audit TCP-88-43 was performed on November 16, 1988 through December 14, 1988 and was included in the response to CAR-88-029. Deficiency TCP-88-43-02 (Finding No. 3) identified four torque wrenches which were calibrated for under 100 ft-lbs., which was outside the calibrated range of the reference standard RS-345 (99.6 to 999.5 ft-lbs) thereby causing uncertainty as to whether the 4:1 accuracy was maintained. NCR 89-2845 was issued to address this condition and the subsequent engineering evaluation concluded that this condition was not significant. a t

1. n-m.w

L.. i - l As a result of CAR-88-029. TV Electric reviewed all applicable calibration I procedures. Nonconforsence reports were issued for reference standards and M&TE equipment found to be deficient (i.e., did not maintain requird 4:1 accuracy. lack of traceability, out of calibration). No additional deficiencies pertaining to torque wrenches were identified by TU Electric. The staff reviewed CAR-88-029 in conjunction with its review of SDAR t CP-88-35 and a separate allegation as discussed in Inspection Report l 50-445/89-71, 50-446/89-71 ( Attachment 16). The staff concluded that ^j although some minor issues involving non-procedura112ed administrative handling of MATE records existed, they did not adversely impact the i results of the M&TE calibration program. l

12. h33 Clarification of safety problems that must be resolved before licensing j

and a projected construction casoletion_date. What, if srty, safety issues will be unresolved at the time tw license is issued. Evaluation The design and design changes for a nuclear power plant are reviewed by l the NRC staff based on docketed information as well as NRC inspections and audits. Normally, the applicant submits information via a Final Safety Analysis Report (FSAR), FSAR amendments or docketed correspondence. The NRC staff conducts an audit review of this information and evaluates its acceptability based on the applicable regulations, regulatory guides, staff positions, and industry codes and standards. The results of these evaluations are occumented in the Safety Evaluation Report (SER) or Supplenents (SSERs). Throughout the course of the licensing review, issues arise which may not be fully acceptable without edditional action. As a plant nears completion and readiness to load fuel, the staff reviews all pending issues and any new issues to determine whether the resolution of the issue is necessary to ensure adequate protection of the public health and safety. These issues fall into three categories: outstanding issues, confirmatory issues and license conditions. Outstanding issues are unresolved concerns for which no agreement has been reached between the staff and applicant as to a solution, and for which no staff imposed solution is feasible. Con-firmatory issues are issues which have been essentially resolved to the staff's satisfaction but for which certain confirmatory information has not yet been submitted on the docket.- To qualify an issue as a confirma-tory issue, the applicant must have committed in writing to provide the confirmatory information for docketing on a schedule acceptable to the staff. By their nature, confirmatory issues imply that a technical review of the confirmatory information may be warranted, in the same manner that the staff audits the FSAR. A license condition is an issue which does not .-,,.m--y.,n. ,.,,-,,---.mn-- -,,1

') e y a 18 - l preclude the issuance of an operating license, because there are adequate compensatory safety measures, but for which certain requirements must be j imposed in a reasonable period of time to assure the adequate protection J of the public health and safety and the environment. TU Electric, as the lead applicant for the Comanche Peak Steam Electric i Station (CPSES), has submitted the FSA2 a-J 78 FSAR anenoments. The NRC staff has issued an SER for CPSES-(NUREG-0797) along with 22 SSERs. SSER 23, which will be issued with the low powar operating license, will document the resolution of all the outstanding issues remaining from SSER 22 and will list the reseining corfirmatory issues and the proposed license conditions. j 1 At the time of low power license issuance, the staff anticipates that there l will be no outstanding issues remaining for CPSES. The staff also antici-l pates that there will be two confirmatory issues associated with the of issuance of a full power operating license) program (within 6 months submittal of the initial in-service inspection and first-cycle performance data for the N-16 transit time flow meter (within 60 days following j start-up from the first refueling outage). The staff will impose three standard license provisions for maintanance of the fire protection program, physical security plan, and mineral exploration limitations, with no license conditions for pending issues. These license conditions are typical of conditions pieceo in all new licenses. i i i i i 9 i

/ l LISTING-OF.ATTACWMENTS.TO-CFOR. ISSUES i 1. Extract from Federal Register dated September 28, 1989, pp 39768-39770. 2. InspectionReport(IR) 50-445/89-73,50-446/89-73. 3. Extract from IR 50-445/89-84, 50-446/89-84, pages 5 and 6. 4. Extract from IR 50-445/89-88, 50-446/89-88, page 4. 5. EA-89-219 dated January 25, 1989. 6. Extract from IR 50-445/88-56, 50-446/88-52, page 19. 7. Extract from IR 50-445/89-03, 50-446/89-03, pages 10 through 14. 8. Extract from IR 50-445/89-18, 50-446/89-18, pages 8 through 11. 9. Extract from IR 50-445/89-78, 50-446/89-78, pages 5 through 7.

10. TU Electric letter dated December 11, 1969 from William J. Cahill, Jr.

to NRC. 11. IR 50-445/89-23, 50-446/89-23. +

12. Extract from IR 50-445/89-76, 50-446/89-76, pages 8 and 9.

13. Extract from 1R 50-445/89-04, 50-446/89-04, pages 13-14 and. l

14. Extract from IR 50-445/89-84, 50-446/89-84, pages 13 through 15.

15. NRC letter dated August 18, 1989 fromC.I.GrimestoCASE(JuanitaEllis) andTUElectric(WilliamCounsil).

1 l

16. TU Electric letter dated Decenbar 15, 1989 from William J. Cahill, Jr.

to NRC. J 17. Extract from IR 50-445/89-71, 50-446/89-71, pages 8, 9, and 16. l L -}}