ML20039E998

Sixth Set of Interrogatories Directed to Applicants & Requests to Produce.Certificate of Svc Encl

ML20039E998
Person / Time
Site:	Comanche Peak
Issue date:	12/04/1981
From:	Ellis J Citizens Association for Sound Energy
To:
References
NUDOCS 8201110702
Download: ML20039E998 (7)

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7 ,r 12/4/81 UNITED STATES OF AMERICA NUCLEAR REOUIATORY CGOESSION IEFORE THE ATO(IC SAFETY AND LICENSIEG BOARD In the Mstter of l l Docket Kos. 50- 45 APPUCATION OF MAS UFIUTIES l and 50-46 GENERATING COMPANY, ET AL. FOR AN l .

OPERATING LICEESE FOR CG4ABCHE l -

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PEAK SMM EI2 CMC STATION l .

uwITS fl AsD #2 (CPSES) -I i

, CASE'S SIXTH SET OF INTERROGATORIES TO APPLICAFfS AND REQUESTS TO PRODUCE COSS NOW CASE (Citizens Association for Sound Energy), hereinafter referred to as CASE, intervenor herein, and files this, its Sixth Set of Interrogatories to Applicants and Requests to Produce.

Pursuant to 10 CFR 2.740b and 2 741, please answer the following interroga-

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tories in the manner set forth herewith. Each interrogatory should be answered fully in writing, under oath or affirmation, and include all pertinent informa-tion known to Applicants, their officers, directors or employees as well as any pertinent information known to their advisors or counsel. Each request to produce applies to pertinent documents which are in the possession, custody or control of Applicants, their officers, directors or employees as well as their advisors.

or counsel. Answer each interrcgatory in the order in which it is asked, numbered to correspond to the number of the interrogatory; do not combine answers. Please identify the person providing each answer or response. )

These interrogatories and requests to produce shall be continuing in nature.

Thus, any time Applicants obtain infomation which renders any previous response

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incorrect or indicates that a response was incorrect when made, Applicants .

should supplement their previous response to the appropfinte interrogatory or request to produce. Applicants should also supplement their responses as necessary with respect to identification of each person expected to be called at the hearing as an expert witness, the subject matter of his or her testimony, and the substance of that testimony. The term " documents" shall include any writings, drawings, graphs, charts, photographs, reports, studies, and other data conspilations frcut which infonmation can be obtained. We, request that at e a date or dates to be agreed upon by mutual consent, Applicants make avmihble for inspection and copying all documents which CASE has specifically. requested or subject to the requests set forth below. All interrogatories which do not request documents should be answered pursuant to 10 CFR 2 7kOb(b).

CONTENTION 5: The Applicants' failure to adhere to the quality assurance [

quality control provisions required by the construction permits for Comanche Peak, Units 1 and 2, and the requi rements of Appendix B of 10 CFR Part 50, and the construction practices employed, speci fically in regard to concrete work, mortar blocks, steel, fracture toughness '

testing, expansion joints, placement of the reactor vessel for Unit 2, welding, inspection and testing, materials used, craf t labor quall-fications and working conditions (as they may affect QA/QC, and training and organization of QA/QC personnel', have raised substantial questions as to the adequacy of the construction of the facility, .As a result, the Commission cannot make the findings requi red by 10 CFR 50.57(a) necessary for issuance of an operating license for Comanche Peak.I Question 1. It is our understanding that the certification stamp which indi-cates compliance with ASME (American Society of Mechanical Engineers) codes will expire January 8, 1982. It is also our understanding that a team of American Society of Mechanical Engineers consultants decided I

in its 10/31/80 rulings, the Board construed Contention 5 to cover the Inspection and Enforcement Reports ide-ntified by ACORN in its Offer of Proof of August 29, 1980. .

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Question 1 (continued):

• against renewing the certification during a regular review of the plant conducted October 12-14, 1981, and that the stamp was not renewed because of inconsistencies between the contractor's manual and actual construction and record-keeping procedures. We further understand that the incon-sistencies are being corrected and will be inspected again by the ASME team on January 18-22, 1982, af ter which the team will inform Texas Utilities whether or not they will issue a new stamp.

With reference to the preceding, please answer the following:

(a) is any part of the preceding information incorrect?

(b) If the answer to (a) above is yes, please state specifically what information is incorrect and provide a statement of the correct facts in the matter.

(c) Was any information provided in writing by the ASME team at the time the certification withdrawal decision was made or since that time?

(d) If the answer to (c) above is yes, provide for inspection and copying all documents provided by the ASME.

(e) If the answer to (c) above is no, provide the names of all' Texas Utilities personnel who were present and invc!ved in any discussions wi th th'e ASME team regarding such decision.

(f) If the answer to (c) above is no, provide the names and addresses of all ASME personnel who were present and involved in any discussions with Texas Utilities personnel regarding such decision.

,uestion Q 2. 10 CFR Part 50, Appendix B, Section XVill. AUDITS, states:

"A comprehensive system of planned and periodic audits 'shall be carried out to veri fy compliance wi th all aspects of the quality assurance program and to determine the ef.fectiveness of the program. The audits shall be performed in accordance with the written procedures or check IIsts by appropriately trained personnel not having direct responsibilities in the areas being audited. Audit results shall be documented and reviewed by management having responsibility in the area audited. Followup action, including reaudit of deficient areas, shall be taken where indicated."

In this regard, please supply the following information: '

(a) Describe briefly your " comprehensive system of planned and periodic audits."

(b) Where is such description contained in your FSAR7 (c) Supply for inspection and copying copies of "the written procedures or check lists" used for such audi ts. ,

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Question 2 (continued): *

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(d) Advise the procedure and method for documentation and review by manage-ment of audit results.

(e). Advise the .uure and method for " followup action, including reaudit ;Ient areas."

(f) Supply for inspection and copying the written proce;ures for documenta-tion and review by management of audit results.

(g) Supply for inspection and copying the written procedures for " followup action, including reaudi t of deficient areas."

(h) Has the NRC conducted any audits to detect trends that may be detri-mental to safe station operation?

(i) If the answer to (h) above is yes, supply for copying and inspection all such audits.

(j) Has the TUGC0 Quality Assurance Division conducted any audits to detect trends that may be detrimental to safe station operation?

(k) If the answer to (J) above is yes, supply for copying and inspection all such audits. .:

(I) Have S.tation Quality Assurance personnel conducted any audits to detect trends that may be detrimental to safe station operation?

(m) If the answer to (1) above is yes, supply for copying and inspection all such audits.

Question 3 CASE now recieves copies of the NRC Inspection and Enforcement Reports (l&E Reports) from the NRC. Howeve', r we do not receive copies of Applicants' answers.to such reports. Please supply CASE with a copy of future' answers to l&E Reports. '

Question 4. How many internal audits have Applicants now performed on Brown and Root?

Quest.lon 5 How many of the internal audits of Brown and Root done by Applicants .

(referenced in Question 4 above) were performed on Brown and Root in Houston and how many were performed on Brown and Root at Comanche Peak?

Question 6. .Please supply for copying and inspection all such audits re'ferenced .

in Questions 4 and 5 above.

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Question 7 10 CFR Part 50, Appendix B, Section XVil, QUAtlTY ASSJRANCE RECORDS, states:

" Sufficient records shall be maintained to furnish evidence of activities affecting quality. The records shall include at least the following:

Operating logs and the results of reviews, inspections, tests, audits, monitoring of work performance, and materials analyses. The records shall also include closely-related data such as qualifications of personnel, procedures, and equipment. Inspection and test records shall, as a mini-m um , identify the inspector or data recorder, the type of observation, 3 the results, the acceptability, and the action taken in connection with any deficiencies noted. Records shall be identifiable and retrievable.

Consistent with applicable regulatory requirements, the applicant'shall establish requirements concerning record retention, such as duration, location, and assigned responsibility."

In this regard, please supply the following information:

(a) Please briefly describe Applicants' requirements concerning record retention, including duration, location, and assigned responsibility.

(b) Where is the information referenced in (a) above contained in Applicants' FSAR?

(c) CASE's 7/7/80 First Set of Interrogatories to Applicants, Question 5. 1 requested copies of each and every Concrete Pour log. Applicants advised that they do not maintain any records as described by CASE as " Concrete Pour logs"; af ter clarification by CASE as to what we wanted, we were shown computerized records of concrete pours.

What was the information for these computerized records taken from7 (d) Provide for inspection and copying the bases for the computerized ,

records referenced in (c) above.

(e) In our 7/7/80 First Set of Interrogatories, CASE requested that Applicants make certain information available for

• Inspection and copying. Please p'rovide for Inspection and copying the following documents since we copied and inspected them; the questions are identi.fied below to correspond with our 7/7/80 interrogatory numbers:

1. Supply copi.es of each and every Deficiency and Disposition Report (DDR) log.

2. Supply copies of each and every Non-Conformance Report (NCR) log.

• l 3 Supply copies of each and every Field Request for Engineering Action (FREA) log (as clarified by CASE).

4. Supply copies of each and every Corrective Action Request (CAR) log.

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Question 7 (continued):

(e) (continued):

19 Supply copies of all quality control manuals, folders, pamphlets, and any other printed information regarding quality control, including procedures for quality control, not only current but the originals and all revisions.

22. Supply copies of all quality control specifications manuals, folders, pamphlets, ard any other printed information regarding quality control specif! cations, not only current but the originals and all revisions.

23 Supply copies of all manuals, folders, pamphlets,'and any other printed information reg'arding quali ty assurance, quality ' assurance specifications, and quality assurance procedures, not only current but the originals and all revisions. If this information has been supplied in response to item 19, so state. -

26. For items 19, 22, and 23, supply full-size, rather than reduced, copies of each.

Respectfully submitted, sdbr &'s

','Mrs. ) Juani ta El li s , Pres i dent ASE (CITIZENS ASSOCI ATION FOR SOUND ENERGY) .

1426 S. Polk Dallas, Texas 75224

. 214/946-9446 214/941-1211, work, usually Tuesdays and.

Fridays only, but varies 3

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UNITED STATES OF AMERICA - "

NUCLEAR REGULATORY COMMISSION ' [

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD J.

In the Matter of I '

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APPLICATION OF TEXAS UTILITIES I Docket Nos. 50-445 ,',

GENERATING COMPANY, ET AL. FOR AN I and 50-446 .

OPERATING LICENSE FOR COMANCHE I , ,[:

PEAK STEAM ELECTRIC STATION I ..

UNITS #1 AND #2 (CPSES)  ! N 4

CERTIFICATE OF SERVICE -

By my signature below, I hereby certify that true and correct copies of CASE's 12/4/82 Sixth Set of Interrogatories to Applicants and Requests to Produce 'e

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have been sent to the names listed below this 4th day of January '.

1982, by: First Class Mall "

l Administrative Judge Marshall E. Miller David J. Preister, Esq. h U. S. Nuclear Regulatory Commission Assistant Attorney General ,f l

Atomic Safety and Licensing Board Panel Environmental Protection Division j Washington, D. C. 20555 P. O. Box 12548, Capitol Station E l Austin, TX 78711 ,

.. I Dr. Kenneth A. McCollom, Dean G. Marshall Gilmore, Esq. I, Division of Engineering, Architecture, 1060 W. Pipeline Road ',

l and 'Ibehnology Nurst, Texas 76053 -

Oklahoma State University ' '

Stillwater, Oklahoma 74074 .

Dr. Richard Cole, Member ,

Atomic Safety and Licensing Atomic Safety and Licensing Board Board Panel U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission

W;shington, D. C 20555 Wasiington, D. C. 20555 Nicholas S. Reynolds, Esq. Atc~.c Safety and Licensing Debevgise & Libe man Appeal Panel 1200 17th St., N. W. U. S. Nuclear Regulatory Commission ,'

W:shington, D. C. 20036 Washington, D. C. 20555 Mr.rjorie Ulman Rothschild, Esq. Docketing and Service Section . .

Office of Executive Icgal Director Office of the Secretary

• U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission t W:shington, D. C. 20555 Washington, D. C. 20555 i

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( 4WY h/dj fMrs.) Juanita Ellis, President CA'SE (CITIZENS ASSOCIATION FOR SOUND ENERGY) M J

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