ML20040F987
| ML20040F987 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/08/1982 |
| From: | Horin A, Horin W, Reynolds N, Reynolds N DEBEVOISE & LIBERMAN, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| References | |
| NUDOCS 8202110047 | |
| Download: ML20040F987 (7) | |
Text
r jpOi4DN gW February 81.jl982
'82 FEB -9 A10:27 UNITED STATES OF. AMERICA NUCLEAR REGULATORY COMMISSION Clii BEFORE THE ATOMIC SAFETY AND LICENSING BOARDh : OG & S% W BRANCli
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/r In the matter of
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'g Nh TEXAS UTILITIES GENERATING Docket Nos. 50-44 aa 8
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7 COMPANY, et al.
)50-44d(k Ngs0
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-y e.
(Comanche Peak Steam Electric )
(Application for
'ch k 'd8 Station, Units 1 and 2)
)
Operating Licenses %4hg \\'M APPLICANTS' RESPOFSE TO CASE'S SIXTH SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS AND CLARIFICATION OF RESPONSES TO CERTAIN INTERROGATORIES Pursuant to 10 C.F.R.
$ 2.741(d), Texas Utilities Generating Company, ej al.
(" Applicants") hereby submit their response to the requests for production of documents set forth in " CASE's Sixth Set of Interrogatories to Appli-cants and Requests to Produce," served on January 4, 1982.
The procedures for inspection and copying of the documents requested by CASE are as set forth in Applicants' March 4, 1981 response to CASE's Fourth Set.
Applicants' responses take into account CASE's clarification of certain requests Provided by telephone on February 4, 1982.
In addition, pursuant to a request made by CASE in a telephone call to Applicants on February 1, 1982, Applicants clarify responses to certain of the Interrogatories in CASE's Sixth Set.
I(
F202110047 820200 PDR ADOCK 05000445 0
. APPLICANTS' RESPONSE TO CASE'S REQUESTS TO PRODUCE CASE's requests to produce are indentified by the item number corresponding to the number in CASE's Sixth Set of Requests to Produce.
1.d.
Applicants will provide for inspection and copying the following documents:
Letter from ASME to R.J. Vurpillat, Brown &
Root, Inc., dated November 23, 1981.
Letter from ASME to R.J. Vurpillat, Brown &
Root, Inc., dated November 25, 1981.
Applicants note that a reinspection was conducted on January 18-22, 1982.
A recommendation concern-ing renewal of the certificates will be considered by the ASME Accreditation Subcommittee in early March.
Applicants believe that renewal of the certificates will be approved at that time.
2.c.,
f These documents are contained in the Corporate and g Quality Procedures / Instructions Manual which is being supplied in response to item 7.e.
(23).
2.k.
As described in our response to Interrogatory 2.j.,
Applicants do not conduct audits only for the purpose of detecting trends.
However, as described in the response to item 6 below, Applicants are providing the site activity audits concerning Brown & Root.
In addition, Applicants will provide all other site activity audits concerning design and construction.
6.
The eight (8) audits of the Brown & Root organiza-tion conducted through February,1978, have already been made available.
In addition, Applicants will provide for inspection and copying site activity audits concerning Brown & Root performed since I
February 1978.
7.d.
Applicants will produce concrete pour cards associated with Cont;ation 7 and made available to CFUR.
7.e.
Applicants will provide for inspection and copying the following documents:
(1), (2), (3), (4), (19), (22) and (23)
Updated versions, if any, of each of the documents previously produced will be made available for inspection and copying.
With respect to previous versions of QA/QC manuals, specific revisions will be produced upon request.
Also, with respect to item (4), the TUGCO Quality Assurance Division has begun to issue CAR's.
A copy of that log will be made available for inspec-tion and copying.
APPLICANTS' CLARIFICATION OF RESPONSES TO CASE'S INTERROGATORIES On February 1, 1982 CASE telephoned Applicants to request clarification of certain of the responses provided to CASE's Sixth Set of Interrogatories.
Specifically, CASE had questions regarding Interrogatories 2.d.
and 2.e.,
2.h. and 2.i.,
and 3.
CASE also had a general request that Applicants identify "the person providing each answer or response."
In response, Appli-cants provide the following information:
Interrogatories 2.d.
and 2.e.
These Interrogatories concern procedures for documentation and review by management of audit results.
Applicants provided the appropriate procedure numbers.
CASE asked that Applicants clarify their response.
Applicants hereby clarify their response, as follows:
.i
The numbers identify procedures contained in the Corporate Quality Procedures / Instructions Manual provided in response to Item 7.e. (23).
Interrogatories 2.h.
and 2.i.
These Interrogatories concern NRC Staff audits to detect trends.
Applicants responded that the NRC Staff conducted audits according to their own procedures and thus the question is best directed to the NRC.
CASE is concerned that Applicants response does not make it sufficiently clear that the information can only be obtained from the Staff.
(See 10 C.F.R.
{ 2.720(h)(2)(ii)).
Applicants believe that their original response was proper.
Interrogatory 3.
This Interrogatory requested copies of Applicants' responses to NRC I & E Reports.
Applicants responded that these documents are available in the local public document room ("PDR").
In its phone conversation with Applicants, CASE indic,ated that it was concerned that as hearings on Conten-tion 5 approached it would not be able to obtain Applicants' responses in a timely manner because of delays in documents reaching the PDR.
Applicants respond, as follows:
Applicants will discuss with CASE arrangements to make available responses to NRC I & E Reports l
which are relevant to Contention 5 when it becomes clear that CASE is unable to obtain Applicants' responses from the PDR in a timely manner.
l I
General CASE requested that Applicants identify the person providing each answer or response to CASE's interrogatories.
Applicants r'espond, as follows:
Each answer was prepared by or under the direct supervision of David N. Chapman, Manager, Quality Assurance, Texas Utilities Generating Company.
Respectfu y submitted, I
)
Nichol b S.i Reynolds V
1)
~
William A.
Horin DEBEVOISE & LIBERMAN 1200 Seventeenth Street, N.W.
Washington, D.C.
20036 (202) 857-9817' Counsel for Applicants February 8, 1982
e UNITED STATES OF AMERICA
,,g.
NUCLEAR REGULATORY COMMISSION "O
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
'82 FEB -9 A10 :27 In the Matter of
)
TEXAS UTILITIES GENERATING Docket No.5d$445 COMPANY, et al.
)
50-446
)
(Comanche Peak Steam Electric )
(Application for Station, Units 1 and 2)
)
Operating License)
CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing
" Applicants' Response to CASE's Sixth Set of Requests For Production of Documents and Clarification of Responses to Certain Interrogatories," in the above-captioned matter were served upon the following persons by overnight delivery (*),
or by deposit in the United States mail, first class postage prepaid this 8th day of February 1982:
Marshall E.
Miller, Esq.
Chairman, Atomic Safety and
~
Chairman, Atomic Safety and Licensing Appeal Panel Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.,20555 Washington, D.C.
20555 Dr. Kenneth A. McCollom Marjorie Ulman Rothschild, Esq.
Dean, Division of Engineering Office of the Executive Architecture and Technology Legal Director Oklahoma State University U.S. Nuclear Regulatory Stillwater, Oklahoma 74074 Commission Washington, D.C.
20555 Dr. Richard Cole, Member Atomic Safety and Licensing David J. Preister, Esq.
Board Assistant Attorney General U.S. Nuclear Regulatory Environmental Protection Commission Division Washington, D.C.
20555 P.O. Box 12548 Capitol Station Chairman, Atomic Safety and Austin, Texas 78711 Licensing Board Panel U.S. Nuclear Regulatory J.
Marshall Gilmore, Esq.
Commission 1060 W.
Pipeline Road Washin,gton, D.C.
20555 Hurst, Texas 76053
i
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Mr. Richard Fouke Mr. Chase R. Stephens 1669-B Carter Drive' Docketing & Service Branch
' Arlington, Texas 76010 U.S. Nuclear Regulatory Commission
- Mrs. Juanita Ellis Washington, D.C.-
20005 President, CASE 1426 South Polk Street Dallas, Texas 75224 i
L
'~
William A. Horin 1
cc:
Homer C. Schmidt j
Spencer C. Relyea, Esq.
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