ML20040G679

First Set of Interrogatories & Requests to Produce. Certificate of Svc Encl.Related Correspondence

ML20040G679
Person / Time
Site:	Comanche Peak
Issue date:	02/10/1982
From:	Ellis J Citizens Association for Sound Energy
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
Shared Package
ML20040G673	List: ML20040G672 ML20040G679
References
NUDOCS 8202160361
Download: ML20040G679 (9)

Text

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nzu'TED ConRESPONDUCS

_ 2/10/82 o f.wp UNITED STATES OF AMERICA

'82 FEB 11 Pz:15 NUCLEAR REGULATORY COMMISSION

.BEFORE THE ATOMIC SAFETY AND LICENSIN'" BOARD' G

In the Matter of I

Docket Nos. 50-445 APPLICATION OF TEXAS UTILITIES I

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

AN OPERATING LICENSE FOR I

COMANCHE PEAK STEAM ELECTRIC STATION UNITS #1 AND #2 (CPSES)

CASE'S FIRST SET OF' INTERROGATORIES AND REQUESTS TO PRODUCE TO NRC STAFF Pursuant to 2.720(h)(2)(ii), CASE herewith files its First Set of Interrogatories and Requests to Produce to NRC Staff.

Please answer the following interrogatories in the manner set forth herewith.

Each interrogatory should be answered: fully in writing, under oath or' affirmation, and include all' pertinent information knowd to the NRC Staff as well as any pertinent in-formation known to their advisors or counsel.

Please identify the person providing each answer or response.

Each request to produce applies to pertinent documents-which in the possession, custody or control of the NRC Staff, its are officers; directors or employees as well as its advisors or counsel.

The term " documents" shall include any writings,1 drawings, graphs, charts, photographs, reports, studies, and other data compilations from which information can be obtained.

INTERROCATORIES AND REQUESTS TO PRODUCE 1.

10 CFR Part 50, Appendix B, Section XVIII. AUDITS, states:

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1. (continued):

"A comprehensive system of planned and periodic audits shall be carried out to verify ccmpliance with all aspects of the quality assurance program and to determine the effectiveness of the program.

The audits shall be performed in accordance with the written proc 2dures or check lists 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 answer the following:

(a) Has the NRC conducted any audits to detect trends that may be detrimental to. safe station operation at CPSES?

(b) If the answer to (a) above is yes, supply for copying and inspection all such audits, or advise how CASE can obtain them through the Public Document Room.

If the audits themselves are not provided, please provide a list of the specific documents so that we can obtain them from the PDR.

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(c) If the answer to (a) above is no, has the NRC conducted any unofficial audits (i.e., perhaps not actual audits '

but efforts to detect such trends) for this purpose?

(d) If the answer to (c) above is yes, supply for copying and inspection all such documents, or advise how CASE can obtain them through the PDR.

If the documents them-selves are not provided, please provide a list of the specific documents so that we can obtain-them from the PDR.

2.

Please provide the names and ' addresses, background information, and subject matter for all witnesses which the NRC Staff plans to call regarding Contention 5.

3.

CASEhasattachedthefollow{ngdocuments, supplied by Applicants of Interrogatories to in response to CASE's 1/4/82 Sixtg : Set Applicants and Requests to Produce l

t l Erroneously dated 12/4/82 in the upper right-hand corner of page 1 but correctly dated on the Certificate of Service.

l 2 See Applicants' January 25,1982 (erroneously dated January 25, l

1981 in the upper right-hand corner of page 1 but correctly dated on the Certificate of Service) Answers to CASE's Sixth Set of Interrogatories and Applicants' February 8, 1982 Response to CASE's Sixth Set of Requests for Production of Documents and l

Clarification of Responses to Certain Interrogatories, and CASE's l

2/10/82 Seventh Set of Interrogatories to Applicants and Requests to Produce, also being filed today.

1 (continued)-

November 23, 1981 letter from Joseph A. Russo,' Manager, Accredi ta tion, N & SPPE, American Society of Mechanical Engineers (ASME) to R. J.

Vurpillat, QA Mgr., Brown &

Root, Inc.

November 25, 1981 letter from Joseph A. Russo, Manager, Accreditation, N & SPPE, American Society of Mechanical Engineers (ASME) to R. J. Vurpillat, QA Mgr., Brown &

Root, Inc.

December 17, 1981 letter from Arlene A. Spadafind, Director, Accreditation, American Society of Mechanical Engineers (ASME) to R. J. Vurpilla t, QA Mgr., Brown & Root, Inc.

In this regard, please answer the following:

(a) Was the NRC Staff aware of these documents?

(b) Did the NRC Staff inform the Atomic Safety and Licensing Board of the certification problems referenced in these

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documents?

(c) If the answer to (b) above is yes, provide for inspection and copying all documents pertaining to such notification by the Sta f f and response by th'e Board.

If verbal communi-cation was made, give specific details of such communication.

If the actual documents are not provided, please advise the titles of them so that we can obtain them from the PDR.

(d) If the answer to (b) above is no, please explain why the NRC Staff does not believe such certification problems come within the Board's Order to the Staff to keep the Board advised of signific, ant events in these proceedings.

(e) Please provide for inspection ar.d copying all documents in the Staf f's possession or of which the Staff has knowledge pertinent to the referenced certification problems, the October 12-14, 1981 ASME inspection, the January 18-22, 1982 ASME reaudit, or other pertinent NRC documents.

If the actual documents are not provided, please provide a listing of them so that we can obtain them from the PDR.

Respectfully submitted, f1AD 7

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XXrs.) Juanita Ellis, President TASE (Citizens Association for Sound Energy) 1426 S. Polk, Dallas, TX 75224 214/941-1211, work 214/946-9446, home 3-

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4 loo Clinton Irive Ecuston, TX 77020 subject: Report of AStfE Ruclear Survey Conducted on October 12-14, 1981 for New EA & b7T (Replacing current site extension N-2222-2 & F-2223-2) at Cecanche Peak Electric station, Units il & #2; Clen Rose, II.

An AS){E Nuclear Survey was conducted et your facilities on the date and location shown above for the subject reqested Autho::ination.

As a result of the Survey, the Tea has reco:cended that 2 Rasurvey is reouired.

Tne ASXE decision on the Tea =a recc=nendation v.11 be forwarded to you shortly.

Toc deficiencies noted in your progren in:lude, but are not limited to, the fol-Icving ite=s which require corrective a: tion:

1.

Cuelity Assurance Manual (A) The r.anual was vague, failed to establish required controls, responsibi-lities, or provide for objective evidence that required activities were satisfacterily perfo med.

(3) Tne nanual established the Sm.: addenda 1974 for piping and Winter ad-denda 1974 fer cceponent supports as the Code cf fectivity. The ca:"al addressed activities only permitted by later Code addenda; such as L-2610, ItA-3867.4(f) and supply of =aterial - ECA-3620(e), without any identifi-cation of the ap p icability of these provisions.

(C) Ths manual control syste= did not include the exhibits displayed in the r.anual or any c2=ual approval method.

(D) The progra= ele =ents of procese control, nonconformity control and document control required significant changes.

(E) The design control elenent (control) cf field change design information and feed back of construction info::ation to the Cvner) vas tissing frca the manual.

vembe-. Arnancan Anoenw.of r ;nnnnn; soem,n.,4cc,, n.non 3:3 3, pen;ineenn; and Teno;ogy

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ky) All elenents raquired changes to provide definitive infer =.stion since few auditable contiels were included.

.11. I= ole:rntation (A) Dec c.ent Control - Le cancal requires that the File Custodians in each depart =>ent maintain a log of desip changes reteived frc: the CW er.

Le File Custodian is to cari the involved decu=ent to indicate that a design change had baan received and then the docu=ent user checks the log to find the applicable design change (s).

'Ihe log being maintained by the QA Department File Custodian contained n e ereus sistakes and was missing infor 2 tion. nree of three design packages, checked by the tea =, centained design changes not properly identified in the log.

(B) Instruction Procedures & Drawings - 3 6 R Construction Pro:edure 6.9C, reviewed by the Site QA Manager, was in direct conflict with the QA Manual and the Code (NA-3241) in thet it stated that the AEI would situ a blank process sheet and then B & R vould add the ANI held peints. The AIA re-presentatives stated that this procedure was not honored by them and that they had requested the procedure to be revised. Tbe procedure has not been revised.

h e purpose of the Site QA' Manager's review is to assure that the procedure ce= plies with the Code and the QA Manual.

(C) Control of Purchased Materials, Items and Services -

(1)

Vender Control - B 6 R procured plate cateriel frec a vender that they had surveyed and qualified as.e.Materi,t1 Supplic cf bolring'and plate

[, a ', e caterials. he caterial had been fomed into a saddle configuration by this vender. The B & R survey and qualification of this vendor did not address review of any operation relative te forming and the B & R purchase order did not define a fer=ing pro:ess or procedure.

(2) ne same catcrial addressed in C1 vas observed in the production shop with verk in process. Tni caterial had not been receipt inspected in con =c=plfance with the QA Maccal and the caterial was not identified as required by the B & R purchase order. 5 & R hac divided the caterial and transferred the caterial identificarica incerrectly. 3 L R does not verify the transfer of cattrial identification and during the review ef the cenual stated that this verific: tion was unneccesary.

(D) Control of Constructicre Processes -

(1) Process Sheets were observed in production that had not been reviewed

'vith the ANI for establisbeent of bold points in conco:Pliance with the B L R QA Hanual and HA-$241 of the Code. Toe pro:ess sheets CC-065-002 '

S33R and >J-035-023-533A are incluced in this finding although nurerous such process sheets are in production. (See B abcve)

(2) ' Welding Procedure Specificatics 11012 fer velding vith impact test re-quirenents did not specify tb: travel speed but instead controlled the heat input by Volt /a=p rangi end marin= bead vidth for a given electrode disneter. Tne 3rocedure Qaalificaties Re: erd 010A3127 fer this k?5 re-corded a beam vidth greather than that alleved by the k?S.

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(E) Nonconfernity Centrol - Nou:enforcity Control Ecport (NO.4) P-ported that a spool piece had been velded into the systen B & E QA deter =ined the dispositien to be rev:rk and no.

thereby the disposition to cut the spool piece cut and re.

the correct cediguration was not reviewed by velding engin.

vould have been required by a repair designation. Tnere appe be no censideration of the best input effects on the caterial, as would be expected with this type of noncenformance.

(T) Identification and Control of P.aterial and items - Co=ponent Support.

are pro:ured as stanped ite=s by the Owner. The Code Data ?.eport does not list Code Case F-225. The Ce=ponent support is supplied to B 6 I with only the Code Data Report by the Ovner. E & E then cuts the co=-

ponent support, removing the velds, and t.scs the catarial to fabricate other co=ponent supports. E & E does not have, the Certificate of Coc-

. pliance (C of C) for the material.

(C). Authorized Nuclear inspector luvolve=e st - The ASI hold points on pre-cess sheets have been bypassed on nu=erous occasions. The ANI logbook docu.sents these conditions and the volune vould indicate a significant

.breakdevn of.the progra= and interface between B 5 R sed the Authorized Inspection Agency personnel (See 2. and D-1 ab=ve).

It is called to your attention that the recurvey vill include a revirv of the entire progre= 6 its implementation, and all areas discussed by the Survey Teen vith your personnel should be given particular consideration.

Tlease note that arrangements to schedule dates for the returvey h=ve been cutde end the ex.ect dates have been or vill be sent tc you shortly. Note that the resurvey t

vill not be held until we have received payment of our invoi:e for the subje:t sm ey.

if you disagree with the decision above and vish to sub=it additional infornstion for reconsideration, you cost sske your intenticus knovn, in vriting, te this effice, to be received within five (5) vorking days af ter receipt of this letter. Tour request for reconsideration cust include the reasons upon which the reconsideration is to be based.

If you have any questions concerning this survey or the resurvey, please contact this office.

Joseph A. Russo P.snsger, 1:craditation - N & BFFI l

(212) f44-8051 l

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3RCN'N & RCYJT, INC.

l E.J. Vurpillat; QA Mgr.

4100 Clinton Drive

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U Houston,.II 77020

Subject:

NA 6 hTT Certifiestes of Authorizatica (H-2222-2 6 h-2223-2) at the Comanche Peak Electric Station, Units il & #2; Clen Rose, Texas, expiring January 6, 1982 Reference is cade to our letter date'd November 23, 1981 which contained the findings of the renewal survey conducted on October 12-14, 1981. The evaluation of the report has been co=pleted zod the decision is to concur with the team's reco==endation that a reservey is required.

After due consideration of the findings as reported to you previously, the decision is that yout subject Certificates are' being per=itted to czpire en January 8,1952 and new Certificetes vill only be issued af ter evalus-tion of a successful resurvey report,*

Note that because of the expiration, we expect return of the Code Synbol Sta=ps NA & NFI on January 8,19E2.

If you disagree with the decision above and wish to sub=it additientl in-formation for reconsiderr. tion, you cust cake your intentions known, in v-iring, to this office, to be received within five (5) vorking days after your receipt of this letter. Your request for reconsideration %xt include the reasons upon which th: reconsideration is to be based.

Please contact this office if you have any questions on this survey or cn the resurvey.

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P.O. Box 3

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Houston, TX 71001

SUBJECT:

Request for Reconsideration of Expiration Date on llA & NPT (N-2222-2 & N-2223-2) at the Comanche Peak Steam Electric l

Station, Units #1 & #2; Cien Rose, TX 1

We are in receipt of your letter of December 4, 1981 requesting recon-I sideration of the expiration of the subject Certificates ca January 8, 1982.

This request will be reviewed at the ASME Subcommittee on "ucler:r Ac-creditation (SC-NA) Meeting on January 11, 1982.

You and/or your repre-sentatives are invited to appear before the subcommittee, if you wish, at 3:00 PM at the United Engineering Center; 345 East 47th Street; New York, NY 10017 in the Council Roor:i to express your views prior to the Subcommittee'r decision.

If you wish to present a written report for consideration, we request that you deliver the original and 25 copies to my attention by 9:00 AM on January 11, 1982.

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Please notify this office by January 4, 1982 if you intend to have repre-sentati'-

present and if so, their name and title.

Therefore, until the result of the hearing is attained, the subject Cer-tificates are being extended by separate letter.

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.9 UNITED STATES OF AMERICA

@ U priS NUCLEAR REGULATORY COMMISSION BEFORETHEATOMICSAFETYANDL[.9CENSING B0 h>]. [>;.

In the Matter of I

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I APPLICATION OF 'IT.XAS UTILITIES I

Docket Nos. 50-445 GENERATING COMPANY, ET '. '. FOR AN I

and 50-446 OPERATING LICENSE FOR COMANCHE I

PEAX STEAM ELECTRIC STATION I

UNITS s1 AND 82 (CPSES)

I CERTIFICATE OF SERVICE By my signature below, I hereby certify that true and correct copies

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of CASE S Request to the Atomic Safety and Licensing Board and CASE's First Set or interrogatories and Reques ts to Produce to NRG Statt have been sent to the names listed below this 10th day of February 1982 by:

Express Mail where indicated by

• and by First. Class Mail otherwise.

• Ad:ninistrative Judge Marshall E. Miller David J. Preirter, Esq.

U.

S.

Nuclear Regulatory Commission Assistant Attorney General Atomic Safety and Licensing Board Panel Environmental Protection Division Washington, D. C.

20555 P. O. Box 12548, Capitol Statio*.

Austin, TX 78711

• Dr. Kenneth A. McCollom, Dean G. Marshall Gilmore, Esq.

Division of Engineering, Architecture, 1060 W. Pipeline Road and Technology Hurst, Texas 76053 Oklahoma State University Stillwater, Oklahoma 74074 Dr. Plchard Cole, Member Atomic Safety and Licensing Atomic Safety and Licensing Board Board Panel U. S. Nuclear Regulatory Comission U. S. Nuclear Regulatory Commission Washington, D. C, 20555 Washington, D. C.

20555

• Nicholas S. Reynolds, Esq.

Atomic Safety and Licensing I

Debevoise & Liberman Appeal Panel 1200 - 17th St., N.

W.

U. S. Nuclear Regulatory Commission Washington, D. C.

20036 Washington, D. C.

20555

• Marjorie Ulman Rothschild, Esq..

• Docketing and Service Section Office of Executive Iegal Director Office of the Secretary U. S. Nuclear Pagulatory Coranission U. S. Nuclear Pegulatory Comission

• dashington, D. C.

2055!

Washington, D. C.

20555

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fffs. ) Juanita Ellis, President CASE (CITIZENS ASSOCIATION FOR' SOUND ENERGY)

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