ML20040H581

Forwards Citizens Association for Sound Energy Second Set of Interrogatories & Requests to Produce Directed to Nrc. Related Correspondence

ML20040H581
Person / Time
Site:	Comanche Peak
Issue date:	02/13/1982
From:	Ellis J Citizens Association for Sound Energy
To:	Cole R, Mccollom K, Mark Miller Atomic Safety and Licensing Board Panel
Shared Package
ML20040H582	List: ML20040H581 ML20040H583
References
NUDOCS 8202180405
Download: ML20040H581 (3)

Text

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_ 2/13/82 ', eq '. 3 UNITED STATES OF AMERICA N k NUCLEAR REGULATORY COMMISSION g BEFORE THE ATOMIC SAFETY AND LICENSING BOARD. In the Matter of l APPLICATION OF TEXAS UTILITIES I Docket Nos. 50-445 GENERATING COMPANY, ET AL. FOR I and-50-446 l AN OPERATING LICENSE FOR I I fi COMANCHE PEAV, STEAM ELECTRIC STATION UNITS #1 AND #2 I (CPSES) l ddministrative Judge Marshall E. Miller U. S. Nuclear Regulatory Commission 1 Atomic Safety and Licensing Board Panel Washington, D. C. 20555 ' Dr. Kenneth A. McCollom, Dean Dr. Richard Cole, Member Division of Engineering, Atomic Safety & Licensing Board Architecture, and Technology U. S. Nuclear Regulatory Commission ~ Oklahoma State University Washington, D. C. 20555 -! Stillwater, Oklahoma 74074

Subject:

CASE 's Second Set of Interrogatories and Reques ts to Produce to NRC Staf f '{ Pursuant to 10 CFR 2.720(h)(2)(ii) and 2.720(h)(3), CASE herewith' files the attached Second Set of Interrogatories and Reque sts to f Produce to NRC Staff. . In support thereof, we would show the following: j (1) All of the interrogatories deal directly with matters in  : controversy in these proceedings under Contention 5, which

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states: . The Applicants' failure to adhere to the quality assurance / quality control provisions required by the construction permits for Comanche PeakT Units 1 and 2, and the require-ments of Appendix B[of-10 ~ CFR -Part 50, and the cons truction . g v, S _ 'x1 DSo?

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practices employed, specifically 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, craft labor qualifications 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 required by 10 CFR 50.57(a) necessa y for issuance of an operating license for Comanche Peak. '. ' Therefore, these interrogatories and requests to produce - are entirely relevant and necessary to a proper decision in this proceeding. c.' (2) The answers to these interrogatories are not reasonably . obtainable from any other source. Question 1 concerns an Inspection Report regarding an - h investigation made by the NRC which was or will be prepared

                                                                                    ._. ,i by the NRC. It is unobtainabl.a from any other source (and                ;

at the moment is not obtainable even from the NRC) . It also concerns further follow-up questions regarding the ASME's 4 audit and reaudit and pulling of the Certificates of Authori '- e zation and the Code Symbol Stamps at CPSES, the NRC's knowledge [ t of and involvement in ASME's audit and reaudit, and related

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_{ f information, all of which is not reasonably obtainable from any other source. , CASE believes that the similarities between the problems I Q experienced in the construction of CPSES and the South Texas y 1 ' In its 10/31/80 rulings, the Board construed Contention 5 to -{ cover the Inspection and Enforcement Reports identified by -4 ACORN in its Offer of Proof of August 29, 1980.  ; T

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Nuclear Project (STNP) are obvious and that the cause of 4 i many of these problems is the same -- 5rown and Root, r'[ Question 2 attempts to ascertain whether or not the NRC Staff has also noticed such similarities, whether they

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have even made such an assessment of whether or not there are similarities, and the results of such assessments. 5 We believe that the answer to these questions is vital i@ and necessary to a proper decision in this proceeding, 7 and it is not reasonably obtainable from any source other a

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than the NRC. " t CASE is very much disturbed by the fact that we found out about 5 the ASME's pulling of the certification certificates and stamps at CPSES from a newspaper article. Obviously this information gj is very pertinent to these proceedings and should have been provided h Pi to'the Board and all parties through the proper channels, by either in-the Applicants or the NRC Staff, or both. We are also very much il ql concerned that we have been trying for months to get a copy of. d I&E Report 81-12, without success. We cannot comply with the Board's h

                                                                                                                                                      'i Order to complete discovery within the specified time frame without                                                                               J qi having such vital information supplied promptly and properly by                                                                                     i Applicants and Staff,                                                                                                                               :

We trust that the Board will take this - into consideration. We ask that the NRC Staff be ordered to

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expeditiously answer our questions and provide the documents requested:  : Respectfully submitted, -

                                                                                                                                                      - { [*,
                                                                                                                                                      'g o db                                                   d Mrs'.) Juanita Ellis, President                             jf f(ASE C       (Citizens Association for Sound Energy)                          -
                        '-                                                            1426 S. Polk, Dallas, Texas                  75224 214/941-1211, wrk                                         .j e 214/946-9446, hcme                                        '

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