ML20052A452
| ML20052A452 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/20/1982 |
| From: | Ellis J Citizens Association for Sound Energy |
| To: | TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| NUDOCS 8204280343 | |
| Download: ML20052A452 (6) | |
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4/20/82 UtlITED STATES OF AMERICA fiUCLEAR REGULATORY COMMISSI0tt N
BEF'sRE THE ATOMIC SAFETY Afl0 LI'CEtiSIf1G BOARD In the Ma tter of APPLICATI0tl 0: TEXAS UTILITIES I
GEt4ERATI f4G C0" patly, ET AL. FOR Docket tios. 50-445 Aff OPERATIfiG LICEllSE FOR and 50-446 COMANCHE PEAK STEAM ELECTRIC 5
STATI0ft U11175 el ANO *2 I
ed (CPSES)
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Ctpsryg CASE'S AtiSWERS TO APPLICANTS' 49R FIFTH SET OF I!1TERROGATORIES $,%=27 A{3 TO CASE AND REQUESTS TO PRODUCE
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g Pursuant to 10 CFR 2.740b(b) and 2.741(d), CASE (Citizens Asa5 ti
$r Sound Energy), Ir.ervenor herein, hereby serves CASE's Answers to Applicants' Fifth Set of Inte rogatories to CASE and Requests to Produce, filed 4/6/82 To expedite discovery, CASE is also responding at this time to Applicants' Requests to Preda:e.
s 1-5.a.The analysis to which we referred consists of obtaining and reviewing docum nts (..-ich we are still in the process of doing, and to which we are at tne : resent tim devoting most of our attention) and analyzing of Appendix 3 of 10 CFR Part 50, to ascertain which o Applicants rave not adhered to.
b.We have not yet made this determination as far as specifics.
we have been able to obtain the documents which we seek and revi As soon as original docnents which we are requesting, we will be in better position to answer this question and will do so at that time, c.We don't knc.. at this time; as soon as possible. See b. above.
d Yes.
e.See b. above.
GDY Goll 820428Q3 G C,
2-5.
We're not certain exactly what Applicants seek in this question.
If Appli-cants are asking for specific sentences or phrases from the specific Criterion Nos. set forth in CASE's 3/16/82 Answers to Applicants' Third Set, Question 4, we have not made such an analysis.
If this does not answer your question, please explain further.
3-5.
Not at this time.
As explained oreviously, right now we are trying to review all the documents we have obtained, are obtaining, and are in the process of reviewing.
After we have had a chance to do this, we will be
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' on analyzing exactly what we have obtained; however, we are nav musing our attention on just getting the information we seek.
4-5.
- a. No.
- b. We don't know; as soon as possible; see 3-5. above. We have also had to spend some time in answering Applicants' Motion for a Protective Order and these interrogatories.
- c. No.
5-5.
- a. We have not made an analysis at this time in the detail Applicants seek.
This was a general statement, based on our general impressions of what we have reviewed so far.
We expect to shov it with specifics when we have completed examining documents, etc.
See 3-5 above.
- b. By " consistent" as used in " troubling aspect is the lack of a consistent QA/QC program," we mean the lack of a QA/QC program which has set forth specific methods and procedures to comply with NPC regulations (5:ecifically 10 CFR Part 50, Appendix B) and carrying out such a program on a continuing basis. We have not made the detailed analysis Applicants seek at this time.
See 5-5 a. above.
- c. By " trend" as used in " primary and continuing concern is the trend of the type of work being done at the plant and continuing breakdown of the entire QA/QC program," we mean the underlying or prevailing tendency; for example, the trend to engineer away problems; the tendency to not re-port problems to the NRC, such as in the case of the patched dome of Unit I containment and the extensive honeycombing of the Unit 11 con-tainment walls.
This should be taken in context with the rest of the sentence.
By " continuing breakdown" we mean that Applicants' QA/QC program hasn't worked correctly, that it has been constantly changing, and that it still is changing.
We have not made a thorough analyiis to the extent Applicants seek at this time.
See 3-5 above.
6-5.
We expect to be able to show specific instances of construction practices
- v. hen we complete our analysis of documents we are presently reviewing and in the process of reviewing. We will supplement our answer as soon as we have done this.
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4 7-5.
We' have not made this analysis ' at this time. We'will probably include some of the audit reports (including the Lob:in. Report) in support cf its position on Contention 5; however, we have n:t as yet decided which carticu-lar reports or portions of reports we will relycon.
3-5.
As stated in our answer.to 5.b. of CASE's 3/15/82 Answers to Applicants'
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Third Set of Interrogatories to CASE:
"...we have not made an a.ialysis at this time which specifically identifies (these items),in groupings by ' mortar blocks', per se."
This is still o_ur answer.
We do not at this time know whether or not we will rely on I&E Reports regarding mortar blocks for our position on C:ntention 5.
9-5.
As stated in our answer to 5.c. of CASE's 3/i5/82 Answers to Applicants' l
Third Set of Interrogatories to CASE:
"...we have not made an analysis at this time which specifically identifies
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(these items) in groupings by ' steel' per se."
This is still our answer.
4 3
We do not at this tire know whether or not we will rely on I&E Reports j
regarding steel for our position on Contenti:n 5.
10-5. With respect to " fractures toughness testing, we do not know at this time whether'or not we will rely upon the Westingh:use agreement, referenced by CFUR. The I&E Peport referenced in our resp:nse to 5.d of the Third Set was referred to-by CFUR: NRC Report 75-06. Je have not yet made ar. analysis of this report or what it deomonstrates with respect to fracture tou;hness tes ting. We do not at this time know whether or not we will rely or I&E Report 75-06 in support of our position on C:qtention 5.
11-5. We have not yet contacted CFUR with respect t: expansion joints, nor have we decided whether or not to pursue this aspect of Contention 5.
i 12-5. Yes, to the extent that it demonstrates Appli: ants' trend to engines-away problems. As to what specific impact this may have. on health and safety of the public, we have not made this analysis at this time.
I 13-5, See 12-5 above.
This was a major design and construction error, which presumably went through several stages of review before it was disccvered.
4 1
How could this have happened? Why wasn't it : aught beforehand?
If this i
could happen on such a major and vital piece of equipment for the plant, what might have happenedon other pieces of ecuipment where the error wasn't
. as obvious? How many other errors may have slipped through inspecti:ns and design review? Why wasn't this reported to e TIRC in a more timely fashion?
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If App.licants' can allow this kind of error :: occur, how can we be assured that they can construct and operate the plant safely?
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14-5. To point out that the items referenced are standard modus operandi.
The quotation of Applicants' responses to CASE's December 4,1980 Third Set to' Applicants was taken from interrogatory answers regarding I&E Report 78-17, which concerned "...a 'Cadweld splice in the Unit 1 Con-tainment wall reinforcing steel (which) had pulled apart upon application-of a light force while preparing the spliced bar for additional splicing.,
The mode of failure was such that grossly poor workmanship had to be the cause, either by intent or by negligence." (Please refer to CASE's 12/4/80 Third Set, Question 11.)
15-5. Not at thip' time.
See 3-5 preceding.
16-5. I&E Report 80-25, SALP (Systematic Assessment of Licensee Perfonnance) for the period August 1,1979, through July 31, 1980, contains pertinent information regarding welding problems as follows:
"b. Enforcement History
- Failure to follow procedures for verification of the performance of automatic welding machines
- Failure to follow welding procedures
- Failure to follow welding procedures "d. Consthuction Deficiency Reports - 50.55(e)
- QA of welded Conduit Supports" No.
1725. Not at this time. See 3-5 preceding.
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18-5. Not at this time. See 3-5 preceding.
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19-5. Not at this time. See 3-5 preceding.
E 20-5. a. We don't know whether all outstanding issues presented in each I&E Report has been resolved to the satisfaction of the NRC Staff or not.
Applicants (and CASE) will have to ask the Staff.
Further, CASE does not accept the pmmise that even if the NRC Staff has been satisfied with the resolution of such issues, they have in fact been satisfactorily
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resolved. This is not one of the criteria we are using.
- b. Not applicable.
- c. ~ Not applicable.
- d. We have not yet made that determination.
- e. See d. above.
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21-5. For purposes of the upcoming hearings, we have dropped the trending analyses for CPSES as compared to STr1P at this time. The trending analyses for CPSES is an attempt to identify trends in construction which may be detrimental to public health and safety in the future.
At the moment, we haven't gone beyond identifying the ISE Reports by subject matter which we have already indicated in response to previous questions by Applicants, such as concrete.
welding, etc.
22-5. tio, other than as indicated above.
23-5. flot applicable.
24-5. As soon as possible.
It would certainly be helpful if the f1RC Staff and Applicants would be more cooperative and quit springing new reports on us (such as the Lobbin Report) and trending information such as has just been supplied to us by the Staff (see attached Motion for Additional Time for Discovery on Contention 5) and let us get on with the business at hand.
We could also do this much faster if we were allowed to review original documents at the plant site on week-ends rather than during the week, since most of CASE's members must work during the week and cannot help th en.
25-5. NRC regulations, including but not necessarily limited to:
10 CFR Part 50, Appendix B 50.55(e) 50.57(a)
...and Applicants' construction permits for Comanche Peak, Units 1 and 2.
The documents, testimony or oral statements to which Applicants refer are as we have already stated in response to specific interrogatories.
26-5. Same as answer to 24-5 preceding.
Respectfully submitted, u
< &AY MWs.) Juanita Ellis, President fASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 214/941-1211, work, part-time.
t UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
, " "O BEFORE THE ATOMIC SAFETY AND LICENSING 30ARJ In the Matter of I
I APPLICATION OF TEXAS UTILITIES I
GENERATING COMPANY, ET AL. FOR AN Docket Nos. 50-445 I
OPERATING LICENSE FOR COMANCHE and 53-446 I
PEAK STEAM ELECTRIC STATION I
UNITS #1 AND #2 (CPSES)
I CERTIFICATE OF SERVICE By my signature below, I hereby certify that of CASE's Answers to Applicants' Fifth Set of Interrocatories to CGE and R true and correct copies to Produce have been sent to the names listed below this 20 th day of Aprit 1982, by:
_ Express Mail where indicated by
- and by tirst ciass ail elsewnere.
- Administrative Judge Marshall E. Miller David J.
Preister, Esc.
U. S. Nuclear Regulatory Commission Assistant Attorney General Atomic Safety and. Licensing Board Panel
- Environmental Protection Diti WrAhington, D. C.
20555 sion P. O. Box 12548, Capitol Station Austin, TX 78711
- Dr. Kenneth A. McCollom, Dean 1
Division of Engineering, Architecture, i
and Technology I
Oklahoma State University l
Stillwater, Oklahoma 74074
- Dr. Richard Cole, Member Atomic Safety and Licensing Board Atomic Safety and Licensing U. S. Nuclear Regulatory Commission Board Panel Washington, D. C.
20555 U. S. Nuclear Regulatory Co ission j
Washington, D. C.
20555
- Nicholas S. Reynolds, Esq.
Debsvoise & Liberman Atomic Safety and Licensing Appeal Panel 1200 - 17th St., M. W.
U. S. Nuclear Regulatory Co=ission Washington, D. C.
20036 Washington, D. C.
20555 L
- M2rj ori e '? Lw.
t i::q and Service Sectic.
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offic* v L mcut.ve :.ma
.. mar vifice of th+: Secretary U.
- 5. Nuclear Regulatory Commission Wmshington, D. C.
20555 U. S. Nuclear Regulatory Co=ission Washington, D. C.
20555
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J4ts.) Juanita Ellis, Preside..t
' CASE (CITIZENS ASSOCIAT! N T~R SOUND ENEP.GY)
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