ML20053A502
| ML20053A502 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/17/1982 |
| From: | Horin W DEBEVOISE & LIBERMAN, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Citizens Association for Sound Energy |
| References | |
| NUDOCS 8205260156 | |
| Download: ML20053A502 (35) | |
Text
-
(; >.,
May 17.71982 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'BEFORE'THE' ATOMIC' SAFETY AND' LICENSING' BOARD In the Matter of
)
)
TEXAS UTILITIES GENERATING
)
Docket Nos. 50-445 and COMPANY, et'al.
)
50-446
)
(Comanche Peak Steam Electric
)
(Application for Station, Units 1 and 2)
)
Operating Licenses)
APPLICANTS' ANSWERS TO. CASE'S
- ELEVENTH SET *OF' INTERROGATORIES Pursuant to 10 C.F.R. 1 2.740b(b), Texas Utilities Generating Company, et al. (" Applicants") hereby submit their answers to " CASE's Eleventh Set of Interrogatories and Requests to Produce," served May 7, 1982. Applicants set forth below answers to both CASE's Interrogatories and CASE's Requests to Produce. These answers are being provided at this time in accordance with the Board's directive to complete discovery on this date.
In addition, Applicants have made the documents requested herein ava13able for inspection and copying beginning May 17, 1982.
O O(\\
1 8205260(EG 6
APPLICANTS' ANSWERS TO CASE'S tusvenin dLA ur 1NrtKxuGATUK1ES 1.
To address this concern, Applicants propose that CASE provide, well in advance of the hearing, copies of the documents it intends to introduce so that Applicants may stipulate as to their authenticity.
2.
a.
Af ter the Nonconformance Report (NCR) is written, the trend category may be assigned by the person who reported the nonconformance, the NCR Coordinator or a Quality Engineer.
The one trend category which is judged best to fit the nonconforming condition is chosen.
In some instances, more than one category may be assigned to an individual NCR.
Thus, no cross-referencing is done.
The trending of NCR's is a method used by QA management to identify recurring nonconformances of a particular type.
b.
After the Deficiency and Disposition Report (DDR) was written, the trend category was assigned by the DDR Supervisor.
The one trend category which was judged best to fit the deficient condition was chosen.
In some instances, more than one category may have been assigned to an individual DDR.
Thus, no cross-referencing was done.
The trend categories were used directly from the DDR or from the DDR log.
The trending of DDR's was a method used by QA management to identify recurring deficiencies of a particular type.
There are no trend categories associated with Corrective Action c.
Requests (CAR's); therefore, no trending has been performed on these documents.
3.
All trending is done manually; there is no computer printout.
Applicants will provide these documents for inspection and copying.
4.
Void; no response required.
5.
The "Fo-Information Only" stamp is used to differentiate between the original document and a copy of the same.
This is its only function.
6.
See response to Interrogatory 7.
In addition, this information was provided to CASE in Applicaats' 5/12/81 telephone conversation with CASE.
7.
Civil /Struc tural C-1:
Excavation / Backfill - nonconformances identified during backfill and/or excavation activities.
C-2:
Preplacement of Concrete - nonconformances regarding preparation for concrete placement.
C-3:
Concrete Batch Plant Operations - nonconformances regarding concrete mixing and/or testing
C-4:
Structural / Miscellaneous Steel Fabrication - nonconformances regarding site fabrication of structural and/or miscellaneous steel.
Structural steel includes such items as beams, girders, steel joists, crane rails, etc.
Miscellaneous Steel includes such items as miscellaneous steel shapes, plates and assemblies, anchor bolt sleeves, equipment mounting plates, etc.
C-5:
Structural / Miscellaneous Steel Installation - nonconformances regarding field installation of structural and/or miscellaneous steel.
Re fer to C-4.
C-6:
Cadwelding - Cadweld nonconformances.
Cadwelding is the splicing of reinforcing steel used in concrete construction.
C-7:
Welding - nonconformances regarding Civil / Structural welding not in compliance with governing documents.
C-8:
Nondestructive Examination Results unsatisfactory results of Nondestructive Examinations (NDE) on civil / structural items.
NDE includes visual, magnetic particle, liquid penetrant, radiographic and ultrasonic tests.
C-9:
Inspection / Surveillance - nonconformances regarding inspections and/or surveillance of civil activities.
C-10:
Defective Concrete - nonconformances regarding concrete attributes or properties.
C-11:
Noncompliance with Specifications / Procedures - noncomplianci with the requirements in appropriate procedures and/or specification.
C __:
(Any other C's) - None General G-1:
Shipping Damage - damage incurred in transit between the supplier and CPSES G-2:
Incomplete Documentation - all required documentation not available upon receipt of item at CPSES.
G-3:
Noncompliance with Specifications (including configuration during receiving / procedures) any noncompliance with the specification and/or procedure, including those identified at receiving.
G-4: Handling / Storage: bonconformances identified during handling of the item or storage of the item, either in the warehouse or in the field.
G-5:
Cleanliness - any item or area that is not adequately " clean" as l
required by project specifications.
. G-6:
Calibration - nonconformances regarding measuring or test equipment calibration and/or timeliness.
G-7:
Coatings / Painting - any nonconformance identified on protective coatings or protective coating activities.
G-8:
Installation Construction Damage - nonconformances regarding damage incurred during installation activities.
C-9:
Lnproper Material - nonconformances regarding the use of a material other than that specified in the applicable drawing, procedure, etc.
G-10: Storage Maintenance - nonconformances regarding items stored in warehouse not properly maintained.
G-11: Installed Maintenance - nonconformances regarding items installed in the field.
G-12: Drawing / Component Modification Card Incorrect - Errors on a drawing (other than those for component supports - refer to M-21) and/or its change notices.
Mechanical M-1:
Equipment Installation - mechanical equipment not installed per design documents and/or procedures, instructions, etc.
M-2:
Equipment Alignment - nonconformances regarding orientation of mechanical equipment M-3:
Piping Fabrication - nonconformances regarding piping fabrication not per specification or drawing.
M-4:
Piping Installation piping not installed per design documents and/or procedures, instructions, etc.
M-5: Welding - nonconformances identified during welding activities.
M-6:
Nondestructive Examination Results - unsatisfatory results of nondestructive e. xminations on mechanical piping and equipuent.
Re fer to C-8.
M-7: Heat Treatment - nonconformances regarding heat treatment of piping and components.
M-8: Hydrostatic Testing - nonconformances identifei during hydrostatic testing of piping systems.
M-9:
Equipment Malfunction mechanical equipment failure to function as specified in purchase documents.
M-10: Inspection / Surveillance - nonconformances regarding inspections and/or surveillances of mechanical activities.
l
7
. M-ll: Minimum W ll - pipe wall thickness below the minimum required by a
design documents and standards.
M-12: Violation of Holdpoints - mechanical piping and equipment inspection holdpoints by passed.
M-13: Material - incorrect material used in or for mechanical piping and equipment.
Mechanical (Component Supports)
M-14: Support Fabrication - support fabrication unsatisfactory, e.g.
incorrect dimensions.
M-15: Support Installation - support not installed per design documents and/or procedures / instructions, etc.
M-16A:
WPS Violation - Welding Procedure Specification (WPS) violated.
The WPS describes the parameters to be used during welding, such as position, bead width, weld rod material, travel speed, etc.
M-16B:
Unqualified Welder - welding performed by a person who is not currently qualified and/or certified to weld to the WPS specified.
M-17: NDE - (typographic error) - nonconformances regarding the results of nondestructive examinations performed on component sup por t s.
Refer to C-8.
M-18: Heat Treatment - nonconformances regarding the heat treatment of component supports.
M-19: Material - nonconformances regarding material used in or for component supports.
M-20: Holdpoint Violation - inspection holdpoints for component supports by passed.
M-21: Drawing / Component Modification Card Incorrect - errors on a component support drawing and/or its change notices.
M-22: Documentation Incomplete / Incorrect - documentation for component supports incomplete and/or incorrect.
The documents may be regarding purchasing, fabrication, installation, inspection, etc.
M-23: Specification Violation - a violation of the applicable component support specification.
Electrical E-1:
Equipment Installation equipment not installed per procedures, instructions, etc.
E-2:
Cable Installation - cable not installed per procedures, instructions, etc.
. E-3:
Cable Tray / Conduit Installation - cable trays and/or conduit not installed per procedures, instructions, etc.
E-4:
Cable Terminations / Connections - nonconformances regarding cable terminations and/or connections.
E-5:
Instrument Calibration - instrument not calibrated properly and/or in a timely manner.
E-6:
Inspection / Surveillance - nonconformances regarding inspections.
and/or surveillances of electrical activities.
8.
"DDR No."
(Deficiency and Disposition Report Number)
This is a sequential listing of all DDR's.
The letter preceding each number indicates the discipline in which the deficiency was noted.
"Date Issued" - This is the date the DDR was originally issued.
" Hold Tag No."
(Number) - This is the number of the particular Hold Tag associated with the DDR, if applicable.
" Reject Tag No."
(Number) - This is the number of the particular Reject Tag associated with the DDR, if applicable.
" Description of Condition" - This provides a brief statement on the subject DDR for identification purposes.
"Dispo. Cat."
(Disposition Category) - This is the category in which di' position for the particular DDR falls. See also response to Interrogatory 9.
"Dispo. Approved" (Disposition) - This is the date on which the disposition was accepted.
" Temp. Whiver Req. No."
(Temporary Whiver Request Number) - This is the number of the essociated Temporary Waiver Tag, if applicable.
" Temp. Whiver Tag No."
(Temporary Whiver Tag Number) - This is the number of the associated Temporary Waiver Tag, if applicable.
" Late Tag Rem."
(Removed) - This is the date the Temporary Whiver Tag was removed.
"Date" - This is the date the DDR was closed.
" Rep. De f. Ye s/No" (Reportable Deficiency) - This refers to whether or not this DDR was considered to be a reportable deficiency under the requirements of 10 CFR Part 50.55(e).
P. L. Bussolini, Brown & Root Project QA Manager was responsible for making this determination.
He is no longer employed on the project.
I
. 9.,_* /
Category A - Indoctrination and Training 1.
Personnel records 2.
Personnel qualifications 3.
Classroom and on-the-job training Category B - Design Control 1.
Quality standards in design document 2.
Control of deviations or changes 3.
Process and material suitability 4.
Control of design documents 5.
Design interface Category C - Instructions, Procedures, Specifications, and Drawings 1.
Documented description of activities affecting quality 2.
Compliance with documented description 3.
Inclusion of acceptance criteria in prescribed documents Category D - Document Control 1.
Release and control of documents 2.
Review and approval of documents by authorized personnel 3.
Changes controlled as original documents Category E - Material Control 1.
Conformance of purchased items and services to procurement documents.
2.
Evaluation and selection of suppliers 3.
Source inspection or audit 4.
Inspection of purchased items on receipt 5.
Documented evidence of conformance 6.
Control of handling, lifting, and rigging 7.
Control of storage 8.
Control of shipping 9.
Control of cleaning 10.
Identification, documentation, and segregation of non-conforming items 11.
Inspection of repaired or reworked items Category F - Identification Control 1.
Establishment and maintenance of item identification and control 2.
Lineage traceability of items
- /
CASE's Interrogatories included two items numbered "9".
This response is to the first of those items.
Category G - Spec.ial Process Control 1.
Establishment and maintenance of process controls (Welding, from fit up to NDE, heat treatment, painting, and coating, etc.)
2.
Qualification of personnel, procedures, and equipment Category H - Inspection, Test, and Test Equipment Control 1.
Establishment and execution of inspection program 2.
In process inspections 3.
Recognition of hold points 4.
Documentation and evaluation of inspection results 5.
Evaluation of measuring and test equipment 6.
Calibration and control of measuring and test equipment 7.
Maintenance and control of standards 8.
Evaluation of discrepant equipment and affected items 9.
Documentation and evaluation of test results 10.
Indication of inspection and test status Category 1 - Records 1.
Preparation and maintenance of quality assurance records 2.
Identification of types of records 3.
Retrievability of records 4.
Retention of records 9.
a.
Civil, Mechanical, Electrical, and Instrumentation.
b.
DDR's for all disciplines were recorded on the DDR log provided to CASE.
The majority of activities in the early stages of the project were in the Civil discipline. Accordingly, the number of DDR's issued was proportional.
Thus, " civil" was entered in the
" Discipline:
" block.
As the activities in other disciplines increased, so did the number of DDR's in these areas, requiring that the entry in the "Liscipline:
" block be expand 9.d to "All."
c.
See response to Interrogatory 9b.
d.
See response to Interrogatory 9b.
10.
76 - 5B 90 - 10 106 - 6 130 - 11 142 - SA 147 - 5A 164 - SA 199 - 5A 246 - 5A 350 - 5A 361 - 11 365 - 11
~
399 - SA 449 - 6 450 - 5B 573 - 10 666 - SA 865 - SB 1226 - 5A 1462 - SA
~
10.
Trend Categories for the remaining items are as follows:
1981 TUCCO NCR's 1982 TUCCO NCR's TREND CATEGORY 1 1680, 1702-1704, 1783 41, 85, 91, 193, 254, 379 TREND CATEGORY 2 115, 157, 198, 303 TREND CATEGORY 3 368 TREND CATEGORY 4A 1597 109, 129, 153, 167, 174, 249-251, 260-263, 432 TREND CATEGORY 4B 78, 255, 434 TREND CATEGORY 4C 1635 162, 269, 369, 409 TREND CATEGORY 5A l
66, 538, 1319, 1349, 1400, 1433, 2-5, 7, 8, 12-17, 23, 30, 1434, 1503, 1513, 1515, 1520, 32-36, 39, 45, 50-52, 1572, 1577, 1607, 1614, 1622, 1624-55-56, 58-61, 65-66, 72, 74-77, l
1630, 1638-1642, 1649, 1655, 1658, 84, 87, 90, 94, 100, 106-107, 1661, 1664, 1665, 1667, 1670, 1673, 110-111, 116-118, 124-125, 137, 1686, 1717, 1795, 1797-1801, 1805 139, 150, 154, 156, 175, 177, 181-184, 188-192, 194-196, 161, 164, 166, 169-170, 172-173, 205-206, 208, 211, 214-215, 217-218, 220-221, 224-225, 230, 232, 235-236, 241-242, 246, 253, 259, 264, 266-268, 270-276, 281-282, 284, 290-291, 293, 297, 301, 307, 313-314, 317-326, 330-331, 333-336, 340, 344-351, l
-EU-353, 356, 371, 375, 377, 380-382, 387-368, 390-391, 394-398, 401-402, 404-405, 408, 410-414, 417-418, 420-424, 427-431, 433, 435-436 TREND CATEGORY 5B 1518, 1522, 1554, 1580, 1581, 1605, 6, 9-11, 19-22, 25, 28, 29, 1609, 1631, 1632, 1634, 1643, 1644, 40, 42-44, 46, 47, 1646, 1648, 1650-1653, 1554, 1669, 53-54, 57, 62-64, 67-69, 79-1660, 1700, 1796, 1826, 1828 83, 88-89, 92-93, 97-99, 101-104, 108, 112, 119-120, 122-123, 133-136, 138, 141-145, 149, 151-152, 155, 158-160, 163, 165, 186, 197, 199-203, 207, 209, 212-213, 216, 228, 231, 233-234, 237-238, 244-245, 247-248, 252, 257-258, 265, 288-289, 300, 302, 305-306, 309-312, 315-316, 328-329, 332, 337-338, 341, 343, 354-355, 357-360, 363-367, 370, 372, 374, 378, 389, 390, 393, 399, 403, 406, 407 TREND CATEGORY SC 1454, 1517, 1525-1534, 1575, 1598, 24, 71, 294, 295, 426 1637, 1671 TREND CATEGORY 6
~
1370-1373, 1475, 1591, 1718, 1823 48 96, 105, 127, 243, 304, 327, 362, 376, 400, 437 TREND CATEGORY 7 1645, 1666, 1709 26, 37, 70, 171, 222, 296, 342, 415, 416, 419 TREND CATEGORY 9 1369 148, 168, 178, 179, 204 TREND CATEGORY 10 1360, 1396, 1399 73, 86, 131, 132, 256 TREND CATEGORY 11 1460, 1623, 1647 185, 239
. VOIDED NCR'S 1536, 1654 277, 278, 280, 283, 285, 286, 287
~
NUMBERS NOT USED 140 11.
"NCR No."
(Nonconformance Report Number) - this is a sequential listing of all NCR's.
" Nonconforming Condition" - this provides a brief discription of the subject NCR for identification purposes.
" Report & Date" - this identifies the person reporting the condition and the date the NCR number was requested.
" Trend Cat." (Category) - this is the category in which the nonconforming condition falls.
" Issued" and " Issued Date" - this is the date the NCR is issued.
" Action Addressee" - this is the person the NCR is assigned to for dispo sition.
SEE also Applicants' response to CASE's Ninth Set of Interrogatories No. 141.
" Disp. Submittal" and "Dispo Submittal" (Disposition) - this is the date the NCR disposition was accepted by Engineering.
" Disp. Approval" and "Dispo Approval" (Disposition) - this is the date the NCR was accepted By Quality Engineering.
" Verification and Closure" and Verif. & Closure" (Verification) - this is the date on which the NCR was verified and closed out.
12.,*/The NCR's trend categories are finalized on a quarterly basis
_ utilizing the NCR itself and not the log.
12.
Yes.
- /
CASE's Interrogatories included two items numbered "12".
This response is to the first of those items.
- 13.
" CAR No."
(Corrective Action Request Number) - This is a sequential listing of all CAR's.
" Condition Description" - This provides a brief statement on the subject CAR for identification purposes.
" Referred To" - This is the person who has been assigned responsibility for responding to the CAR.
"Date" - This is the date the CAR was originally issued.
" Reply Requested Data" - This is the date that the CAR reponse is due to Quality Assurance.
" Reply Received Date" - This is the date that the CAR response is received by Quality Assurance.
" Accepted PQAM/Date" - (Project Quality Assurance Manager) This is the date that the response was accepted by Quality Assurance.
"QA File No."
(Quality Assurance File Number) - This is a reference to the file where the subject CAR is maintained.
" Reply Accepted Date" - This column replaced the " Accepted PQAM/Date" column on the CAR log.
This indicates the date the response is accepted by Quality Assurance.
"Verif/C0 Date" (Verify Close Out) - This column replaced the "QA File No." column.
This indicates the date that the response to the CAR was verified and closed out.
14.
No trending is performed on Brown & Root Corrective Action Requests.
15.
As stated in our February 8,1982, response to CASE's Sixth Set of Requests for Production of Documents, TUGC0 QA Divsion has begun to issue CAR's.
At that time, CASE was provided with a copy of the Brown
& Root CAR Log and the TUGC0 QA CAR Log.
CAR's 001-005 were items on the TUCCO QA CAR Log and are not a part of the Brown & Root CAR Log.
There were no Brown & Root CAR's issued in 1981.
16.
See reaponse to Interrogatory 15.
17.
No.
18.
Not applicable.
19.
"DR No." (Deficiency Report Number) - this is a sequential listing of all DR's.
" Description of Condition" - this provides a brief statement on the subject DR for identification purposes.
"De ficiency Trend Cat." (Deficiency Trend Category) - this is the category in which the particular DR falls.
" CAR Req'd Yes/No" (Corrective Action Request Required, Yes/No) - if a CAR was issued a Yes was inserted; if not, a No was inserted.
i
" Reportable Yes/No" - this refers to whether or not this DR was considered to be a reportable deficiency under the requirements of 10CFR50.55(e).
" Issued" - date when the deficiency report was issued.
" Resolution Assignment" - identifies what individual the deficiency was sent to for resolution / disposition.
" Resolution Due" - the date when the disposition is due.
" Resolution Submittal" - the actual date when the disposition was submitted to Quality Engineering.
" Resolution Approval" - the date when the disposition was approved by Quality Engineering.
" Verification / Closure" - the date when the disposition was verified and the deficiency closed.
20.
Deficiency Reports were categorized utilizing the associated 10 CFR Part 50, Appendix B criteria as follows:
I - Organization II - Quality Assurance Program III - Design Control IV - Procurement Document Control V - Instructions, Procedures, and Drawings VI - Document Control VII - Control of Purchased Material, Equipment, and Services VIII - Identification and Control of Materials, Parts, and Components IX - Control of Special Processes X - Inspection XI - Test Control XII - Control of Measuring and Test Equipment XIII - Handling, Storage, and Shipping XIV - Inspection, Test, and, Operating Status XV - Nonconforming Materials, Parts, or Components XVI - Corrective Action XVII - Quality Assurance Records XVIII - Audits 21.
Trending was done to ascertain whether or not corrective action for a given function / activity was warranted.
This was done by reviewing deficiencies and nonconformances to preclude repetition of significant conditions adverse to quality.
Trending of deficiencies was performed and reported on a conthly basis by Quality Engineering personnel.
The trending was performed manually utilizing both the DR Log and the DR's.
22.
Applicants will provide these documents for inspection and c'opying.
23.
Void, no response required.
24.
CASE has already been provided these documents for inspection and copying, pursuant to CASE's Tenth Set of Interrogatories to Applicants.
25.
Yes.
26.
a.
TUGC0 has performed trending on Field Deficiency Reports (FDR's) and Component Modification Cards (CMC's).
See Applicant's reponse to Interrogatory 93.
TUGC0 has prepared Pipe Weld Trend Reports.
This trending was a management tool used to provide meaningful data on the quality of safety-related welds.
b.
The requested information on FDR's and CMC's is contained in the documents being provided in response to Interrogatory 3.
Applicants will provide the additional documents subject to this request for inspection and copying.
27.
Applicants will provide these documents for inspection and copying.
28.
Applicants will provide these douements for inspection and copying.
29.
16.1 is the designation given to the vault file in which CAR's are contained.
30.
DDR's Prior to April 1,1977, all nonconformances and deficiencies were documented on the Deficiency and Disposition Report.
Each DDR was then entered on the DDR Log.
The purpone of the DDR Log is to serve as an administrative aid and as a quick reference fo general information.
Brown & Root NCR's and DR's Starting April 1,1977, nonconformances were documented on the NCR and deficiencies were documented on the DR.
The following can be used as guidance for distinguivcing between nonconformances and deficiencies:
Nonconformance - a defic'iency in characteristic, documentation, or l
procedure which renders the quality of an item unacceptable or indeterminate.
Deficiency - a product condition which departs from applicable project procedures / instructions and can be resolved with an existing standard repair procedure 0]( a project procedural violation not directly associated with an item.
Brown & Root NCR's are included on the Brown & Root NCR log.
Brown &
Root Deficiency Reports are included on the Brown & Root DR Log.
The purpose of these logs is to serve as an administrative aid and as a quick reference for general information.
NCR's are still being used; however, the use of DR's was discontinued in 1978.
FDR'S In 1978 the Field Deficiency Report was initiated.
Accordingly, the FDR's were entered on the FLR Log.
The purpose of the log is to serve as an administrative aid and as a quick reference for general in fo rmation.
TUCCO NCR's In July of 1980, the NCR program was changed to its present structure.
Nonconformances of ASME activities are documented on Brown & Root NCR's, while nonconformances of non-ASME activities are documented on TUCCO NCR's.
The Brown & Root and TUCCO NCR's are entered on their respective log as an administrative aid and as a quick reference for general information.
CAR' s Corrective Action Requests are issued as deemed necessary by the QA Management.
Refer to Applicants' answer 76 for' further details.
if one or more NCR's are judged to be indicative of a significant problem that warrants formalized corrective action, a CAR may be issued.
The Corrective Action Requests are entered,on a CAR log.
The purpose of this log is as an administrative aid and as a quicks referenceffor m
general information.
SUMMARY
~
~
There is no relationship be' tween the reports and logs excepttas described above, and there are no steps involved in going from_ report to report.
See also, response to Interrogotories 31-48.
31-48.
Applicants discussed their responses to these Interrogatories ~ (and portions of Interrogatory 30) with CASE,od May 13, 1982,'during a visit by CASE to the site tc inspect doc #ments.
On phy 14, 1982, Applicants provided CASE with a summary of these responses as requested by CASE.
CASE signed that summary with the uhderdtanding 2
that Applicants thereby satisfied CASE's # requests for information set forth in these Interrcgatories.
49.
Reactor Building Rock Overbreck -
e See documents being provided in response to Interrogatory 104.
Inspection & Enforcement"(I&E) Reports 75-09, 76-03, and 76-05
/
Cold joint in Reactor Building Base Mat -
I&E Reports 75-10 and 75-12
~
Containment #1 Base Hat Cohetete Coring -
DDR-C-224 I&E Reports 76-04, 76-05, and 76-10 e
- N 4
Safe Shutdown Impoundment Dam Filler Material -
I&E Reports 76-10 and 77-01 Design Deficiencies in Fuel Building Crane Systems -
I&E Reports 78-04 and 78-05 Overtravel on AR Relay -
I&E Report 77-10 I&E Bulletins 77-02 and 77-03 Operation of Safeguard Actuation Block / Reset Circuitry -
I&E Bulletins 77-02 and 77-03 s
Unit #1 Polar Crane Support Brackets -
I&E Reports 77-06 cnd 77-08 Pipe Wall Thickness may not meet ASME Code Stress Requirements -
I&E Reports 81-09, 79-13 NCR-M-857 NCR-M-915 NCR-M-935 NCR-M-859 NCR-M-916 NCR-M-943 NCR-M-862 NCR-M-919 NCR-M-947 NCR-M-868 NCR-M-920 NCR-M-951 NCR-M-890 NCR-M-921 NCR-M-953 NCR-M-897 NCR-M-923 NCR-M-1055 NCR-M-900 NCR-M-924 NCR-M-1134 NCR-M-901 NCR-M-926 NCR-M-1187 NCR-M-908 NCR-M-929 NCR-M-1249 NCR-M-910 NCR-M-930 NCR-M-1398 DCa-1360 DCA-9457 DCA-1593 DCA-2109 DCA-1559 DCA-1521 s
D A-5551 DCA-1560 Cable, Tray Hangers without full Penetration Welds as required -
I&E Reports 79-16 and 79-27/26 DCA-5671 DCA-5675 DCA-5679 DCA-5672 DCA-5676 DCA-5680 DCA-5673 DCA-5677 DCA-5683 DCA-5674 DCA-5678 Installation of Drilled In Expansion Anchors -
CMC-48'327 CMC-34145 CMC-30292 CMC-50582 r
CMC-43927 Installation & inspection of welded Conduit Supports -
- D Claza V Pipe Supports -
I&E Report 79-27/26, 81-11 DCA-7955 NCR-1933 CMC-30749 CMC-5404 DCA-7952 NCR-1934 CMC-6537 CMC-2040 DCA-5021 NCR-1935 CMC-6163 CMC-12378 IE Bulletin 79-14 Concrete Honeycomb in Unit #2 Steam Generator Compartment Walls -
I&E Reports 01, 80-08, 80-11
' NCR-C-1824 NCR-C-1784 NCR-C-1766 NCR-C-1791 i
Discs for Service Water Control Valves -
NCR-2069 I&E Reports 80-03 and 80-08 Welded Connections of Control Boards I&E Reports 80-01 DCA-3150 NCR-2087 DCA-7394 Two Inch Architectural Concrete in Floor Slabs -
NCR-81-01667 I&E Report 80-18, 81-18 Diesel Generator Pipe Supports I&E Report 81-09 Hilti Kwik Bolt Installation I&E Report 81-18 NCR-81-00001 NCR-81-01223 NCR-81-00232 NCR-80-00126 NCR-81-00555 NCR-81-00371 NCR-81-00079 NCR-81-00126 NCR _81-00030 NCR-81-00108 NCR-81-00033 NCR-81-00008 NCR-81-00086 CMC-00293 FDR-7051 FDR-7052 FDR-7053 FDR-7054 Westinghouse Cate Valves NCR-M-2679 I&E Report 81-18 I&E Bulletin 81-02 Bahnson HVAC Anchor Bolts I&E Report 81-09 NCR-M-81-00093 HVAC Cooling System I&E Report 81-09 Seismic Design Criteria for Instrumentation Supports developed for CBE not SSE I&E Report 82-01 NCR-I-81-00241 CMC-57415, CMC-47643, CMC-47645, CMC-47647, CMC-57411, CMC-47601, CMC-47644, CMC-47646, CMC-57410, CMC-57413, CMC-57475, CMC-57481, CMC-57487, CMC-47629, CMC-47643, CMC-57411 Orifice Plates supplied by BIF are outside ISA standard RF3.2 tolerances -
DCA-11515 DCA-6152 I
DECP-1863 Borg W rner Valves may not close properly if installed between 22-1/20 a
and 157-1/20 of vertical NCR-M-30835 NCR-3155 50.
Inspection & Enforcement Reports are a matter of public record.
Copies are contained in the Public Document Room.
Applicants will provide the remaining documents for inspection and copying.
51.
Applicants will provide these documents for inspection and copying upon specific request, after CASE's review of the documents provided in response to Interrogatory 50.
52.
a.
The as-built program development is in progress.
b.
The as-built program h
- been partially implemented.
c.
Ye s.
d.
Verification of the as-built program will be done consistent with work progress.
e.
Yes, to the degree described above.
f.
Not applicable.
g.
These documents will be provided for inspection and copying.
h.
These documents will be provided for inspection and copying.
These drawings have already been incorporated into the as-built program.
53.
Applicants will provide these documents for inspection and copying.
(
l l
54.
There are no " form letters" used during dispositioning of NCR's.
Each letter is generated and issued on an as-need basis.
55.
The initials are GFB - George F. Bentinck 56.
Applicants will provide these documents for inspection and copying.
The first form was initiated July 14, 1975, and revised September 8, 1978, and February 1,1980.
57.
This information is contained in CP-QAP-17.1 (Brown & Root QA Procedures Manual) and CQP-CS-7 (Corporate Quality Procedures / Instructions Manual).
58.
Applicants will provide the Brown & Root documents for inspection and copying.
A copy of procedure CQP-CS-7 (Corporate Quality Procedures / Instructions Manual) which defines the use of CAR's initiated by TUGC0 QA, Dallas, has already been provided to CASE in our response to CASE's Sixth Set of Requests for Production of Documents.
59.
See Attachment 1 for a listing of all current QC Inspectors at CPSES, their disciplines and dates of hire.
In addition, the names and dates of employment and termination for all past Brown & Root QC Inspectors are contained on a computer printout list being made available for inspection and copying.
Past QC Inspectors not employed by Brown &
Root are listed in Attachment 1.
60.
Applicants will provide these documents for inspection and copying.
61.
This process is defined in procedures CP-QP-16.1 (TUGC0 " Quality Procedures Manual") and CQP-CS-6 (Corporate Quality Procedures /
Instructions Manual"), copies of which have previously been made available to CASE for inspection and copying.
62.
The basic process for reporting items under 10 CFR 50.55(e) has remained relatively constant.
Initially, the person identifying a nonconformance was responsible for completing the appropriate box on j
the NCR form, subject to review by Brown & Root and TUGC0 QA t
management.
Af ter these reviews, if necessary, a report was made to the NRC.
In September,1978, the Brown & Root NCR form was revised, l
deleting the requirement that the initiator of the NCR make any l
documented determination for reportability.
Concurrently, TUGC0 QA procedure CP-QP-16.1 was issued which more specifically defined the reporting requirements.
TUGC0 QA management continued to review NCR's l
to determine the need for reporting under the criteria set forth in 10 CFR 50.55(e).
In April,1980, Applicants met with the NRC Region IV office to
[
discuss the reporting requirements for 10 CFR 50.55(e).
The NRC indicated that they not only wanted to be informed of items that had been determined to be formally reportable but wanted to be apprisea of "potentially" reportable items "also.
Accordingly, TUGC0 QA management began reporting items prior to the final determination of i
reportability.
l t
63.
Var.ious organizations, all of which report to TUGC0 QA.
64.
CQP-CS-8 (Corporate Quality Procedures / Instructions Manual) requires the use of a "QA Significant Deficiencies Log."
The reportability determination for each Significant Deficiency is recorded on this log.
65.
Applicants will provide this document for inspection and copying.
66.
a.
Brown & Root Procedure CP-QAP-l'.1, Rev. O o
b.
Applicants will provide these documents for inspection and copying.
c.
Yes.
67.
No.
68.
Not applicable.
69.
No.
70.
No, af ter Oc tober,1981, the Temporary Waiver Request (TWR) form was discontinued.
71.
TUGC0 maintains the handwritten copies of their NCR's; however, Brown
& Root does not.
72.
Applicants will provide these documents for inspection and copying.
73.
No.
74.
Not applicable.
75.
a-e. These referenced headings are input data fields used only by records management personnel for record-keeping indexing purposes.
These fields have no quality significance except for the " status" field which is the NCR issuance number.
The fields in question were filled in by the NCR Coordinator so that input into the computerized record indexing system could be performed directly from the individual document.
f.
This information is contained on the back of the Brown & Root NCR form itself, a copy of which was provided to CASE on April 22, 1982.
E.
1.
Block 7, J. P. Clarke, Brown & Root, see "f" above 2.
Block 14, G. McGee, Brown & Root, see " f" above 3.
Block 16, Ron Michels, TUGCO, see "f" above
~
4.
Block 20, D. Fellinger, Gibbs & Hill, see "f" above 5.
Block 25, Melvin R. Todd, Brown & Root, see "f" above h.
N/A stands for Not applicable.
Signature was not required because condition identified on NCR was not applicable to their area of responsibility.
See response to Interrogatory 75f.
l 1.
The referenced stamp is used to indiccte that the document has been reviewed by Brown & Root QA.
In ti e case of NCR this review is performed by NCR Coordinator prior to it, transnittal to the Records Vault.
The blocks have the following meaning:
1.
RTN - Retention time of document, "L"
stands for life time retention.
2.
QA Review - Date and initials of individual performing review.
3.
File No. - Location of file in vault 4.
Subfile No. - Subfile location in the vault which is the same-as the NCR number J.
Item 7.
k.
Yes.
1.
As stated in response to 75 a-e above, the system for indexing information onto the computer has changed.
The NCR form was revised to reflect this change.
See response to Interrogatory 75.f.
m.
n.
The person whose signature appears in Item 25.
76.
Corrective Action Requests are issued for the purpose of providing corrective action to preclude repetition of significant conditions adverse to quality.
In many cases, corrective action is an on going activity and is taken when nonconformances/ deficiencies are identified, thus eliminating the need to formalize a CAR.
The decision to obtain formal corrective action is made at the discretion of QA Management.
77.
Applicants provided their response to this Interrogatory with their responses to Interrogatories 31-48.
78.
Debra L. Anderson - Quality Assurance Auditor (Coordinator, Vendor Evaluation / Audits)
Bailey F. Campbell - Quality Assurance Auditor Roland F. Cote' - Senior Quality Assurance Auditor Steve Davis - Associate Auditor Al' An Kesler - Associate Auditor Larry Rillera - Senior Quality Assurance Auditor Robert H. Shoemake - Quality Assurance Auditor Susan L. Spencer - Quality Assurance Auditor Lisa M. Bielfeldt - Special Projects Engineer John Maxwell - Sr. Technician Jim Smith - Sr. Technician Leonard A. Lamb - Technician Cecil Manning - Senior QA Technician Rick Hoelscher - Associate Engineer Antonio Vega - Supervisor, Quality Assurance Services Tony Valdez - Senior Engineer Debara Paris - Engineer Albert Boren - Supervisor, Vendor Compliance
e Wayne Parry - Ssnior QA Tachnicien David Deviney - Operations Quality Assurance Supervisor Richard Curtis - Sr. Technician Charles Killough - Sr. Technician John Echterhoff - Associate Technician Alan Lancaster - Sr. Technician The Manager, Quality Assurance has delegated to the Supervisor, Quality Assurance Services responsibility for implementing the audit program.
79.
The National Board of Boiler and Pressure Vessel Inspectors have performed two audits of CPSES activities.
These audits were performed on April 4, 5, and 6, 1979, and May 22 and 23, 1979.
00.
Applicants will provide these documents for inspection and copying.
81.
Although these documents did not fall specifically within the scope of CASE's interrogatories, Applicants provided them for inspection and copying in response to CASE's First Set of Interrogatories and Requests to Produce.
CASE reviewed these documents on October 2, 1980.
82.
The audits referenced in our response to Question 53 in CASE's Ninth Set of Interrogatories and Requests to Produce are the same audits being provided in response to 80.
83.
Yes.
84.
Not applicable.
85.
Applicants will provide these documents for inspection and copying.
86.
Yes.
87.
Applicants will provide these documents for inspection and copying.
88.
1975 W-001-75 C-001-75 through C-067-75 G-001A-75 G-001-75 through G-008-75 1976 i
l C-068-76 through C-133-76 M-001-76 through M-004-76 G-009-76 through C-029-76 1977 C-134-77,through C-162-77 E-001-77 through E-008-77 M-005-77 through M-015-77
- N3 -
r G-030-77 through G-052-77 G-054-77 through G-063-77 1978 P-001-78 P-002-78 W-002-78 W-003-78 C-163-78 through C-180-78 E-009-78 through E-010-78 M-016-78 through M-025-78 G-064-78 through G-100-78 89.
As stated in Applicants' response to Interrogatory 128 of CASE's Ninth Set of Interrogatories, Applicants will supply these documents for inepection and copying.
90.
No.
91.
Final determination for reportability under 10 CFR 50.55(e) was made by R. G. Tolson, TUGC0 Site QA Supervisor for the following NCR's.
NCR-669 NCR-906 NCR-831 NCR-907 NCR-899 Final determination for reportability for the following NCR's was made by D. N. Chapman, TUGC0 Manager, Quality Assurance.
NCR-704 NCR-810 NCR-722 NCR-811 NCR-806 NCR-815 NCR-833 NCR-809 NCR-894 92.
D. N. Chapman, TUCCO Manager, Quality Assurance.
93, n.
" Report Number" - this is a sequential listing of all FDR's.
" Deficiency Description" - this provides a brief description of the subject deficiencies for identification purposes.
"Date issued" - this indicates the date the FDR was issued.
I "Date Closed" - this indicates the date the FDR was closed.
" Comments" - this contains any comments regarding the subject FDR.
b.
SEE reponse to Interrogatory 30.
c.
SEE reponse to Interrogatories 25 and 26.
l l
- 24 1 94.
Prior to July 10, 1980, ell NCR's were documented in end tracked by the Brown & Root NCR System.
95.
Copies of the Brown & Root NCR logs have previously been provided to CASE.
96.
a.
A. Vega, TUGCO, Supervisor, Quality Assurance Services b.
6186 Campfire Columbia, Maryland 21045 (301) 730-6663 c.
As stated in Applicants' response to CASE's Ninth Set of Interrogatories, Mr. Lobbin was retained to evaluate the TUCCO QA Program.
The results of his evaluation are contained in his report, and we consider them to be self explanatory.
Wb see no reason, therefore, to question Mr. Lobbin at this time.97-100.
Applicants are unable to identify at this time persons who are knowledgeable in all aspects of the general categories of construction activities listed in Interrogatory 97.
Each of these categories encompasses many areas of expertise.
The particular areas of expertise in which CASE is interested are not clear from the Interrogatory.
Accordingly, Applicants are willing to discuss with CASE providing additional information in response to these Interrogatories upon further specification of the Interrogatories by CASE.
101-105.
Applicants believe these interrogatories are irrevelant to Contention 5 in that they concern matters that were the subject of CFUR's Contention 7, which has been dismissed from this pro-ceeding.
Nonetheless, Applicants will provide for inspection and copying all documents provided to CFUR in response to its discovery requests on Contention 7.
In addition, Applicants direct CASE to Applicants' Motion for Sinnmary Disposition regarding Contention 7, filed in January, 1982.
That motion contains additional information regarding rock overbreak.
Finally, as Applicants indicted in their May 12, 1982, conference call with CASE, if CASE still has questions on this matter it should contact Applicants.
106.
a.
(1) The horizontal dimensions of the shrinkage cracks were not recorded.
However, the nonconformance report cited by CASE, as well as the June 3,1977, memo contained in the NCR, reflect these horizontal dimensions.
(2) Applicants will provide this document for inspection and copying.
b.
No.
c.
Not applicable.
d.
(1) As evidenced on the subject NCR, Brown & Root QA did not consider the matter reportable under 10 CFR 50.55(e) (i.e. the "No" block in Saction 12 of tha Nonconformance Report was checked).
Mr. R. G. Tolson, TUGC0 Site QA Supervisor, concurred with this conclusion and, therefore, no further regulatory action was required or taken.
(2) Shrinkage cracks in concrete are not considered significant and do not meet criteria for reporting under 10 CFR 50.55(e).
4 (3) No.
(4) 2001 Bryan Tower, Dallas, TX 75201.
~
e.
All documents regarding this matter are contained and/or referenced in NCR-C-650, a copy of which has been provided to CASE.
Documents which are referenced but not contained in the NCR will be provided for inspection and copying.
107.
Applicants will provide this document for inspection and copying.
DC/DDA 1560 had been used as a means to disposition and close out 108.
a.
NCR's concerning minimum wall thickness violations.
When DC/DDA 1560 was determined to be in error, it was necessary to reopen the NCR's to assure their proper disposition.
b.
The original basis for DC/DDA 1560 being used to disposition NCR's was the ability of the piping system to maintain pressure integrity under the design temperature and pressure conditions in accordance with ASME Section III.
c.
DC/DDA 1560 was rescinded because it did not consider worst case stress levels to which the piping system could be subjected.
d.
No specific individual made the decision to rescind DC/DDA 1560.
When it was determined to be in error, project procedures required corrective action to be taken.
Mr. Mark W. Smith, Mechanical Engr. TUSI, prepared the necessary paper-work.
e.
No additional NCR's are currently being re-opened.
f.
Applicants have already provided a copy of this document to CASE.
109.
Applicants will provide a copy of this document to CASE.
Respectfully submitted, William A. Horin Debevoise & Liberman 1200 Seventeenth Street, N.W.
W'shington, D. C.
20036 a
(202) 857-9800 May 17, 1982 Counsel for Applicants 9
r Pags 1 of 6 ATTACll:ENT I Brown &,Roo_t Insp,ec_ tors at Comanche Peak P.adiography Date of flire Roger talters 1-03-78 Fo;.ae liarper 2-12-79 Jene Radcliffe 5-22-79 Frederick Baker 10-6-81 Jef frey Bevan 5-12-81 La rry Bungardner 12-20-81
'like Dennan 4-4-82 John Cleveland 11-8-81
!!ary Gilbreath 7-6-81 Je ff Ivie 4-20-82 Curt Grunwald 4-7-81 David Lotterhos 10-28-81 Johnny Lunsford 12-20-81 Paul ?lcDowe11 7-16-80 Janes Parker 12-11-79 Randal Pendergrass 3-16-81 Clayton Johndrow 4-25-82 Pipe 11elding x
Donny Doyle 7-23-79 Richard Allstron 6-14-79 Phil Atkins 11-27-78 Allen Adkins 9-14-81 Johnny Blanscet 9-28-81 John Butler 9-17-79 John Caldwell 3-21-82 Robert 11. Darby 2-5-80 Greg Fanning
\\
8-29-78 Janes T. Goode
\\
7-3-79 Charles Swindell 1-8-79 Raul 11ernandez 5-1-78 Rus Ililton 10-22-79
!!elinda lloider 78 Jin !!athis 12-19-77 Anthony Patterson 1-29-79 Charlie Saengerhausen 3-21-82 Doug Snow 11-13-78 Duight tJoodyard 3-1-82 Andrew Canznann 1-16-76 Sid tiaynick 9-8-75 Richard liasegawa 2-12-79 Lee !!cDowell 10-29-80 llarlow Itall 5-11-82
Page 2 of 6 Conpletions/Startup Creg Bennetzen 6-6-77 Jack llenline 11-28-77 Ton Ellis 12-7-81 Brian Coffin 5-12-81 Terry !!atheny 5-12-80 Richard Sprouse 7-23-79 Jon Rogers 1-25-82 Scott Wagner 3-22-82 Jin Shaver 1-8-79 Janes E. Lloyd, Jr.
5-10-82 Conponent Supports Billy Snellgrove 2-12-79 Bobby Bronson 3-17-82 Robert Creen 1-24-82 11arry Johnson 8-20-79 Ramesh Lahoti 12-16-82 Uayne !!ansfield 10-15-81 Je ff !!cConnas 1-4-80 Barry NcNellie 5-28-80 Ted Neely 3-14-82 Donald Nisich 2-1-82 John Reed 1-8-80 Willian T. Sins 11-5-76 Richard Smith 3-15-82 Cary Vaughan 9-23-80 Robert Walston 10-13-80 Larry Wilkerson 12-7-81 Rex Ondracek 4-12-82 Thonas Colenan 5-4-82 Sanny Bell 3-5-79 Janes Cole 5-29-79 Uillian Canpbell 4-19-82 Richard lieuer 4-6-82
!!cchanical Equipment Richard Ice 2-14-77 U.
D. Bishop 3-21-82 John Frazier 7-24-78 flike Ivey 11-10-81 Earl Lindberg 2-9-82 D. H. !!acDonald 1-31-82 Carland Osborne 7-12-76 fielvin Todd 2-17-76 Ben Conner 5-10-82
r Pxg2 3 of 6
'teceiving QC John !!orton 10-18-76 Kenneth Cox 12-13-81 llenry Dickson 3-21-82 Donna Dyer 7-10-78 Docunentation Bact. log Ray Eckert 4-8-82 Dusty Earley 11-23-81 Uillian Been 4-26-82 Willian Darby 1-22-81 Ralph Darby 1-6-82 QC Startup Robert L. Adans 5-26-81 Ilarold Glover 4-3-78 Thomas Jensen 7-27-81 Billy R. !!orrow 4-25-82 Tinothy Sawa tsky 4-25-82 Electrical QC Stan Vore 9-18-79 Randall McCaughy 10-9-78 Randy C. lhitnan 1-28-77 Jerry Beck 7-17-78 Sherry Burns 11-22-81 Arnando Canacho 12-7-81 David Dial 3-28-82 Ezequiel Flores 12-7-81 I!illian Ford 12-7-81 Janes W. Griffith 2-1-82 Sheree liarding 11-14-78 Michael W. ilolland 9-21-81 Billy lloines 11-15-81,
Shirley Starr 4-25-82 Janes !!cCann 2-6-80 Debra tabe 5-28-80 John O'Grady 6-18-79 Dewey Oliver 7-17-78 Jerry Osborne 3-28-82 Richard P1 inner 1-11-82 Patsy Rabon 11-16-81 Eddie Snyder 4-4-82 Lesie Taggart 7-17-78 Jack Vance 11-16-81 llector Villarreal 11-16-81 Wayne 1.hitehead 11-16-81 Uarner Uiags (Robert) 7-1-80 Eddie Dantzler 10-9-79
Page 4 of 6 Civil OC 7 a A. Scoggins 7-17-78
!! ark Tatarko 5-1-78 Uillian J. Reynolds 7-17-78 Jo Ann Anundson 4-11-82 Phyllis !!ay 10-9-80 Paula Robinson 4-11-82 Andrew Roach 1-3-82 Rix ?!cClenny 9-15-81 Bryan Belew 4-14-82 Robert Gutierrez 7-27-78 David Osborne (Charles) 7-17-79 John L. Roberts 3-26-82 David Wood (Benny) 1-14-80 Cecelia Pa:me 2-21-82 Protective Coatings Uillian Avery 12-7-81 Fred Dunham 4-13-82 Shelia Brown 3-21-82
!! ark Dendy 3-29-82 ilouston Gunn 10-10-77 Timothy Wilcoxson 3-24-82 Joseph Fazi 2-18-77 Wil1 inn Dunhan 11-18-81 Plechanical - Conduit Supports tiike Warner 3-14-77
!!ike Uptnore 6-18-79 Dan Chandler 5-2-77 Tony Chandler 6-26-81 Ken Conser 5-28-81 David Gray 7-30-79 Ray llughes 10-19-81 Uillian Jones (Oren) 8-17-81
!!arian Kiernan 6-4-81 John Long 11-17-80 Richard ttoreland 3-29-82 Robert Ray Posey 3-9-82 Scott Pa tterson 12-1-81 I
Le slie Sanchez 12-1-82 Doug Winberley Il-9-81 Instrunentation Curtis Biggs 7-17-81 Bobby L. Berry 7-17-78 Billy B. Cecil 6-18-79 John Criffith 10-28-81 Tinothy Jackson 1-20-82 Ki Anthony !!arley 11-15-81
r Paga 5 of 6
!! arcus Palner 9-24-80 Valinda Sain 7-2-80 Ceannette Sweat 12-29-79
!!echanical (Non-AS!!E)
Randall D.
Snith 6-13-80
!!ikal S. Young -
10-22-79 La rry G. liite
'10-23-79 Villian Iattness-12-6-81 Da rlene Stiner 8-1-80 David Stinson 11-1-81 Eddie Tatun 10-13-81 Kirby Scott 4-13-81 9
Page 6 of 6 p inspectors UNITED ENSITEERS John Divetru Mechanical
~2/8/S2 to present John Igneszewski Mechanical 2/8/82 to 3/17/82 Charles Wolf Mechanical 2/8/82 to present Tim Barber Electrical
' 2/8/82 to present Tcn Jackson Electrical 2/8/82 to present Dave Brown Mechanical 1/12/82 to present l
l TUGC0 Yerr.on Mahan Electrical 12/17/79 to present NFS i
Chi Van Cao.
Civil 3/29/82 to present EBASCO C. Randall Nechanical 11/13/82 to 4/i6/fi2 R. Shields NDE 5/7/82 to present C, T. Brandt Mech / Civil / Inst-9/9/80 to present T. D. Schmidt Mechanical 8/27/80 to 5/7/81 l
N. E. Foote Mechanical / Civil I/5/82 to present C. Reeves Mechanical 3/29/82 to present-L. Stolliker Mechanical I/10/82 to present E. Yando Civil 3/31/82 to present T. Finn Civil 1/29/82 to present L. Gleason Civil 4/5/82 to present R. Wallace Civil 1/27/82 to present R. Perry NDE 3/8/82 to present D. Bradley Mechanical 4/5/82 to present D. Hanke Mechanical 12/14/81 to present l
11/30/82 to present M. Elliott Civil.
5/3/82 to present W. Lawrence Mechar,ical-A.' Scart Electrical 4/30/82 to present M. Kenne#
Mechanical 4/16/82 to present C. Scvvggs MDE 5/7/82 tn present E. Stout IKIE 5/7/82 to present L. Tessier NDE 5/7/82 to present D. Cux RDE 5/7/82 to present Y. Pk:Dermott NDE 5/7/82 to present E. Ferris KDE 5/7/82 to present 5
,-------r-
STATE OF TEXAS
)
)
COUNTY OF SOMERVELL)
John S. Marshall, being duly sworn deposes and says:
That he is Licensing Supervisor, Texas Utilities Services, Inc.
and knows the contents of the foregcir.g Applicants' Answers to CASE's Eleventh Set of Interrogatories; that the same is true of his own knowledge except as to matters herein stated on information and belief, and as to that he believes them to be true.
eL '#/ M
(
John S. MarshaT1
{
Subscribed and sworn to before me this 17th day of May 1982.
l l
i&
A40%frQ o 9,.3 o f g )
l l
i 1
I l
r UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 1;
r.> $
t In the Matter of
)
)
L TEXAS UTILITIES GENERATING
)
Docket Nos. 50-445 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' Answers to CASE's Eleventh Set of Interrogatories," in the above-captioned matter were served upon the following persons by deposit in the United States mail, first class postage prepaid this 17th day of May, 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 Commission Washington, D.C.
20555
r
.
- Mrs. Juanita Ellis Mr. Scott W. Stucky President, CASE Docketing & Service Branch 1426 South Polk Street U. S. Nuclear Regulatory Dallas, Texas 75224 Commission Washington, D.C.
20005
%W William A. Horin ec: Homer C. Schmidt Spencer C. Relyea, Esq.
- Copy to be provided to CASE by hand May 17, 1982 in addition to the f
copy served by first class mail.