ML20082R592

Response Forwarding Chart of Show & Tell Trip to Facility. Certificate of Svc Encl.W/O Chart

ML20082R592
Person / Time
Site:	Comanche Peak
Issue date:	12/05/1983
From:	Ellis J Citizens Association for Sound Energy
To:
References
NUDOCS 8312130228
Download: ML20082R592 (6)

Text

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DOLKET,E12/5/83 UNITED STATES OF AMERICA N NUCLEAR REGULATORY COMMISSION BEFORE THE AIOMIC SAFETY AND LICENSIN Bf$d2 P2:55 In the Matter of [;'[,.NdIg[

g BRANCH

APPLICATION OF TEXAS UTILITIES g Docket Nos. 50-445 4

GENERATING COMPANY, t'T AL. FOR and 50-446 AN OPERATING LICENSE FOR I COMANCilE PEAK STEAM ELECTRIC I ""

STATION UNITS #1 AND #2 I (CPSES) -

CASE'S RESPONSE TO BOARD'S REQUEST FOR CHART OF "Sil0W-AND-TELL" TRIP TO COMANEllE PEAK 1

On December 1,1983, Board Chairman Bloch telephoned CASE and requested that CASE supply the Board with a chart giving general locations CASE witnesses propose to take the Board to at Comanche Peak on the proposed trip to identify specific deficiencies at the plant (referred to herein as the "show-and-tell" trip), as well as hos much time would be required to complete the necessary reviews of the items in question, and an identification as te which of CASE's witnesses would be available to qo in what ti,ae frames.

! Attached is CASE's response to the Board, s request. The times required j include both identification and actual viewing of the items'in question, as well as follow-up tracing of paperwork regarding the items; in addition, we have noted the type of equipment which would need to be supplied to do the ,

tests ' required.

All of CASE's witnesses have indicated that, as far as they know at this time (and this would only change should any of the individuals presently un-employed find jobs in the meantime), they would be able to be present during 8312130228 831205 PDR 0 ADOCK 05000445 PDR g.

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the time frame presently under consideration by the Board, around the last ,

t of January or first of February or slightly later.  ;

As indicated previeusly, most of CASE's witnesses do not wish to identify in any great detail the specific deficiencies or their locations, because they ,

are convinced that if they do so, the problems will be covered-up or removed ,

by the time the Board makes its site visit, thereby rendering such a visit useless and prejudicial in favor of the Applicants. The affidavits attached to CASE's 11/28/83 Answer to Board's 10/25/83 Memorandum (Procedure Concerning Quality Assurance) gave as much specificity as our witnesses were comfortable in supplying. However, in response to the Board's request, we have contacted them again (with the exception of a few whom we have not been able to contact by phone, and whom we have sent requests by mail), and they have supplied somewhat greater detail which is t eflected on the attached chart. (In the instance of the individuals whom we have not been able to re-contact at this

- time, we have estimated the amount of time and general locations based on our previous conversations with them; we will advise the Board immediately should their estimates differ substantively f.em ours.)

It should be noted that CASE, as discussed previously,'has some misgivings

, about taking the Board to the site under the conditions the Board has set forth.

t g Further, had +.he NRC allowed Bob Messerly and J. R. Dillingham to take the NRC to the plant and show them the specific probleus with which they were concerned 1

l at the time they requested to do so ( April 14, 1983, and Aug12st 24, 1983, respectively) -- to the personal knowledge of CASE President Juanita Ellis

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-- CASE would be able to have offered the Board more assurance now that the problems would have been identified. As it is, CASE has little expectation that most of the problens with which Mr. Messerly is concerned (with the ex-ception of some which would be difficult if not impossible to cover up or remove) will still be in the same state which they were in seven months a20 when Mr. Messerly requested that he be allowed to take the NRC and show them the problens. In the case of Mr. Dillingham, the situation now is much more dis turbing. Had he been allowed to take the NRC and show then his concerns (which he stated he had not fully detailed in his deposition) when he requested to do so almost three months ao_o, those concerns would have at least been known and dealt with in sone manner. As it is, CASE has not heard from Mr.

Dillingham in about two nonths and is unable to contact him. (It should be noted that CASE was contacted by an NRC investigator on 12/5/83 (today) and advised that the NRC was now through with its investigation into his concerns and could now supply Mr. Dillingham with a copy of his deposition, which he had requested be supplied immediately at the time he gave his deposition, but was denied to him by the NRC investigators. Since CASE does not presently know his whereabouts or how to contact him, neither Mr. Dillingham, nor CASE, nor apparently_ the Licensin,y Board will have the benefit of the information contained in his deposition -- even though hed"id not wish to remain confidential, again to the personal knowledge of CASE's Mrs. Ellis and others present at I his deposition. Of even greater concern is the fact that, because Mr. Dillingham was not allowed to show the NRC his concerns at the time he wished to do so, w

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although he clearly stated to the NRC investigators that he was leaving town, the possibility now exists that problems -- perhaps major problems -- in q l

construction of Comanche Peak currently exist which have not, and perhaps will j not, be corrected before the plant goes into operation, perhaps with disasterous consequences.)

The task CASE is undertaking is a monumental one which should not, in CASE's opinion, be relied upon totally by the Board as a basis for believing Comanche Peak is safely built even if CASE's witnesses are unable to show the {

Board major problems in construction. Because of the delays experienced, as discussed previously, and the Board's understandable desire for some measure of specificity, as well as the problems which will undoubtedly be encountered due to the fact that many of CASE's witnesses have not been at the plant for some time, the Board cannot be certa _in that the problems identified by CASE's witnesses j would have been discovered by Applicants' QA/QC program had our witnesses not l brought them to the attention of the NRC and the Board. CASE wants to emphasize  ;

l again that we do not (onsider this "show-and-tq11" trip to be a primary ingredient of our case in these proceedings and urge that the Board consider it only in the total context of testimony by our witnesses.

Respectfully submitted, i

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l Mrs.) Juanita Ellis, President CASE (Citizens Association for Sound Energy) )

1426 S. Polk "

Dallas, Texas 75224 214/946-9446 cc: With Attachment, to Licensing Board, Applicants' counsel Nicholas Reynolds, a NRC Staff's counsel Stuart Treby, State of Texas counsel David Preister Without Attachnient, to balance of service list ATfADMN IS FOR RESTRICTED LEE OtLY

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t UNITED STATES OF AMERICA

, NUCLEAP. REGULATORY COMMISS10!1 BEFORF THE ATOMIC SAFELY AND LICENSif;G BOARD In the Matter of l

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APPLICATION OF TEXAS UTILITIES Q GENERATING COMPAllY, ET AL. FOR Q Docket Nos. 50-445 AN OPERATING LICEllSE FOR Q and 50-446

' COMANCHE PEAK STEAM ELECTRIC Q

' STATION UNITS #1 AND #2 (CPSES) l CERTIFICATE OF SERVICE

'By my signature below, I hereby certify that true and correct copies of

/ CASE's RESPONSE TO BOARD'S REQUEST FOR CHART OF "SHOW-AND-TELL" TRIP TO COMANCHE PEAK  ;-

have been sent to the names listed below this 5th day of December , 198_1, by: XEX#NdE#XMKIIX#N#MMXIMHu1HXQXXXhM First Class Mail.El3X$heXW. ,

• = with attachment ( ATTACHMENT IS FOR RESTRICTED USE ONLY. )

0 Administrative Judge . Peter B. Block Alan S. Rosenthal, Esq., Chairman U. S. Nuclear Regulatory Commission Atomic Safety and Licensing Appeal Board Atonic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Washington, D. C. 20555 0 Dr. Kenneth A. McCollom, Dean Dr. W. Reed Johnson, Member Division of Engineering, Atomic Safety and Licensing Appeal Board Architecture and Technology U. S. Nuclear Regulatory Comatission Oklahoma State University Washington, D. C. 20555 Stillwater, Oklahoma 74074 Thomas S. Moore, Esq., Member 0

Dr. Walter H. Jordan Atomic Safety and Licensing Appeal Board 881 W. Outer Drive U. S. Nuclear Regulatory Commission Oak Ridge, Tennessee 37830 Washington, D. C. 20555 0 Nicholas S. Reynolds , Esq. Atomic Safety and Licensing Appeal Panel Debevoise & Libernjan U. S. Nuclear Regulatory Commission 1200 - 17th St. , N. W. Washington, D. C. 20555 ,

Washington, D. C. 20036 Docketing and Service Section (3 copies)

O Stuart Treby, Esq. Office of the Secretary Office of Executive Legal Director U. S. Nuclear Regulatory Conmission U. S. Nuclear Regulatory Conmission Washington, D. C. 20555 Washington, D. C. 20555 Atomic Safety and Licerising Board Panel U. S. Nuclear Regulatory Coniaission Washington, D. C. 20555 4

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',- Certificate of Service Page 2

• David J. Preister, Esil.

Assistant Attorney General 3 Environmental Protection Division F. O. Box 12548, Capitol Station

' Austin, Texas 78711 .

John Collins .

Regional Administrator, Region IV U. S. fluclear Regulatory Cor. mission 611 Ryan Plaza Dr., Suite 1000 Arlington, Texas 76011 1, -

Mr. R. J. Gary

, , Executive Vice President and l  :, General Manager h

Texas Utili ties Generating Company i 2001 Bryan Tower Dallas, Texas 75201 Lanny Alan Sinkin 114 W. 7th, Suite 220 Austin, Texas 78701 Dr. David H. Boltz 2012 S. Polk Dallas, Texas 75P24 i

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, , . (IE7Juanita Ellis, President

• j 3 CASE (Citizens Association for Sound Energy)

, 1426 S. Polk

. Dallas , Texas 75224 214/946-9446 E