ML20083M739
| ML20083M739 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/12/1984 |
| From: | Ellis J Citizens Association for Sound Energy |
| To: | |
| References | |
| NUDOCS 8404180321 | |
| Download: ML20083M739 (8) | |
Text
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4/12/84 00CMETED llNITED STATES OF AMERICA USNT<C NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSIN'04 317 P2:00 B0 In the Matter of I
- 7; d u SECETAPY l
r mETms & SEPvv3 TEXAS UTILITIES GENERATING i
Docket Nos.BW445-1 and COMPANY, et al.-
l*
50-446-1 i
(Comanche Peak Steam Electric Station 1-Station, Units 1 and 2)
-1 CASE'S RESPONSE TO APPLICANTS' PLAN TO RESPOND TO MEMORANDUM AND ORDER (OUALITY ASSURANCE FOR DESIGN)
On March 13, 1984, Applicants filed their Supplement to Applicants' Plan to Respond to Memorandum and Order (Quality Assurance for Design). As CASE understand 3 it, Applicants' Supplement was necessary because of comments the Licensing Board made at the close of the 2/24/84 hearing session (Tr. 10,337-39), wherein the Board expressed its concerns regarding Applicants' original' Plan and stated:
t "If the plcn fails to succeed in producing that level of confidence, we do not anticipate another. opportunity to do.the design review that we requested as an additional way of giving us confidence.
That matter would then fall before-the Appeal Board."
CASE filed a partial answer to Applicants' original Plan on 2/10/84
/1/, and on 3/5/84 we filed our answer to their original Plan /2/.
We believe that our earlier pleadings express CASE's views of Applicants' original Plan.
/1/
CASE's 2/10/84 Partial Answer to Applicants' Plan to Respond to Memorandum and Order (Quality Assurance for Design).
/2/ CASE's-3/5/84 Answer to Applicants' Plan to Respond to Memorandum and Order (Quality Assurance for Design).
8404180321 840412
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D o-l CASE is filing this response to Applicants' Supplement within the twenty-day time period provided 'for in the Board's 12/28/83 Order l.
(excluding the week-end immediately prior to hearings and the week of hearings).
We see little in Applicants' supplement to alleviate our concerns or change our views.
In fact, there have been other recent indications that our concerns were well founded. We call the Board's attention specifically i
to the 10 CFR 2.206 petition and related documents _ filed by the Government Accountability Project (GAP) on March 19, 1984,* on behalf of CASE, GAP, and i
workers and former workers who have come forward with their conce rns.
Included in those documents was a request-for an immediate halt-in construction and suspension of the construction permit for Comanche Peak until such time as an NRC special inspection team made up of NRC investigators and inspectors from across the country who have " experience in_
determination of design / construction problems.at near-completed facilities" has an opportunity to investigate the concerns raised.
It-is
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CASE's understanding that a_special NRC inspection team,- headed by Darrell Eisenhut, NRC Director of_ Licensing, Washington,
'D.C.,
made a surprise visit-to the Comanche Peak site on Tuesday, April 3,
to investigate; allegations of improper construction practices -at the plant.
Although to CASE's knowledge there,has been no ' official word regarding.the ! surprise visit,- public statements by -the NRC ' Region IV Administrator indicate _ thAt-the' inspection team found " deficiencies"_'in the plant's document control center.- (See attached 4/6/84 FORT WORTH STAR-TELEGRAM' article.)
2 F
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Of special interest to CASE is the public statement by the NRC Region IV Administrator that the special inspection team does not include Region IV inspectors.. (See attached 4/6/84 DALLAS TIMES HERALD article.) As the Board is
- aware, CASE has long sought an independent
)
l investigation / inspection by NRC personnel outside the Region IV office.
If the newspaper article is correct, this increases CASE's optimism regarding the team's ability to identify problems which exist at the plant.
Obviously, if the newspaper articles are correct and deficiencies have indeed been found in the document control center, this may raise further questions regarding Cygna's independent assessment program at. Comanche Peak.
As further information regarding the inspection. team's findings becomes available, it may be necessary to pursue this matter further insofar as it applies to Cygna's report.
In addition, there are other recent developments which are pertinent to these matters.
One is that the NRC Staff at the national level has exptassed concerns regarding certain aspects of Cygna's independent assessment program at Comanche Peak; and a meeting between~ the Staff, j
Applicants, and Cygna is currently scheduled fo April 19, 1984,-in Bethesda, to discuss these matters.
The results of that meeting may also have importance fer our hearings on the-Cygna Report.
And finally.
there may be additional pertinent information regarding
(
Cygna's abilities and handling of'the independent assessment program to be found in the concerns raised by the. NRC's' Isa Yin in the. Diablo Canyon hearings. CASE is not certain at this time whether or not the deficiencies 3
and problems identified by Mr.
Yin parallel those at Comanche Peak.
-However, we will be reviewing the information coming from Diablo Canyon with interest, and will take whatever action seems appropriate at a later time.
CASE just received the NRC Staff's 4/6/84 Comments /3/ today as we were preparing our response, and we note'that we also share the concerns expressed by the Staff in items II.A.,
B.,
C.,
and D.
However, while we are aware that the Board cannot prejudge, we believe that it will be absolutely necessary for the record to be held open (barring unforeseen developments) for the receipt of evidence on the multi-discipline review.
We point this out at this time so that the Board and parties can be considering it when considering scheduling and time required for hearings.
Respectfully submitted, Ad h
i p E (Citizens Association for Sound Energy) s.) Juanita Ellis, President CAS 1426 S. Polk Da11ss, Texas 75224 214/946-9446 i
/3/
NRC Staff's 4/6/84 Comments on Supplement to Applicants' Plan to Respond to Memorandum and Order Quality. Assurance for Design.
t 4
fortWorthStar-Tele ram Frider. Apris s.1ses Psicg2se Flaws found in nudear plant documentation Sv BRUCE MILLAR
- cies* in the plant s document ' coni inspection. De deficiencies that President tou rikar.
creventheprehminarytesultsof an recorosta be requested for a review 8'*'*8'""'"
trol center.a n a rca that is the ta reet werecited werepmhminaryinspec-Pl*ntownerswereunwareof the inspection. N RC offiel11s are f or bid-of document control and the accu-A surprise inspection at the Co-of two investigations I:y the NRC tion results and NRC officials have defaciencies until questioned by a den to make pubhe statements racyordesign drawings.The review manche Peak nuclear power plant and plant ownersL not determined if they are signife reperter.said Dick Ramsey. spokes. about inspections until a fmal re-was part of a design review by con-man for plant ownerTexas Utahties port is issued. he said-sultantsCygna Energy ServicesInc.
revcated defkeencies in a key plant Essenhut supervisesan NRC task cant, he said.
record keepans area.but federalof-force assigned to check allegations ' *l wouldn't call them problems-Co. "We just don't have any idea he plant's dorument control of San Frzt.cssco.
ficials dechned Thursday to disclose of unsafe constructson at the plant. Weidentified somedeficienciesina what they might be." he said, center has been at the heart of a lastley also said in a statement details of the problems or their im-which is under construction 45 short period of time." Collins said.
Ramsey said plant officials wor id continumg controversy since Feb-subnutted to the U.S. Atomic Safety portance.
males southwest of Fort Worth.
Accompanying Eisenhutand Col-not know details of the inspection ruary.
and Licensing Board that plant su-Aninspection teamled by Darrell JohnColhns.administratorof the hason theinspectionTuesday were until a final report is issued.
Formerdocumen:scontrolsuper-pervisors vk4sted procedures for Eisenhut, director of the bcensing NRC's regior.at office in Arhngton, Mike Spence, pres' dent of plant op-Clyde Wisner. spokesman for the visor Dobie flat!cy said in a swc.n maintamingact*>raterecordsof de.
division of the U.S. Nuclear Regula-saidit would be" presumptuous"for crator Texas Utilities Generating NRC in Arhngton, said that it was statement released Feb.14 that sign drawing cnanges.
tary Comraission, found "defacien-himtoelaborateontheresultsofthe Co,. and TUGC0 Executive Vice fienient"forColhnstote!!areport-plant officials were given notice of Please see Nuclear on Page 8
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NRC launches probe -
DahaS limes at Comanche Peak )
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hnston confumed that the
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at FRIDAY. APRIL 6,1984 By JACK D00nf allegauons that safety records does mt incliale Region W inspec Staff Writer hm been destmyed or alted ist an effort by the company to cover tors, who have been widely criti.
Under orders from top officials up construction flaws.
ctred by former plant workers fog
, of the Nuclear Regulatiry Com-lleeded by Dartell Usenhut, di. allegedyt being hostile to whittle-missaan, a team of Laspectors this rector of licensing in the NRC's blowers who have pointed, cut He d
week began a surpnse invesuga. Washington DC, headquarters, problems at the plant.
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tion of widespread allega: ions of the group of about seven inspec.
Plant spokesman D6ck Ramsey improper construction practices at tors atso is examining a number of sand the utihty "wekximes the op-the Comanche Peak nuclear plant. other allegataons made by current portunity for (the NRC) to,.see The mvestigation, whach could and former werkers at the plant, that there are no problems",,
determme the outcome of bcens-according to an NRC opokesman.
Many of the more recent 25 Cents ing hearings for the plant near The resuits of the sweeping in. charges of improper constructaon Glen Rose, began Tuesday when vestigation will be used in hear. actavities were contained in sworn the impretors showed up unan-ings on licensmg the plant that affodavits given to the NRC othce nounced and began interviewing will continue through the in Washington by the Govyrn-employees at the plant's document summer.
nient Accountability Project
- a
~ ~
- control center. The document cen-John Collins, admmistrator of ter had been the focus of recent the NRC's Region IV o!! ace in Ar.
See CUMANCHE en Page11 e
.. A-Il DALLAS TIMES IIERALD. Friday. April 6.1964,
,XRC investigators quiz plant's document workers t
COMANCHE - Freen Page One enticized in ment national NRC NRC inspections, and that docu-ments are bemg altered and shut-document center will "put to rest in that warmng. Peter B Bloch, audats for either covering up prob-ments have beert lost or falsified tied around m a wholesale man-some cf the rumors that have chairman of the U.S. Annrme Safe-W A -based group that re-lems or performing inadequate in-era a recurrmg basis.
ner as the company scrambles to been circulating from various ty and Larensmg Eksard that over.
Mts whastle-blowmg workers spections and for reveahng the The team inspection, which Cole erase traces of falsifacataan, mis-sources, the ones about the pezuc " sees Comanche Peak, md' the Kt nuclear plants throughout the narne of a whistic-blower.
hns said will last "as long as is matchmg and odier problems with study - the semnd country.
necessary 13 make fmdings on the documentation," the GAP netter The special investigation by Ei. by the utabty - will be the last As a mndition for providmg the The allegations brought fur-allegations" was hunched after said.
senhut's team also follows a feder-chance to convince the board.
cffidavits. GAP representativt ward by GAP include claarns that GAP made an appeal to the five al hcenang board's warmng that
, Bdhe Garde specifbd that the repaars were made illegally, that NRC -..-w on March 19 Ramsey a spokesman for the the plant's operatmg bcense will
.- wy eurrent and forzatr workers unacceptab6e - ;.ww. matert-to order an immediate halt to Texas Utahtaes Generatmg Co., the he derued unless a new design re.
The NRC u would riot talk to any inspectors als were used after documents work at the plant and to take unsortium of ax utahtscs that view
" by the utihty rule on the plant's license request from Region W-were altered, that plant officials steps to protect plant records.
own the plant, said he was confi. resolves the board's concerns after remvsng a recormriciadation Region IV anspectors also were were tipped off in advance about
'Our sources andicate that docu-dent that the insoettaan of the about the proeret's dessen.
from the bcensmg teard
.w 00(.KETED USNRC UNITED STATES OF AMERICA 84 APR 17 P2:00 NUCLEAR REGULATORY COMMISSION
- R ik 0F SECALIAF-BEFORE THE ATOMIC SAFETY AND LICENSINGrBOAme & SERvicf.
trtANCH In the Matter of
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TEXAS UTILITIES ELECTRIC
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Docket Nos. 50-445-1 COMPANY, et al.
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and 50-446-1 (Comanche Peak Steam Electric
}{
Station, Units 1 and 2)
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CERTIFICATE OF SERVICE By my signature below, I hereby certify that true and correct copies of CASE's Resoonse to Anolicants' Plan to Resnnnd tn Memnrandum and Ordor 3
(Quality Assurance for Design) l have been sent to the names lilsted below this 12th day of April
,198{,
by:
ymee -Mei+whece-i dic;;;d-by *-and First Class Mail elsewhere.
i Administrative Judge Peter B. Bloch Nicholas S. Reynolds, Esq.
U. S. Nuclear Regulatory Commission Bishop, Liberman, Cook, Purcell 4350 East / West Highway, 4th Floor
& Reynolds Bethesda, Maryland 20814 1200 - 17th St., N. W.
Washington, D.C.
20036 Ms. Ellen Ginsberg, Law Clerk U. S. Nuclear Regulatory Commission Geary S. Mizuno, Esq.
4350 East / West Highway, 4th Floor
. Office of Executive Legal Bethesda, Maryland 20814 Director U. S. Nuclear Regulatory Dr. Kenneth A. McCollom, Dean Commission Division of Engineering, Maryland National Bank Bldg.
Architecture.and Technology
- Room 10105 Oklahoma State University 7735 Old Georgetown Road Stillwater, Oklahoma. 74074 Bethesda, Maryland
.~20814 Dr. Walter H. Jordan Atomic. Safety and Licensing Board 881 W. Outer Drive PanW Oak Ridge, Tennessee 37830 U. S.
i :: lear Regulatory Commission Washington, D. C.
20555-t j
1 i
. ~.
1 Alan S. Rosenthal, Esq., Chairman Renea Hicks, Esq.
Atomic Safety and Licensing Appeal Assistant Attorney General Board Environmental Protection Division U. S. Nuclear Regulatory Commission Supreme Court Building Washington, D. C.
20555 Austin, Texas 78711 Dr. W. Reed Johnson, Member John Collins Atomic Safety and Licensing Appeal Regional Administrator, Region IV Board U. S. Nuclear Regulatory Commission
(
U. S. Nuclear Regulatory Commission 611 Ryan Plaza Dr., Suite 1000 Washington, D. C.
20555 Arlington, Texas 76011 Thomas S. Moore, Esq., ~ Member Lanny A. Sinkin i
Atomic Safety and Licensing Appeal 114 W. 7th, Suite 220 Board Austin, Texas 78701 U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Dr. David H. Boltz 2012 S. Polk Michael D. Spence, President Dallas, Texas
-75224 Texas Utilities Generating Company Skyway Tower Atomic Safety and Licensing Appeal 400 North Olive St., L.B. 81 Panel Dallas, Texas 75201 U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Docketing and Service Section (3 copies)
Ms. Nancy H. Williams Office of the Secretary Project. Manager U. S. Nuclear Regulatory Commission Cygna Energy Services Washington, D. C.
20555' 101 California Street, Suite 1000-J San Francisco, California 94111-5894 David R. Pigott, Esq.
Orrick, Herrington, & Sutcliffe 600 Montgomery Street i
San Francisco, California 94111-AKEk a fR 13 p s.)-Juanita Ellis, President
. CASE (Citizens Association for Sound Energy) 11426 S. Polk Dallas, Texas 75224 i
214/946-9446 2
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