ML20086U147

Motion Re Summary of cross-examination Areas Supplied to Cygna on 840222.Applicants Have Used Thin Wall Pipe & Many Instances of Min Pipe Wall Violations Exist.W/M Walsh Affidavit.Related Correspondence

ML20086U147
Person / Time
Site:	Comanche Peak
Issue date:	02/29/1984
From:	Ellis J Citizens Association for Sound Energy
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20086U151	List: ML20086U147 ML20086U166 ML20086U170
References
NUDOCS 8403070177
Download: ML20086U147 (4)

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BEFORE THE-ATOMIC SAFETY AND LICENSING BOARD

~In the~ Matter'of APPLICATION OF' TEXAS UTILITIES I Docket Nos. 50-445 GENERATING COMPANY, ET AL. FOR I and 50-446 I

AN OPERATING LICENSE FOR I COMANCHE' PEAK STEAM ELECTRIC I

STATION . UNITS #1 AND #2 '

-(CPSES)

CASE'S MOTION REGARDING CASE'S

SUMMARY

OF CROSS-EXAMINATION 1984 AREAS SUPPLIED TO CYGNA ON FEBRUARY 222 On February 22, 1984, CASE (Citizens Association for Sound Energy), at the Board's request, supplied Cygna with a brief summary of our cross-examination areas on the Cygna Report.

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As indicated in the attached Af fidavit of Mark Walsh, Mr.

Walsh- has received new and significant information which, although.-it .does not pertain to a new area of inquiry, is

' additive to the specific information previously supplied to Cygna'. - (See Walsh Af fidavit and attachment for specifics.)

Mr._ Walsh states.in his affidavit (page 2) that "I believe that at Comanche Peak, Applicants have used what is commonly referred t'o as ' thin wall? pipe in many instances, and that there

' are also many instances of minimum pipe wall violations at Comanche Peak."

CASE would point out to the Board that this matter would also appear to be.conne2ted to a matter raised by CASE witness Charles Atchison, as discussed on pages 46 and 47 of the Board's 8403070177 840229

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.m 7/29/83 Proposed Initial Decision (Concerning aspects of 3

construction' quality control, emergency planning and Board questions):

"Mr. Atchison's final allegation' was that minimum wall thickness' violations had occurred in piping. /201/ He

-testified that- an NCR had been written on this matter and had led to two backfit programs./202/ As far as he knew the NCR had not been closed./203/ Since an NCR had been written on_ the problem and there are controls requiring that there

.be an appropriate disposition, we find that this allegation demonstrate s the correct working of the quality assurance program and. does not present an allegation that we should pursue sua sponte.

"201 Atchison Testimony, CASE Ex. 650, at 63.

"202 .Id. at 63-64.

~"203 .H.at64."

Since, in the instance noted by Cygna in observation PI 01, the pipe was actually -thinner than was assumed in the pipe analysis, it appears that the possibility exists that the problem identified in the _NCR referenced by Mr. Atchison was not adequately addressed and-dispositioned, as was assumed by the

_ Board. If- this is indeed the case, it would appear that this demonstrates.a breakdown of-the quality assurance program. This Lis an: additional reason CASE believes it is essential that this be addressed by:Cygna and that it be pursued in the hearings on ti.e-Cygna Report.

(CASE believes that the'NCR discussed by Mr. Atchison is the

'same NCR discussed in the July 1982 hearings at Tr. -1971/8-1972/2 2 .

-______.________._-_____.m_.____ _ _ _ _ _ . _ _ _ _ _ - . _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ . _ _ _ _ . . _ _ . _ _ . .

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and 2086/4-2103/4. The NCR referred to in these portions of the transcript was NCR 857; it was approximately.8" thick, and it incorporated many NCR's which had been erroneously closed out which were subsequently reopened under NCR 857. At the time CASE received the documents on discovery, the NCR was still open. We do not know the present status of this NCR. See also CASE Summary of Exhibits, pages 12 and 13; as indicated therein, CASE withdrew many additional NCR's on minimum wall violations in order to comply with the Board's directive to cut down our exhibits. It is CASE's recollection that those NCR's were in addition to those which were incorporated under NCR 857, although we are not-absolutely certain of this at this point in time. The Design Change Authorizations (DCA's) regarding this matter are in the record, however, as CASE Exhibits 449-459, which were the latest DCA's available at that time.)

lin addition to the preceding, it should be noted that the procedures under which we are operating (whereby CASE. is supplying . Cygna L with the basic areas of our cross-examination questions)'is very unusual. Normally, CASE would be allowed to pursue on cross-examination in the hearings any issues which are relevant and material.. Thus, under normal procedures, there is no question but that CASE would have been allowed to pursue this 3 -

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particular matter on cross-examination. (It should also be noted that Mr. Walsh has indicated that he will have a few cross-examination questions which he believes can be answered simply "yes" or "no." We do not believe that this type of question falls into the category covered by the Board's request that we supply to Cygna in advance, and plan to ask them during regular cross-examination.)

For the reasons discussed herein, CASE hereby requests and moves that the Board allow us to supplemer.t our summary of cross-examination areas supplied to Cygna on February 22, 1984.

Respectfully submitted, sj A i fNO gKrs.)JuanitaEllis, President CASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 o

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