ML20093G159
| ML20093G159 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/19/1984 |
| From: | Ellis J Citizens Association for Sound Energy |
| To: | TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| Shared Package | |
| ML20093G128 | List: |
| References | |
| OL, OL-1, NUDOCS 8407230351 | |
| Download: ML20093G159 (9) | |
Text
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RELhTCD COTiMPONDENCE 7/19/84 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'3.Kf7pg BEFORE THE ATOMIC SAFETY AND LICENSING BOARD "4
'81 In the Matter of 23 4.,,
APPLICATION OF TEXAS UTILITIES Docket Nos'.J50,445 GENERATING COMPANY, ET AL. FOR and 50-446 AN'0PERATING LICENSE FOR I
COMANCHE PEAK STEAM ELECTRIC STATION UNITS #1 AND #2 (CPSES) g CASE'S TWENTY-F0URTH SET OF INTERR0GATORIES AND REQUESTS TO PRODUCE TO APPLICANTS Pursuant to 10 CFR 2.740b and 2.741, CASE (Citizens Association for Sound Energy), Intervenor herein, hereby files this, its Twenty-Fourth Set of Interrogatories and Requests to Produce to Applicants.
Please answer the following interrogatories and requests for documents in the manner set forth herewith:
1.
Each interrogatory should be answered fully in writing, under oath or affirmation.
2.
Each interrogatory or document response should include all perti-nent infonna. tion known to Applicants, their officers, directors, or employees, their agents, advisors, or counsel.
Employees is to be construed in the broad sense of the word, including specifi-cally Brown and Root, Gibbs & Hill, Ebasco, any consultants, sub-contractors, and anyone else perfonning work or services on behalf of the Applicants or their agents or sub-contractors.
3.
Each document provided should include a sworn statement of its authenticity.
8407230351 840719 PDR ADOCM 05000445 0
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4.
Answer each interrogatory in the order in which it is asked, numbered to correspond to the number of the interrogatory. Do not combine answers.
5.
Identify the person providing each answer, response, or document.
6.
These interrogatories and requests for documents shall be continuing -
in nature, pursuant to 10 CFR 2.740(e) and the past directives of the Licensing Board. Because of the time restrictions under which we are presently working, we request that supplementation be 4
made on an expedited basis.
7.
For each item supplied in response to a request for documents,
[
identify it by the specific question number to which it is in r
]
response.
If the item is excerpted from a document, identify i
it also by the name of the document.
Please also provide the copies in the correct order (rather than in reverse order).
i 8.
The term " documents" shall be construed in the broad sense of the word and shall include any writings, drawings, graphs, charts, photographs, reports, studies, slides, internal memoranda, hand-I written notes, tape recording, calculations, and any other data i
compilations from which information can be obtained.
I CASE'S INTERROGATORIES AND REQUESTS TO PRODUCE TO ~ APPLICANTS The following interrogatories pertain to information necessary to respond l
to Applicants' 6/25/84 Motion for Sunniry Disposition of Maximum Roughness Surface Preparation Issue, as well as other aspects of protective coatings.
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l 1.
Provide for inspection and copying the original and all revisions of Comanche Peak construction procedure CCP-30, " Coating Steel Substrates Inside Reactor Building and Radiation Areas."
(Referenced in Brandt Affidavit at 2.)
2.
Regarding the statement on page 2 of Mr. Brandt's Affidavit:
" Applicants' personnel prepare steel substrates in three alternative ways: sandblasting; power tooling; and hand sanding. Power tooling includes the use of flapper wheels, 3-M Clean 'n' Strip disks (used with a rotary power tool), and belt sanders."
. is documentation of these statements contained in construction procedure CCP-30?
3.
If the answer to 2. is no, identify by name and number the procedure, specification, etc., in which such documentation is contained.
4.
Provide for inspection and copying the original and all revisions of such procedure, specification, etc., identified in 3. above.
5.
Identify by name, number, and date the procedures which were used or are being used for protective coatings at Comanche Peak.
6.
Identify by name, number, and date the specifications which were used or are being used for protective coatings at Comanche Peak.
7.
Provide for inspection and copying the original and all revisions of each of the procedures identified in 5. preceding.
8.
Provide for inspection and copying the original and all revisions of each of the specifications identified in 6. preceding.
9.
What documentation is there to support the statements on page 2 (bottom paragraph):
"All steel substrate inside containment, including the liner plate and all structural steel, was originally prepared for primer coat by sandblasting. Applicants utilize power tooling only for repair or rework. The major part of the total area of all safety-related coating surfaces, therefore, were prepared by sandblasting."
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10.
Supply the documentation referenced in 9. preceding for inspection and copying.
(If it is included in any of the other documents already requested herein, identify the document (s) and the page number (s).)
11.
Are Applicants' committed to Steel Structures Painting Council (SSPC)
Surface Preparation Specification No. 10, Near-White Blast Cleaning (commonly referred to as SP-10)? (Brandt Affidavit at 3.)
12.
If the answer to 11 is yes, what document sets forth this commitment?
13.
If the answer to 11 is yes, supply the original and all revisions of the document which sets forth this commitment for inspection and copying.
14.
What document to which Applicants are committed sets forth Applicants' commitment to the use of No. 3 blasting sand for sandblasting?
15.
Supply the original and all revisions of the document referenced in 14.
preceding for inspection and copying.
- 16. With reference to the use of blasting with large sand (Brandt Affidavit at 3, first paragraph), it is stated:
"According to the specification, therefore, Applicants will normally achieve a maximum profile height of 2.8 mils for steel substrate i
surfaces prepared by sandblasting." (Emphasis added.)
(a) Have there been instances where a maximum profile height of more than 2.8 mils has been achieved?
(b) Have there been instances where a maximum profile height of more than 3 mils has been achieved?
(c) If the answer to (a) or (b) is yes, give complete details for each such instance.
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s 16.
(continued):
In the instances where a maximum profile height of more than 3 (d) mils was achieved, was a report of some sort issued documenting that this was a non-conforming condition?
If the answer to (d) is yes, what kind of report (NCR, IR, Unsat, (e) etc.) was issued in each instance?
If the answer to (d) is yes, supply for inspection and copying (f) the original and all revisions of each such report.
How many instances have there been where a maximum profile height (g) of more than 3 mils was achieved?
Was there ever a Corrective Action Report or CAR issued because a (h) maximum profile height of more than 3 mils was achieved?
the achieving of a (i) Was there ever a report made to the NRC that maximum profile height of more than 3 mils was a potential significant deficiency?
If the answer to (1) is yes, identify by name, number, and date (j) the specific report (s) made.
If the answer to (i) is yes, supply each such report and all (k) related documents for inspection and copying.
Have there been instances where a minimum profile height of less than 17.
1.0 mils has been achieved?
If the answer to 17. is yes, give complete details for each such 18.
instance.
In the instances where a minimum profile height of less than 1.0 mils 1
19.
was achieved, was a report of some sort issued documenting that this l
i was a nonconforming condition?
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s 20.
If the answer to 19. is yes, what kind of report (NCR, IR, Unsat, etc.)
was issued in each instance?
21.
If the answer to 19. is yes, supply for inspection and copying the original and all revisions of each such report.
22.
How many instances have there been where a minimum profile height of less than 1.0 mils was achieved?
23.
Was there ever a Corrective Action Report or CAR issued because a minimum profile height of less than 1.0 mils was achieved?
24.
Was there ever a report made to the NRC that the achieving of a minimum profile height of less than 1.0 mils was a potential significant deficiency?
25.
If the answer to 24. is yes, identify by name, number, and date the specific repcrt(s) made.
26.
If the answer to 24. is yes, supply each such report and all related documents for inspection and copying.
- 27. What documentation is there for the statement (Brandt Affidavit at 3, last paragraph):
"Even if sandblasting were to produce a surface profile in excess of 2.8 mils, there would be no loss in the integrity of the primer coating."
28.
Supply for inspection and copying the documentation referenced in 27.
I preceding.
l There are additional questions and requests for documents regarding Applicants' 6/25/84 Motion for Summary Disposition of Maximum Roughness Surface Preparation Issue, as well as other aspects of protective coatings which we will be filing. We are filing what we have here so that we can get 6
. d it into the hands of the Applicants, the Staff and the Board as quickly as possible. Additional requests will be forwarded in the next day or so.
Respectfully submitted, M '.
/ t a-w pits.)JuanitaEllis, President CASE (Citizens Association for Sound Energy) 1426 S. Polk l
Dallas, Texas 75224
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214/946-9446 i
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>- a UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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TEXAS UTILITIES ELECTRIC
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Docket Nos. 50-445-1 and 50-445-2 COMPANY, et al.
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and 50-446-1 and 50-446-2 (Comanche Peak Steam Electric
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Station, Units 1 and 2)
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CERTIFICATE OF SERVICE B
si I hereb certify that true and correct copies of CASE's Motiofi 6posinatNre below, Motion for Summary Disposition of Maximum Roughness Surface ng pplrants Preparation Issue and Motion for Discovery; CASE's Request to Applicants and NRC Staff for Admissions; and CA E cwency-iourcn set or interrogatories ana requests to produce to Applicants have been sent to the names listed below this 19th day of July
,1981, by: Express Mail where indicated by
- and First Class Mail elsewhere.
- 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 Chairman, Atomic Safety and Licensing 881 W. Outer Drive Board Panel Oak Ridge, Tennessee 37830 U. S. Nuclear Regulatory Commission Washington, D. C.
20555
- Herbert Grossman, Alternate Chairman Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission 4350 East / West Highway, 4th Floor Washington, D. C.
20814 1
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t Renea Hicks, Esq.
Chairman Atomic Safety and Licensing Appeal Assistant Attorney General Board Panel Environmental Protection Division U. S. Nuclear Regulatory Commission Suprame Court Building Washington,-D. C.
20555
. Austin, Texas 78711 John Collins Lanny A. Sinkin Regional A'dministrator, Region IV~
114 W. 7th, Suite 220 U. S. Nuclea'r Regulatory Commission
. Austin, Texas 78701 611 Ryan Plaza Dr., Suite 1000 Arlington, Texas 76011' s
MichaelD. Spence, Pre'sident Dr. David H. Boltz Texas Utilities Generating Company 2012 S. Polk Skyway Tower Dallas, Texas 75224 400 North Olive St.,'L.B. 81 Dallas, Texas 75201 s
Docketing and Service Section Anthony Roissan, Esq.
(3 copies)
Trial Lawyers for Public Justice Office of the Secretary 2000 P St., N.W., Suite 611 U. S. Nuclear Regulatory Commission Washington, D. C.
20036 Washington, D. C.
20555 Ms. Billie P. Garde
,Covernment, Accountability Project 1901 Que Street, N. W.
Washington, D. C.
20009 s,
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gpMfai)JuanitaEllis, President CASE.(Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224 214/946-9446 e
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