ML20093M700
| ML20093M700 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/18/1984 |
| From: | Ellis J Citizens Association for Sound Energy |
| To: | TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| CON-#484-636 OL, NUDOCS 8410230162 | |
| Download: ML20093M700 (11) | |
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10/18/84 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION COCKETED BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of l
.M M 22 M 11 TEXAS UTILITIES GENERATING i
Docket Nos. 50-445-1 COMPANY, et al.
l and 50-446-1 5e I
(Comanche Peak Steam Electric Station l Station, Units 1 and 2) l CASE'S DISCOVERY REQUESTS TO APPLICANTS REGARDING CROSS-0VER LEG RESTRAINTS y
Pursuant to the Board's 10/5/84 Memorandum and Order (Discovery on Cross-Over Leg Restraints) and the Board's 10/11/84 Memorandum (Telephone Conference Held This Morning) (at paga 2), CASE (Citizens Association for Sound Energy) files this, its Discovery Requests to Applicants Regarding Cross-Over Leg Restraints.
(See also 10 CFR 2.740b and 2.741.)
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 pertinent information known to Applicants, their officers, directors, or employees, their agenti, advisors, or counsel.
Employees is to be construed in the broad sense of the word, includir~ specifically Brown & Root, Gibbs & Hill, Ebasco, any consultants, sub-contractors, and anyone else performing work or services on behalf of the Applicants or their agents or sub-contractors.
8410230162 841018 PDR ADOCK 05000 a
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3.
Each document provided should includa a sworn statement of its authenticity.
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 tha past directives of the Licensing Board. Because of the time restrictions under which we are presently working, we request that supplementation be 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 response.
If the item is excerpted from a document, identify it also by the name of the document. Please also provide the copies in the correct order (rather than in reverse order).
- 8.
,The term " documents" shall be construed in the broad sense of the word and shall include any and all writings, drawings, graphs, charts, photographs, reports, studies, slides, internal memoranda, hand-written notes, tape recordings, calculations, and any other data compilations from which information can be obtained.
CASE'S INTERROGATORIES AND REQUESTS TO PRODUCE TO APPLICANTS 1.-
In Applicants Attachment 1 to their 9/14/84 Response to CASE Motion for Discovery Regarding Inspections of Main Coolant System Crossover Leg Restraints (8/23/84 TXX #4271, response to NRC), Applicants state:
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"The installations shall be inspected to current design documents in accordance with.the established QA/0C Program."
and the original design documents and all revisions Provide the " current design documents" referenced,dincluding any and all applicable specifications, procedures, guidelines, etc.
2.
.On page 3 of Applicants' Attachment 1, they state:
"A review of this issue showed that documentation does exist on
.the installation, however, it was found to be incomplete to u
. substantiate the acceptability of the installation under the quality program.
It should be noted that craft and QC had
. recognized the need for the components-to be inspected, however, the' documentation was'not completed..Therefore, this situation appears to be, isolated in its occurence and no further action
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outside of the re-inspection is anticipated."
(a) Provide the documentation which exists on the installation (as referenced in first sentence above).
(b)- In what way was the documentation found to be incomplete; i.e.,
what specifically was necessary to complete the documentation?
l (c). Provide a list of the specific QA/QC procedures which would be applicable to the inspections of the installations of the crossover leg restraints.
(d) Provide copies of the specific QA/QC procedures which would be applicable to the inspections of the installations of the crossover leg restraints.-
(e) Provide the basis, and any and all supporting documentation, for-the statement that " craft and QC had recognized the need for the components to be inspected."
(f) Applicants stated that "this situation appears to be isolated in its occurrence and no further action outside of the re-inspection is anticipated." Provide a list, and copies of, the specific QA/QC procedures which would be applicable to the inspections oft l
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i the upper lateral restraint; and the moment restraint (referenced in CASE's 8/22/83 Proposed Findings of Fact and Conclusions of Law (Walsh/Doyle Allegations) beginning at page XIX - 18).
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- 3.
On page.3 of Attachment 1, Applicants state
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"The inspections shall be completed no later than August 24,
' 1984. " - (Although this seems to have been changed in Attachment 2.)
(a)' Have the inspections now been completed?
(b)
If the answer to (a) above is no, when will they be completed?
(c) lIf the answer to (a) above is yes, provide any and all documentation regarding such inspections.
4.
Provide the following information regarding Applicants' Attachment 2 to their 9/14/84 Response to CASE Motion for Discovery Regarding Inspections of Main Coolant System Crossover Leg Restraints (9/7/84, TXX-4294, supplementary response to NRC):
,(a) Provide copies of the original and all revisions of NCR-H84-100281.
(b) Applicants stated:
"Approximately two years ago, a decision was made to intentionally postpone completion of the installation (shimming and torquing) of the crossover les restraints until af ter completion of Hot Functional Testing."
(1) Who specifically made or had input into such decision (name, company affiliation, title, and job responsibility)?
(2) Provide any and all documentation for Applicants' statement above.
..(3)
What was the reason for the postponement of the testing until after completion of Hot Functional Testing and/or until power ascension testing?
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(4) Provide any and all documentation of the reasons for such postponement.
(5) Is it Applicants' current intention to postpone this testing until during power accension testing?
(6) If the answer to (5) above is yes, what is the reason for r
such postponement?
(7) If the answer to (5) above is yes, provided any and all documentation of the reasons for such postponement.
(c) Provide the original and all revisions of Tent Instruction /
Procedure Deviation (TPD) Report No. 12 on the Reactor Coolant System.
(d) Provide any and all documentation that thermal monitoring of the shims will take place during power ascension testing (i.e.,
specific procedures which oo state, memoranda, etc.)
(e) Provide any and all documentation that the " work required to be completed during plant heat-up after fuel load is identified as a known work item on the Master System Punchlist."
(f) Provide the original and all revisions of NCR-H84-100182.
(g) Provide any and all documentation that "Further work required by TPD-12 has been carried as an open item in the Test Deferral Package since the issuance of TPD-12 oa May 25, 1983."
(h) llave Applicants performed any testing regarding the torquing of the bolts for the crossover Icg restraint installations, especially in light of the results of Appilcants' tests regarding the torque used for U-bolts (see CASE's Answer to Applicants' Statement of Haterial Facts As To Which There in No Genuine Isnue 5
'Regarding Consideration of Cinching Down of U-Bolts, in the form l'
of Affidavit of CASE Witness Jack Doyle, at page 10)?
(1) If the answer to (h) above is yes, provide all such tests and test results.
(j)- If the answer to (h) above is no, do Applicants anticipate performing any such tests?- (If not, why not?)
(k),If the answer to (h) above is no, what assurance is.there that the I
bolts will perform in a predictable manner throughout the life of the plant?
(1) Provide any and all documentation for your answer to (k) above.
(m) Applicants state:
"We will conduct the necessary inspections when an engineering determination indicates the timeliness for completing the inspections."
(1) Provide any and all procedures which state that such an engineering determination will be made.
(2) Provide any and all procedures which set forth the criteria for such engineering determination.
(n) Applicants statet "It is unclear whether the inspector saw the OC inspector's checklists for the crossover leg restraints. TPD-12 was not presented to the inspector."
(1) Why would the NRC inspector not have seen the QC inspector's checklists for the crossover leg restraints (i.e., where would the QC inspector's checklists have been if not with the documentation which the NRC inspector saw)?
Include in your i
answer, in detail, what steps Applicants have taken to discover the answer to theso questions and the results of 6
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r Applicants' efforts in this regard, and the answers to the following questions:
(1) How could this have occurred?
(11) What assurance l's there (including any and all documentation for'such assurance) that this has not and will not also be the case in other instances?
(iii) What steps have Applicants taken to assure themselves (and the Board) that this is an isolated instance and not a generic (to Comanche Peak) problem?
(2) (1) Why was TPD-12 not presented to the NRC inspector?
(ii) Why would TPD-12 not be included in the package for the crossover leg restraints?
(iii) Is there a procedure which states that such TPD's shall be included in the packages for the respective items to which they pertain (and, if so, provide any and all such procedures)?
(iv) Include in your answer, in detail, what steps Applicants have taken to discover the answer to these questions and the results of Applicants' efforts in this regard, and the answers to the following questions:
(aa) How could this have occurred?
(bb) What assurance is thero (including any and all documentation for such assurance) that this has not and will not also be the casa in other instances?
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(cc) What steps have Applicants taken to assure
's themselves (and'the Board) that this is an
.h isolated instance and not a generic (to Comanche Peak) problem?
(o)' Provide-any and.all documentation (if not already provided in response to the preceding) to support Applicants' statement that:
"(1) the completion of the inspections of the restraints were intentionally postponed, and.(2) testing documentation does demonstrate the need for the inspections."
(p) (1)
Were any of the QC inspectors involved in any way with inspections of the crossover leg restraints who quit or were terminated (including being laid off) in connection with or because of the recently identified drug-related problems at Comanche Peak?
(2) If the answer to (1) above is yes, give comp 7ete details, including the name(s), title (s), specific areas and systems on which the' individual (s) worked at any time (and specifically when, for what period of time, and specifically what part such individual (s) had regarding) on the inspections of the crossover leg restraints), and any other pertinent details.
(3) If the answer to (1) above is no, describe _in detail what steps Applicants have taken to ascertain the information requested in (1) above.
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(q) How much of the information requested in the preceding was:
(1)f Requested by the NRC representative at the CPSES site?
(2): Provided to the NRC representative at the.CPSES site prior to
-this pleading?
To expedite matters, if Applicants would prefer (since CASE will probably want all of the documents requested in the preceding anyway), they can go. ahead and supply us copies of all requested documents at $.07 per page.
In the alternative, please provide the documents for inspection and copying.
Respectfully submitted, ist W N
% g.') Juanita Ellis, President GSE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas' -75224 214/946-9446 9
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RELATED CORRESf,0),D3@
00'.KETED UNITED STATES OF AMERICA USNRC NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 84 0CT 22 All:11 In'the Matter of~
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00CKEiad a SLHLii TEXAS' UTILITIES ELECTRIC-
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Docket Nos. 50-445-1 BRANCH COMPANY,Let al.
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and 50-446-1 (Comanche Peak Steam Electric
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. 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 Discovery Requests to Applicants Regarding Cross-Over Leg Restraints have been sent to the names listed below this 18th day of October,1984,
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
- Judge Elizabeth B. Johnson Oak Ridge National Laboratory
- Geary S. Mizuno, Esq.
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P._ O. Box X, Building 3S00 Office of Executive Legal Oak Ridge, Tennessee 37833 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 1
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Chairman Renea Hicks, Esq.
II Atomic' Safety and Licensing Appeal Assistant Attorney General Board Panel Environmental Protection Division U. S. Nuclear Regulatory Commission Supreme Court Building
-Washington,.D. C.
20555 Austin, Texas 78711 John Collins Regional. Administrator, Region IV U. S.JNuclear Regulatory Commission 611 Ryan Plaza Dr.. Suite 1000 Arlington,-Texas 76011 Lanny A. Sinkin 114 W. 7th, Suite 220
'Dr., David H. Boltz 2012 S. Polk Dallas, Texas 75224
~ Michael D. Spence, President Texas Utilitics Generating Company Skyway Tower 400-North Olive ~St.,
L.B. 81 Dallas,. Texas 75201 Docketing and Service Section (3 copies)
Office of the Secretary U. S. Nuclear Regulatory Commission Washington, D. C.
20555
/L Ns f/Jf 'u
- g. s.) Juanita Ellis, President UASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas,-Texas 75224 214/946-9446
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