ML20093M838

Affidavit of M Walsh in Form of Partial Response to Applicant Statement of Matl Facts as to Which There Is No Genuine Issue Concerning Applicant QA Program for Design of Piping & Pipe Supports.Certificate of Svc Encl

ML20093M838
Person / Time
Site:	Comanche Peak
Issue date:	10/18/1984
From:	Mary Walsh Citizens Association for Sound Energy, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20093M798	List: ML20093M796 ML20093M804 ML20093M815 ML20093M838
References
OL, NUDOCS 8410230316
Download: ML20093M838 (6)

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UNITED STATES OF AMERICA

, NUCLEAR REGULATORY COMMISSION 00CKETED BEFORE THE ATOMIC -SAFETY AND LICENSING BOARD USNEC In the Matter of- l l- *84 OCT 22 A11:08 TEXAS UTILITIES. GENERATING - l Docket Nos. 50-445-1

- COMPANY, et alc l -end 50-446-1xc s st u n l 00cnEimG c. SEPv (Comanche Peak ' Steam Electric Station l N Station,: Units 1 and 2) l CASE'S PARTIAL ANSWER TO APPLICANTS' STATEMENT OF MATERIAL FACTS AS TO WHICH THERE.IS NO GENUINE ISSUE REGARDING APPLICANTS'

~ QUALITY ASSURANCE PROGRAM FOR' DESIGN OF PIPING AND PIPE SUPPORTS FOR COMANCHE PEAK' STEAM ELECTRIC STATION

'in the form of AFFIDAVIT OF CASE WITNESS MARK WALSH Q: Have-you completed your review of the documents being supplied by Applicants'which CASE has requested on discovery regarding Applicants' Motion (for Summary Disposition Regarding Applicants'. Quality Assurance

~ Program for Design of Piping and Pipe Supports for Comanche Peak Steam Electric Station)?

A: No,' I haven't.- I am still in.the process of. reviewing the procedures, .

specifications, and.other documents which Applicants have supplied and.

which they will be supplying.

- Q:- 'Is.there anything you would like to call to the Board's attention at

-this time regarding the implementation of Applicants' quality assurance program for design?

A:. Yes. Applicants'. Statement 4 states:

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"Each design organization has implemented design control measures which include verification and/or checking of the adequacy of each design, including the initial design of the piping or support prior to release of the design for construction. These measures include documentation of-the design reviewer's findings and correction of the deficiencies by the original designer. ~Each design organization also requires that the person performing design review may not be the same person who

. performed the original design, although he may be part of the same organization as the original designer. (Affidavit at 20-22 (G&H), 30 (W), 35-37 (NPSS), 40-41 (ITTG), and 46-48 (PSE).)"-

And Applicants' Statement 5 states:

"During the course of construction of the piping and support system changes in design of supports are virtually unavoidable.

Implementation of the changes are governed by established procedures and instructions. The most commonly employed method to implement such changes is through Component Modification Cards ("CMCs"). These changes are subject to design review, verification and approval in accordance with procedures commensurate with the design review process employed in the original design. With respect.to design changes not initiated by field modifications, each organization also conducts design reviews of the change in a manner commensurate with the

. procedures for new designs. The design change control process for each organization provides that the organization which performed the original design to also perform the design review of the design changes. (Affidavit at 50-56.)"

I will not discuss this in detail at this time, but I want to call the Board's_ attention to our previously-flied Answers to Applicants' various Motions for Summary Disposition. Just as a couple of examples:

The problem regarding bending in the bolt for the Richmond inserts was called to Applicants' attention by CASE Witness Jack Doyle. But.

even after it was called to their attention, Applicants did nothing about it until their Motion for Summary Disposition, when they finally admitted that Mr. Doyle was correct. (See discussion at page 39 of CASE's Answer to Applicants' Statement of Material Facts Relating to Richmond Inserts As to Which There Are No Feterial Issues, in the form of Affidavit of CASE Witness Mark Walsh.)

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The problem of' instability is one which clearly documents a complete breakdown of Applicants' QA/QC program for design. I discussed this in detail in our,recent Answer to Applicantc' Motion for Summary Disposition on stability (see CASE's Answer to Applicants' Statement of Material Facts As To Which There Is No Genuine Issue Regarding Stability of Pipe Supports, in the form of Affidavit of CASE Witnesses Mark Walsh and Jack Doyle, entire Answer).

Throughout our Answers to Applicants' Motions for Summary

- Disposition, as well as CASE's First Motion for Summary Disposition, there are clear patterns of numerous continuing breakdowns in Applicants' QA/QC program which are repeated time and again.

Q: Do you have any further comments?'

A: Not at this time.- However, as I stated earlier, I am still in the s

process of reviewing the procedures, specifications, and other documents which Applicants have supplied and which they will be

. supplying. And I will be discussing Applicants' Statements further in a supplement to this partial answer.

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.The preceding CASE's Answer to Applicants' Statement of Material Facts As To Which There Is No Genuine Issue was prepared jointly under the personal direction of the undersigned, CASE Witnesses Jack Doyle and Mark Walsh. We can be contacted through CASE President, Mrs. Juanita Ellis, 1426 S. Polk, Dallas, Texas 75224, 214/946-9446.

Our qualifications and background are already a part of the record in these proceedings.- (See CASE Exhibit 842, Revision to Resume of Jack Doyle, accepted into evidence at Tr. 7042, and CASE Exhibit 841, pevision to Resume of Mark Walsh, accepted into evidence at Tr. 7278; see also Board's 12/28/83 Memorandum and Order (Quality Assurance for Design), pages 14-16.)

We have read the st 4tements therein, and they are true and correct to the best of.our. knowledge and belief. We do not consider that Applicants have, in-their Motion for Summary Disposition, adequately responded to the issues raised by uy however, we have attempted to comply with the Licensing Board's directive to answer only the specific statements ma by Applicants.

(Signed) Mark Walsh STATE OF TEXAS On this, the fM day of /Q, t-[ , 1984, personally appeared Mark Walsh, knbwn to me to'be the person whose name is subscribed to the foregoing instrument, and acknowledged to me that he executed the same for the purposes therein expressed.

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. Subscribed and sworn before me on the 19 day of [9 ,

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. :' - N iE . State.of Texas

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-NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY' AND LICENSING BOARD'84 0CT 22 All :08 In the Matter of }{ g.g g g y; ,

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TEXAS UTILITIES ELECTRIC }{ Docket Nos. 50-445-1 BR ANCH COMPANY, et al. }{ and 50-446-1 (Comanche Peak Steam Electric }{

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CERTIFICATE OF SERVICE By my signature below, I hereby certify that true and correct copies of CASE's Partial. Answer to Applicants' Motion for Summary Disposition Regarding Applicants'

-Motion for Summary Disposition REcarding Applicants' Quality Assurance Program for Design of Piping and Pipe Supports for Comanche Peak Steam Electric Station -- anc -- CASE's 10/18/84 1;tter to ADolicants re: Documents Request by CASE on Discovery Re: Applicants' Motion for Sunnary Disposition Re: Allegations Concerning QA for Design have been sent to the names listed below this 18th day of October ,1984 _,

by: Express !bil 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 ,

• Ceary S. Mizuno, Esq.

P. O. Box X, Building 3500 Office of Executive Legal Oak Ridge, Tennessee 37830 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 M. 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 I  %

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< s Chairmane _ Renea Hicks, Esq.

Atomic Safety and-Licensing Appeal Assistant Attorney General Board Panel Environmental Protection Division

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U..S. Nuclear Regulatory Commission Supreme Court Building

We'shington, D. C. 20555 Austin, Texas 78711

-John' Collins JRegional' Administrator, Region-IV

.U.iS. Nuclear Regulatory Commission 611: Ryan' Plaza Dr., Suite 1000

1. Arlington.. Texas 76011

Lanny-A. Sinkin . .

114 W. 7th, Suite 220

' Austin; Texas 78701

_Dr.-David H. Boltz 2012-S. Polk-Dallas, Texas 75224 Michael D. Spence, President

--Texas Utilities Generating Company 1 Skyway Tower 400. North Olive'St., L.B. 81.

-Dallas, Texas- 75201

' Uocketing and Service Section f(3 copies)

Office of'the Secretary ,

U.-S. Nuclear Regulatory; Commission

_ Washington, D. C. 20555 L

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(p.)JuanitaEllis, President CASE (Citizens Association for Sound Energy) 1426 S. Polk Dallas, Texas 75224

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214/946-9446 2

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