ML20098G824

Informs That 20-day Period for Case to Reply to Util Production of Documents Re Design QA Program for Piping & Supports Should Commence No Later than 841010.Related Correspondence

ML20098G824
Person / Time
Site:	Comanche Peak
Issue date:	10/04/1984
From:	Horin W BISHOP, COOK, PURCELL & REYNOLDS, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Ellis J Citizens Association for Sound Energy
References
CON-#484-286 OL, NUDOCS 8410050567
Download: ML20098G824 (3)

Text

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RELATED ccZESPONDENCE .>

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(202)857-9800, QQ[QidgG 4 $$yjQ yg ,,eng,yg,yonnsoc3e TELE x 440574 INTLAW Ut TELEX 222767 W RIT E R*$ O' R EC T DI A L (2 021 October 4, 1984 e

Mrs. Juanita Ellis -

' President, CASE 1426 South Polk Street

Dallas, Texas- 75224-Subj: Texas Utilities Electric Company (Comanche Peak Steam Electric Station, Units 1 and 2);

Docket Nos. 50-445 and 50-446 d C Dear Juanitar.

~

As you know, the - Board ruled during the August 22, 1984, conference call that Applicants need not respond to. CASE's extensive discovery requests concerni'ng Applicants' summary disposition motion regarding the design quality assurance program

'for piping and supports (Tr.-13,999-14,000). The Board also

- determined that CASE should file its answer to Applicants' motion within 20 days 1following receipt of certain information the Board -

had. requested from Cygna (Tr. 14,000). The information was transmitted to' CASE on August 23, 1984.

Following these events, Applicants informed CASE that

-irrespective of'the Board's ruling'we intended to provide the documents you requested which had been referenced and relied on

-in our motion. .We did not expect, there fore , that the twenty day period with which CASE was to provide its answer would begin to run until we completed transmitting those documents. ~

As dis-

- cussed below, we have now made those documents available to CASE,

- with the exception of those-as to which Westinghouse and ITT-

-Grinnell have requested execution of a protective' agreement.

Accordingly, the twenty day. period for your reply should commence with the execution of the agreements, and in no event later than October 10.

The_ documents we have provided include the procedures (including. revisions) and guidance material requested by CASE which are referenced and relied on in our motion. These documents consist of over 4000 pages of material. The item 8410050567'841004 PDR^ADOCK 05000445 g- PDR p r, - -- - ,---,-c. , ,, ,..-n-,, , , - se -,.,-.,-.~,,,---,-a,, ,

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to numbers of-the specific requests.(as set forth in your August 15,

1984,5 1etter) to which we.have responded are, as follows:

tl-22,1first 28 (no documents), 30-34, 51-55, 59-60,.62-66,1 68-83, 87-90, 92, 93, 95, 100,

.101,,104, 105 (included with 55), 106-08 J(same as . 68-69,175)-

The material not provided generally' involves matters the centent of which:are not relied upon in.our motion, such as stechnical specifications ~(3, 4), individual audits (23-27, 29,

.,_' 39,"46-50,56-583 84, 102, 103, 114 and 117),2'ANI procedures and documents (109-113), individua11nonconformance reports (140) and logs thereof (120). Some requests seek information which'is simply.beyond the-scope of thefmotion, such as number of noncon- -

formance documents (119), ANI' contract. terms and organizational structure (127-131),- support: upgrade' procedures (132-135),

information relating to specific I&E Reports (136-139), and

management reviews (141, 142).- Finally, other requests involve

- matters which to the extent relevant are already discussed-in the E

motion itself, viz., methods to document nonconforming conditions (ll8):and trending mechanisms (121-126).

lThe only requests not addressed above are those involving-

.the procedurestof Westinghouse-and ITT-Grinnell (second 28, 40-45, 61, 67, 85, 86, 94, 96-99) covered by'the protective agree--

ment:we~ transmitted to you on September 29, 1984. As I requested in ouriphone conference yesterday,-you'should contact me promptly if you have-any questions concerning-those agreements. I will-

forward the' subject documents to you immediately upon' execution-of the agreements. As'we agreed in our discussion earlier today, 1

1 Item 64Lis'a computer listing which is continuously updated.

We-provided a sample page from a recent printout of that

' list.

lh -We address--in the motion the existence of various audit

. programs and mention only the number of different audits conducted. We have provided the relevant procedures for

those programs, if requested. You will note we provided

( ' examples of many of the audits as attachments to the motion.

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3-there is'no' reason execution cannot be completed by October 9, at which time I will transmit the subject documents. Accordingly, the twenty day period for your response will commence October 10.

Sincerely, William A. Horin Counsel for Applicants

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