ML20100A176

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Response to Case 841018 Discovery Request Re Crossover Leg Restraints.Certificate of Svc Encl.Related Correspondence
ML20100A176
Person / Time
Site: Comanche Peak  
Issue date: 11/30/1984
From: Reynolds N
BISHOP, COOK, PURCELL & REYNOLDS, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Citizens Association for Sound Energy
References
CON-#484-385 OL, NUDOCS 8412030494
Download: ML20100A176 (25)


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hEt E-u.._~. a;;pq U](TED UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD "l

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In the Matter of

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' TEXAS UTILITIES ELECTRIC

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Docket Nos. 50-445 and

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COMPANY, _et _al.

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50-446 L

(Comanche Peak Steam Electric

)

(Application for Station, Units 1 and 2)

)

Operating Licenses)

APPLICANTS' RESPONSE TO CASE'S DISCOVERY REQUESTS REGARDING CROSSOVER LEG RESTRAINTS I.

INTRODUCTION On October 13, 1984 Citizens Association for Sound Energy

(" CASE") filed discovery requests to Applicants regarding inspection of the Unit 1 crossover leg restraint installations.1/

At the time, Applicants had a Motion for Reconsideration of the Board's order allowing CASE discovery on the crossover leg restraints pending before the Board.1/

On November 7, 1984, the Board issued a Memorandum and Order denying Applicant's Motion for Reconsideration.1/

Applican ts ' responses to the discovery requests are provided herein.

8412030494 841130 PDRADOCK05000pgg G

1/ " CASE's Discovery Requests to Applicants Regarding Cross-Over Leg Restraints" (October 18, 1984).

1/ " Applicants' Motion for Reconsideration of Board Order Granting Disovery on Crossover Leg Restraints" (October 19, 1984).

1/ "Memorandun (Reconsideration:

Cross-Over Leg Restraints)"

(November 7,1984).

E_.

. 11.

PRELIMINARY STATEMENT In accordance with our obligation to keep this Board apprised of information related to matters before the Board,

.s attached as Attachment 1 is a copy of a letter from B. R.

Clements to D. R. Hunter, Chief Reactor Proj ect Branch 2, NRC (TXX #4370) (November 28, 1984).

The letter responds to questions raised in a letter from Hunter to M.

D. Spence (November 2, 1984), which is also attached as Attachment 2 for your information.

Tne letter also admits a mistake in and withdraws the September 7, 1984 supplemental response to Region IV regarding Notice of Violation 445/84-08-02i/ as it relates to crossover leg restraints.

The mistake in that supplemental response has been mirrored in Applicants' legal filings in this proceeding which relied upon the supplemental response.

In Applicants' original response to CASE's discovery motion regarding the crossover leg restraints,l/

and in the subsequent motion for reconsideration of the Board's ruling, Applicants referred to outstanding construction work on the restraint installations which would have to be completed prior to required inspections.

Consistent with the supplemental response, we explained that this work involved installation of shims and tightening of the anchorage bolts.

Applicants reported that this construction work would not be completed until the b/ TXX #4294, B. R. Clements to R. L. Bangart (September 7, l

i 1984).

1/ " Applicants' Response to CASE Motion for Discovery Regarding Inspections of Main Coolant System Crossover Leg Restraints" (September 14, 1984).

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. pipes are in a hot condition in order that final shim clearances can be determined.

As reportbd in the November 28 -letter from Clements to Hunter, this explanation, however, was based upon mistaken assumptions.

As is-now clear (see Attachment 1), there was confusion between two potential locations for shim placement on each crossover leg restraint installation.

First, there could be shims associated with the baseplates and the anchor bolts for the restraints.

These baseplate shims would be installed, if necessary, to level the restraint prior to tightening the anchor bolts.

Inspections of work related to baseplate leveling and bolt tightening were not completed and therefore were the subj ect of the Notice of Violation.- As explained below, this construction work and the associated inspections have now been completed (as committed to in the August 23, 1984 response to Region IV).5/

The baseplate shimming attribute was confused with piping shims, which are to be installed between the pipes and the res train t structures.

These piping shims are not related to the anchorage of the crossover leg restraints.

They are located at the piping rather than at the baseplates.

It is these latter shims referred to in Applicants' supplemental response to NRC Region IV which must be monitored with the pipes in a hot condition in order that proper clearances can be determined.

This thermal monitoring was not completed during hot functional 1/ TXX #4271, B. R. Clements to R. L. Bangart (August 23,'1984).

l

' testing.and will not be completed until the next ' heat-up of the pipes.

The piping shims, however, are unrelated -to anchorage of theJ restraints and do not need to be installed or monitored for thermal expansion prior to tightening the anchor bolts and completing the baseplate inspections.

The piping shims therefor'e are not relevant to the Notice of Violation and the previously incomplete inspections of the baseplates.

In the November 28 letter, Applicants have withdrawn the supplemental response and therefore the discussion of piping shims.

The distinction between the shims should be kept in mind in reviewing the following discovery responses.

Because the discovery requests were based in part upon the. September 7 supplemental response, many are not directly relevant to the baseplate work or the Notice of Violation.1/

III. DISCOVERY RESPONSES INTERROGATORY 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:

N "The installations shall be inspected to current design documents in accordance with the estabrished QA/QC Program."

s Provide the " current design documents" referenced, and the original design documents and all revisions including any and all applicable specifications, procedures, guidelines, etc.

7 he wish to state our recognition of the obligation we have to notify the Board if facts relied upon in pleadings to the Board are later found to be incorrect.

This obligation would have arisen regarding the instant matter when the mistake was realized by Applicants, regardless of whether or not the matter had been closed by the -Board.

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1 4

RESPONSE

l '.

The following applicable, _ current documents are ' provided :

r Drawing 2323-S1 -0550, L Rev. 4 Drawing 2323-S1 -0551, Rev. 6 Drawing 2323-S1 -0519, Rev. 4 DCA # 3265, Rev. 1-DCA # 11,312, Rev. 2 DCA # 21,128, Rev. 3 Specification 2323-SS-16B Procedure QI-QP-11.14-1, Rev. 18 The following applicable prior revisions of the documents are provided:

Drawing 2323-S1 -0550, Revs.1 -3 Drawing 2323-S1 -0551, Revs. 1 -5 Drawing 2323-S1 -0519, Revs. 0-3 DCA # 3265, Rev. 0 DCA # 11,312, Revs. 0-1

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DCA # 21,128, Revs. 0-3 1

INTERROGATORY 2.

On page 3 of Applicants' Attachment 1, they state:

"A review of this issue showed that i

documentation does exist on the installation, however, it was found to be incomplete to substantiate the acceptability of the installation under the quality program.

It l

should be noted that craft and QC had recognized the need for the components to be inspected, however, the documentation was not com ple ted.

Therefore, this situation appears to be isolated in its occurrence and no further action outside of the re-inspection 4

j is anticipated."

(a)

Provide the documentation which exists on the installation (as referenced in first sentence above).

RESPONSE

2.

(a)

The following documents are provided:

CP-QCP-3.1 Installation Checklists (4) for inspections of the crossover leg restraints.

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- INTERROGATORY (b)

-In what way was the documentation found to' be incomplete:

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what specifically was'necessary to complete the documentation?

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RESPONSE

L (b)

Part C of each of the installation checklists is incomplete.

This reflects an inspection open item for one or.more of the following:

" item positioned L

properly"; " item leveled properly"; " item shimmed properly"; " bolts torqued properly".

These checklists i

refer to construction / inspection ' activities related to the baseplates and the anchor bolts for the crossover leg restraints.

INTERROGATORY i

(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.

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RESPONSE

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(c)

The applicable QA/QC procedure at the time the crossover leg restraints were originally installed was CP-QCP-3.1.

This procedure was implemented by ' the 4 Inspection Checklists provided in response 2(a).

The procedure currently applicable to the installations is QI-QP-11.14-1, Rev. 18.

)

j INTERROGATORY (d)

Provide copies of the specific QA/QC procedures whic h would be applicable to the inspections of the installations of the crossover leg restraints.

RESPONSE

(d)

Copies of the documents referred to in response 2(c) are provided in response to requests 1 and 2(a), above.

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INTERROGATORY c

(e)

Provide the basis, and any and all supporting documen ta tion, for the statement that " craft and QC had recognized the need for the components to be inspected."

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. RESPONSE

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(e)

This statement was based upon the fact that the inspection checklists (see 2(a), above) existed for the crossover leg restraints.

INTERROGATORY

( 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 of:

the upper lateral restraint; and the moment re s train t (referenced in CASE's 8/22/83 Proposed Findings of Fact and Conclusions of Law (Walsh/Doyle Allegations) beginning at page XIX - 18).

RESPONSE

(f)

The procedure applicable to inspection of these restraints i s QI-QAP-11.1 -28, Rev. 27, and is provided.

The procedure does not relate to the subj ect of inspections of the crossover leg restraint installations.

INTERROGATORY 3.

On page 3 of Attachment 1, Applicants state:

"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 com pleted ?

(c)

If the answer to (a) above is yes, provide any and all documentation regarding such inspections.

RESPONSE

3.

(a)

Yes.

(b)

N/A (c)

The following Travelers documenting the inspections are provided:

. a CE-84-1-31 -8 902 CE-84-132-8902 CE-84 -133 -8 902 CE-84-134-8902 s

INTERROGATORY 4.

Provide the following information cdgarding Applicants' to their 9/14/84 Response to CASE Motion for Discovery Regarding Inspections or' Main Coolant System Crossover Leg Restraints (9/7/84, TXX-4294, supplementary response to NRC):

(a)

Provide copies of the original and a$11 revisions of NCR-M84-100281.

RESPONSE

s 4.

(a)

NCR-M-84 -100281 is provided.

INTERROGATORY s

(b)

Applicants stated :

"Approximately two years ago, a decision was made to intentionally postpone completion of the installation (shimming and torquing) of the crossover leg restraints until af ter completion of Hot Functional Testing."

(1)

Who specifically made or had input into such decision (name, company affiliation, title, and j ob responsibility)?

(2)

Provide any'and all documentation for Applicants' statement above.

(3)

Uhat was the reason for the postponement of the testing until af ter completion of Hot Functional Testing and/or until power ascension testing?

(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 ascension testing?

(6)

If the answer to (5) above is yes, what is the reason for s.uch postponement?

(7)

If the answer to (5) above is yes, provide any and all documentation of the reasons for such postponement.

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~ RESPONSE-(b)

The decision referred-to in the quoted statement was made at a routine startup meeting and is not documented.

The decision related to installation of the shims between the pipe and the restraint structures

.and did not relate L to tightening anchor bolts at the

'baseplates.

As explained in the November 28 letter from Clements to Region IV (TXX #4370), work on the piping shims is. not relevant to the NRC's Notice of l

Violation.

INTERROGATORY t

s (c)

Provide the original' and all revisions of Test Instruction / Procedure Deviation (TPD) Report No. 12 on*

the Reactor Coolant System.

7

RESPONSE

^

-(c)

Test Instruction / Procedure Deviation (TPD) No. 12 is provided.

There have been no revisions.

The document is not relevant to the baseplate inspections' cited in i

the Notice of Violation.

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INTERROGATORY (d)

Provide any and all documentation that thermal

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monitoring of the shims will take place during power j

ascension testing (i.e., specific procedures which so I

j state, memoranda, etc.).

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RESPONSE

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(d)

Post Fuel Load Deffered Test Packages #5 and #12 are j

provided.

The piping work described in the documents is not relevant to the baseplate inspections cited in l

the Notice of Violation.

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l INTERROGATORY j

(e)

Provide any and all documentation that the " work i

required to be completed during plant heat-up af ter i

fuel load is identified as a known work item on the

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Master System Punchlict."

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RESPONSE

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t (e)

The quoted statement has been withdrawn.

However, a prin tout from the Master System Punchlist is provided.

The punchlist includes an entry for the baseplate work 3

l and the inspections performed to close NCR-M-84-100281.

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_. - _,., _....__ _. _.,..... _.._, ~., _....._._.

4 The Punchlist also contains an entry for installation of piping shims which was also completed af ter return to ambient temperature pursuant to TPD-12.

INTERROGATORY (f)

Provide the original and all revisions of NCR-M84-100182.

RESPONSE

( f)

NCR-M-84-100182 was referred to in the September 7 supplemental response only as a result of a typographical error.

The NCR relating to this subj ect is NCR-M-84-100281 and has been provided in response to interrogatory 4(a).

INTERROGATORY (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 on May 25,1983."

RESPONSE

(g)

Documentation of further work is provided by TPD-12 itself, and Deferred Test Packages #5 and #12.

These documents have been provided in response to interrogatories 4(c) and 4(d) above.

This work is not relevant to the baseplate inspections cited in the Notice of Violation.

INTERROGATORY (h)

Have Applicants performed any testing regarding the torquing of the bolts for the crossover leg restraint installations, especially in light of the results of Applicants' tests regarding the torque used for U-bolts (see CASE's Answer to Applicants' Statement of Material Facts As To Which There Is No Genuine Issue Regarding Consideration of Cinching Down of U-Bolts, in the form of Affidavit of CASE Witness Jack Doyle, at page 10)?

RESPONSE

(h)

No.

Crossover leg restraint anchor bolts have nuts installed snug tight and are not torqued in the sense that U-bolts are torqued.

. -INTERROGATORY (i)

If the answer to (h) above is yes, provide all such tests and test results.

RESPONSE

(i)

N/A INTERROGATORY (j )

If the answer to (h) above is no, do Applicants anticipate performing any such tests?

(If not, why not?)

RESPONSE

(j )

No.

Because the bolts are not torqued, no tests are necessary.

INTERROGATORY (k)

If the answer to (h) above is no, what assurance is there that the bolts will perform in a predictable manner throughout the life of the plant?

RESPONSE

(k)

The snug tight condition on the anchor bolts is consistent with design requirements in a current DCA.

Double nuts have been provided to prevent nut loosening.

No design consideration requires that the anchor bolts be other than snug tight.

The considerations involved in torquing of U-bolts and addressed in Applicants' motion simply are irrelevant to baseplate bolts.

CASE may note that the crossover

-._.s leg restraint base plate is designed with shear lugs embedded in concrete, which provides for shear transfer at the base.

_,,,,_~s.

INTERROGATORY (1)

Provide any and all docunentation for your answer to (k) above.

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RESPONSE

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(1)

See the design documents provided in response to interrogatory I above.

In particular, see DCA #11, l

312, Rev. 2.

. INTERROGATORY (m)

Applicants state:

"We will conduct the necessary inspections when an engineering determination indicates 2

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.

RESPONSE

(m)

The statement referenced in the request has been withdrawn.

The incomplete inspections of the baseplates cited in tha Notice of Violation have been completed as described in response 3 above.

l INTERROGATORY i

(n)

Applicants state:

"It is unclear whether the inspector saw the QC inspector's checklists for the crossover leg restraints.

TPD-12 was not pecsonted to the inspector."

(1)

Why would the NRC inspector not have seen the QC inspector's checklists for the crossover les 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 answer, in detail, what steps Applicants have taken to discover the answer to these questions and the results of Applicants' i

efforts in this regard, and the answers to the following questions:

(i)

How could this have occurred?

(ii) What assurance is 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 Comancho Peak) problem?

+ RESPONSE (n)

(1 )

Aaplicants believe that the NRC inspector did see t ac QC inspector's checklists.

The recollection of the responsible QC inspector maintaining the open checklists is that he presented the

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checklists to the NRC inspector for his review in i

November 1983.

The situation was referred to as

" unclear" in the referenced statement because the NRC Notice of Violation (84-08-02) indicates that no documents rec,uiring inspection of the restraints coulc be found.

As described in response to request 3, the incomplete inspections have now been performed.

INTERROGATORY (n)

(2)

(1)

Why was TPD-12 not presented to the NRC inspector?

l (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 i

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)?

i (iv) Include in your answer, in detail, what steps Applicants have taken to discover the answer to these questions and the results of 1

Applicants' efforts in this regard, and the answers to the following questions:

(aa) liow could this have occurred?

(bb) What assurance is there (including any and all documentation for such i

assurance) that this has not and will not also be the case in other instances?

(cc) What ste)s have Applicants taken to 4

assure t aemselves (and the Board) that this is an isolated instance and not a generic (to Comancho Peak) problem?

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i RESPONSE (n)

(2)

As described in the November 28 letter from Clements to Hunter, the September 7 supplemental response with respect to TPD-12 and piping shim work has been wit adrawn as irrelevant to the baseplate issue.

INTERROGATORY (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."

RESPONSE

(o)

As explained in the response to Region IV, the quoted s ta temen t has been withdrawn.

INTERROGATORY

( 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 o f f) 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 complete details, including the name(s), title (s), specific areas and systems on which the individual (s) wocked 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 les 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.

RESPONSE

i (p)

(1)

No (p)

(2)

N/A

( p)

(3)

The Applicants have reviewed the files for all QC inspectors involved with the installation of the crossover leg restraints.

None of the individuals was connected with the subj ect drug-related problems.

INTERROGATORY (q)

How much of the information requested in the preceding was:

(1)

Requested by the NRC representative at the CPSES site?

(2)

Provided to the NRC representative at the CPSES site prior to this pleading?

RESPONSP.

l (q)

(1 )

As described in response to interrogatory 4(n)(1), the NRC in s pec to r had access to all documents referenced above related to the baseplate installations at the time of the i

inspections in November 1983.

At the time of the inspection, the NRC did not seek information with respect to l

the piping shima, and there is no reason why it should have done so.

This 1

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information was volunteered and made s '

available by Applicants at the time of

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the September 7, 1984 supplemental response to the Notice of Violation.

(q)

(2)

All information relevant to the Notice

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of Violation referenced in these discovery responses has previously been made available to the NRC representative at the Comanche Peak site.

1

i Respec ful y submitted,

/

Nichol)' S Reynolds Davidle. Re pka BISH0E, L{ GERMAN, COOK, PURC' L uMD REYNOLDS 1200 Seventeenth Street, N.W.

Was hing ton,

D.C.

20036 (202) 857-9800 Counsel for Applicants November 30, 1984

l tiNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD s

In the Matter of

)

)

TEXAS UTILITIES ELECTRIC

)

Docket Nos. 50-445 COMPANY, et al.

)

50-446

)

(Comanche Peak Steam Electric

)

Application for Station, Units 1 and 2

)

Operating Licenses) j AFFIDAVIT OF CLAIRE H.

WELCH I,

Claire H. Welch, having first been duly sworn, hereby depose and state:

1.

I am employed by Texas Utilities Generating Co. at Comanche Peak Steam Electric Station as a Site QA Supervisor.

1 I

2.

I have been responsible for providing the information contained in " Applicants' Responses to CASE's Discovery Requests regarding Crossover Leg Restraints."

I have reviewed the responses and they are true and correct to the best of my knowledge and belief.

1

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Claire H.

Welch 573re cc wra S ca,suev orss.s<w,!'"

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I Subscribed and Sworn to before me this 47 d day of November, 1984

$</ O J/e dce. -

Ndtary Public b, < :r, jk ac,c >

r,y co m,nts cre a ;Yper:84-100281.

With regard to the Staff's I

additional questions, we provide the following responses:

1 Enclosure TyX-4370 Page 2 Cuestien 1 What document (i.e.,

operational traveler, etc.) iraplemented Procedure CP-QCP-3.1 for inspection of the crossover leg restraint?

e Resoonse The inspection checklists which were attached to f CR-M8.4-100281 were the documents that implemented CP-QCP-3.1.

Questien 2

/

How was the intentional postponerrent of the reouired inspection cocumented?

Response

s The activity discussed in cur September 7 response that was intentionally postponec was the shirrninc cn the top of the crossover leg restraint, related to piping work.

Acccrdingly, as r.oted above, we withdraw that ciscussion as not relevant tc the flotict cf Violation.

Cuestion 2 Was the individual that signed the CC inspecticn checklist for the crossover leg restraints (attached to "PC F84-1C0251) certified to make these in-spections at the tire the inspections were made?

Rescense tio.

The individual vero signed the inspection checklists in questien was certified Level Il for visual exenination on January 28, 1978 in acccrdance with Brown a Rnnt Incorporated Personnel Training P,anual.

He was not, however, certified to perform the full scope of the inspections covered by the checklists until Septemoer, ;978.

Considering the incividual's inspection background, there should be no questien relative to his qualificatiens for performing all of the inspections.

s Ouestion 4 Why were the required inspections related to positioning, leveling and bolt torcuing of the ficor trounted crossover leg restraint postponed, since the gap measuren:ents to deternine shim requirements taken during hot furetional testing would be based on the permanent location of this restraint?

Enclosure TXX-4370 Page 3 f

Resconse As noted above, the statement in cur September 7,1984 supplemental response confused piping-relatec shims on tcp of the crossover leg restraints with a

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shimming attribute en a checklist used to install the Crossover Leg Restraints.

The shirrning attribute on the checklist was previded in case baseplate leveling shims were used.

There would be no reason to await hot functional testing before performing the baseplate work.

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ga* 88cg UNITED STATES

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NUCLEAR REGULATORY COMMISSION f.I REGloN IV

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%,,9, D4g PAPKWAY CENTRAL PLAZA BUllolNG 611 HYAN PLAZA CRIVE SulTE 1000

,a ARUNGToN. TEXAS 7Eo11 MOV 0 2 W In Reply Refer To:

Dockets:

50-445/E4-03 Texas Utilities Electric Ccepany ATTN:

M. D. Spence, President, TUGC0 Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Gentlemen:

Thank you for your letters of August 23, 1934, and September 7, 1984 We have reviewed your replies, end the supplemental information you provided in your letter of September 7, 1934, raised some questions concerning the Severity level IV Violation (445/S403-01), Failure to Perform Inspections of Installation Activities Related to Unit 1, Main Coolant System Crossover Leg Restraints.

In addition to reviewing your response, an NRC inspector also reviewed your Tracking Item #135 package of related information, and discussed the subject with cognizant TUGC0 representatives.

The questions that arose out of these reviess and discussions are delineated below:

1.

What document (i.e., operational traveler, etc.) implemented Pro-cedure CP-0CP-3.1 for inspection of the crossover leg restraint?

2.

How was the intentional postponement of the required inspections documented?

3.

Was the individual that signed the CC inspection. checklists for the crossover leg restraints (attached to NCR.Y84-100281) certified to make these inspections at the time the inspections were made?

4.

Why were the required inspections relatd'EIpositioning, leveling, and bolt torquing of the floor mounted crossover leg restraint postponed, since the gap measurements to cetermine shin requirements taken during hot functional testing would be based on the permanent location of this restraint?

We request that you provide ycur response to the above questions within 20 days.

The response directed by this letter is not subject to the clearance procedures of the Of fice of Paragement and Euc;et as required by.M;p, Paperwork Reduction Act of 1930 PL 96-511.

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Texas Utilities Electric Com any 2

Cummins (817)/897-2201).Should you have any question regar r, please contact Mr. J. E.

Sincerely, D. R. Hunter, Chief Reactor Project Branch 2 CC:

Texas Utilities Electric Company ATTN:

B. R. Clements, Vice President, Nuclear Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Texas Utilittes Electric Company ATTN:

H. C. Schmidt, Manager Nuclear Services Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 5

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a UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE. ATOMIC SAFETY AND LICENSING-BOARD In_the Matter of

)

)

6 TEXAS UTILITIES ELECTRIC

)

Docket Nos. 50-445 and COMPANY,'et _al.

)

50-446

)

l -

(Comanche Peak Steam Electric

)

(Application for Station, Units 1 and 2)

)

Operating Licenses)

CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing " Applicants' 1

Response to CASE's Discovery Requests Regarding Crossover Leg Restraints" in the-above-captioned matter were served upon the following persons by hand delivery,

  • or by Federal Express **,

or i

by deposit in the United States mai1***,

first class, postage j

prepaid, this 30th day of November, 1984:

i

  • Peter B.

Bloch, Esq.

      • Chairman, Atomic Safety and Chairman, Atomic Safety and Licensing Appeal Panel

)

Licensing Board U.S.

Nuclear Regulatory U.S.

Nuclear Regulatory Commission i

Commission Washington, D.C.

20555

}

Washington, D.C.

20555

      • Mr.

William L.

Clements i

    • Dr.

Walter H. Jordan Docketing & Service Branch 881 West Outer Drive U.S.

Nuclear Regulatory Oak Ridge, Tennessee 37830 Commission Washington, D.C.

20555

  • *Dr. Kenneth A. McCollom i

Dean, Division of Engineering i

  • Stuart A.

Treby, Esq.

I Architecture and Technology Oklahoma State University Office of the Executive Stillwater, Oklahoma 74074 Legal Director U.S. Nuclear Regulatory Commission i

      • Mr. John Collins

~

7735 Old Georgetown Road j

Regional Administrator,'

Bethesda, Maryland 20814 Region IV. __

j U.S.

Nuclear Regulatory

    • Chairman, Atomic Safety and Commission i

j 611 Ryan Plaza Drive Licensing Board Panel l

Suite 1000 U.S. Nuclear Regulatory Arlington, Texas 76011 Commission j

Washington, D.C.

20555 i

i

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a ***Renea Hicks, Esq.

    • Mrs. Juanita Ellis Assistant Attorney General President, CASE Environmental Protection 1426 South Polk Street Division Dallas, Texas 75224 P.O.

Box-12548 Capitol Station

  • Ellen Ginsberg, Esq.

Austin, Texas 78711 Atomic Safety and Licensing Board Panel

      • Lanny A.

Sinkin U.S.

Nuclear Regulatory 114 W.

7th Street Commission Suite 220 Washington, D.C.

20555 Austin, Texas 78701 i A Nicholi s S.f eynolds b

cc:

John Beck Robert Wooldridge, Esq.