ML20102A605

Motion for Reconsideration of ASLB 840629 Memorandum & Order Re Rulings on Cap Welds Due to Concern of Safety & Health of Public.Certificate of Svc Encl

ML20102A605
Person / Time
Site:	Comanche Peak
Issue date:	02/04/1985
From:	Ellis J Citizens Association for Sound Energy
To:	Atomic Safety and Licensing Board Panel
References
CON-#185-430 OL, NUDOCS 8502080466
Download: ML20102A605 (18)

Text

'

p-D 2/4/85

~

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 00CKETED

'BEFORE THE ATOMIC SAFETY AND LICENSING BOARD UShRC

~

b 4.

In the Matter of I

Docket Nos 50-445 aBE 50 44NeJJl :32' 2

i

- TEXAS ' UTILITIES ELECTRIC 1

f COMPANY, et al.

l c,, - _.. _

7-l (Application' for an '

(Comanche Peak Steam Electric I

Operating License)

Station, Units 1 and 2) l CASE'S MOTION FOR RECONSIDERATION OF

^

LICENSING BOARD'S 6/29/84 MEMORANDUM AND ORDER (Written-Filing Decisions, #1: Some AWS/ASME Issues)

CASE'(Citizens Association for Sound Energy), Intervenor herein, files this, its Motion for Reconsideration of Licensing Board's 6/29/84 Memorandum and Oider;(Written-Filing Ifecisions, #1: Some AWS/ASME Issues). This Motion concerns the rulings by the Board regarding cap welding.

In its decision,

~

the 3oard stated that Applicants would be dealing with_AWS/ASME design

' issues in a separate written motion, and that (page 5):

"Atlthis time, we' address only whether welding procedures at Comanche 13-Peak that are based entirely on the ASME Code are adequate to assure the fabrication of sound welds [ footnote omitted] - when used by qualified welders in the context of an appropriate QC (quality control) system. -(For the purpose of deciding this motion, we do not consider it relevant to determine whether Applicants use qualified welders or thave an appropriate QC system.) In addition, we are concerned with the

' appropriateness'of Applicants' precedures for weave welding,-downhill welding, preheat requirements, and cap welding (footnote omitted].

This motion does not cover in any way whether the plant has been constructed according to the applicable procedures."

t-

-(Emphases added.)-

. Cap l welding was specifically discussed in the' Board's Order:

-8502000466 050204 DR ADOCK 050004y 1

l g363.

p-At.page 9:

a "With respect to cap welding, the core ' disagreement' is that Applicants state that there are no ' unique restrictions in placing new weld material cxt an old weld,' and CASE attempts to rebut this by stating that each pass of a multiple pass weld 'must have the same heat

' input as.provided... by Table 2.7.'

However, this does not join the issue. Applicants never contended that heat input requirements are inapplicable. -Heat input is not a ' unique' restriction on a multiple N

pass, it.is uniformly applicable to all weld passes regardless of whether they are part of a ' cap' weld made some time after the remainder of the weld is completed.

"With respect to. undersized welds, there is no reason to believe that the original weld material would be subject to an increased risk of cracks. Hence, they represent no special risk and there is no reason given by CASE to prohibit repair by laying on a new weld over the top.

"With respect to underbead cracking, CASE does not indicate any AWS section to'which. applicants ought to comply but to which they do not comply."

(Emphases added.),

On page'11:

"... Applicants' procedu es for.... cap welding comply with the ASME Code./13/. CASE-has not indicated that there are any provisions of the.AWS code that need.co be applied with respect to these factors in order to assure' adequate' safety of the welding process. Staff has found that Applicants' procedures also comply with the AWS Code, and CASE has not persuaded us otherwise."

"/13/ Applicants' Affidavit (Affidavit of W. E. Baker, M. D. Muscente, J. D. Stevenson, and R.~E. Lorentz,.Jr. Regarding Allegations Involving AWS and ASME Code Provisions, April 2, 1984) at 17-21."

H The underlying-and primary concern.of CASE has always been with the publid' health and safety, and the impact of. the = manner in which. Applicants

-have designed and constructed Comanche Peak on such' health and safety. This 4

.is also'true regarding.the issue of. cap. welds. New and significant.

information supports CASE's concern that the extensive use.of cap welding at-

-Comanche Peak may be unsafe and jeopardize the public health and safety.

2 e,

j

The basis for CASE's Motion for Reconsideration is a discussion during the 1/10/85 meeting between the NRC Staff, Cygna Energy Services, and

' Applicants regarding the Phase 3 Independent Assessment Program for Comanche Peak /1/. CASE-moves that the Board obtain a copy of the transcript of the 1/10/85 meeting and that the Board review and take official notice of the transcript /2/, which states (pages 54-60) regarding Observation PS-04:

"MR. BRIDGES [EG&G Idaho]: The final one I have is pipe support observation 04, had to deal with the minimum size of the fillet welds.

You concluded.that this observation should be closed, based on a stress analysis. And my concern here is that the requirement for those minimum size welds isn't a stress requirement, but it's a procedural

. requirement to assure weld penetration. And it seems like you have two options to get around this: The code allows you to get around it by using special welding techniques -- for example, preheating the thicker plate -- or doing something special in terms of inspection.

"So I question qualifying this based on stress analysis since it's a --

"MR. TERA 0 [NRC/TRT]: Let's see if I understand the concern here, Tom.

-You are saying it's not that they found undersized welds but undersized welds-were specified on the design drawing; is that what you are saying?

"MR. BRIDGES: That's correct. The welds were in accordance with the drawings. They were specified.

"MS. WILLIAMS [Cygna):. We agee that there's a code violation there, so we agree.on the definitional problem.

I'think all we were trying to say here was the basis why there was no design impact when we went back and checked the numbers.

f1/ For the. convenience of the Board, we are attaching copies of the applicable.pages from the Phase 3 Cygna Report; we have indicated on them the sections from which they are taken.

f2/. CASE will be referring to many portions of the 1/10/85 meeting in other pleadings in addition to references made in the instant pleading.

Further, CASE believes that this entire transcript contains much

- information in which the Board has indicated it is interested and which will_ very likely be discussed in future hearings on the Cygna Reports.

CASE is only_ quoting the portions here with which we are primarily concerned in this Motion, with enough information so that the Board can understand the context; however, there is additional.information in the

. transcript which will be of interest to.the Board. _ The burden should not be upon CASE to quote.the entire transcript or to supply the Board with entire such transcripts.

3

[T

~

1 y

"MR. BRIDGES: My comment is the requirement isn't a stress requirement, but it is something to assure that you have a sound weld.

"MS. WILLIAMS:

Oh, from an installation standpoint.

"MR.' BRIDGES: That's correct. Don, is that a correct interpretation?

','MR.L ' LANDERS [Teledyne Eng. Services /NRC Consultant]: Yes.

"MS.: WILLIAMS: We agree."

(Emphases added.)

(There then was a discussion regarding possible changes in the AWS code, which the' Board may want to read also.)

"MR. BUSH [ Review and Synthesis Association):

I think your question is more basic, though, and that is, do you have a good weld? That's a different matter, and that gets into what you should do - te establish that'you have~a-good weld, if it's there.

"In'other words, if they are consistently ' undersized' as defined by

that,.the argument is that you don't have enough heat input that you might have cracking. That's another animal.

s

- '"MR. LANDERS: Except if the design drawing calls out X size weld and the procedure is adequate for an X sized weld, that's the difference;

. the assumption is the weld can be made'. to whatever size it's qualified to be :made' to.

"MR. BUSH: I All I'm saying is you don't know that per..se.

'"MR.) LANDERS:. You have to look.at the weld procedures; but the fact

~

lO that it's smaller-than the code requirement -- in.today's world --

"MR. BUSH: Is it-to the procedures or not, is it below or not, and then more importantly, is'it a good weld or not? That's really the gut issue on the thing."

'(Emphases added.)

m "MR. : TERAO: 7 It may.be'a closed issue from the Cygna standpoint, but we_.

are stil1~1 eft with a violation of the code.- And a violation of the

- code is important-in-its own right,.because.it contributes to the s

. worker's understanding of the extent to which codes-are to be followed E scrupulously and taken seriously. So the question really focuses on c

r s

-4

why did this occur? How can someone specify a weld size less than minimum code when it's very clear all he has to do is look in the table and see what weld size he needs? How could that occur?

"MS. WILLIAMS: Made a mistake.

"MR. LANDERS: Unfortunately, he probably did it based on analysis.

And that was demonstrated to be acceptable by Cygna in their review."

(Emphases added.)

"MS. WILLIAMS: TUGC0 did take some corrective action in the first paragraph here, just.to be clear on this one too, Tom.

"MR. BRIDGES: Which was?

"MR. MINICHIELLO [Cygna):

Basically -- TUCCO had committed to review the drawings, reissue them for vendor certification, and basically fix the supports. Bring the welds up to code.

"MR. BUSH: You can do that by putting a wash pass on and that will make it worse, not better. -You've got to be careful of that.

"MR. LANDERS: That's right.

If what we are worried about here is safety, that's not the best approach.

"MR. BUSH: That might make it worse, not bitter. Because the standard procedure is often to put a wash pass on and that doesn't accomplish much of anything, based on practical experience.

I'm not talking, now, about precisely meeting the code.

"MR. GEORGE [TUGC0]: We have done just that on a lot of welds that were supposedly quarter-inch fillet welds. QC put gauges on them and the come up with findings like those -- in fact 7/32 instead of one quarter; and the corrective action is we go in there and do just what you said.

It's been done all over the plant.

[

"MR. BUSH: I know it.

At about $1500 a weld.

"MR. GEORGE: That's correct.

.(Emphases added.)

(Additional discussion followed regarding possible change in procedures

- and the codes, significance, whether it met the code as it was at the time, etc.)

5

~. - -

t 4

As indicated by the preceding, CASE's concerns regarding cap welding

'(that it may cause cracking, and even be worse than leaving the weld

. undersized, thereby making the weld unsafe) appear to be shared by Messrs.

? Bridges,. Landers, and Bush. Particularly disturbing is Mr. George's 1

statement that this has been done all over the plant, thereby making this a

. generic problem to Comanche Peak, the exact' extent of which is unknown.but

apparently extensive.

-CASE: realizes that the statements made during the 1/10/85 Cygna/ Staff

-/ Applicants meeting.were not under oath. However, it is a well-established

-principle that' Applicants are expected to tell the truth to the NRC i.

fregardlessaof whether or'not statements'are made under oath; Applicants are

? aware of this. Also, there is no reason to expect that Cygna or the NRC

' Staff or.'the'ir: representatives would not have made the same statements had Lthey.been under oath. CASE moves that-the-Board-invite Cygna, the NRC-

, Staff, and Applicants to correct the transcript of the-1/10/85-meeting:

-(similar?to the opportunity afforded in the Board's 11/9/84 Memorandum ~

(Official-Notice Concerning' Pipe Supports), where the Board allowed the t

~

' parties to-file corrections' within ten days). -In.the alternative, if the:

-Board-believes it needs additional:information, CASE moves that the Board' invite;the parties toJfurther discuss,and clarify this matter /3/.

f

^

e

' s r

1/3/= lt.should be noted that CASE has filed' this Motion for Reconsideration -

~ at-the request.of CASE Witness-Jack Doyle, following his review of the

~ > :

11/10/85 meeting transcript.

i

. r

=6

~ <

J

~~

7

- IN CONCLUSION:-

For the reasons discussed in the preceding, CASE moves:

(1) That.the Board: obtain a copy of the transcript of the 1/10/85 Cygna/NRC Staff / Applicants meeting; review such transcript; and

, take official notice of the transcript.

(2)~ That the Board invite the parties and Cygna to correct the g

transcript of the 1/10/85 meeting (similar to the opportunity afforded in the Board's-11/9/84 Memorandum (Official Notice

. Concerning' Pipe, Supports), where the Board allowed the parties to file corrections within ten days).

_ 3), That the BAard reconsider its 6/29/84 Memorandum and Order

(

(Written-Filing Decisions, #1: Some AWS/ASME Issues) regarding cap L

welding and find that:

(a) The practice of capping welds by putting a' wash pass on over. an undersized weld may make it worse (not better),

and may cause cracking..

(b) Such practice may' jeopardize the public health and safety.,

~(c) Applicants have made a practice of capping welds by.

putting a wash-pass:on over an undersized weld, and the

. exact extent of such practice at Comanche Peak is V:

unknown but extensive and has been done all over the plant, including safety-related areas.

a 7

f I ['}

(d) Under such circumstances, even if Applicants are in compliance with applicable codes, the following provisions of 10 CFR Part 50, Appendix A, Criterion 1, must be applied:

"Where generally recognized codes and standards are used,.they shall be identified and evaluated to determine.their applicability, adequacy, and sufficienty and shall be supplemented (nr modified as necessary to assure a quality product in keeping with the ' required safety function."

(e) At the present time, a condition exists at Comanche Peak (the exact extent of which is unknown but which is extensive and has been done all over the plant, including safety-related areas) which renders-the adequacy of welds which have been capped, as well as the safety of the plant, and the public health and safety, indeterminate at best.

Respectfully submitted, m=W f//2

. % s.) Juanita Ellis, President GSE (Citizens Association for Sound Energy)-

1426 S. Polk Dallas, Texas 75224 214/946-9446~

8

j. ~

c.

v-.

No. TR-84042-01 FINAL REPORT INDEPENDENT ASSESSMENT PROGRAM OF COMANCHE PEAK STEAM ELECTRIC STATION (PHASE 3)

Prepared for Texas Utilities Generating Company 2001 Bryan Tower Dallas, Texas 75201 Prepared by Cygna Energy Services 101 California Street, Soite 1000 San Francisco, California 94111 a

1 o '1/ Tf Approved by

/

/ ate D

Project Manager

/',/

s

/

/

/IF

//h W

},'

i or Review Team

. Approved sw -

Sen Date July 16, 1984 u:

1lll111111!!!!!!!1111111111lll

Observation yea,f L4M' fd Record it!!!!!!!!!!!!!illiiiiiiiiiii!

d-Checkilat No.

.PS-042, PS-050 Revision No.-

0 sheet 1 of 1

Observation No.

PS-04 g,

Orio:nated ay C.K. Wong pl Q, $. Q q oste 7/1/84 7h0((4

- Reviewed By G. Bjorkman

],Q g0 Date 6 Q

' 1.0 Description The fillet weld size specified on the following drawings is smaller than the minimum fillet weld size required by the ASME B&PV Code:

Support CC-1-028-725-533R, fillet weld between items 1 and 4.

Support CC-1-031-009-S33R, fillet weld at support nodes 6 and 11, 2.0 Requi rement 2.1 Gibbs and Hill, Inc., Specification 2323-MS-46A, Rev. 5, for the Comanche Peak Steam Electric Station, Section 3.3 " Codes and Standards", subpara-graph a.(2) (p).

2.2 ASME B&PV Code,Section III,1977 edition plus addenda through winter of 1979. Table XVII - 2452.1-1 " Minimum Size of Fillet Welds and Partial Penetration Welds".

.3.0 Document Reference 3.1 Brown and Root Pipe Support Drawing CC-1-028-725-S33R, Rev. 3 3.2 Brown and Root Pipe Support Orawing CC-1-031-009-533R, Rev. 3 4.0 Potential Design Impact For the two minimum fillet weld size vlolations observed, tne weld stresses are well within allowable stress with the weld size indicated on the drawing.

Thus, there is no impact on tne design. However, they are code violations.

Attachment A.

Observation Record Review.

l Estent A

lExtenelve l Other (Specify) f leolated l

Texas' utilities Electric Company; 84042 Independent Assessment Program, Phase 3

Observation 4L t i Record Review Attaehment A Revision No.

O Checklist No.

PS-042,PS-050 Sheet 1 of 1

Observation No.

PS-04 Yes No Valid Observation X

Closed X

Ccmments 1.0 Probable Cause 4

Design oversight / documentation error, f

- 2.0 Resolution In their respsonse, dated June 8,1984, question 31, TUGC0 concurs with Cygna's observations that the welds are 1/16" undersize on the drawi ng. In that letter, TUGC0 has noted that both drawings were revised and reissued for vendor certi fi cati on.

In the 131 supports (with numerous welds) reviewed by Cygna in Phase 3, these were the only two weld size violations. As such, Cygna considers the error isolated. In addition, neither weld violation had design impact since the i

loads on both welds were small. Therefore, this observation is closed.

i 3

!~

?

I l

l C Approvals oa 7/(c/ N or****

c. K. LO owg.,

%y/[

Date Q f @,,,,, [}, g _

Project Engineer -

/"WM3f&-4

/

o=i. 7//4/ry erai.et wa=e-

• • "* * ** ' = dFusM//A/4G/e m c Y lil /d u Texas utilMs Electric Co'mpaify; 84042 Indeoendent Assessment Program, Phase 3

.c.

~

Independent Design k09J Review' Checklist' Lt i

~

I PIPE SUPPORT CC-1-028-725-S33R m

C; viewer

_d.P. Russ/C. Wong App,ov.,

.l. Minichiello Checklist No.

PS-042 Calculation No. CC-1-028-725-S33R, Rev. 2; B&R Drawing No. CC-1-028-725-S33R, Rev. 3 Date 3/1S/84 S atisf actory Item Yes No N/A Comments 4

21.

Is the design of the support frame member in accnrdance with Cygna Criteria 84042-DC-2, Section 4.1.107 X-l

22. Is the design of the welded connection of the X

Weld of Item 1 to Item 4 is members in accordance with Cygna shown and checked as a 1/4" Criteria H4042-DC-2, Section 4.1.10?

fillet. S/16" fillets are minimum required. Weld is l

acceptable per TilGCC response dated

. lune 8, 84 to Cygna Question 31 (see Observation PS-04).

The weld of item 3 to item I is checked using enveloped emergency l

loads. The actual and allowable loads were incorrect, and wrong j

weld pattern was used in calculations. However, the welds are acceptable per Cygna Cdlculation F-13 (84042, 4-F).

23.

Is the design of the member connection, including local See comments under item 22.

stiffening, adequate for load transfer in accordance with Cygna Criteria 84042-DC-2 Section 4.1.10?

X 1

Tcxas Utilities Electric Company; 84042 Sheet 9 of 10 Independent Assessment Program, Phase 3 b,f

~

Mt Independent ' Design

~

i Review Checklist E"""""""""

PIPE SUPPORT CC-1-028-725-S33R

Ceviewe, J.P. Russ/C. Wong

. Approver J. Minichiello Checklist No.

PS-042 Calculation No. CC-1-028-725-S33R, Rev. 2; BAR Drawing No. CC-1-028-725-S33R, Rev. 3 Date 3/15/84 Satisfactory item Yes No N/A Comments

21. Is the design of the support frame member in accordance with Cygna Criteria 84042-DC-2, Section 4.1.10?

X 22.

Is the design of the welded connection of tha X

Weld of Item 1 to item 4 is members in accordance with Cygna shown and checked as a 1/4" Criteria 84042-DC-2, Section 4.1.107 fillet. S/16" fillets are minimum required. Weld is acceptable per TUGC0 response dated June 8, 84 to Cygna Question 31 (see Observation PS-04).

The teld of Item 3 to item I is checked using enveloped emergency loads. The actual and allowable loads were incorrect, and wrong weld pattern was used in calculations. Ilowever, the welds are acceptable per Cygna calculation F-13 (84042, 4-F).

23. Is the design of the member connection, including local See comments under Item 22.

stiffening, adequate for load transfer in accordance with Cygna Criteria 84042-DC-2, Section 4.1.107 X

i t

Texas Utilities Electric Company; 84042 Sheet 9 of 10 Independent Assesstnent Prograrn, Phase 3

Independent Design Review Checklist L

t i PIPE SUPPORT CC-1-028-725-S33R R e'esswer d.P. Russ/C. Wong approver.

J. Minichiello Checklist No.

PS-042 Calculation No. CC-1-028-725-S33R, Rev. 2; ll&R Urawing No. CC-1-028-725-S33R, Rev. 3 Date 3/15/84 Satisfactory item Yes No N/A Comments

24. Code Allowable Stress Requirements:

a.

Does the design meet the requirements.of Cygna

'X See comments under Item 22.

Criteria 84042-DC-2, Section 4.47 b-Does the design meet the requirements of X

Gall ffpecification 2323-MS-46A, Rev. 5, Section 3.6?

For buckling, is the appropriate length used, X

(,

considering the full unstif fened span?

25. As-Built Support:

Do the dimensions, section properties and configuration X

of the as-built support conform to the final design calculation?

A Texas Utilities Electric Company: 84042 Sheet 10 of 10 Independent Assessment Program, Phase 3

9.1.W,e,e;i.r,. -

c..

7

n --

s,ql y /.: :

s-

, g, 1

s.

-Q X.

1

,i i

m i

m m

s 1.L1 m

, =.

wr.;;dw s- =;;,,4 er t

':=.

s.

,-s c.,

s m

u-i

h. ;. l w n

}.

x

.u i i

t ? { e

-l

~

i I-i..

m c.n 5

-c 9 t

s W,M B.

s y i

e ctt '

m

,.* m o

i.a Qr R

g U

- a

r y

w.

v E.c

~

A; %

l

[

- $l $'

(;q

~

W

^

l c- (.

l%,e w g

2=5 J"

a

s W

= '

i o x

i ; t :;

3p f

[>.

G c:

iD 5 y e

J;*1, s-1

=

s; s. l:a:;h gg <

p

,g

o _m o

= E 7 h e

• stg a pq E

,7 i t.

N

.h h:. :.

j h

Et

.I

'r

1. l a

i 8+4

=

5

-l 5 g dyp C

15,o. sd :f

}qs D,a-r i

'~

g

3 at =2

.:c s. e -

e-S h

Moo n

h=3

.s r.

a t em e<

i Ot D

')

'^'

a pale >o s g! = tid @5; J Pl

- a t s 4

p.

(*

QJ l

om 8

sb'uye m aa os e

& 4(

u 6

&e h,,s a G

.c 2 *=:

-l 4, g e.W.a t e F

E55 g

m.

d..g.

e

!! Tgg:; ; j.: j! ; W a

i 3ydgi E

N IN WlV M.C[1k.p:*,Mj art @ l l i **

I IE {iilbiN I J' Cd EKi 'lif @

5 3jFieA I l d *p 3E i iL-INf Md y*

1 T

l ii 4 4 1 1 2 V 2 ipii AW

,I N,W EB H 4 4 Elft.

E 1.h f 3@

@jml 1.i

,u

.. ~

J J{

F.

7

- f. O l',

a e

.Y.ws 4

s '.

8' 8.8 7 n,d.!{!5)h; a-r N

.g.

K e

as

.g, 5

e'r sp=W %g I

N. f-4 e

!l l

%~,

e dh.;

we au

.j f3 5, G_

p 1'

E9 n

y

.,l e

s p

l

.y /, j'

=e.

_. &.,. y.g,.,.. ;w.{"

m.

s. \\r/5 n:

t

.u 1

an u.uw x-

..~jij (

7 gJ 2M li l

--e i t-l.a

>d Wh

'I a

- ),h{

M.

l_h.

E q=o*f o

hen a

e,9.

8,3. i. a, s,e. a..

m n

ux w

w

v

(

n 9

1 v,!

_ m-!s j

'r " $ a d3 J.

us e

.Mf

.WI GO$~e k.J s4

&W M.. W.,,.h s.)' #

!EhiM, i

we y

A i,

m. p.

. gj;(

p

3. g i

5-af d 3l

~

'i

+ '.

l

?

g,, ^j%

.~

~

n 'm

.e m

."Ib t

s G 1

r--

.I

._cs w y

t p,4 ', 'S

I

,C a..,

g. 3

.o g

l-ag

'e y

om

", u:.'t

-(

e.-

g.

.. l a/..j sA. ;i.=F: 5h-v win b.l J'W

,,,1 4,...,;. + 4- =

L::: -+

p g r. ;,.:.~.%

.l -

. o a

w

.i H;tj,.: t 8

,~

l gi l'1..

4 iu. q= 9 relg

u...a w. n.z w jag l::.e-". t :-. m..w

% 9.g g.. 4., h

t 5

.r g,

5 s a.

-. m e. /..

---.---c.-.-

,,,-,w.

,v-,

r,-ry-v<-

e,--ww,,-.-n-e.-r---

m,,.-_--ww.w<--.---,r---,--e,y. -, -

w--+.------.-s.--.--+

p.E. 3 4 a.

.e ;o1

.{.

h,*,..

..,, >.. ;11f.;.,_,.2 p.9 y pv4w n.

a t

.;, 3.,73..- - -

-.. -.... =

• l'rB~t W =

'.~-I

.rwl0.

h4 OJCLINE 4144' 9

w). sa.as N' i i ss s

=

l

.om cur

.~.

w.>

l i 1,./.h. :.

i

m'AS. BUILT 8

. f gef M s.

_p u

us.

c p

3

,_e-3 i

Iy V

_ _ _O, gg:::- ::, -:::-:::

.. 8.

E S-ly- -.-tl-4 L

l mcon erswe.r

.- i 4

..n

.c

,{

'e k

s

, ns..aao' two" -

u. ' ^

r -

- - g.-

, j.r L+

i 4

L.

I j-is L-.+

4 _l-

.(

r l

)

i

-~

4 vo-i.im2 A

_ s't" d j

'"' SE C ~10K1 W A

mt. e... r!'

C i

HK.* vo.t on 'tio-SWt k

. fos arrused f-p:rnod r-e :*-

.,u.

I

.i ysj.

MY.St t.

I f

8'

.a.

~

ceses.

L.

r-K%

r 5

h alA u s m i m

K 3...,..

, p

.. y' b urs m 5~. 9o-

'3.0 h W c...,=

II D.E a

r x______

(.- w}

l

. c 97.

- %m m i. g y..p' gyiyipp'- Mg' i.

J Oc., '

A 1

-?

N'o

• t \\'i-d, l

ser.==o cerui t g i

l'!,@ !.

. *iuetn wret' w'f H

g'Y

' 'y J

i [t-'

s._ -,..

y*y m

~~ #

~ ~Sl~C T)dfj *DIO* *

[ VENDOR CERilElEQ

,mla.lca yag DEscarprion anown a noor,me.

{ uL

- = y%g' gqmmm I

1> DRAWitiG REV. Q e

i iA g

8"*"'"*** **""*c'a"*

( ev %: oArte, ei n fif l!

Pop vcAlpoe c6RT.

{W yg REF. DR AWING NUMBER $_

er l

,i f-U

! ~ [ 'j' '~

~

i PtPE s 9 f r r-3 Et.ECT:

[

i I, -

H.VA O.*

' k:(sm,lradasel Oh.9"#/#f/0N- - -

STEft.!

i "L

.._ L_

g CUSTOlyR TEI A4 Um f r#ES GEN E 18e(

l

. -. ~

ORDER OR CCNT. NO. Cr.00**

' mar l'

{ "h gspacosor o m s m.,u,ars.

_o_ a usant cannsnckl VLAK t(2 sM

.h

,tf.F Mr,os,t 9% 0r..r 0 a

J 2

Il.--

t'ang Nei c c.i-orm. yp g.ds-si a n THIRO PARTY thSPEC1 TON.T 5 A

^-

^'

C00E CLAsss A'StMtL nr. _4 jh I., 9. ' f,rl W[;77 R."g@Q sxETCH NO.

f TO.*I ll og 5 /

,/ /

/

d's0.?/,,T.".i,2 / * ; " * *

~

l l q..p -..

..n.,

.-_........;....a.. t._.

. _..__. __ _ _. =..._.

t

e p.

r.

u

~..

3 4

+

l i

.fp -

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE-THE ATOMIC' SAFETY AND LICENSING BOARD In'hhe Matter of

}{

}{

{ TEXAS UTILITIES ELECTRIC

-}{

Docket Nos.~ 50-445-1

r

_-COMPANY, et al.-

}{

and 50-446-1 (Comanche Peak Steam Electric

}{

n;

' Station,-Units l'and 2)

}{

CERTIFICATE OF SERVICE By my' signature:below, I hereby certify that true and correct copies of O

i+ '

-CASE's Motion for, Reconsideration of Licensing Board's 6/29/84 Menorandum and

g

.-and Order (Written-Filing Decisions, fli Some AWS/ASME ' Issues)

'have?beenisentzto:the. names listed below this' 4th. day.of February:,1985_,

^

'by: ; Express' Mail-where-indicated by.* and First: Class. Mail elsewhere.

q p.f

• Administrative Judge Peter.B.' Bloch

• Nicholas:S..Reynolds, Esq.

fW

~U.-S.ENuclear Regulatory Commission Bishop,- Liberman, Cook, Purcell-y 4350 East / West:l Highway,14th Floor

& Reynolds

.-Bethesda, : Maryland : ; 20814?

1200.'-;17th St.. N. W.

~

tWashington, D.C.- -

20036

!/

1;I D*! Judge' Elizabeth--3. Johnson-J

-Oak Ridge; National-Laboratory

• fGeary S.:Mizuno, Esq.-.

P.(0.. Box X,' Building 3500..

Of fice 'of: Executive - Legal y[

(Oak Ridge, Tannessee ' 37830, Director

.U. S.-' Nuclear Reegulatory

'iDr.(Kenneth,A".}McCollon, Dean' Commission.

1

Division of Engineering,.

Maryland National Bank Bldg. -

i- ~

Architecture:and Technology,

. - Room ~10105 LOklahoma. State:Univer'sity:

7735 Old.Georgetown Road,

~

,(Stillwater,10klahoma 74074:

Bethesda,-Maryland. '20814 q

s h

?*lDr.; Walter'H. JordanL Chairman, Atomic Safety and.Licensings m

l Board Panel 18811W. OuterLDrive.

JOak; Ridge,;Ter.nessee-l37830.

.U..S. Nuclear Regulatory' Commission >

W Washington,'D. C.

c20555

~

^

m gg 6

~

r

(

'34

l' ~

',Q.ld W[. ::4;;,u.:

(

w b;

.

. ' -L4

- N 1 ;^

s 3

<.x

W --

.D g

,qs r

+

?

EChairman-Renea Hick s, Esq.

Atomic Safety and Licensing Appeal Assistant Attorney General Board Panel.

Environmental Protection Division U. S. Nuclear RegulatorytCommission Supreme Court Building Washington, D. C..

20555 Austin, Texas 78711

-Mr. Robert Martin Anthony Z. Roisman, Esq.

-_ Regional Administrator, Region IV Trial Lawyers for Public Justice

.s U. S.-Nuclear Regulatory Coenission 2000 P Street, N. W., Suite 611 m

611 Ryan Plaza Dr., Suite 1000 Washington, D. C.

20036 LArlington, Texas 76011 Mr. Owen S. Merrill j

Lanny A. Sinkin Staff Engineer L Executive Director-Advisory Committee for Reactor

~

Nuclear Information and Resource Safeguards (MS H-1016)

- Service -

U. S. Nuclear Regulatory Commission

.1346 Connecticut Avenue, N.-W.,

Washington, D. C.

20555

. 4th Floor

~

[ Washington,LD.C.

'20036 e

-Dr. David H. Boltz 2012 S.' Polk-Dallas, Texas 75224 Michael D.LSpence,-President Texas Utilities Generating Company; Skyway Tower 400 North' Olive St., L.B. 81 Dallas, Texas. '75201

' Docketing. and Service. Section -

(3 copies)-

j-

. Office of the Secretary LU. S. Nuclear Regulatory. Commission Washington,-D. C.

20555 4 -

,. q /,e J

?'

??+mb JfKrsg),Juanita Ellis, President CASE'(Citizens-Association for(Sound Energy) 1426 S. Polk

(

Dallas,' Texas 75224 1214/946-9446

'j r,

+. '

l' s

"2.

a

?

O xJ '

pf,

iL lM',